Additions for notional interest, ad-hoc expenses, and trade

Additions for notional interest, ad-hoc expenses, and trade payables are invalid after favorable remand report

Issue

Whether the Assessing Officer can sustainably maintain tax additions for notional interest on subsidiary loans, ad-hoc expense disallowances, and unexplained trade payables when the revenue’s own remand report subsequently accepts the assessee’s explanations without any adverse remarks.

Facts

The Assessee: A corporate entity engaged in the business of developing and operating Information Technology (IT) Parks.
Notional Interest Addition: The assessee advanced an interest-free loan to its wholly-owned subsidiary, prompting the Assessing Officer to add national/deemed interest income to its total receipts.
Ad-hoc Disallowance: The Assessing Officer mechanically disallowed 20% of the genuine business expenses claimed by the assessee under the heads of Power & Fuel, Repairs & Maintenance, and Other Administrative Expenses.
Unexplained Cash Credit: The Assessing Officer reclassified standard outstanding trade payables as unexplained cash credits under Section 68 and added the entire amount to the assessee’s taxable income, despite the return declaring a loss.
The Remand Report: During appellate proceedings before the Commissioner (Appeals), a remand report was called from the revenue. The Assessing Officer submitted the report without raising any adverse remarks, effectively accepting the assessee’s detailed explanations on all three issues.

Decision

Deemed Interest Deleted: The addition for notional interest cannot stand since the revenue’s own remand report accepted the business rationale of the interest-free funding to the subsidiary.
Ad-hoc Disallowances Reversed: The 20% flat-rate disallowance on administrative, power, and maintenance expenses is deleted because the commercial utility and documentation were accepted in the remand proceedings.
Trade Payables Addition Quashed: The Section 68 cash credit addition is set aside as the identity, genuineness, and creditworthiness of the trade payables were validated by the revenue’s clean remand report.
Outcome: The Commissioner (Appeals) was entirely justified in deleting all three additions, and the deletions are upheld in favor of the assessee.

Key Takeaways

Conclusive Nature of Remand: Once the tax department evaluates evidence in a remand report and drops its objections, it cannot later defend the original, unverified additions.
No Notional Income Fiction: Income tax is levied on real income; commercial loans to a wholly-owned subsidiary cannot be artificially taxed with “deemed interest” unless specific anti-avoidance provisions apply.
Arbitrary Disallowances Unsustainable: Percentage-based ad-hoc disallowances of routine operational expenditures (like power, fuel, and repairs) without pinpointing specific non-business leakage are illegal.

IN THE ITAT DELHI BENCH ‘E’

Deputy Commissioner of Income-tax

Advant IT Park (P.) Ltd.

SATBEER SINGH GODARA, Judicial Member
and Naveen Chandra, Accountant Member

IT Appeal No. 7513 (Del) OF 2025
[Assessment year 2022-23]

JUNE 29, 2026

Vir Sain, Adv. and Ms. Amisha S. Gupt, CIT-DR for the Appellant. Rohit Kapoor, Adv. for the Respondent.

ORDER

Naveen Chandra, Accountant Member. – This captioned appeal has been filed by the Revenue against the order of the Commissioner of Income Tax (Appeals)-3, Noida dated 23.09.2025 arising from the assessment order passed under section 143(3) of the Income Tax Act, 1961 (hereinafter referred as ‘the Act’) dated 27.03.2024 passed by DCIT, NFAC, New Delhi for the Assessment Year 2022-23.

2. Brief facts of the case are that the assessee is a company engaged in the business of setting-up, running, operating and maintaining of IT Park, Software Technology Park, Office Spaces, etc., wherein complex commercial services are rendered by the assessee.

3. The assessee e-filed revised return of income for A.Y. 2022-2023 on 02.11.2022 where under the assessee declared total loss of Rs. 20,38,94,424/-. Thereafter, case was selected for scrutiny assessment on the ground that the assessee has shown low net profit, interest expenditure is high, high ratio of TDS to refund, claim of large value refund, etc. Accordingly, notice was issued under Section 143(2) of the Act on 23.06.2023 as well as Section 142(1) of the Act. The assessee duly responded to all the notices issued by the Assessing Officer from time to time. Thereafter, during the course of assessment proceedings, various notices were issued under the provisions of Section 142(1) of the Act which were duly responded by the assessee. Finally, a Show Cause Notice dated 21.03.2024 was issued. In response assessee company could not file any reply because Finance Head of the assessee Company (Mr. Ravinder Kudiyal) was on leave during that time on account of his marriage on 02.03.2024. Thereafter, assessment was framed by adding following disallowance of expenditure/addition to the total income of the assessee :

Addition of Rs. 6,16,29,807/- being the deemed interest income on interest free loan of Rs. 51,35,81,730/- given by the assessee to its wholly owned subsidiary.

Disallowance of Expenditure of Rs.5,48,84,622/- being 20% of the expenditure claimed by the assessee under the head Power & Fuel (Rs.11,53,79,145/-), Other Admin Expense (Rs. 8,35,96,717/-) & Repair & Maintenance (Rs. 7,54,47,248/-).

Addition of Trade Payable of Rs. 4,07,12,410/- under Section 68 as unexplained cash credit.

4. Aggrieved, assessee was in appeal before the CIT(A)/NFAC. In which learned CIT(A)/NFAC observed as under :

“Issue (1): Notional interest on advances to subsidiary – Rs. 6,16,29,807/-Nature and chronology of advances: The record shows that the appellant advanced funds to its wholly owned subsidiary over multiple years for the purpose of purchasing and developing a plot from Noida Authority and for associated pre-development activities. The ledger and bank evidence demonstrate that the aggregate of advances stood at Rs. 51,35,81,730/- at the relevant period.

Purpose of the advances: Documentary material allotment letter, lease deed, possession letter, payment challans to Noida Authority, architectural/ consultancy agreements, soil test reports, environmental clearances and other project documents establishes that the subsidiary was engaged in land acquisition and development for IT/ITES use and the funds were used for business purposes.

Receipt of interest: There is no material on record to indicate that any interest income flowed to the assessee in respect of the advances during the year under consideration. The assessee’s books do not record any interest receivable or accrued from the subsidiary for these advances in the relevant year.

AO’s basis for imputation: The AO has applied a notional rate (12%) on the outstanding advances as at the end of the year and added the notional interest to the assessee’s income, on the premise that the advances were interest-free and the assessee had incurred interest on its borrowings.

Principle of consistency: It is seen that the advance under contention has been given by the assessee to its subsidiary over a number of years but no such addition has been made by the AO in the earlier years meaning thereby that the principles of consistency have not been followed.

Evaluation of AO’s approach: For an imputation of income in the form of ‘notional interest’ to be sustainable, there must be objective, cogent material showing that an income has accrued or that the assessee has realized an economic gain in the form of interest, or there is a statutory basis to treat the transaction as yielding income. In the present case:

•

The advances are proven by bank records and ledger entries in the books the assessee and of the subsidiary; the payments were used for accepting an asset (plot) and for project development expenses by the subsidiary.

•

The subsidiary did not make payments to the assessee in the nature of interest, nor has any interest income been reflected in the assessee’s accounts for the year.

•

There is no material to show diversion or misappropriation of funds for personal use or non-business purposes by directors or related parties of the assessee.

Commercial expediency and nexus: The documents show that the advances were in furtherance of the commercial plan of the assessee group to develop and operate IT Park-related infrastructure and that the subsidiary’s activities were directly related to the assessee’s business objectives. The funds were therefore deployed for the overall business plan of the group and not as passive deposits from which interest income would be expected in isolation. It has been held in a number of judgments that notional interest cannot be charged/ disallowance of interest u/s 36(1)(iii) cannot be made on interest free advances to subsidiaries when the said advances have commercial expediency involved as the same have been utilized for the expansion of the business of the appellant company. The appellant has further submitted that sufficient interest free funds were also available with the assessee company during the various years when the funds were advanced to its subsidiary i.e. SS Techno Park Pvt. Ltd.

The Hon’ble Supreme Court of India in the case of Additional Commissioner of Income-tax v. Tulip Star Hotels Ltd. reported at (SC) has held as under:

In S. A. Builders Ltd. v. CIT (Appeals) , the Supreme Court has held that’. where it is obvious that a holding company has a deep interest in its subsidiary, and hence if the holding company advances borrowed money to a subsidiary and the same is used by the subsidiary for some business purposes, the assessee would .. ordinarily be entitled to deduction of interest on its borrowed loans’

Further, the Hon’ble SUPREME COURT OF INDIA in the case of Hero Cycles (P.) Ltd. v. Commissioner of Income-tax (Central), Ludhiana reported at (SC) has held as under:

Section 36(1)(iii) of the Income-tax Act, 1961 – Interest on borrowed capital (Interest free loans) – Assessment year 1988-89 – Whether once it is established that there is nexus between expenditure and purpose of business (which need not necessarily be business of assessee itself), revenue cannot justifiably claim to put itself in armchair of businessman or in position of Board of Directors and assume role to decide how much is reasonable expenditure having regard to circumstances of case – Held, assessee filed its return claiming deduction of interest paid on borrowed sums from Bank under section 36(1)(iii) – Assessing Officer finding that assessee had used owed funds for giving interest free loans to its subsidiary company and directors, rejected assessee’s claim – High Court upheld order of Assessing Officer – It was noted that advance to subsidiary company became imperative as a business expediency in view of undertaking given to financial institutions by assessee to effect that it would provide additional margin to subsidiary company to meet working capital for meeting any cash losses Insofar as loans to directors were concerned, said loans were granted out of assessee’s own surplus funds -Whether in view of aforesaid, impugned order passed by High Court was to be set aside – Held, yes [In favour of assessee]

Further, the Hon’ble HIGH COURT OF ALLAHABAD in the case of Hindalco Industries Co. v. Commissioner of Income Tax, Allahabad reported at (Allahabad) has held as under:

Section 36(1)(ii) of the Income-tax Act, 1961 – Interest on borrowed capital (Interest free loan) – Assessment year 1989-90 – Where for welfare and proper functioning of subsidiary companies, assessee in its wisdom decided to advance loan to them at lower rates of interest than that paid by it on borrowed funds, so that subsidiary companies might function properly and assessee being holding company would also be benefited, it could be said that loan advanced to sister companies was for commercial expediency and assessee was entitled to deduction of interest paid under section 36(1)(iii) [In favour of assessee]

Further, the Hon’ble HIGH COURT OF DELHI in the case of Commissioner of Income-tax v. Dalmia Cement Bharat Ltd. reported at (Delhi) has held as under:

“Section 36(1)(iii) of the Income-tax Act, 1961 Interest on borrowed capital – Assessment year 1977-78 Assessing Officer disallowed a part of interest paid by assessee-company on its borrowed funds on ground that it had advanced an interest free loan to its 100 per cent subsidiary company – Whether when clearly loan given by assessee to its subsidiary company was for purpose of business and commercial expediency, disallowance of part of interest by Assessing Officer was justified – Held, no”

Further, the Ld. Tribunal ITAT DELHI BENCH ‘SMC’ in the case of Moonrock Hospitality (P.) Ltd. v. ACIT reported at [2022] (Delhi – Trib.) has held as under:

Section 36(1)(iii) of the Income-tax Act, 1961 – Interest on borrowed capital (Interest free loans to subsidiary) Assessment year 2016-17 -Whether where assessee company had advanced interest free loan to its subsidiary company for purpose of business, no interest paid on borrowed funds could have been disallowed under section 36(1)(iii) -Held, yes [Para 14] [In favour of assessee]

Further, the Hon’ble HIGH COURT OF MADRAS in the case of Commissioner of Income-tax, Chennai v. KEC International Ltd reported at (Madras) has held as under:

Interest paid on borrowed funds utilized for investment in group companies strategic business purpose was allowable as deduction under section 36(1)(iii)

Further, the Hon’ble HIGH COURT OF BOMBAY in the case of Principal Commissioner of Income-tax, Goa v. Sesa Resources Ltd reported at (Bombay) has held as under:

Section 36(1)(iii) of the Income-tax Act, 1961 – Interest on borrowed capital (Interest e loans) Assessee borrowed fund and advanced same to its sister concern as interest free loan – Assessing Officer disallowed interest under section 36(1)(i) – It was admittedly not a case where amount was either a donation or loan was given to an individual or to a director of company in his personal capacity – Thus, only possible other purpose, as opposed to a business purpose or commercial expediency, was a ‘personal’ one, and a commercial entity can have no such personal purpose – Whether on facts, Tribunal was justified in allowing interest under section 36(1)(ii) Held, yes [Para 12] [In favour of assessee]”

Further, the Ld. ITAT MUMBAI BENCH ‘C’ in the case of Deputy Commissioner of Income Tax, Circle 7(3)(2), Mumbai v. Piramal Realty (P.) Ltd reported at (Mumbai – Trib.) has held as under:

“Section 36(1)(iii) of the Income-tax Act, 1961 – Interest on borrowed capital (Interest free advances) Assessment year 2012-13 Assessing Officer disallowed a part of interest paid by assessee-company on its borrowed funds on ground that it had advanced an interest free loan to a company wherein assessee had 50 per cent of stake through its 100 per cent subsidiary company – Whether when clearly loan given by assessee was for purpose of assessee’s business and was given according to its corporate strategy, and same was never contested by revenue, impugned disallowance of part of interest by Assessing Officer was unjustified – Held, yes [Paras 20 and 21] [In favour of assessee]”

The submissions of the appellant were forwarded to the AO during remand proceedings but no comments were offered on the merits of the case. In view of the above discussion and stated judicial pronouncements, the addition made by the AO on account of notional interest is deleted.

Issue (2): Ad-hoc 20% disallowance on Power & Fuel, Admin and Repairs & Maintenance – Rs. 5,48,84,622/-

Quantum and nature of claimed expenses: The assessee claimed under the three expense heads the following amounts:

Power & Fuel : Rs. 11,53,79,145/-

Other Administrative Expenses : Rs.8,35,96,717/-

Repairs & Maintenance : Rs. 7,54,47,248/-

Total = Rs. 27,44,23,110/- (20% of which was disallowed by AO).

AO’s reasoning: The AO applied a blanket ad-hoc disallowance of 20% across these heads, indicating concern about the high magnitude of such expenses relative to declared turnover and the refund claimed.

Documentary support produced by assessee: The assessee has produced a vendor-wise break-up, sample invoices and schedules, vendor confirmations, payment through banking channels, electricity invoices and challans, PNG bills, diesel invoices, ledger entries, and a reconciliation sheet indicating the appropriateness of the claimed amounts. Specific large payments (electricity, gas, diesel) are supported by vendor invoices with corresponding bank payments.

Nature of business and expense profile: The assessee operates an IT Park which, by its commercial nature, legitimately attracts substantial power, fuel and maintenance outlays. High consumption of electricity, significant cost of backup power and associated maintenance are expected and consistent with the business model. The presence of numerous tenants and the requirement of continuous facility management explain a high level of recurring operational costs.

Absence of specific disproof by AO: The AO has not identified a set of specific transactions as forged, unsubstantiated or paid in cash; rather the AO made broad-brush percentage disallowance without pointing to transaction-specific infirmities. Given the vouchers, sample invoices, confirmations and bank evidence on record, a blanket 20% reduction lacks transactional basis.

All the above disallowances are without any substantive reasoning and are adhoc in nature. Just making ad-hoc disallowances of a lump-sum amount to cover various leakages of revenue appears to be made on the basis of presumptions rather than core evidence. Such a disallowance is in the nature of ad-hoc disallowance which is solely based on presumptions and surmises.

The Hon’ble Supreme Court of India in the case of Omar Salay Mohamed Sait v. Commissioner of Income-tax reported at [1959] 37 ITR 151 (SC)[05-03-1959] held as under:

“Section 254 of the Income-tax Act, 1961 – Appellate Tribunal – Order of – Assessment year 1948-49 – Whether Tribunal should not base its findings on suspicions, conjectures, or surmises nor should it act on evidence at all or on improper rejection of material and relevant evidence or partly on evidence and partly on suspicions, conjectures or surmises and if it does anything of that sort, its findings, even though on questions of fact, will be liable to be set aside by Supreme Court – Held, yes”

Further, the Hon’ble Supreme Court in the case of Dhakeshwari Cotton Mills Ltd. v. CIT reported at 26 ITR 775 held as under:

“Section 143 of the Income-tax Act, 1961 [Corresponding to section 23(3) of the Indian Income-tax Act, 1922] – Assessment – Additions to income – Assessment year 1944-45 – Whether though ITO is not fettered by technical rules of evidence and pleadings and he is entitled to act on material which may not be accepted as evidence on account of law, but in making assessment under section 23(3) of 1922 Act he is not entitled to make a pure guess and make an assessment without reference to any evidence or any material at all Held, yes Whether where, on request of Tribunal, departmental representative had produced certain material, Tribunal should have given an opportunity to assessee to rebut such material and should have also taken into account material produced by assessee on issue in question – Held, yes.”

Further, the Hon’ble Supreme Court in the case of Principal commissioner of Income Tax v. R.G. Buildwell Engineers Ltd. reported at (SC) has held as under:

Section 37(1) of the Income-tax Act, 1961 Business expenditure Allowability of (Onus to prove) In course of assessment, assessee claimed deduction of expenses towards bricks, machinery repair, cartage, labour expenses etc. Assessing Officer disallowed 10 per cent of said expenses on ground that insufficient evidence was adduced – Tribunal set aside said ad-hoc disallowance on two grounds, firstly, assessee’s books of account were not rejected and secondly, such expenses were allowed consistently in post in scrutiny assessments High Court upheld order passed by Tribunal – Whether SLP filed against view taken by High Court was to be dismissed -Held, yes [Para 2] [In favour of assessee]”

Further, the Ld. ITAT DELHI BENCH ‘SMC-2’ in the case of Mantram Commodities (P.) Ltd. v. Income Tax Officer Ward 1(5) Faridabad reported at (Delhi – Trib.) has held that the additions based on presumptions and surmises are liable to be deleted.

Similar view has been held by Ld. ITAT DELHI BENCH ‘E’ in the case of Assistant Commissioner of Income-tax, Central Circle-3, New Delhi v. Navneet Kumar Sureka reported at (Delhi –Trib.).

Further, the Ld. ITAT Bench of Raipur in the case of Kailas Chand Agrawal v. Deputy Commissioner of Income-tax reported at (Raipur – Trib.) has held as under:

“Where it was not case of revenue that any part of expenditure in question was either bogus or fictitious or same was not incurred by assessee wholly and exclusively for purpose of his business, ad-hoc disallowance of expenditure was not justified”

Further, the Ld. ITAT Amritsar Bench in the case of Baba Farid Public Welfare Society v. Income-tax Officer (Exemptions) reported at (Amritsar – Trib.) has held as under:

“Where Assessing Officer made ad-hoc disallowance of 10 per cent of total expenses, as Assessing Officer had not specified specific lacuna related to disallowance of expenditure, disallowance so made was to be deleted”

The submissions of the appellant were forwarded to the AO during remand proceedings but no comments were offered on the merits of the case. In view of above discussion and stated legal pronouncements, it is held that the AO has made the said additions on an ad-hoc basis which are liable to be deleted.

Issue (3): Addition of Trade Payables under Section 68- Rs. 4,07,12,410/-

Nature of claim: The assessee’s books record trade payables totaling Rs.4,07,12,410/ The AO has treated these balances as unexplained credits and added them to income under s. 68.

Material placed by assessee: The assessee submitted party-wise ledgers, PAN and addresses of creditors, confirmations/acknowledgements, bank statement entries showing payments were made and copies of account ledgers maintained with suppliers. In respect of certain creditor balances, an arbitration was in process and a final arbitration award has been placed on record indicating the commercial nature of the liability.

Examination of genuineness: Trade payables arise in ordinary course of business from procurement of services and consumables for facility management, construction, store issues, vendor supplies and other operating requirements. The ledger entries, confirmations and bank payments (where applicable) forma coherent and consistent documentary matrix demonstrating the commercial origin of the liabilities.

AO’s failure to point to suspicious conduct: The AO has not shown any specific transaction to be fictitious, nor has he demonstrated that the payables were advances or credits from unnamed persons. The assessee has explained nature of transactions and provided supporting vouchers and correspondence.

The Hon’ble HIGH COURT OF DELHI in the case of Commissioner of Income Tax v. Ritu Anurag Aggarwal reported at (2010) (Delhi) has held as under:

“Once this is accepted, we are of the opinion that the approach of the ITAT was correct inasmuch as the Assessing Officer did not consider this aspect while making additions of the sundry creditors under section 68 of the income Tax Act As there was no case for disallowance for corresponding purchases, no addition could be made under section 68 inasmuch as is not in dispute that the creditors’ outstanding related to purchases and the trading results were accepted by the Assessing Officer.

The assessee has satisfactorily explained the origin and nature of the trade payables with adequate documentary support. Hence, treatment of these balances as unexplained cash credits is not warranted. The submissions of the appellant were forwarded to the AO during remand proceedings but no comments were offered on the merits of the case. In view of above discussion and stated legal pronouncements, the addition of Rs. 4,07,12,410/- is liable to be deleted.

Accordingly, these grounds of appeal are allowed.

4.2 Other Grounds of Appeal: Since the addition has been deleted on merits of the case, other grounds of appeal become academic in nature, no specific adjudication is required in these grounds.

In the result, the appeal is allowed.”

“Decision : I have carefully considered the facts of the case as well as submission of the appellant and gone through the observation and findings of the AO .The contention of the appellant on this ground is acceptable in as much as it is observed from the assessment orders vis – vis above remand report that main reason of making disallowance of sundry creditors being on account of non- furnishing of proofs in relation to identity genuineness and creditworthiness of the creditors claimed by the Appellant Company during the FY 2015-16 , have been verified by the AO in remand proceeding and neither any negative observation nor any adverse remark in relation to transaction in respect of trade creditors has been marked by the Assessing Officer (AO) in the remand report.

In view of that considering the entire conspectus of the case I am of opinion that the appellant is able to establish beyond doubt with corroborating evidence the identity genuineness and creditworthiness of the creditors. Accordingly, I find infirmity in the order of the AO and find the disallowance being made under unexplained expenditure not being justified in as much as the addition being made not in accordance with law . Accordingly disallowance of Rs.5,02,58,246/- invoking section 69C of the Act stand deleted and the ground relating to this issue is allowed.”

5. Aggrieved by the order of CIT(A)/NFAC, Revenue is now in appeal before us with the following grounds:

“1.

Whether on the facts and circumstances of the case and in law, the Ld. CIT(A) has erred in deleting the addition of Rs. 6,76,29,807/-made by the Assessing Officer on account of notional interest on interest-free advances to a subsidiary company without properly appreciating that the assessee failed to establish a nexus between borrowed funds and business expediency, and that the advances were made out of mixed funds involving borrowed capital.

Whether on the facts and circumstances of the case and in law, the Ld. CIT(A) has erred in deleting the disallowance of Rs. 5,48,84,6221-made by the Assessing Officer on account of unveriliable and excessive expenses towards power, fuel, administrative, and repair heads, without appreciating that the assessee failed to furnish complete supporting evidences during assessment and that the AO’s disallowance was justified under the circumstances.

Whether on the facts and circumstances of the case and in law, the Ld. CIT(A) has erred in deleting the addition of Rs. 4,07,12,1701-made under section 68 of the Income Tax Act, 1961, without appreciating that the assessee failed to discharge the primary onus of establishing the identity, creditworthiness, and genuineness of the creditors, and that the AO had rightly invoked the provisions of section 68 of the I.T.Act, 1961.

Whether on the facts and circumstances of the case and in law, the Ld. CIT(A) has erred in granting complete relief to the assessee without properly appreciating the findings of the Assessing Officer and the cumulative evidences gathered during assessment, thereby rendering the appellate order perverse and unsustainable.

Whether on the facts and circumstances of the case and in law, the Ld. CIT(A) has erred in admitting and relying upon additional evidence produced by the assessee during appellate proceedings without affording the Assessing Officer an adequate opportunity to examine and rebut the same, in contravention of Rule 46A of the Income Tax Rules, 1962.

That the order of Ld. CIT(A)-3, Noida being erroneous in law and facts be set aside and order of the A.O. be restored.

That the above grounds are without prejudice to each alter and appellant craves leave to add, alter or amend any ground or grounds on or before the date of hearing of appeal. “

6. Before us, learned Representative of the department submitted that learned CIT(A) has erred in law and on facts in deleting the addition on account of notional interest on interest free advances to a subsidiary company, disallowance of expense towards power, fuel, administrative, and repair heads and loan received from party creditors.

7. We have heard the learned DR and perused the material available on record. We find that the CIT(A) deleted the additions on the basis of remand report of the AO which had no adverse remarks on the issue of notional interest; ad-hoc disallowance of expense and addition of trade payables. Once the Department itself in its remand report has accepted the assessee’s explanation on notional interest; ad-hoc disallowance of expense and addition of trade payables, there is no scope for making addition. We are therefore of the considered view that we have no reason to interfere with the decision of the CIT(A). Accordingly, all the grounds of the Revenue stands dismissed.

8. In the result, appeal filed by the Revenue in ITA No. 7513/DEL/2025 is dismissed.