Income Tax Appellate Tribunal Delhi Ptc India Limited,Delhi vs Dcit, Circle19(1), New Delhi on 19 November, 2025 ITA No.961/Del/2023 & 3225/Del/2024 IN THE INCOME TAX APPELLATE TRIBUNAL DELHI "C" BEFORE SHRI SUDHIR KUMAR, JUDICIAL MEMBER & SHRI MANISH AGARWAL, ACCOUNTANT MEMBER ITA No.961/Del/2023 [Assessment Year : 201819] PTC India Ltd. vs DCIT 2nd Floor, NBCC Tower, Circle19(1), Bhikaji Cama Place, 15, Delhi R.K.Puram (Main), New Delhi110066. PANAABCP7947F APPELLANT RESPONDENT ITA No.3225/Del/2024 [Assessment Year : 201819] DCIT vs PTC India Ltd. Circle19(1), 2nd Floor, NBCC Tower, Delhi Bhikaji Cama Place, 15, R.K.Puram (Main), New Delhi110066. PANAABCP7947F APPELLANT RESPONDENT Appellant by Shri Salil Kapoor, Adv. & Ms. Soumya Singh, Adv Respondent by Shri D S Sidhu, CIT DR Date of Hearing 25.08.2025 Date of Pronouncement 19.11.2025 ORDER PER MANISH AGARWAL, AM : The present crossappeals are filed by assessee and the Revenue against the order dated 03.02.2023 passed by Ld. Commissioner of Income Tax (A), National Faceless Appeal Centre ("NFAC"), Delhi ["Ld. CIT(A)"] in Appeal No. NFAC/2017 Page | 1 ITA No.961/Del/2023 & 3225/Del/2024 18/10017467 u/s 250 of the Income Tax Act, 1961 ["the Act"] arising out of assessment order dated 25.03.2021 passed u/s 143(3) r.w.s. 143(3A) & 143(3B) of the Act pertaining to assessment year 2018 19. 2. The appeal of the Revenue is delayed by 461 days. Alongwith appeal memo, a petition is filed for condonation of delay wherein it is stated that due to high pendency of time barring matters, the appeal could not be filed in time. As the delay is Bonafide, it is submitted by the AO that the approval was taken from the Competent Authority for filing the appeal from Ld. Pr. CIT after following the new procedure and thus due to these reasons delay was occurred, He requested for condonation of delay. 3. Heard the contentions of both the parties and perused the material available on record. In the instant case, the order of Ld. CIT(A) was delivered through online on 03.02.2023 thus, it was served upon the assessee as well as on the AO on the very same day however, the appeal is filed by the revenue before the Tribunal on 08.07.2024 thus, it is delayed by 461 days. In the prayer filed, it is stated by the AO that he was preoccupied in heavy time barring issues and therefore, could not be able to file the appeal in time. It is further requested by the AO that this being the first occasion and it will not happen in future thus, delay be condoned. Page | 2 ITA No.961/Del/2023 & 3225/Del/2024 4. Considering the submissions made by the AO, the delay is condoned and the appeal of the Revenue is admitted to decide on merits. ITA No.961/Del/2023 [Assessment Year : 201819] [Assessee's appeal] 5. First, we take the appeal of the assessee in ITA No.961/Del/2023 [Assessment Year 201819] wherein assessee raised following grounds of appeal: 1. That on the facts and circumstances of the case and in law, the Commissioner of Incometax (Appeals) ["Ld. CIT(A)"] has erred in upholding the addition of Rs. 17,09,49,711/ under section 14A of the Incometax Act, 1961 ("the Act") read with Rule 8D of the Incometax Rules, 1962 ("the Rules") based on the incorrect appreciation of facts and law and hence this action of Ld. CIT(A) is illegal, bad in law and deserves to be deleted. 2. That the Assessment Order passed and the addition/disallowan