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FININ2MINJudgment Intelligence

PCIT (Central)-1 v. Hiranandani Builders

Important disclaimer

Finin2min Judgment Intelligence is provided for general informational and educational purposes only. It is not legal, tax, accounting, investment or other professional advice and is not a substitute for advice on the user's specific facts. The Finin2min summary, Q&A, reliance profile, fact-match indicators, comparisons and practical takeaways are editorial analysis and are not part of the Court/Tribunal judgment. Before citing, filing, advising or acting on a case, read the complete official judgment/order, verify the cause title, case number, coram, date, applicable statutory text and jurisdiction, and check subsequent appellate history, review/SLP status and later amendments. A similar fact pattern does not guarantee the same outcome. No advocate-client, CA-client or other professional relationship is created by use of this page.

High CourtRevenue tax appeal dismissed; section 80IA treatment of the identified receipts sustainedFull text available; primary replacement pendingLater-history check open
Source status: Sanitized readable full judgment copy packaged; official primary replacement pending. Open full judgment PDF. Verify against the issuing court/tribunal record before legal reliance.

Case in 2 minutes

The reported High Court matter concerns the nexus between an eligible business and interest arising from excess tax/refund. The Revenue appeal is reported as not raising a substantial question on the issue.

Case snapshot

Court / TribunalBombay High Court
Case numberTAX APPEAL NO.1413 OF 2016
Decision date—
Assessment year—
Law familyIncome Tax
OutcomeRevenue tax appeal dismissed; section 80IA treatment of the identified receipts sustained

Sections / provisions: 80IA

Questions before the Court / Tribunal

  • Section 80IA and interest on tax refund/excess tax: The reported High Court matter concerns the nexus between an eligible business and interest arising from excess tax/refund. The Revenue appeal is reported as not raising a substantial question on the issue.
SOURCE-DRIVEN CASE RECORD - condensed from the packaged judgment copy

Material facts and background

IN THE HIGH COURT OF JUDICATURE AT BOMBAY ORDINARY ORIGINAL CIVIL JURISDICTION INCOME TAX APPEAL NO.1413 OF 2016 Principal Commissioner of Income Tax(Central)­1 … Appellant V/s. Hiranandani Builders

Mr.Suresh Kumar for the Appellant. Mr.K.Gopal with Mr.Tanmay Phadke for the Respondent. ­­­ CORAM : AKIL KURESHI AND M.S.SANKLECHA, JJ. DATE : JANUARY 10, 2019. P.C.:­ 1.

consideration: “Whether on the facts and in the circumstances of the case and in law, the ITAT was justified in upholding the Ld. CIT(A) decision that interest received has a direct nexus with the development activities and hence eligible for deduction u/s. 80IA ignoring the fact that it is an interest received on excess payment of tax which has no nexus with

assessment year 2009­10 and revolves around the assessee's claim of deduction under Section 80IA of Income Tax Act, 1961 (“the Act” for short). The respondent­assessee is engaged in the business of

income from leasing out such properties. Undisputedly, such income qualifies for deduction under Section 80IA of The revenue however contests the assessee's

Tribunal. The assessee having paid excess income tax, received refund with interest. Further, the assessee had obtained deposits from the lessees for performance

deposits which earned interest. The entire transaction of leasing out the property at specified lease rent upon the lessees agreeing to offer deposit without claiming interest thereon is integral part of the assessee's principal business of leasing out the premises in I.T. Parks and S.E.Z. and therefore, Tribunal correctly concluded that such income can be stated to have been derived from the assessee's eligible business. No question of law arises. Tax Appeal is therefore, dismissed.

Appellant / assessee submissions

The judgment copy does not separately set out this component in a distinct section; refer to the full order and the reasoning section below.

Revenue / respondent submissions

The judgment copy does not separately set out this component in a distinct section; refer to the full order and the reasoning section below.

Court / Tribunal analysis and reasoning

deposits which earned interest. The entire transaction of leasing out the property at specified lease rent upon the lessees agreeing to offer deposit without claiming interest thereon is integral part of the assessee's principal business of leasing out the premises in I.T. Parks and S.E.Z. and therefore, Tribunal correctly concluded that such income can be stated to have been derived from the assessee's eligible business. No question of law arises. Tax Appeal is therefore, dismissed.

Operative decision and relief

deduction for various other receipts such as interest on income tax refund, interest on FDRs etc.

business of leasing out the premises in I.T. Parks and S.E.Z. areas. We are broadly in

Tribunal. The assessee having paid excess income tax, received refund with interest. Further, the assessee had obtained deposits from the lessees for performance

deposits which earned interest. The entire transaction of leasing out the property at specified lease rent upon the lessees agreeing to offer deposit without claiming interest thereon is integral part of the assessee's principal business of leasing out the premises in I.T. Parks and S.E.Z. and therefore, Tribunal correctly concluded that such income can be stated to have been derived from the assessee's eligible business. No question of law arises. Tax Appeal is therefore, dismissed.

Authorities and precedents appearing in the judgment

  • No reliable precedent list was extracted automatically; use the full judgment for the citation chain.

This list is machine-assisted from the judgment text and is not a substitute for checking the full citation chain in the PDF.

FININ2MIN ANALYSIS

Ratio and legal principle

The decision turns on Section 80IA and interest on tax refund/excess tax. The operative result is classified as Revenue tax appeal dismissed; section 80IA treatment of the identified receipts sustained. Read the rule only with the statutory version, factual findings and precedent chain recorded in the full judgment.

Why this judgment matters

The case is relevant to taxpayers, advisers and litigators dealing with Section 80IA and interest on tax refund/excess tax. Its practical value lies in the interaction between the statutory text, the evidentiary record and the procedural route followed in this case.

Practitioner action points

  • Use the judgment as a fact-specific precedent: match the statutory version, assessment period, procedural stage and evidentiary record before relying on the result.
  • Check whether a later High Court/Supreme Court order has affirmed, reversed, distinguished or rendered the decision academic.
  • For litigation, attach the full judgment/order to the working paper and cite the paragraph/page supporting the proposition rather than relying on a headnote alone.

Do not over-read this case

  • The packaged PDF is not yet an issuing-authority certified copy
  • Apply the statutory law applicable to the relevant year; later amendments can change the result.
  • Check whether a later High Court or Supreme Court judgment has affirmed, distinguished, reversed or superseded this decision.

How to apply this decision in practice

This Bombay High Court decision should be used by matching the client’s facts to the precise controversy in the case—Section 80IA and interest on tax refund/excess tax—rather than by relying only on the result. Start with the statutory version applicable to the relevant year and compare it with 80IA. Amendments, notifications, later Supreme Court/High Court decisions and a different procedural stage can materially change the answer.

For an assessment or litigation file, retain the documents that prove the factual bridge on which the judgment turns: the original notice/order, replies and objections, acknowledgements of filing/service, ledger and banking trail where relevant, contracts or property instruments where relevant, and the complete appellate chronology. If the case succeeds on jurisdiction or natural justice, do not assume the same outcome where the authority cures that defect. If it succeeds on evidence, identify exactly which documents the Court or Tribunal considered persuasive.

Before citing the case, verify the latest appellate status and whether the decision is final, distinguished, stayed, reversed or confined to its facts. The packaged PDF and source trail should be read together with the current statutory text.

Finin2min reliance rule: cite the case for the narrow legal proposition actually decided, record any contrary authority, and attach the full judgment to the working paper or litigation file. This reduces the risk of a headnote or short summary being used outside its factual and statutory context.

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Decision support built around the judgment: reliance, fact match, Q&A, section impact, related-case network and practical next steps.

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Can I rely on this judgment?

Authority levelHigh Court
Reliance effectBinding within the High Court’s territorial jurisdiction on subordinate authorities; persuasive elsewhere, subject to Supreme Court law.
Source integrityA sanitized local full-text judgment copy is packaged; official-primary replacement remains pending.
Subsequent historySubsequent appellate history is not fully closed in the current ledger. Recheck before filing or opinion work.
Finin2min statusLater-history check open

Does this case match your facts?

Stronger match when

  • Your dispute raises the same core issue: Section 80IA and interest on tax refund/excess tax.
  • The same statutory provisions or materially equivalent provisions apply: 80IA.
  • Your matter is at a comparable appeal/revision stage.
  • Your documentary/evidentiary record is materially similar to the facts the Bombay High Court considered: IN THE HIGH COURT OF JUDICATURE AT BOMBAY ORDINARY ORIGINAL CIVIL JURISDICTION INCOME TAX APPEAL NO.1413 OF 2016 Principal Commissioner of Income Tax(Central)­1 … Appellant V/s.

Weaker / distinguishable when

  • A later Supreme Court or jurisdictional High Court ruling changes the legal position.
  • The statutory provision was amended for your year or transaction.
  • Your evidence, transaction structure, notice chronology or procedural stage differs on a fact the judgment treated as material.
  • The case succeeded on a narrow jurisdictional/procedural defect that the authority has cured in your matter.

Questions this judgment answers

What was the main dispute in PCIT (Central)-1?

The reported High Court matter concerns the nexus between an eligible business and interest arising from excess tax/refund. The Revenue appeal is reported as not raising a substantial question on the issue.

Which facts mattered most to the result?

IN THE HIGH COURT OF JUDICATURE AT BOMBAY ORDINARY ORIGINAL CIVIL JURISDICTION INCOME TAX APPEAL NO.1413 OF 2016 Principal Commissioner of Income Tax(Central)­1 … Appellant V/s. Hiranandani Builders Mr.Suresh Kumar for the Appellant. Mr.K.Gopal with Mr.Tanmay Phadke for the Respondent. ­­­ CORAM : AKIL KURESHI AND M.S.SANKLECHA, JJ.

What did the Bombay High Court ultimately decide?

deduction for various other receipts such as interest on income tax refund, interest on FDRs etc. business of leasing out the premises in I.T. Parks and S.E.Z. areas. We are broadly in Tribunal.

What legal principle can be taken from this judgment?

The decision turns on Section 80IA and interest on tax refund/excess tax. The operative result is classified as Revenue tax appeal dismissed; section 80IA treatment of the identified receipts sustained. Read the rule only with the statutory version, factual findings and precedent chain recorded in the full judgment.

Which provisions should be checked before relying on the case?

The case engages 80IA. The relevant statutory version for — should be checked together with any later amendment, notification, circular and controlling higher-court authority.

When is this judgment most useful to a taxpayer or adviser?

The case is relevant to taxpayers, advisers and litigators dealing with Section 80IA and interest on tax refund/excess tax . Its practical value lies in the interaction between the statutory text, the evidentiary record and the procedural route followed in this case.

What could make this judgment distinguishable or unsafe to rely on?

The packaged PDF is not yet an issuing-authority certified copy Apply the statutory law applicable to the relevant year; later amendments can change the result. Check whether a later High Court or Supreme Court judgment has affirmed, distinguished, reversed or superseded this decision.

Can this judgment be cited as current law without another check?

Binding within the High Court’s territorial jurisdiction on subordinate authorities; persuasive elsewhere, subject to Supreme Court law. Subsequent appellate history is not fully closed in the current ledger. Recheck before filing or opinion work. A sanitized local full-text judgment copy is packaged; official-primary replacement remains pending.

Section / provision impact

  • 80IA — 80IA is part of the statutory framework considered in the context of section 80ia and interest on tax refund/excess tax. Read the exact provision applicable to the relevant year with the Court/Tribunal reasoning.

How the decision changes your analysis

1. Frame the issue

Before using this authority, frame the issue under 80IA and identify the decisive facts/evidence. The result should not be assumed from the case title alone.

2. This judgment

The decision turns on Section 80IA and interest on tax refund/excess tax. The operative result is classified as Revenue tax appeal dismissed; section 80IA treatment of the identified receipts sustained. Read the rule only with the statutory version, factual findings and precedent chain recorded in the full judgment.

3. Current use

Binding within the High Court’s territorial jurisdiction on subordinate authorities; persuasive elsewhere, subject to Supreme Court law. Subsequent appellate history is not fully closed in the current ledger. Recheck before filing or opinion work.

Case network: similar and different outcomes

Closest related cases in the Finin2min repository

Related cases with a different result

Related-case links are repository similarity connections, not a claim that one judgment cites or overrules another. Use the cited-authority list and later-history check for formal precedent analysis.

Working-paper citation

PCIT (Central)-1 v. Hiranandani Builders, TAX APPEAL NO.1413 OF 2016, Bombay High Court, decided 2019-01-10

Full judgment and source trail

Read / download the clean local judgment copy

Packaged source classSanitized local full-judgment copy; official primary replacement pending
Pages3
SHA-256f65db02d800667cca62e2636b200cd60c32aa635b03941c5691bbbcfaba76d71
Local document URLOpen the packaged local document
Source authenticationSanitized local full-text copy - official primary replacement pending

Related Finin2min guidance

Educational and professional reference only — not financial, tax or legal advice. Verify the current official position from the primary source before relying on any figure, rate, provision or deadline.