SHREE SHANKHESHWAR AND F A,MUMBAI vs. ITO-26(2)(1), MUMBAI

आदेश / ORDER

ITA 4065/MUM/2026 SHREE SHANKESHWAR AND F A PER MAKARAND VASANT MAHADEOKAR, ACCOUNTANT MEMBER: This appeal by the assessee is directed against the order dated 18.12.2025 passed by the learned Commissioner of Income- tax (Appeals), National Faceless Appeal Centre, Delhi [hereinafter referred to as "the CIT(A)"], under section 250 of the Income-tax Act, 1961 [hereinafter referred to as "the Act"], for the assessment year 2018-19. The impugned appellate order arises from the reassessment order dated 22.03.2024 passed under section 147 read with section 144B of the Act. Condonation of delay 2. The registry noted a delay of 38 days in filing appeal before us. The appeal is accompanied by a petition seeking condonation of a delay of 37 days, supported by an affidavit of Shri Paresh D. Jain, partner of the assessee firm. It is stated that the partner was continuously travelling during February and March 2026 and, therefore, could not provide the necessary papers to the consultant for preparation of the appeal. It is further stated that, upon resuming office in the second week of March 2026, he appointed a Chartered Accountant and took immediate steps for preparing and filing the present appeal. The assessee has submitted that the delay was neither intentional nor deliberate but occurred due to circumstances beyond its control. 3. We have considered the petition and the supporting affidavit. The delay is of 37 days and the explanation furnished by the assessee is supported by the sworn affidavit of its partner. There is nothing on record to indicate that the delay was deliberate or that the assessee stood to derive any advantage by filing the appeal belatedly. In our considered view, the assessee has shown sufficient cause for not presenting the appeal within the prescribed period. The Departmental Representative (DR)raised no objection in condoing the delay. Accordingly, in exercise of the power conferred under section 253(5) of the Act, the delay of 37 days is condoned and the appeal is admitted for adjudication on merits. 4. The assessee has raised the following grounds of appeal: Ground No. 1: Order passed in violation to the principle of natural justice is invalid and bad in law 2

ITA 4065/MUM/2026 SHREE SHANKESHWAR AND F A 1.1 On the facts and in circumstances of the case and in law, the learned CIT(A) erred in passing the impugned order without grant of sufficient opportunity of hearing thereby causing the impugned order passed in violation to the principles of natural justice to be set aside; 1.2 The learned CIT(A) failed to appreciate and ought to have either issued a notice granting final opportunity of hearing or a letter rejecting the adjournment application inasmuch as action of the learned CIT(A) in passing the impugned order without grant of final opportunity of hearing was untenable and makes the impugned order liable to be set aside. Ground No. 2: Reassessment Order passed u/s. 147 rws 144B of the Act is invalid and bad in law 2.1 On the facts and in circumstances of the case and in law, the learned CIT(A) erred in upholding the reassessment proceedings for the captioned assessment year based on an incorrect information regarding sale of an immovable property inasmuch as appellant has not sold any property during the year thereby making the entire reopening proceedings based on incorrect information void ab initio; 2.2 On the facts and in circumstances of the case and in law, the learned CIT(A) erred in affirming action of the learned AO in issuance of notice u/s. 148A(b) of the Act without conducting independent inquiry as mandated u/s. 148A(a) of the Act thereby making the entire reopening proceedings conducted in violation to the prescribed procedures under the Act as bad in law; WITHOUT PREJUDICE TO THE ABOVE Ground No. 3: Addition of deemed rental income on adhoc basis 3.1 On the facts and in circumstances of the case and in law, the learned CIT(A) erred in affirming action of the learned AO on assuming 20% of the market value (as per stamp duty records) of tenancy property (under pagdi system) as deemed rent income without giving any cogent reasons inasmuch rent in ownership property and tenancy property (under pagdi system) is totally incomparable thereby making the entire absurd addition liable to be deleted; 3.2 On the facts and in circumstances of the case and in law, the learned CIT(A) erred in affirming action of the learned AO in assuming rent income at 20% of market value (as per stamp duty records) of tenancy property (under pagdi system) inasmuch as entire addition made is purely fictitious basis surmises and conjectures and thus, addition made under the head ‘Income from House Property’ is liable to be deleted; 3.3 The learned CIT(A) failed to appreciate and ought to have held that appellant had already offered actual rent income received from the immovable property (whose tenancy right was transferred during the year) thereby resulting in double taxation on same income liable to be deleted;

ITA 4065/MUM/2026 SHREE SHANKESHWAR AND F A Ground No. 4 - Incorrect taxation of rent income earned in the course of business under the head ‘Income from House Property’ instead of ‘Income from Business’ as already offered to tax in return of income 4.1 On the facts and in circumstances of the case and in law, the learned CIT(A) erred in affirming action of the learned AO in taxing the rental income earned embedded in development of immovable property as ‘Income from House Property’ inasmuch as earning rental income and developing properties being main object of appellant’s business was correctly offered to tax under the head ‘Income from Business’; 4.2 The learned CIT(A) failed to appreciate and ought to have held that since inception appellant is engaged in the business of development of property and earning rental income which has been consistently offered to tax under the head ‘Income from Business’; 4.3 On the facts and in circumstances of the case and in law, the learned CIT(A) erred in affirming action of the learned AO in making addition of gross rent income amounting to Rs. 11,15,200/- under the head ‘Income from House Property’ and also upheld the net rent income of Rs. 29,487/- (gross rent income of Rs. 11,15,200/- minus business expenditure) already offered to tax under the head ‘Income from Business’ in return of income thereby resulting in double addition of same income which ought to be deleted. Ground No. 5 - Incorrect levy of interest u/s. 234A of the Act and Fee u/s. 234F of the Act 5.1 On the facts and in circumstances of the case and in law, the learned CIT(A) erred in affirming action of the learned AO in levy of interest u/s. 234A of the Act and fee u/s. 234F of the Act inasmuch as return of income for captioned assessment year was filed before the statutory due date thereby causing the incorrect levy of interest u/s. 234A of the Act and fee u/s. 234F of the Act liable to be deleted. Ground No. 6 - Incorrect levy of interest u/s. 234B of the Act 6.1 The said ground of appeal is consequential in nature. The appellant craves leave to add, alter, delete or substitute all or any of the aforesaid grounds of appeal. 5. The facts, in brief, are that the assessee is a partnership firm. It filed its return of income for the year under consideration declaring total income of Rs.29,490/-. Information was flagged on the Insight portal to the effect that the assessee had sold an immovable property during the financial year 2017-18 for nil consideration as against the stamp duty value of Rs.33,20,000/- under a registered agreement bearing No.5269/2017 dated

ITA 4065/MUM/2026 SHREE SHANKESHWAR AND F A 14.11.2017. The information further stated that the assessee had not offered any income under the head “Capital Gains”. 6. On the basis of the aforesaid information, the Assessing Officer issued a notice dated 21.03.2022 under section 148A(b) of the Act. In response, the assessee filed a reply dated 18.04.2022 explaining that the transaction was not a sale of immovable property by the assessee. The assessee explained that the property was governed by the tenancy law and that it was merely the landlord of the said property. The original tenant, Shri Pradeep Jethalal Shah, had expired and his tenancy rights had devolved upon his legal heirs, namely, Smt. Kusum Pradeep Shah, Shri Tarak Pradeep Shah and Smt. Nisha Nimesh Shah. These legal heirs transferred their tenancy rights to Shri Jayantilal Chunnilal Prajapati under the agreement dated 14.11.2017. The assessee stated that it had joined the agreement merely as a confirming party in its capacity as landlord and that it had neither transferred the tenancy rights nor received any consideration under the agreement. 7. The assessment order records that an order under section 148A(d) was passed on 28.04.2022 and a notice under section 148 was issued on the same date. The assessee filed its return in response to the notice under section 148 on 22.11.2023 declaring income of Rs.29,490/-. Thereafter, statutory notices were issued and the reassessment proceedings were completed. 8. The Assessing Officer did not make any addition under the head “Capital Gains” in respect of the alleged sale of immovable property referred to in the notice under section 148A(b). Instead, the Assessing Officer proceeded to estimate the annual rental value of the property. He adopted 20 per cent of the stamp duty value of Rs.33,20,000/- as the notional rent and determined the same at Rs.6,64,000/-. After allowing a deduction of 30 per cent, described in the assessment order as a deduction under section 24(b), the Assessing Officer made an addition of Rs.4,64,800/- under the head “Income from House Property”. 9. The Assessing Officer further noticed that the assessee had credited rental receipts of Rs.11,15,200/- to its Profit and Loss Account and had offered the net income therefrom under the head

ITA 4065/MUM/2026 SHREE SHANKESHWAR AND F A “Profits and Gains of Business or Profession”. The Assessing Officer held that the rental receipts were assessable under the head “Income from House Property”. After allowing deduction of Rs.3,34,560/- and granting credit for the net business income of Rs.29,487/- already offered by the assessee, the Assessing Officer made a further addition of Rs.7,51,153/-. Consequently, the total income was assessed at Rs.12,45,443/- as against the returned income of Rs.29,490/-. 10. Aggrieved, the assessee preferred an appeal before the learned CIT(A). The learned CIT(A) issued multiple notices and observed that the assessee had failed to furnish submissions and supporting documents and, therefore, dismissed the appeal ex parte by the impugned order dated 18.12.2025. It is pertinent that the impugned order first records that adjournment was sought by the assessee but subsequently records that no adjournment had been sought. The learned CIT(A) did not adjudicate the grounds on their individual merits. 11. Before us, the learned Authorised Representative (AR) submitted that the reassessment was initiated on factually incorrect information that the assessee had sold an immovable property for nil consideration against its stamp duty value of Rs.33,20,000/-. Drawing our attention to the reply dated 18.04.2022 filed in response to the notice under section 148A(b), the learned AR submitted that the transfer was between the outgoing tenants and the incoming tenant. The assessee had joined the agreement merely as a confirming party in its capacity as landlord and had neither transferred the tenancy rights nor received any consideration. 12. The learned AR further submitted that the rental income had already been accounted for and offered to tax. He referred to the computation of income and the Profit and Loss Account placed in the paper book. The Profit and Loss Account reflected gross rental receipts of Rs.11,15,200/- and net profit of Rs.23,587/-. After making an addition of Rs.5,900/- in the computation, the assessee had offered business income of Rs.29,487/-, rounded off to Rs.29,490/-.

ITA 4065/MUM/2026 SHREE SHANKESHWAR AND F A 13. The learned AR submitted that the notice under section 148A(b) was issued only on the allegation of escapement of capital gain arising from the purported sale of immovable property. No addition was ultimately made under the head “Capital Gains”. The Assessing Officer instead estimated notional rent with reference to the stamp duty value and made additions under the head “Income from House Property”. It was contended that the income forming the sole basis of the notice under section 148A(b) was not assessed and that the additions ultimately made related to altogether different issues. 14. In support of this contention, the learned AR relied upon the following decisions: In CIT v. Jet Airways (I) Ltd. [2010] 195 Taxman 117 i. (Bom.)/[2011] 331 ITR 236 (Bom.) In S.V. Jadhav v. ITO [2024] 163 taxmann.com 263 ii. (Bom.)/[2025] 477 ITR 80 (Bom.) In Pr. CIT v. Lark Chemicals (P.) Ltd. [2018] 99 iii. taxmann.com 311 (Bom.). The Special Leave Petition filed by the Revenue was dismissed by the Hon’ble Supreme Court in Pr. CIT v. Lark Chemicals (P.) Ltd. [2018] 99 taxmann.com 312 (SC)/[2018] 259 Taxman 365 (SC). In Devi Manubhai Shah v. ITO [2026] 182 taxmann.com iv. 326 (Mum. Trib.)/[2026] 217 ITD 123 (Mum. Trib.). In Narendra Vinayak Palmure v. ITO [2026] 187 v. taxmann.com 748 (Bang. Trib.)/[2026] 219 ITD 338 (Bang. Trib.). In Subhash Runwal v. ITO [2025] 170 taxmann.com 798 vi. (Pune Trib.) 15. On the basis of the aforesaid decisions, the learned AR submitted that the reassessment order was without jurisdiction and was liable to be quashed. 16. Per contra, the learned Departmental Representative relied upon the orders passed by the authorities below and supported the reassessment proceedings and the additions made by the Assessing Officer. 7

ITA 4065/MUM/2026 SHREE SHANKESHWAR AND F A 17. We have considered the rival submissions and perused the material available on record. The principal question for our consideration is whether, after initiating reassessment on the allegation that capital gain arising from an alleged sale of immovable property had escaped assessment, the Assessing Officer could sustain the reassessment solely by making additions on account of notional rental income and by changing the head under which the disclosed rental receipts were assessable, without making any addition in respect of the alleged capital gain. 18. The notice dated 21.03.2022 issued under section 148A(b) expressly alleged that the assessee had sold an immovable property during the financial year 2017-18 for nil consideration as against its stamp duty value of Rs.33,20,000/- and had not offered any income under the head “Capital Gains”. Thus, the alleged escapement forming the basis of the notice was the capital gain purportedly arising from the alleged sale of the property. 19. In its reply dated 18.04.2022, the assessee explained that it had not sold the property. The tenancy rights had been transferred by the legal heirs of the deceased tenant to another tenant. The assessee was merely the landlord and a confirming party to the agreement and had received no consideration. The assessment order itself proceeds on the basis that the transaction was an agreement for transfer of tenancy rights and not a sale of the property by the assessee. Significantly, the Assessing Officer made no addition under the head “Capital Gains” in respect of the transaction referred to in the notice under section 148A(b). 20. The Assessing Officer instead estimated notional rent by applying 20 per cent to the stamp duty value and made an addition of Rs.4,64,800/- under the head “Income from House Property”. He also made a separate addition of Rs.7,51,153/- by assessing the disclosed rental receipts under the head “Income from House Property” instead of the head “Profits and Gains of Business or Profession”. These additions concern the determination and classification of rental income. They are distinct from the alleged capital gain arising from the purported sale of the property, which alone formed the basis of the notice under section 148A(b).

ITA 4065/MUM/2026 SHREE SHANKESHWAR AND F A 21. The contention raised by the learned AR is a pure question of law arising from the notice under section 148A(b), the assessee’s reply and the reassessment order, all of which form part of the existing record. No investigation into any new fact is required. The contention also falls within the amplitude of Ground No. 2, whereby the assessee has challenged the validity of the reassessment proceedings. We, therefore, proceed to adjudicate the same. 22. In S.V. Jadhav v. ITO (supra), the Hon’ble jurisdictional High Court considered proceedings initiated under the post-2021 reassessment regime. The Assessing Officer had accepted the explanation furnished by the assessee in respect of the transactions referred to in the notice under section 148A(b) but sought to proceed on another issue. The Hon’ble High Court, after applying the principle laid down in CIT v. Jet Airways (I) Ltd. (supra), held that the order under section 148A(d) could not be sustained. 23. The relevant observations of the Hon’ble jurisdictional High Court in S.V. Jadhav v. ITO (supra) are reproduced below: “9. Admittedly, in the notice issued under Section 148A(b) of the Act, certain allegations have been made to which reply has been filed and the AO has accepted that the information is accounted for by the assessee. ... In paragraph 6.1, however, the AO proceeds on the basis that on a search conducted under Section 132 of the Act on one Prathamesh Constructions, it was found that Prathamesh Constructions was subcontracting its jobs to various subcontractors and Petitioner was one of such subcontractors. The AO, therefore, wanted to verify the genuineness of the contract work done by Petitioner or whether any accommodation entry was provided to Prathamesh Constructions. It is necessary to note that, first of all, in re-assessment proceedings, the law is clear. An Assessing Officer cannot indulge in a fishing enquiry. In Asstt. CIT v. Rajesh Jhaveri Stock Brokers (P.) Ltd. [2007] 161 Taxman 316/291 ITR 500 (SC), the Apex Court has held that at the stage of issuance of notice, the only question is whether there was relevant material on which a reasonable person could have formed the requisite belief of escapement of income. In the notice issued under Section 148A(b) of the Act, there is not even a reference of what is stated in paragraph 6.1 of the impugned order. As held by this Court in Mrs. Neetu M. Chandaliya v. ITO [2023] 156 taxmann.com 85/[2024] 462 ITR 50 (Bombay)/2023 SCC Online Bom 2046, the reasons as

ITA 4065/MUM/2026 SHREE SHANKESHWAR AND F A mentioned in paragraph 6.1 of the impugned order, at the highest, can only be termed as ‘a suspicion subject to a case of fishing enquiry’. ... 11... In any case, the Division Bench of this Court in CIT v. Jet Airways (I) Ltd. [2010] 195 Taxman 117/[2011] 331 ITR 236 (Bombay)/2010 SCC Online Bom. 2065, held that the effect of Section 147 is that the AO has to assess or reassess such income that has escaped assessment and which was the basis of the formation of belief and if he does so, he can also assess or reassess any other income which has escaped assessment and which comes to his notice during the course of the proceedings. However, if after issuing a notice under Section 148 of the Act, the AO accepts the contention of the assessee and holds that the income which he has initially formed a reason to believe had escaped assessment, has as a matter of fact not escaped assessment, it is not open to him independently to assess some other income.

... In this case, the AO has accepted the contention of the assessee and held that the information report by the Insight portal is accounted for by the assessee in his books and income arising out of those transactions is duly offered for taxation. Therefore, the impugned order dated 21st April 2023 under Section 148A(d) of the Act cannot be sustained. At the same time if the AO wishes to, he could issue a fresh notice under Section 148A(b) of the Act if, that is permitted in law. We are expressing no opinion.” 24. The aforesaid decision directly applies to the controversy before us. In the present case also, the notice under section 148A(b) was confined to the allegation that the assessee had sold an immovable property for nil consideration against its stamp duty value of Rs.33,20,000/- and had not offered the resultant capital gain to tax. The assessee explained that it had not sold the property and that it was merely a confirming party to the transfer of tenancy rights between the outgoing and incoming tenants. The assessment order accepts the essential factual position that the transaction was a transfer of tenancy rights and not a sale of the property by the assessee. No addition whatsoever was ultimately made under the head “Capital Gains”. 25. The cumulative ratio emerging from juridical precedents relied upon is that where reassessment is initiated in respect of a particular item of escaped income, the Assessing Officer must assess or reassess that income before assuming jurisdiction to assess any other income coming to his notice during the 10

ITA 4065/MUM/2026 SHREE SHANKESHWAR AND F A reassessment proceedings. If the income which formed the foundation of the reassessment is accepted as not having escaped assessment and no addition is made in respect thereof, the Assessing Officer cannot sustain the reassessment solely by making an addition on an independent issue. 26. In Jet Airways (I) Ltd. (supra), the Hon’ble jurisdictional High Court held that where the Assessing Officer accepts that the income forming the basis of reopening had not escaped assessment, “it is not open to him to independently assess some other income.” The said principle was reiterated in Lark Chemicals (P.) Ltd. (supra), wherein it was held that “the order passed on reassessment is bad in law” in the absence of reassessment of the income which formed the basis of the reopening. The Special Leave Petition filed by the Revenue against that decision was dismissed by the Hon’ble Supreme Court in Pr. CIT v. Lark Chemicals (P.) Ltd. [2018] 99 taxmann.com 312 (SC)/[2018] 259 Taxman 365 (SC). 27. The Co-ordinate Bench in Devi Manubhai Shah (supra) similarly held that “the Assessing Officer did not have jurisdiction to make some other addition/disallowance in the hands of the Assessee.” In Subhash Runwal (supra), it was held that where the very basis recorded for reopening did not result in an addition, “such reassessment cannot be treated as a valid order in the eyes of law.” In Narendra Vinayak Palmure (supra), which involved reopening on the ground of a difference between the stamp duty valuation and the disclosed consideration, the Co-ordinate Bench held that “no other addition can be sustained in the reassessment order” when no addition was made on the issue for which the assessment was reopened. 28. Thus, the consistent judicial position is that the Assessing Officer cannot abandon the income specified in the notice under section 148A(b) and sustain the reassessment only on the basis of another and distinct item of income. The Explanation to section 147 does not dispense with the statutory requirement that the reassessment must remain founded upon an income which had escaped assessment. Nor can an issue not disclosed to the assessee in the notice under section 148A(b) be used as a

ITA 4065/MUM/2026 SHREE SHANKESHWAR AND F A substitute for the original allegation after the assessee has satisfactorily explained that allegation. 29. In the present case, the alleged escapement specified in the notice under section 148A(b) was capital gain arising from the alleged sale of immovable property. The additions ultimately made, however, were towards the notional annual letting value of the property and the classification of the disclosed rental receipts under the head “Income from House Property”. The source, character and statutory basis of these additions are different from the alleged capital gain forming the subject matter of the notice. Once the Assessing Officer accepted that there was no sale of the property by the assessee and made no addition under the head “Capital Gains”, the very foundation on which the reassessment was initiated ceased to survive. 30. The learned DR has relied upon the orders of the authorities below but has not pointed out any material distinction from the binding decisions of the Hon’ble jurisdictional High Court. The learned CIT(A) also did not adjudicate the jurisdictional challenge on merits and dismissed the appeal for want of compliance. 31. Even on merits, we find that the addition of Rs.4,64,800/- towards notional rental income was founded solely upon the Assessing Officer’s assumption that the annual rent should be taken at 20 per cent of the stamp duty value of Rs.33,20,000/-. The assessment order does not refer to the municipal rateable value, comparable instances of rent in the same locality, any report of a valuation officer or any other material demonstrating that the property could reasonably be expected to fetch rent of Rs.6,64,000/- per annum. Stamp duty value represents the value adopted for the purposes of registration and cannot, by itself and without any supporting material, constitute the annual letting value under section 23(1)(a) of the Act. The adoption of 20 per cent of the stamp duty value is, therefore, an ad hoc estimate unsupported by any discernible basis. 32. We further notice that, after estimating the rent at Rs.6,64,000/-, the Assessing Officer allowed a deduction of 30 per cent but described the same as a deduction under section 24(b). The statutory deduction of 30 per cent of the annual value is

ITA 4065/MUM/2026 SHREE SHANKESHWAR AND F A provided under section 24(a), whereas section 24(b) concerns deduction for interest payable on borrowed capital. Though this erroneous description may not by itself determine the issue, it reflects the absence of a proper examination of the statutory computation. 33. As regards the addition of Rs.7,51,153/-, the Profit and Loss Account records gross rental receipts of Rs.11,15,200/-. Thus, there is no finding that the rental receipts were suppressed or omitted from the books of account. The dispute is essentially confined to the head under which those receipts were assessable. Even if the Assessing Officer considered the receipts taxable under the head “Income from House Property”, the income already included in the business computation was required to be excluded and the computation recast transparently under the appropriate head so that the same receipts were not retained under both heads. The final computation continues to reflect business income of Rs.29,487/- while separately assessing the house-property income. The assessment order does not contain a clear reconciliation demonstrating that the same income has been eliminated from the business computation. 34. We also find that the learned CIT(A) dismissed the appeal without examining the aforesaid factual and computational aspects. Nevertheless, since the reassessment itself is held to be without jurisdiction, it is unnecessary to record a final conclusion on whether the rental receipts constituted business income or income from house property. It is sufficient to observe that the additions, in the manner framed, are also unsupported by an adequate factual and computational foundation. 35. In view of the foregoing discussion and respectfully following the binding decisions of the Hon’ble jurisdictional High Court, we hold that the reassessment order dated 22.03.2024 passed under section 147 read with section 144B of the Act cannot be sustained. The same is accordingly quashed. Ground No. 2 raised by the assessee is allowed. 36. Since the reassessment itself has been quashed, Ground No. 1 concerning the opportunity afforded by the learned CIT(A), Ground Nos. 3 and 4 concerning the additions on merits, Ground

ITA 4065/MUM/2026 SHREE SHANKESHWAR AND F A No. 5 concerning interest under section 234A and fee under section 234F, and Ground No. 6 concerning interest under section 234B have become academic and do not require separate adjudication. 37. In the result, the appeal filed by the assessee is allowed.

Order pronounced in the open court on 18.08.2026.

Sd/- Sd/- CHALLA NAGENDRA PRASAD MAKARAND VASANT MAHADEOKAR (JUDICIAL MEMBER) (ACCOUNTANT MEMBER) Mumbai, Dated 18/08/2026 Soumili, PS आदेश की �ितिलिप अ�ेिषत/Copy of the Order forwarded to : 1. अपीलाथ� / The Appellant 2. ��थ� / The Respondent. 3. संबंिधत आयकर आयु� / The CIT(A) 4. आयकर आयु�(अपील) / Concerned CIT 5. िवभागीय �ितिनिध, आयकर अपीलीय अिधकरण, मु�बई / DR, ITAT, Mumbai 6. गाड� फाईल / Guard file.

आदेशानुसार/ BY ORDER, स�ािपत �ित //True Copy// उप/सहायक पंजीकार ( Asst. Registrar) आयकर अपीलीय अिधकरण, मु�बई मु�बई मु�बई / ITAT, Mumbai मु�बई 14