ACIT-CC-4(2), MUMBAI, MUMBAI vs. NEEV HOMES PRIVATE LIMITED, MUMBAI

IN THE INCOME TAX APPELLATE TRIBUNAL “B” BENCH MUMBAI BEFORE SHRI SAKTIJIT DEY, VICE PRESIDENT & SHRI MAKARAND VASANT MAHADEOKAR, ACCOUNTANT MEMBER ITA No. 7861/Mum/2025 (Assessment Year: 2013) ACIT CC 4(2), Mumbai Neev Homes Private BKC, Kautilya Bhavan, Limited Mumbai-400 051 Vs. 101, 1st floor, Sunder Apartment, Near Mazgaon Circle, Mazgaon, Mumbai- 400 010 PAN/GIR No. AABCN9519R (Applicant) (Respondent) Revenue by Shree Kumar C., Ld. DR Assessee by Shri Rahul Hakani & Shri Abhishek Modi, Ld. ARs Date of Hearing 24.06.2026 Date of Pronouncement 08.07.2026 आदेश / ORDER PER MAKARAND VASANT MAHADEOKAR, AM: This appeal by the Revenue is directed against the order dated 02.09.2025 passed by the learned Commissioner of Income Tax (Appeals)-52, Mumbai [hereinafter referred to as "the CIT(A)"], under section 250 of the Income Tax Act, 1961 [hereinafter

2 ITA No. 7861/Mum/2025 Neev Homes Private Limited

referred to as "the Act"], for A.Y. 2013-14. The impugned appellate order arises from the assessment order dated 23.03.2016 passed by the Assessing Officer, Central Circle 4(2), Mumbai [hereinafter referred to as "Assessing Officer"] , under section 143(3) of the Act. Facts of the Case 2. The assessee is a company engaged in the business of builders and developers. The assessee filed its return of income for A.Y. 2013-14 on 31.12.2013 declaring total income of Rs.3,03,96,760/-. The return was processed under section 143(1) of the Act. The case was selected for scrutiny assessment under CASS and notice under section 143(2) dated 02.09.2014 was issued and served upon the assessee. Thereafter, notice under section 142(1) read with section 129 of the Act along with questionnaire, was issued due to change in incumbency and for calling for necessary details. In response, the assessee furnished the details called for. 3. In the assessment order, the Assessing Officer computed the income of the assessee by taking income as per statement at Rs.3,16,39,696/-, making addition of Rs.3,97,000/- towards disallowance of expenses and Rs.2,50,00,000/- towards undisclosed income, and after allowing adjustment of brought forward business loss of Rs.12,20,214/- and brought forward unabsorbed depreciation of Rs.22,723/-, assessed total income at

3 ITA No. 7861/Mum/2025 Neev Homes Private Limited

Rs.5,57,93,759/-, rounded off under section 288A to Rs.5,57,93,760/-. 4. The principal dispute in Ground Nos. 1 to 5 of the Revenue’s appeal relates to deletion by the learned CIT(A) of addition of Rs.2,50,00,000/- made by the Assessing Officer on account of alleged undisclosed income arising from Deed of Assignment dated 19.03.2013. During the assessment proceedings, the Assessing Officer noticed from the profit and loss account that the assessee had shown receipt of Rs.5,00,00,000/- under the head “compensation for Kamgar Property”. The assessee was called upon to submit the relevant deed of development of the property. In response, the assessee submitted the Deed of Assignment along with letter dated 26.02.2016. On perusal of the Deed of Assignment, the Assessing Officer observed that, under the head “Grant”, the assignee was to pay an amount of Rs.80,00,00,000/- to M/s. Neev Infrastructure Pvt. Ltd. and M/s. Neev Homes Pvt. Ltd. The Assessing Officer further observed that pages 8 and 9 of the Deed of Assignment explained the manner in which the amount of Rs.80,00,00,000/- was to be distributed between M/s. Neev Infrastructure Pvt. Ltd. and the assessee. 5. As per the Assessing Officer, according to the conditions recorded in the Deed of Assignment, after completion of the project, M/s. Neev Infrastructure Pvt. Ltd. was to receive Rs.72,50,00,000/- and the assessee was to receive Rs.7,50,00,000/-. The Assessing Officer observed that M/s. Neev

4 ITA No. 7861/Mum/2025 Neev Homes Private Limited

Infrastructure Pvt. Ltd. had offered Rs.72,50,00,000/- for taxation in A.Y. 2013-14, whereas the assessee had offered only Rs.5,00,00,000/- instead of Rs.7,50,00,000/- during the year under consideration, even though, according to the Assessing Officer, the project had been completed. Accordingly, the authorised representative was asked vide order sheet noting dated 29.02.2016 to explain why the receipt of Rs.2,50,00,000/- from Kamgar Nagar as per the Deed of Assignment had not been offered to tax and why the same should not be added to the total income of the assessee. As recorded by the Assessing Officer, there was no reply at that stage. The authorised representative was again asked vide order sheet noting dated 11.03.2016 to explain why the receipt of Rs.2,50,00,000/- should not be added to the income of the assessee. 6. In response, the assessee submitted letter dated 19.03.2016 on 21.03.2016 stating that the balance payment of Rs.2.50 crores, that is Rs.2,50,00,000/-, to be received from Skylark Buildcon Pvt. Ltd. against the sale of Kamgar Nagar Property was not offered in F.Y. 2012-13, as it was not reasonably certain that the said sum would be received by the company. It was further stated that the auditors of the company were of the view that the same should be offered for taxation only when it was reasonably certain that the sum would be received. The assessee also stated that the income would be offered for tax once the same was received and that even till the date of the said letter, after a lapse of three years, the payment had not been received.

5 ITA No. 7861/Mum/2025 Neev Homes Private Limited

6 ITA No. 7861/Mum/2025 Neev Homes Private Limited

consideration of Rs.80,00,00,000/- to M/s. Skylark Buildcon Pvt. Ltd. It was submitted that the assessee’s total share of Rs.7,50,00,000/- was receivable in three tranches, namely Rs.3,50,00,000/- as advance on or prior to execution of the Deed of Assignment, Rs.1,50,00,000/- on compliance with the conditions stated in clause 4(i)(a), and Rs.2,50,00,000/- on compliance with the conditions stated in clause 4(i)(b) of the Deed of Assignment. The assessee explained that the first two tranches aggregating to Rs.5,00,00,000/- were recognised and offered to tax, whereas the third tranche of Rs.2,50,00,000/- was not recognised as the relevant conditions precedent had not been satisfied during the year under consideration and the amount was also subject to step-in rights under clause 4(ii), whereby necessary costs could be deducted from the assignors’ compensation. 9. The assessee further submitted before the learned CIT(A) that the right to receive or accrual of Rs.2,50,00,000/- was not established in the year under consideration and the amount to be received was neither quantifiable nor measurable during the said year. It was contended that the addition made by the Assessing Officer was towards notional income and not real income, which had not accrued to the assessee during the assessment year under consideration. The assessee also filed additional evidences, including details relating to subsequent receipts, civil proceedings and other documents. It was stated that, out of the amount of Rs.2,50,00,000/-, the assessee received Rs.50,00,000/- on

7 ITA No. 7861/Mum/2025 Neev Homes Private Limited

06.11.2019 and offered the same to tax in A.Y. 2020-21, and the remaining amount continued to be disputed. The assessee also referred to subsequent Consent Terms dated 30.05.2025 approved by the Hon’ble Bombay High Court on 02.06.2025 in Arbitration Application (L) No.38847 of 2022 and submitted that the said development showed that the entire amount of Rs.2,50,00,000/- had not accrued in A.Y. 2013-14. 10. The learned CIT(A) called for remand report from the Assessing Officer on the admissibility of additional evidences and on the merits of the additions made. The Assessing Officer, in the remand proceedings, accepted that the additional evidences were relevant and essential to decide the grounds before the learned CIT(A) and stated that the same may be admitted. On merits, however, the Assessing Officer maintained that the Deed of Assignment gave rise to enforceable right to receive the amount and that the assessee, following mercantile system of accounting, was required to offer Rs.2,50,00,000/- in A.Y. 2013-14. 11. After considering the assessment order, submissions of the assessee, additional evidences, remand report and rejoinder, the learned CIT(A) deleted the addition of Rs.2,50,00,000/-. The learned CIT(A) observed that, although the assessee followed mercantile system of accounting, as per Accounting Standard-9 only those accruals could be offered as revenue for taxation where there was reasonable certainty of receipt. The learned CIT(A) held that since the conditions in clause 4(i)(b) of the Deed

8 ITA No. 7861/Mum/2025 Neev Homes Private Limited

of Assignment had not been fulfilled, the legal right to receive the balance amount of Rs.2,50,00,000/- never came into the hands of the assessee during A.Y. 2013-14. It was further held that the amount was receivable only at the stage of the third tranche and the right was conditional. Accordingly, the learned CIT(A) held that the assessee had rightly not offered Rs.2,50,00,000/- for taxation in A.Y. 2013-14 and deleted the addition. 12. The second dispute, raised in Ground Nos. 6 and 7 of the Revenue’s appeal, relates to deletion of disallowance of Rs.3,97,000/- made by the Assessing Officer under section 37(1) of the Act. During the assessment proceedings, the Assessing Officer observed from the profit and loss account that the assessee had debited Rs.33,60,258/- under the head “other expenses”. The assessee was asked to substantiate the expenses vide order sheet noting dated 29.02.2016 and was granted one more opportunity vide order sheet noting dated 03.03.2016. In response, the assessee submitted details of expenses on 08.03.2016. The Assessing Officer noted that most of the expenses pertained to earlier years and the assessee explained that such expenses formed part of work-in-progress, which was substantiated by submitting earlier year balance sheet and relevant schedules. However, the Assessing Officer further noticed that certain bills were not in the name of the assessee and, in one instance, the assessee could not substantiate the expenditure with bills.

9 ITA No. 7861/Mum/2025 Neev Homes Private Limited

10 ITA No. 7861/Mum/2025 Neev Homes Private Limited

followed percentage completion method of accounting; that these expenses related to F.Y. 2009-10, relevant to A.Y. 2010-11, and were then transferred to work-in-progress; and that A.Y. 2013-14 was the year in which the assessee first recognised revenue from the project and, therefore, the expenses were transferred from work-in-progress and debited to the profit and loss account.

11 ITA No. 7861/Mum/2025 Neev Homes Private Limited

enforceable upon execution of the deed, and hence, taxable on accrual basis under the mercantile system of accounting. 3. On facts and in law, the learned CIT(A) erred in ignoring that the assessee’s own conduct, such as issuance of demand notices dated 14.03.2018, 05.04.2022, and 02.07.2022, and filing of a civil suit claiming interest from 19.03.2013, clearly established that the right to receive the amount had arisen in FY 2012-13. 4. On facts and in law, the learned CIT(A) erred in deleting the addition of Rs.2,50,00,000/- without appreciating that the assessee’s sister concern, M/s Neev Infrastructure Pvt. Ltd., which was a party to the same Deed of Assignment, had offered its entire share of Rs.72.50 crore to tax in the same year, thereby confirming that the consideration had accrued and become due during A.Y. 2013-14. 5. On facts and in law, the learned CIT(A) erred in relying upon additional evidences filed under Rule 46A which were created after the completion of assessment and which did not alter the factual position regarding accrual of income. 6. On facts and in law, the learned CIT(A) erred in deleting the disallowance of Rs.3,97,000/- made by the Assessing Officer under section 37(1), without appreciating that certain bills were not in the assessee’s name, some were in the name of ‘Neev Group,’ and one advertisement bill of Rs.50,000/- was unsupported by any evidence. 7. On facts and in law, the learned CIT(A) failed to appreciate that the Assessing Officer had rightly disallowed the aforesaid expenditure after proper verification during assessment proceedings and that the assessee failed to substantiate the genuineness of the claim with proper documentary evidence. The appellant craves to leave, to add, to amend and / or to alter any of the ground of appeal, if need be. The appellant, therefore, prays that on the ground stated above, the order of the Ld. CIT (A)-52, Mumbai, may be set aside and that of the Assessing Officer restored.

12 ITA No. 7861/Mum/2025 Neev Homes Private Limited

13 ITA No. 7861/Mum/2025 Neev Homes Private Limited

of the contractual conditions. Therefore, the learned CIT(A) correctly held that the legal right to receive Rs.2,50,00,000/- never came into the hands of the assessee during the year under consideration. 19. The learned AR also submitted that the learned CIT(A), after considering the merits of the case, the subsequent settlement approved by the Hon’ble Bombay High Court, the accounting treatment, and the judicial pronouncements relied upon before him, rightly concluded that the assessee had not offered Rs.2,50,00,000/- in A.Y. 2013-14 for taxation. He further submitted that the case of the assessee was distinguishable from that of its sister concern, M/s. Neev Infrastructure Pvt. Ltd., and the learned CIT(A) has examined the distinction and found the same to be in order. He, therefore, submitted that the finding of the learned CIT(A) deleting the addition of Rs.2,50,00,000/- calls for no interference and the grounds raised by the Revenue on this issue deserve to be dismissed. 20. The learned Departmental Representative (DR), per contra, strongly relied upon the assessment order as well as the remand report submitted by the Assessing Officer during the appellate proceedings before the learned CIT(A). He submitted that though the Assessing Officer, in the remand report, had stated that the additional evidences produced by the assessee may be admitted, the Assessing Officer had categorically objected to the claim of the assessee on merits. It was submitted that the learned CIT(A)

14 ITA No. 7861/Mum/2025 Neev Homes Private Limited

erred in deleting the addition of Rs.2,50,00,000/- without properly appreciating the detailed factual findings recorded by the Assessing Officer in the remand report. 21. We have considered the rival submissions and perused the material available on record, including the assessment order, the order of the learned CIT(A), the remand report of the Assessing Officer, the Deed of Assignment dated 19.03.2013, the subsequent correspondence, the civil proceedings and the Consent Terms dated 30.05.2025 approved by the Hon’ble Bombay High Court on 02.06.2025 in Arbitration Application (L) No.38847 of 2022. The Revenue is aggrieved by the action of the learned CIT(A) in deleting the addition of Rs.2,50,00,000/- made by the Assessing Officer on the footing that the said amount had accrued to the assessee during A.Y. 2013-14 under the Deed of Assignment. 22. The material facts are not in serious dispute. The assessee, along with M/s. Neev Infrastructure Pvt. Ltd. and others, was party to the Deed of Assignment dated 19.03.2013 with Skylark Buildcon Pvt. Ltd. Under the said deed, the assignors agreed to transfer rights, title, benefits and interest in the slum land and future rights in respect thereof for an aggregate consideration of Rs.80,00,00,000/-. Out of the said consideration, the share of M/s. Neev Infrastructure Pvt. Ltd. was Rs.72,50,00,000/- and the share of the assessee was Rs.7,50,00,000/-. The assessee admittedly offered Rs.5,00,00,000/- to tax in A.Y. 2013-14,

15 ITA No. 7861/Mum/2025 Neev Homes Private Limited

comprising Rs.3,50,00,000/- received on or prior to execution of the deed and Rs.1,50,00,000/- relatable to the tranche linked with clause 4(i)(a). The dispute is confined to the balance amount of Rs.2,50,00,000/-, which, as per the assessee, was linked with fulfilment of clause 4(i)(b) and was further subject to the step-in and adjustment mechanism contained in clause 4(ii) of the deed. 23. In our considered view, the controversy is not merely whether the assessee ultimately had a claim against the assignee. The real question is whether, during the previous year relevant to A.Y. 2013-14, the assessee had acquired a vested, unconditional and enforceable right to receive Rs.2,50,00,000/- so as to bring the said amount to tax on accrual basis. Even under the mercantile system of accounting, income cannot be taxed merely because a claim is made or because an amount is mentioned in an agreement. There must be accrual in the real sense. Accrual postulates the coming into existence of a debt due, coupled with a corresponding obligation on the other party to pay. Where the right to receive is conditional, uncertain, disputed or dependent upon fulfilment of future obligations, the income cannot be said to have accrued merely on the basis of an agreement mentioning the amount. 24. This aspect assumes importance in the present case because the assessee’s case is specifically founded on Accounting Standard-9. The learned CIT(A) has correctly noticed that though the assessee follows mercantile system of accounting, revenue

16 ITA No. 7861/Mum/2025 Neev Homes Private Limited

recognition under Accounting Standard-9 is governed by the principle of reasonable certainty of ultimate collection. The concept of “reasonable certainty” is not alien to the mercantile system. It operates at the stage of determining whether income has, in fact, accrued as real income. Where the receipt is contingent upon performance of conditions and is subject to adjustment or reduction, the mere mention of a figure in the deed does not automatically result in taxable accrual. 25. The remand report itself records that the payment of Rs.2,50,00,000/- to the assessee was linked with fulfilment of the condition stated in clause 4(i)(b) of the Deed of Assignment. The report further records that, under clause 4(ii), if the assignors failed to comply with or fulfil the conditions set out in clause 4(i)(b), the assignee was entitled to undertake or perform such obligations and deduct the cost from the second tranche balance consideration payable to the assignors. Thus, the remand report, while arguing against the assessee, itself brings out that the amount was not simpliciter payable without reference to any condition. The payment was connected with a condition and was also subject to reduction by the rectification amount or cost incurred by the assignee. Once this factual position is accepted, it becomes difficult to hold that the entire amount of Rs.2,50,00,000/- had accrued with reasonable certainty in A.Y. 2013-14.

17 ITA No. 7861/Mum/2025 Neev Homes Private Limited

18 ITA No. 7861/Mum/2025 Neev Homes Private Limited

19 ITA No. 7861/Mum/2025 Neev Homes Private Limited

sustainable. Subsequent events may be looked into when they throw light on the true nature of the right claimed in the earlier year, particularly where the issue is whether there was reasonable certainty of receipt. 30. It is also relevant that the assessee actually received only Rs.50,00,000/- in F.Y. 2019-20 and offered the same to tax in A.Y. 2020-21. It was further submitted before the learned CIT(A) that under the settlement approved by the Hon’ble Bombay High Court, further taxability would arise only to the extent of actual crystallisation or receipt and that the entire balance of Rs.2,50,00,000/- was not received. These facts support the assessee’s case that the whole amount of Rs.2,50,00,000/- was not an accrued income in A.Y. 2013-14. If the entire amount had really accrued with certainty in A.Y. 2013-14, there was no reason for the matter to remain disputed for years and to be ultimately resolved through court approved Consent Terms. 31. The Revenue has also placed strong reliance on the fact that M/s. Neev Infrastructure Pvt. Ltd., being a party to the same Deed of Assignment, offered its entire share of Rs.72,50,00,000/- to tax in A.Y. 2013-14. The learned CIT(A) has considered this aspect and accepted the assessee’s explanation distinguishing its case from that of M/s. Neev Infrastructure Pvt. Ltd. In our view, the tax treatment adopted by another assessee, though a relevant fact for examination, cannot be determinative of accrual in the hands of the present assessee. Each assessee’s income has to be

20 ITA No. 7861/Mum/2025 Neev Homes Private Limited

assessed in accordance with its own facts, its own right to receive, its own accounting treatment and the certainty of its own receipts. The share of M/s. Neev Infrastructure Pvt. Ltd. was much larger and its role, rights and commercial position were stated to be different. Merely because the sister concern offered its income in a particular manner, an amount which had not accrued with reasonable certainty to the present assessee cannot be brought to tax in its hands. 32. The learned CIT(A), in paragraphs 7.9 and 7.10 of the impugned order, has specifically recorded that although the assessee was following mercantile system of accounting, as per Accounting Standard-9 only those accruals could be offered for taxation where there was reasonable certainty of receipt. He further recorded that since the conditions in clause 4(i)(b) of the Assignment Deed had not been fulfilled, a legal right to receive the last balance of Rs.2,50,00,000/- never came into the hands of the assessee and the said amount was receivable only at the time of the third tranche, such right being conditional. The learned CIT(A) also took note of the Consent Terms approved by the Hon’ble Bombay High Court and the judicial principles relied upon before him and held that the assessee had rightly not offered Rs.2,50,00,000/- in A.Y. 2013-14. 33. We find no infirmity in the aforesaid findings of the learned CIT(A). The learned CIT(A) has not deleted the addition merely on sympathetic consideration or merely on the basis of subsequent

21 ITA No. 7861/Mum/2025 Neev Homes Private Limited

settlement. The deletion is founded on the central fact that the balance amount of Rs.2,50,00,000/- was conditional, disputed, not reasonably certain of collection, and not crystallised as an enforceable income during the previous year relevant to A.Y. 2013-14. The remand report, when read as a whole, does not dislodge this conclusion. On the contrary, the remand report confirms that the payment was linked with clause 4(i)(b) and subject to the mechanism of clause 4(ii). These very features support the view that revenue recognition in A.Y. 2013-14 was not warranted in respect of the disputed balance amount. 34. In view of the above discussion, we uphold the order of the learned CIT(A) deleting the addition of Rs.2,50,00,000/-. Ground Nos. 1 to 5 raised by the Revenue are accordingly dismissed. 35. Ground Nos. 6 and 7 of the Revenue’s appeal relate to deletion of disallowance of Rs.3,97,000/- made by the Assessing Officer under section 37(1) of the Act. At the time of hearing, no specific arguments were advanced by either side on this issue. However, since the Revenue has raised these grounds in appeal, we proceed to adjudicate the same on the basis of material available on record and the findings recorded by the learned CIT(A). 36. The Assessing Officer had disallowed the aggregate amount of Rs.3,97,000/- comprising MCGM property tax of Rs.2,47,000/- , advertisement expenses paid to Pudhari Publications Pvt. Ltd. of Rs.1,00,000/-, and advertisement expenses paid to Ni Sa

22 ITA No. 7861/Mum/2025 Neev Homes Private Limited

Entertainment of Rs.50,000/-. The disallowance was made mainly on the ground that some bills were not in the name of the assessee and, in one instance, the bill was not produced. The Assessing Officer held that the assessee failed to substantiate the genuineness of these expenses. 37. Before the learned CIT(A), the assessee explained that Rs.2,47,000/- represented MCGM property tax paid by demand draft No.698265, debited from the assessee’s current account with Vijaya Bank on 11.12.2009. The amount of Rs.1,00,000/- represented advertisement expenses paid to M/s. Pudhari Publications Pvt. Ltd. for creative advertisement relating to the Kamgar real estate project, paid vide cheque No.227483 on 14.08.2010 from the current account with Vijaya Bank. The amount of Rs.50,000/- represented advertisement expenses paid to M/s. Ni Sa Entertainments vide cheque No.227470 on 04.05.2010 from the current account with Vijaya Bank for the Kamgar property. The assessee further explained that it was following the percentage completion method of accounting and that the expenses, though incurred in earlier years, were transferred to work-in-progress and claimed in A.Y. 2013-14 when the corresponding revenue from the project was recognised. 38. The learned CIT(A), after examining the details, accepted the explanation of the assessee. The learned CIT(A) recorded that the payments were made through the assessee’s bank account and were relatable to the Kamgar project. The learned CIT(A) further

23 ITA No. 7861/Mum/2025 Neev Homes Private Limited

held that, since the assessee was following the percentage completion method, the expenses were rightly carried as work-in- progress and claimed in the year in which the revenue was offered. He also recorded that there was no finding of double claim of the said expenditure. On this basis, the learned CIT(A) held that the expenses were genuine and bona fide business expenses allowable under section 37(1) of the Act. 39. Having considered the findings of the learned CIT(A), we find no reason to interfere. The disallowance made by the Assessing Officer was based mainly on the description appearing on the bills and alleged insufficiency of supporting material. However, the learned CIT(A) has recorded a factual finding that the payments were made from the assessee’s own bank account and were connected with the assessee’s business project. The Revenue has not brought any material before us to controvert these factual findings. Further, once the assessee was following the percentage completion method and the expenses were carried as work-in-progress, the claim in the year of revenue recognition cannot be rejected merely because the expenditure was incurred in an earlier year, particularly when no double deduction has been shown. 40. Accordingly, in the absence of any specific argument or contrary material from the Revenue, and considering the factual findings recorded by the learned CIT(A), we uphold the deletion of

24 ITA No. 7861/Mum/2025 Neev Homes Private Limited

disallowance of Rs.3,97,000/-. Ground Nos. 6 and 7 raised by the Revenue are dismissed.

Order pronounced in the open court on 08.07.2026.

Sd/- Sd/- (SAKTIJIT DEY) (MAKARAND VASANT MAHADEOKAR) VICE PRESIDENT ACCOUNTANT MEMBER Mumbai, Dated 08/07/2026 Dhananjay, Sr.PS आदेश की प्रतितिति अग्रेतिि/Copy of the Order forwarded to : 1. अपीलार्थी / The Appellant प्रत्यर्थी / The Respondent. 2. संबंधित आयकर आयुक्त / The CIT(A) 3. आयकर आयुक्त(अपील) / Concerned CIT 4. धिभागीय प्रधतधिधि, आयकर अपीलीय अधिकरण, मुम्बई / DR, ITAT, Mumbai 5. गार्ड फाईल / Guard file. 6. आदेशानुसार/ BY ORDER, सत्याधपत प्रधत //True Copy// 1. उि/सहायक िंजीकार ( Asst. Registrar) आयकर अिीिीय अतिकरण, मुम्बई / ITAT, Mumbai