NAROTAM SEKHSARIA TANVI TRUST,MUMBAI vs. ITO, WARD 42(2)(1), MUMBAI, MUMBAI

ITA 2211/MUM/2026Status: DisposedITAT Mumbai08 July 2026AY 2021-225 pages

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Income Tax Appellate Tribunal, “B” BENCH, MUMBAI

Before: SHRI SANDEEP GOSAIN & SHRI JAGADISH

For Appellant: Shri Fenil Bhatt
For Respondent: Shri Kumar C. (SR. AR)
Hearing: 06.07.2026Pronounced: 08.07.2026

Per: SHRI JAGADISH, A.M.:

1.

This appeal by the assessee is directed against the order dated 12.12.2025 passed by the Ld. Addl./JCIT(A), Gwalior (hereinafter referred as the Ld. CIT(A) for the assessment year 2021-22. 2. The assessee has raised the grievance that though the Ld. CIT(A) allowed the appeal by holding that surcharge at the rate of 37% levied by CPC in the rectification order was incorrect and that surcharge was chargeable only at 15%, the operative direction contained in para 5.6 of the appellate order is restrictive inasmuch as it confines the rate of surcharge of 15% only to dividend income and long-term capital gains taxable under section 112A, instead of clarifying that the

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