KAMLESH MANHARLAL SHAH, LEGAL HEIR OF LATE MANHARLAL VRJALAL SHAH,MUMBAI vs. INCOME-TAX OFFICER, WARD 25(2)(1), MUMBAI

IN THE INCOME TAX APPELLATE TRIBUNAL “K” BENCH MUMBAI BEFORE MS. KAVITHA RAJAGOPAL, JUDICIAL MEMBER & SHRI MAKARAND VASANT MAHADEOKAR, ACCOUNTANT MEMBER ITA No. 2707/Mum/2026 (Assessment Year: 2011-12) Kamlesh Manharlal ITO Ward 25(2)(1) Shah (Legal Heir of Kautilya Bhawan, Late Manharlal Vrjalal Vs. Bandra Kurla Shah) Complex, Bandra Boulevard 3 Flat No. East, Mumbai- 503, The Addresse 400 051 (Wadhwa) Opp R. City Mall, LBS Marg, Ghatkopar west, Mumbai-400 086 PAN/GIR No. AMOPS9091H (Applicant) (Respondent) Assessee by Shri Mehul Shah, Ld. AR Revenue by Shri Sumit Kumar Jha, Ld. DR Date of Hearing 07.05.2026 Date of Pronouncement 29.06.2026 आदेश / ORDER PER MAKARAND VASANT MAHADEOKAR, AM: The present appeal has been filed by the assessee, through the legal heir of Late Shri Manharlal Vrajlal Shah, against the order dated 19.01.2026 passed by the Office of Commissioner of

2 ITA No. 2707/Mum/2026 Kamlesh Manharlal Shah (Legal Heir of Late Manharlal Vrjalal Shah) Income Tax, Appeal - learned Addl./JCIT(A), Agra[hereinafter referred to as "CIT(A)"] under section 250 of the Income-tax Act, 1961 [hereinafter referred to as "the Act"] for Assessment Year 2011-12, arising out of the assessment order dated 21.12.2018 passed by the Income Tax Officer, Ward-17(2)(3), Mumbai [hereinafter referred to as "Assessing Officer"]under section 143(3) read with section 147 of the Act. Facts of the Case 2. Briefly stated, the facts of the case are that the assessee had not originally filed his return of income for Assessment Year 2011-12. The case was reopened by the Assessing Officer on the basis of information available in the departmental system reflecting sale of an immovable property for a consideration of Rs. 1,20,00,000/-. After recording reasons and obtaining approval under section 151 of the Act, notice under section 148 was issued on 23.03.2018. In response thereto, the assessee filed his return of income electronically on 03.11.2018 declaring total income of Rs. 2,110/-. 3. During the reassessment proceedings, the Assessing Officer noticed that the assessee, along with two other co-owners, had sold a residential flat during the relevant previous year for a total consideration of Rs. 1,20,00,000/- and the assessee's share in the property was 33.33%. The Assessing Officer observed that the assessee had not disclosed the capital gains arising from the said transaction in the return of income filed in response to notice

3 ITA No. 2707/Mum/2026 Kamlesh Manharlal Shah (Legal Heir of Late Manharlal Vrjalal Shah) issued under section 148 of the Act. Notices under sections 142(1) and 143(2) were issued and served upon the assessee. In response thereto, the assessee furnished the computation of income and copies of the purchase and sale agreements pertaining to the property. 4. During the course of assessment proceedings, the assessee claimed exemption under section 54 of the Act in respect of long- term capital gains arising from the aforesaid transfer. The assessee submitted before the Assessing Officer that he had sold his share in the jointly held residential property on 18.06.2010 and had received approximately Rs. 40,00,000/- representing his 33.33% share. It was further submitted that the assessee had entered into an agreement with M/s Wadhwa Group and had invested Rs. 35,84,350/- on 05.02.2014 towards acquisition of a residential flat under construction. The assessee accordingly furnished a revised computation of income claiming deduction under section 54 amounting to Rs. 24,80,391/- against the long- term capital gains. 5. The Assessing Officer, however, did not accept the explanation of the assessee. According to the Assessing Officer, for availing exemption under section 54, the residential house was required to be purchased within the prescribed period of two years from the date of transfer or constructed within the period stipulated under the statute. The Assessing Officer observed that the property had been sold on 18.06.2010, whereas the agreement for acquisition of the new residential property was

4 ITA No. 2707/Mum/2026 Kamlesh Manharlal Shah (Legal Heir of Late Manharlal Vrjalal Shah) entered into only on 05.02.2014, which was beyond the prescribed period. He therefore held that the assessee had not complied with the statutory conditions for claiming exemption under section 54. The Assessing Officer further observed that no claim under section 54 had been made in the return of income filed in response to notice under section 148 and that Schedule CG of the return reflected nil capital gains. Relying upon the judgment of the Hon'ble Supreme Court in the case of Goetze (India) Ltd. v. CIT (157 taxman 1), the Assessing Officer held that a fresh claim not made in the return of income could not be entertained during assessment proceedings merely on the basis of a revised computation. Accordingly, the claim of exemption under section 54 amounting to Rs. 24,80,391/- was disallowed and brought to tax under the head "Long-Term Capital Gains". The assessment was consequently completed under section 143(3) read with section 147 of the Act at a total income of Rs. 24,82,500/-. 6. Aggrieved by the aforesaid action of the Assessing Officer, the assessee carried the matter in appeal before the learned CIT(A). During the appellate proceedings, the assessee reiterated the submissions advanced before the Assessing Officer and relied upon various judicial precedents in support of the claim under section 54. It was submitted that the assessee had invested the entire long-term capital gains in a residential flat under construction at Ghatkopar, Mumbai and that the delay in completion and registration of the flat was attributable to the

5 ITA No. 2707/Mum/2026 Kamlesh Manharlal Shah (Legal Heir of Late Manharlal Vrjalal Shah) builder and was beyond the control of the assessee. It was further contended that investment in an under-construction property amounted to construction of a residential house for the purposes of section 54. The assessee also submitted that the omission to claim exemption under section 54 in the return of income was merely an inadvertent and bona fide procedural lapse. According to the assessee, all relevant particulars relating to capital gains and the claim for exemption had been furnished before the Assessing Officer through the computation of income and, therefore, the substantive claim ought not to be denied on technical grounds. It was also pleaded that the appellate authorities possess plenary powers to entertain a lawful claim even if such claim had not been made in the return of income. 7. The learned CIT(A), however, was not persuaded by the submissions of the assessee. The appellate authority observed that the original residential property had been sold on 18.06.2010 whereas the new residential flat was registered in favour of the assessee only on 05.02.2014. According to the learned CIT(A), the acquisition of the new residential house was completed beyond the period prescribed under section 54 both for purchase as well as construction. The learned CIT(A) further held that mere booking of a flat with a builder and making payments would not automatically amount to construction for the purposes of section 54 unless the statutory conditions stood satisfied. The appellate authority also observed that the delay attributable to the builder could not override the clear mandate of the statute

6 ITA No. 2707/Mum/2026 Kamlesh Manharlal Shah (Legal Heir of Late Manharlal Vrjalal Shah) and that exemption under section 54 being a conditional exemption, the same could not be granted on equitable considerations. The learned CIT(A) further noted that the assessee had not disclosed the capital gains transaction in the return of income filed in response to notice under section 148 and had raised the claim for exemption only through a revised computation during assessment proceedings. Relying upon the decision of the Hon'ble Supreme Court in Goetze (India) Ltd. (supra), the learned CIT(A) upheld the action of the Assessing Officer in rejecting the claim. The appellate authority ultimately concluded that the assessee had failed to substantiate eligibility for exemption under section 54 with cogent evidence and accordingly confirmed the assessment order.

7 ITA No. 2707/Mum/2026 Kamlesh Manharlal Shah (Legal Heir of Late Manharlal Vrjalal Shah) Assessing Officer had all the details of capital gains including claim of exemption, and not filling the columns of capital gains in form of Return of Income was mere accidental in as much as erroneous on part of the professional filing Return of Income. 3. On the facts and circumstances of the case and in law, learned Commissioner of Income-tax (Appeal) failed to appreciate that appellate authorities have plenary powers to admit a legal claim, even if not made in the return; and learned Commissioner of Income- tax (Appeal) failed to appreciate that the Appellant was senior citizen, and that non-disclosure of capital gains in the return was a bonafide, inadvertent procedural lapse, with all material facts already on record during assessment. 4. Your Appellant craves leave to add to, amend, alter, modify, and / or delete any of the above grounds of appeal at or before final disposal of appeal. 9. During the course of hearing before us, the learned Authorised Representative (AR) appearing on behalf of the assessee reiterated the facts and submitted that the assessee had not furnished the return of income for Assessment Year 2011-12 as his income was below the taxable limit. It was submitted that upon receipt of notice issued under section 148 of the Act, the assessee electronically filed his return of income on 03.11.2018.

8 ITA No. 2707/Mum/2026 Kamlesh Manharlal Shah (Legal Heir of Late Manharlal Vrjalal Shah) made immediately upon transfer of the original residential property and therefore demonstrated the assessee's intention to reinvest the capital gains in acquisition of a new residential house. 11. The learned AR further submitted that the Assessing Officer proceeded on an erroneous premise that since the assessee had not personally undertaken construction of the house but had invested in a residential project under construction, the case would fall within the category of "purchase" and not "construction". It was argued that investment in an under- construction flat through a builder is in substance equivalent to construction of a residential house at the instance of the assessee. The learned AR submitted that even under indirect tax laws, namely VAT, Service Tax and GST, a builder is regarded as executing works on behalf of the purchaser and therefore acquisition of a flat under construction has consistently been treated by courts as akin to construction of a residential house for the purposes of section 54 of the Act. 12. Addressing the second objection raised by the Assessing Officer, the learned AR submitted that although the registration of the flat took place on 05.02.2014, the assessee had performed his part of the obligation by investing the entire capital gains in the residential project within the year of transfer itself. According to him, any delay in completion of construction or execution of the conveyance deed occurred solely on account of the builder and was beyond the control of the assessee. It was contended

9 ITA No. 2707/Mum/2026 Kamlesh Manharlal Shah (Legal Heir of Late Manharlal Vrjalal Shah) that once the assessee had invested the capital gains within the prescribed period, exemption under section 54 could not be denied merely because the builder failed to complete the project within the stipulated period. 13. The learned AR further drew our attention to page 13 of the paper book and submitted that the booking advance paid to M/s Wadhwa Builders amounting to Rs. 35,84,350/- had been duly disclosed in the balance sheet and formed part of the records furnished before the Assessing Officer. It was therefore contended that the investment in the new residential property stood fully evidenced from contemporaneous records and that the authorities below erred in denying exemption under section 54 despite the availability of complete documentary evidence demonstrating utilization of the capital gains for acquisition of a new residential house. 14. In support of the aforesaid contentions, the learned Authorised Representative placed reliance upon various decisions of the co-ordinate Benches of the Tribunal and submitted that the controversy involved in the present appeal is no longer res integra. It was contended that the consistent judicial view is that where an assessee invests the capital gains in acquisition of a residential flat under construction through a builder, such investment is to be regarded as construction of a residential house and not as purchase of a completed residential property. It was further submitted that once the assessee has invested the capital gains within the prescribed period, exemption under

10 ITA No. 2707/Mum/2026 Kamlesh Manharlal Shah (Legal Heir of Late Manharlal Vrjalal Shah) section 54 cannot be denied merely because the builder fails to complete construction or hand over possession within the stipulated period. 15. Reliance was first placed on the decision of the Co-ordinate Bench in the case of Manoj Khaturia v. ITO in ITA Nos. 2040/Mum/2012 and 4218/Mum/2014 dated 05.02.2018. The learned Authorised Representative drew our attention to the findings of the Tribunal wherein the assessee had invested the entire sale consideration in a residential flat booked with a developer, but the builder failed to complete the construction and hand over possession within the prescribed period. The Tribunal held that the assessee had complied with his obligations by making the investment within the stipulated period and that the failure of the builder to complete construction was a factor beyond the control of the assessee. The Tribunal further observed that section 54F is a beneficial provision intended to promote acquisition of residential houses and that completion of construction or obtaining possession within the specified period is not a mandatory requirement where the assessee has already invested the capital gains in the new residential property. Accordingly, exemption under section 54F was directed to be allowed. 16. The learned AR next relied upon the decision of the Co- ordinate Bench in the case of Kishore H. Galaiya v. ITO in ITA No. 7326/Mum/2010 dated 13.06.2012. Referring to the said decision, it was submitted that the Tribunal, after considering

11 ITA No. 2707/Mum/2026 Kamlesh Manharlal Shah (Legal Heir of Late Manharlal Vrjalal Shah) CBDT Circular No. 471 dated 15.10.1986 and Circular No. 672 dated 16.12.1993, held that booking of a flat with a builder is to be treated as construction of a residential house and not as purchase thereof. The Tribunal further held that where the assessee has invested the capital gains in construction of a residential house within the prescribed period, exemption under section 54 cannot be denied merely because possession of the flat was not handed over within three years due to delay on the part of the builder. The Tribunal observed that the material test is investment in the new residential house and acquisition of domain over the property and not the actual delivery of possession within the prescribed period. 17. Reliance was also placed upon the recent decision of the Co- ordinate Bench in the case of Seema Heera v. ACIT in ITA No. 517/Mum/2024 dated 10.07.2024. The learned Authorised Representative submitted that in that case the Assessing Officer himself accepted in the remand report that all the statutory conditions prescribed under section 54 stood satisfied but the claim was denied solely because the assessee had not filed the return of income. The Tribunal, while examining the scope of the decision of the Hon'ble Supreme Court in Goetze (India) Ltd. v. CIT, observed that the restriction laid down therein applies only to the powers of the Assessing Officer and does not curtail the powers of appellate authorities to entertain a lawful claim. It was therefore contended that even assuming there was an omission in the return of income, the appellate authorities were fully

12 ITA No. 2707/Mum/2026 Kamlesh Manharlal Shah (Legal Heir of Late Manharlal Vrjalal Shah) empowered to examine and grant the exemption if the assessee was otherwise entitled to the same on merits. 18. The learned AR further relied upon the decision of the Co- ordinate Bench in the case of Pranav Bhawnath Jha v. ITO in ITA No. 3464/Mum/2023 dated 15.04.2024. Referring to the said decision, it was submitted that the Tribunal held that investment in an under-construction residential project is to be regarded as construction of a residential house and not as purchase of a completed house. The Tribunal, relying upon CBDT Circular Nos. 471 and 672 as well as earlier judicial precedents, held that commencement of construction prior to the date of transfer or allotment of the property before the transfer of the original asset would not disentitle the assessee from claiming exemption under section 54. The relevant consideration is whether the construction is completed and the investment is made within the period contemplated by the statute. The learned Authorised Representative accordingly submitted that the ratio laid down in the aforesaid decision squarely supports the case of the assessee. 19. On the strength of the aforesaid judicial precedents, the learned AR submitted that the authorities below erred in treating the booking of a flat under construction as purchase of a completed residential house and in denying exemption merely because registration was completed subsequently. It was accordingly prayed that the exemption claimed under section 54

13 ITA No. 2707/Mum/2026 Kamlesh Manharlal Shah (Legal Heir of Late Manharlal Vrjalal Shah) be allowed and the addition of Rs. 24,80,391/- sustained by the learned CIT(A) be deleted. 20. Per contra, the learned Departmental Representative (DR) strongly relied upon the orders of the Assessing Officer and the learned CIT(A). The learned DR submitted that the assessee had admittedly not filed the original return of income for Assessment Year 2011-12. It was further pointed out that even in the return of income subsequently filed on 03.11.2018 in response to notice issued under section 148 of the Act, the assessee had neither disclosed the capital gains arising from sale of the residential property nor claimed exemption under section 54 of the Act. 21. We have heard the rival submissions and perused the material available on record. We have also carefully examined the assessment order, the appellate order, the documentary evidences placed in the paper book and the judicial precedents relied upon by the learned AR. The controversy involved in the present appeal lies in a narrow compass. The assessee claims exemption under section 54 of the Act in respect of long-term capital gains arising from transfer of his share in a residential property, whereas the Revenue has denied the claim on two grounds, namely: (i) that the new residential property was registered only on 05.02.2014, beyond the period prescribed under section 54, and (ii) that the claim under section 54 was not made in the return of income filed in response to notice under section 148 and was raised only during assessment proceedings through a computation of income.

14 ITA No. 2707/Mum/2026 Kamlesh Manharlal Shah (Legal Heir of Late Manharlal Vrjalal Shah) 22. Before adverting to the legal position, it would be appropriate to examine the factual matrix emerging from the record. The assessee sold his share in the residential property on 18.06.2010. Simultaneously, the assessee invested the sale proceeds in a residential project developed by Wadhwa Residency Private Limited by booking Flat No. 503, 5th Floor, Boulevard-3, Ghatkopar (West), Mumbai. The booking memo dated 13.06.2010 was produced before the authorities below and forms part of the paper book. More importantly, the assessee has placed on record a receipt issued by Wadhwa Residency Private Limited acknowledging receipt of an aggregate amount of Rs. 97,44,300/- from the purchasers towards part consideration of the flat. 23. The said receipt assumes considerable significance. The details contained therein reveal that substantial payments were made immediately after the transfer of the original asset. The receipt records payment of Rs. 26,00,000/- on 16.06.2010, Rs. 40,00,000/- on 17.07.2010, Rs. 3,00,000/- on 17.07.2010, Rs. 6,73,625/- on 18.09.2010 and further amounts thereafter, aggregating to Rs. 97,44,300/-. Thus, the contemporaneous documentary evidence establishes beyond doubt that the assessee had appropriated and invested the capital gains in the new residential project within the period contemplated by section 54. The Revenue has neither disputed the genuineness of the booking nor the payments made to the developer. The sole basis adopted by the authorities below is that the registration of the flat ultimately took place on 05.02.2014.

15 ITA No. 2707/Mum/2026 Kamlesh Manharlal Shah (Legal Heir of Late Manharlal Vrjalal Shah) 24. In our considered opinion, the approach adopted by the Assessing Officer and affirmed by the learned CIT(A) is legally unsustainable. The authorities below have proceeded on the premise that acquisition of a flat in an under-construction project is equivalent to purchase of a completed residential house and therefore the assessee was required to satisfy the conditions applicable to a case of purchase. Such an approach ignores the settled judicial position consistently followed by the Courts and Tribunals for decades. 25. The CBDT itself, in Circular No. 471 dated 15.10.1986 and Circular No. 672 dated 16.12.1993, has clarified that allotment of a flat by a development authority, cooperative society or similar institution is to be regarded as construction of a residential house. The rationale behind the circulars is that where an assessee acquires rights in a property under construction and makes payments in stages linked to progress of construction, the assessee is in substance getting a residential house constructed through an agency. The builder merely acts as an instrumentality for construction. Consequently, such cases are to be treated as cases of construction and not purchase. 26. We find that this principle has been consistently followed by various judicial forums. In the case of Kishore H. Galaiya v. ITO, the Co-ordinate Bench held that booking of a flat with a builder has to be treated as construction of a residential house and once the assessee has invested the capital gains within the stipulated period, exemption cannot be denied merely because

16 ITA No. 2707/Mum/2026 Kamlesh Manharlal Shah (Legal Heir of Late Manharlal Vrjalal Shah) possession was not handed over within three years due to delay on the part of the builder. Similarly, in Manoj Khaturia v. ITO, the Bench held that where the assessee had invested the entire consideration in a residential project and the builder failed to complete construction, the assessee could not be penalised for circumstances beyond his control. The Bench observed that section 54F being a beneficial provision must receive a liberal interpretation to advance the legislative intent of encouraging investment in residential housing. The same principle has recently been reiterated by the Co-ordinate Bench in Pranav Bhawnath Jha v. ITO, wherein it was held that investment in an under-construction project constitutes construction of a residential house and the date of commencement of construction is immaterial so long as the investment satisfies the statutory requirements. 27. Applying the aforesaid principles to the facts of the present case, we find that the assessee had booked the new residential flat immediately upon transfer of the original asset and had invested substantial amounts towards acquisition of the flat within the prescribed period. The documentary evidence placed before us clearly demonstrates that the assessee had performed all obligations required to be performed on his part. The subsequent delay in completion of the project and execution of the conveyance deed was entirely attributable to the developer. The assessee neither controlled nor could influence the pace of construction undertaken by the builder. Once the assessee had

17 ITA No. 2707/Mum/2026 Kamlesh Manharlal Shah (Legal Heir of Late Manharlal Vrjalal Shah) irrevocably committed the capital gains towards acquisition of the residential house and had substantially invested the consideration within the statutory period, the benefit conferred by section 54 cannot be denied merely because the builder completed the project or executed the conveyance deed at a later point of time. 28. We may also observe that acceptance of the Revenue's contention would lead to wholly unjust and anomalous consequences. An assessee who has invested the entire capital gains in a residential project would lose the benefit of exemption solely because of delays attributable to the builder, even though such delays are completely beyond his control. Such an interpretation would defeat the very object of section 54, which is to encourage reinvestment of capital gains in residential housing. Beneficial provisions intended to promote housing investment cannot be interpreted in a manner that frustrates their legislative purpose. 29. The second objection of the Revenue pertains to the fact that the assessee did not claim exemption under section 54 in the return of income filed in response to notice under section 148. It is undisputed that the assessee had not originally filed a return of income as his income was below the taxable limit. It is equally undisputed that after reopening, the assessee filed a return on 03.11.2018. It is true that the capital gains schedule in the return was not filled in and exemption under section 54 was not specifically claimed therein. However, the record simultaneously

18 ITA No. 2707/Mum/2026 Kamlesh Manharlal Shah (Legal Heir of Late Manharlal Vrjalal Shah) reveals that during assessment proceedings the assessee furnished a detailed computation of income containing complete working of the long-term capital gains together with the claim under section 54. The assessee also furnished the booking memo, payment details, balance sheet and supporting documentary evidences evidencing investment in the new residential property. 30. Thus, this is not a case where the assessee sought to raise a fresh claim unsupported by material on record. On the contrary, all primary facts relating to the transfer of the original asset, computation of capital gains and investment in the new residential house were duly disclosed before the Assessing Officer. The omission was only that the relevant entries were not reflected in the return form. The assessee, who is stated to be approximately 87 years old, explained that the omission occurred on account of an inadvertent mistake while filing the return. Be that as it may, the fact remains that all material particulars were available before the Assessing Officer. 31. The reliance placed by the authorities below upon the decision of the Hon'ble Supreme Court in Goetze (India) Ltd. v. CIT is, in our view, misplaced. The Hon'ble Supreme Court itself clarified that the decision was confined to the powers of the Assessing Officer and did not impinge upon the powers of appellate authorities. The appellate authorities, including the Tribunal, possess wide powers to entertain a lawful claim and grant relief if the assessee is otherwise entitled to the same. This position has repeatedly been recognised by the Courts. Even the

19 ITA No. 2707/Mum/2026 Kamlesh Manharlal Shah (Legal Heir of Late Manharlal Vrjalal Shah) decision of the Co-ordinate Bench in Seema Heera v. ACIT has reiterated that a legitimate claim cannot be denied by appellate authorities merely because the same was not made in the return of income. 32. Once the factual entitlement of the assessee to exemption under section 54 stands established on the basis of the documentary evidence and settled legal principles, denial of the claim merely on account of a procedural omission in the return would amount to sacrificing substantive justice at the altar of technicality. Tax administration is concerned with determining the correct tax liability in accordance with law and not with denying legitimate reliefs on hyper-technical grounds. 33. Having regard to the totality of facts and circumstances of the case, the documentary evidence evidencing investment in the residential project, the booking memo dated 13.06.2010, the receipt issued by Wadhwa Residency Private Limited acknowledging payments aggregating to Rs. 97,44,300/-, the balance sheet reflecting the investment, and the judicial precedents discussed hereinabove, we are of the considered opinion that the assessee had duly complied with the substantive requirements of section 54 of the Act. The delay in registration or completion of construction being attributable to the builder cannot be put against the assessee. We further hold that the claim cannot be rejected merely because the exemption was not specifically claimed in the return of income when complete particulars were furnished before the Assessing Officer during the

20 ITA No. 2707/Mum/2026 Kamlesh Manharlal Shah (Legal Heir of Late Manharlal Vrjalal Shah) assessment proceedings and the claim is otherwise legally admissible.

Order pronounced on 29/06/2026 as per Rule 34(4) of the Income Tax (Appellate Tribunal) Rules, 1963.

Sd/- Sd/- (KAVITHA RAJAGOPAL) (MAKARAND VASANT MAHADEOKAR) JUDICIAL MEMBER ACCOUNTANT MEMBER Mumbai, Dated 29/06/2026 Dhananjay, Sr.PS आदेश की प्रतितिति अग्रेतिि/Copy of the Order forwarded to : 1. अपीलाथी / The Appellant 2. प्रत्यथी / The Respondent. 3. संबंधधत आयकर आयुक्त / The CIT(A) आयकर आयुक्त(अपील) / Concerned CIT 4. धिभागीय प्रधतधनधध, आयकर अपीलीय अधधकरण, 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