LATE ANILKUMAR AGGARWAL ( LEGAL HEIR OF SARANGA ANIL KUMAR AGGARWAL),MUMBAI vs. ITO WARD 17(1)(1), MUMBAI

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ITA 9044/MUM/2025Status: DisposedITAT Mumbai28 April 2026AY 2015-168 pages

In favour of the assessee: the assessee's appeal was allowed. From the AI summary of this appeal.

AI SummaryAllowed

What did the Tribunal hold?

The Tribunal held that the notices issued under Section 148 were issued beyond the period of limitation, considering the extensions and the 'stop-the-clock' mechanism. Consequently, the reassessment proceedings and orders were quashed.

What were the facts?

The assessee's appeals concerned reassessment proceedings initiated against a deceased person for assessment years 2015-16, 2016-17, and 2017-18. The primary challenge was to the validity of the notices issued under Section 148 of the Income Tax Act.

What were the issues?

Whether the notices issued under Section 148 were within the prescribed limitation period, considering the provisions of the Taxation and Other Laws (Relaxation and Amendment of Certain Provisions) Act, 2020 and the 'stop-the-clock' mechanism.

Which sections of the Income-tax Act were involved?

Section 148,Section 148A,Section 147,Section 144,Section 151A,Section 251(1)(a)

AI-generated summary — verify with the full judgment below

Income Tax Appellate Tribunal, MUMBAI BENCH “A” MUMBAI

Before: SHRI OM PRAKASH KANT & SHRI ANIKESH BENERJEE

For Appellant: Shri Surendra Mohan, (SR. DR)
Pronounced: 28.04.2026

IN THE INCOME TAX APPELLATE TRIBUNAL MUMBAI BENCH “A” MUMBAI

BEFORE SHRI OM PRAKASH KANT (ACCOUNTANT MEMBER) AND SHRI ANIKESH BENERJEE (JUDICIAL MEMBER)

ITA Nos.9043, 9044 & 9245/MUM/2025 Assessment Years: 2015-16, 2016-17 & 2017-18

Late Anil Kumar Aggarwal, Income Tax Officer, [Represented By Legal Heir – Saranga Ward 17(1)(1), Aayakar Bhawan, Vs. Anilkumar Aggarwal], 7th Floor, RNA M.K. Road, Mumbai – 400020, Corporate Park, Kalanagar, Bandra East, Maharashtra. Mumbai – 400051, Maharashtra. PAN NO. AABPA 3657 N APPELLANT RESPONDENT

: Shri Aditya Ramchandran Assessee by : Shri Surendra Mohan, (SR. DR) Department by : 23.04.2026 Date of Hearing Date of pronouncement : 28.04.2026 ORDER PER BENCH

These three appeals filed by the assessee are directed against three separate orders passed by the Learned Commissioner of Income-Tax (Appeals) - National Faceless Appeal Centre, Delhi, for Assessment Years 2015–16, 2016–17, and 2017–18 respectively. As common issue in dispute is involved in these appeals and therefore same were heard together and disposed off by way of this consolidated order for the sake of convenience.

Late Anil Kumar Aggarwal, Late Anil Kumar Aggarwal, 2 ITA Nos.9043, 9044 & 9045/MUM/2026

2.

Now we take up the appeal of the assessee for the A.Y. 2015-16: 2. Now we take up the appeal of the assessee for the A.Y. 2015 2. Now we take up the appeal of the assessee for the A.Y. 2015

2.1. The Grounds ra The Grounds raised by the assessee are reproduced as under: ised by the assessee are reproduced as under:-

1.

On the facts and circumstances of the case and in law, the order On the facts and circumstances of the case and in law, the order On the facts and circumstances of the case and in law, the order issued uls 148A(d), notice issued u/s 148 and assessment order issued issued uls 148A(d), notice issued u/s 148 and assessment order issued issued uls 148A(d), notice issued u/s 148 and assessment order issued u/s 147 r.w.s 144 of the Act are required to be declared as invalid and u/s 147 r.w.s 144 of the Act are required to be declared as invalid and u/s 147 r.w.s 144 of the Act are required to be declared as invalid and bad in law in as much as they have been issued in the name of deceased bad in law in as much as they have been issued in the name of deceased bad in law in as much as they have been issued in the name of deceased person. 2) On the facts and circumstances of the case and in law, the notice 2) On the facts and circumstances of the case and in law, the notice 2) On the facts and circumstances of the case and in law, the notice issued under section 148 of the Act dated 15/04/2021 was not covered issued under section 148 of the Act dated 15/04/2021 was not covered issued under section 148 of the Act dated 15/04/2021 was not covered by the provisions of Taxation and Othe by the provisions of Taxation and Other Laws (Relaxation and r Laws (Relaxation and Amendment of Certain Provisions) Act, 2020 as held by the Hon'ble Amendment of Certain Provisions) Act, 2020 as held by the Hon'ble Amendment of Certain Provisions) Act, 2020 as held by the Hon'ble Supreme Court in the case of UOI vs. Rajeev Bansal [2024] 167 Supreme Court in the case of UOI vs. Rajeev Bansal [2024] 167 Supreme Court in the case of UOI vs. Rajeev Bansal [2024] 167 taxmann.com 70 (SC) and, consequently, the said notice as well as the taxmann.com 70 (SC) and, consequently, the said notice as well as the taxmann.com 70 (SC) and, consequently, the said notice as well as the order passed under section 147 r.w. order passed under section 147 r.w.s. 144 of the Act is required to be s. 144 of the Act is required to be declared as bad in law and without jurisdiction. declared as bad in law and without jurisdiction. 3. On the facts and circumstances of the case and in law, notice issued On the facts and circumstances of the case and in law, notice issued On the facts and circumstances of the case and in law, notice issued u/s 148 dated 28/07/2022 is required to be declared as null and void u/s 148 dated 28/07/2022 is required to be declared as null and void u/s 148 dated 28/07/2022 is required to be declared as null and void as it suffers from the jurisdi as it suffers from the jurisdictional defect of not complying with the ctional defect of not complying with the requirements of Circular No. 19 of 2019 dated 14th August, 2019 issued requirements of Circular No. 19 of 2019 dated 14th August, 2019 issued requirements of Circular No. 19 of 2019 dated 14th August, 2019 issued by the CBDT. 4. On the facts and circumstances of the case and in law, the order 4. On the facts and circumstances of the case and in law, the order 4. On the facts and circumstances of the case and in law, the order issued u/s 148A(d) and also the notice issued u/s 148 of the Act as well d) and also the notice issued u/s 148 of the Act as well d) and also the notice issued u/s 148 of the Act as well as the entire assessment proceeding is required to be declared as null as the entire assessment proceeding is required to be declared as null as the entire assessment proceeding is required to be declared as null and void as it suffers from the jurisdictional defect of not complying with and void as it suffers from the jurisdictional defect of not complying with and void as it suffers from the jurisdictional defect of not complying with the provisions of Section 151A and the notification the provisions of Section 151A and the notification issued thereunder issued thereunder notifying e-Assessment of Income Escaping Assessment Scheme, 2022 Assessment of Income Escaping Assessment Scheme, 2022 Assessment of Income Escaping Assessment Scheme, 2022 5) On the facts and circumstances of the case and in law, the Ld. CIT(A) 5) On the facts and circumstances of the case and in law, the Ld. CIT(A) 5) On the facts and circumstances of the case and in law, the Ld. CIT(A) has erred in setting aside the assessment and referring the case back to has erred in setting aside the assessment and referring the case back to has erred in setting aside the assessment and referring the case back to the Assessing Officer for the Assessing Officer for making a fresh assessment by invoking the making a fresh assessment by invoking the proviso to Section 251(1)(a) of the Act without appreciating that the proviso to Section 251(1)(a) of the Act without appreciating that the proviso to Section 251(1)(a) of the Act without appreciating that the assessment proceeding was suffering from several jurisdictional defects assessment proceeding was suffering from several jurisdictional defects assessment proceeding was suffering from several jurisdictional defects which were fatal due to which the assessment was required to be which were fatal due to which the assessment was required to be which were fatal due to which the assessment was required to be quashed in its entirety in its entirety.” 3. The Assessee has raised several grounds challenging the The Assessee has raised several grounds challenging the The Assessee has raised several grounds challenging the validity of the reassessment proceedings. The primary thrust of the validity of the reassessment proceedings. The primary thrust of the validity of the reassessment proceedings. The primary thrust of the challenge is directed against the jurisdictional validity of the notice challenge is directed against the jurisdictional validity of the notice challenge is directed against the jurisdictional validity of the notice

Late Anil Kumar Aggarwal, Late Anil Kumar Aggarwal, 3 ITA Nos.9043, 9044 & 9045/MUM/2026

issued under Section 148 Section 148 of the Income Tax Act, 1961 [hereinafter of the Income Tax Act, 1961 [hereinafter "the Act"], contending that the same is barred by limitation and fails "the Act"], contending that the same is barred by limitation and fails "the Act"], contending that the same is barred by limitation and fails to satisfy the legal requirements established by the Hon’ble to satisfy the legal requirements established by the Hon’ble to satisfy the legal requirements established by the Hon’ble Supreme Court.

4.

At the outset, the Ld. Counsel for the Assessee submitted that At the outset, the Ld. Counsel for the Assessee submitted that At the outset, the Ld. Counsel for the Assessee submitted that the reassessment in this case is he reassessment in this case is void ab initio. It was contended that . It was contended that for AY 2015-16, under the substituted provisions of section 148 , under the substituted provisions of section 148 , under the substituted provisions of section 148 introduced by the Finance Act, 2021, the maximum limitation introduced by the Finance Act, 2021, the maximum limitation introduced by the Finance Act, 2021, the maximum limitation period for the issuance of a notice under Section 148 expired on period for the issuance of a notice under Section 148 expired period for the issuance of a notice under Section 148 expired 31.03.2022. The Ld. Counsel further elaborated that while the . The Ld. Counsel further elaborated that while the . The Ld. Counsel further elaborated that while the Revenue initially issued a notice under the erstwhile (pre- Revenue initially issued a notice under the erstwhile (pre Revenue initially issued a notice under the erstwhile (pre amendment) Section 148, the subsequent proceedings, undertaken amendment) Section 148, the subsequent proceedings, undertaken amendment) Section 148, the subsequent proceedings, undertaken in the purported implementation of the Hon’ble Supreme Court’s in the purported implementation of the Hon’ble Supreme Court’s in the purported implementation of the Hon’ble Supreme Court’s judgment in Union of India vs. Ashish Agarwal [2022] 444 ITR 1 Union of India vs. Ashish Agarwal [2022] 444 ITR 1 Union of India vs. Ashish Agarwal [2022] 444 ITR 1 (SC),resulted in a fresh notice under Section 148 dated ,resulted in a fresh notice under Section 148 dated ,resulted in a fresh notice under Section 148 dated 28.07.2022. It is the Assessee’s case that since this notice was issued beyond It is the Assessee’s case that since this notice was issued beyond It is the Assessee’s case that since this notice was issued beyond the sunset date of 31.03.2022, it is hit by the bar of limitation as the sunset date of 31.03.2022, it is hit by the bar of limitatio the sunset date of 31.03.2022, it is hit by the bar of limitatio clarified by the Hon’ble Supreme Court in the recent decision of clarified by the Hon’ble Supreme Court in the recent decision of clarified by the Hon’ble Supreme Court in the recent decision of Union of India vs. Rajeev Bansal [2024] 167 taxmann.com 70 Union of India vs. Rajeev Bansal [2024] 167 taxmann.com 70 Union of India vs. Rajeev Bansal [2024] 167 taxmann.com 70 (SC). Therefore, the reassessment proceedings in the case are non Therefore, the reassessment proceedings in the case are non Therefore, the reassessment proceedings in the case are non- sustainable.

5.

We have heard the rival submissions and perus We have heard the rival submissions and perus We have heard the rival submissions and perused the relevant material on record. The undisputed facts emerging from the material on record. The undisputed facts emerging from the material on record. The undisputed facts emerging from the

Late Anil Kumar Aggarwal, Late Anil Kumar Aggarwal, 4 ITA Nos.9043, 9044 & 9045/MUM/2026

Assessment Order reveal that the Assessing Officer (AO) sought to Assessment Order reveal that the Assessing Officer (AO) sought to Assessment Order reveal that the Assessing Officer (AO) sought to regularize the proceedings following the regularize the proceedings following the Ashish Agarwal (supra) Ashish Agarwal (supra) ruling. The AO issued a show ruling. The AO issued a show-cause notice under Section 148A(b) cause notice under Section 148A(b) and subsequently passed an order under Section 148A(d), and subsequently passed an order under Section 148A(d), and subsequently passed an order under Section 148A(d), culminating in the issuance of the culminating in the issuance of the notice under Section 148 on notice under Section 148 on 28.07.2022, which is evident from the following Para of the , which is evident from the following Para of the , which is evident from the following Para of the AO:-

“Subsequently, in compliance to the decision of Hon'ble Supreme Court of India in Subsequently, in compliance to the decision of Hon'ble Supreme Court of India in Subsequently, in compliance to the decision of Hon'ble Supreme Court of India in the case of Union of India Vs. Ashish Agarwal and consequent CBDT instruction the case of Union of India Vs. Ashish Agarwal and consequent CBDT instruction the case of Union of India Vs. Ashish Agarwal and consequent CBDT instruction no 01/2022 in F No. 279/Misc/M no 01/2022 in F No. 279/Misc/M-51/2022-1TZ dated 11.05.2022, information 1TZ dated 11.05.2022, information and material relied u and material relied upon was provided to the assessee wherein the assessee pon was provided to the assessee wherein the assessee was given a Show-cause notice and considering the reply of the assessee and cause notice and considering the reply of the assessee and cause notice and considering the reply of the assessee and facts of the case the assessee was issued fresh notice on 25.05.2022 requesting facts of the case the assessee was issued fresh notice on 25.05.2022 requesting facts of the case the assessee was issued fresh notice on 25.05.2022 requesting to furnish the explanation along with supporti to furnish the explanation along with supporting documents/evidences, as to why ng documents/evidences, as to why a nolice is 145 of the Act should not be issued in his case for the above mentioned a nolice is 145 of the Act should not be issued in his case for the above mentioned a nolice is 145 of the Act should not be issued in his case for the above mentioned assessment year allowing the assessee two weeks to submit its reply. assessment year allowing the assessee two weeks to submit its reply assessment year allowing the assessee two weeks to submit its reply 2.2 The assessee has failed to file any reply to the notice. Hence it is presumed 2.2 The assessee has failed to file any reply to the notice. Hence it 2.2 The assessee has failed to file any reply to the notice. Hence it that the assessee has nothing to say in this regard that the assessee has nothing to say in this regard 3. Notice u/s 148 of t 3. Notice u/s 148 of the Act dtd.28.7.2022 has been issued after obtaining 28.7.2022 has been issued after obtaining necessary approval from competent authori y approval from competent authority.” 5.1 The pivot of the controversy lies in whether the The pivot of the controversy lies in whether the The pivot of the controversy lies in whether the Taxation and Other Laws (Relaxation and Amendment of Certain Provisions) Act, r Laws (Relaxation and Amendment of Certain Provisions) Act, r Laws (Relaxation and Amendment of Certain Provisions) Act, 2020 [TOLA] could extend the limitation for AY 2015 could extend the limitation for AY 2015 could extend the limitation for AY 2015-16. The Hon'ble Supreme Court in Union of India vs. Rajeev Bansal Union of India vs. Rajeev Bansal Hon'ble Supreme Court in (supra) has authoritatively settled the interplay between TOLA and has authoritatively settled the interplay between TOLA and has authoritatively settled the interplay between TOLA and the new reassessment regime. the new reassessment regime. Since, the limitation for issuance of Since, the limitation for issuance of the notice u/s 148 under old provis the notice u/s 148 under old provisions was not expiring ons was not expiring on 31/3/2021, therefore the provisions of therefore the provisions of TOLA were not applicable on were not applicable on

Late Anil Kumar Aggarwal, Late Anil Kumar Aggarwal, 5 ITA Nos.9043, 9044 & 9045/MUM/2026

the said assessment year e said assessment year 2015-16 under the amended provisions of under the amended provisions of section 148. Therefore, t Therefore, the limitation for issuing notice in respect limitation for issuing notice in respect of the A.Y.2015-16 expired on 31.03.2022, whereas notice u/s 148 16 expired on 31.03.2022, whereas notice u/s 148 16 expired on 31.03.2022, whereas notice u/s 148 has been issued on 28.07.2022, which is beyond the limitation. has been issued on 28.07.2022, which is beyond the limitat has been issued on 28.07.2022, which is beyond the limitat

5.2 In light of the judicial precedent set by the Hon’ble Supreme In light of the judicial precedent set by the Hon’ble Supreme In light of the judicial precedent set by the Hon’ble Supreme Court, we find that the notice issued under Section 148 dated Court, we find that the notice issued under Section 148 dated Court, we find that the notice issued under Section 148 dated 28.07.2022 is hit by the bar of limitation. A jurisdictional defect of is hit by the bar of limitation. A jurisdictional defect of is hit by the bar of limitation. A jurisdictional defect of this nature is fundamental and goes to the very root of the AO's this nature is fundamental and goes to the very roo this nature is fundamental and goes to the very roo power to assess. Consequently, the notice and the resulting power to assess. Consequently, the notice and the resulting power to assess. Consequently, the notice and the resulting assessment order passed under Section 147 read with Section 144 assessment order passed under Section 147 read with Section 144 assessment order passed under Section 147 read with Section 144 of the Act are hereby of the Act are hereby quashed as being without jurisdiction and as being without jurisdiction and void ab initio.

6.

As the reassessment proceedings themselves have been As the reassessment proceedings themselves have been As the reassessment proceedings themselves have been quashed on the threshold issue of limitation, the other grounds quashed on the threshold issue of limitation, the other grounds quashed on the threshold issue of limitation, the other grounds raised by the Assessee on the merits of the additions are rendered raised by the Assessee on the merits of the additions are rendered raised by the Assessee on the merits of the additions are rendered academic and are dismissed as academic and are dismissed as infructuous.

7.

Adverting to the appeals p Adverting to the appeals preferred for AY 2016 AY 2016-17 and AY 2017-18, the Assessee has raised a synchronous challenge to the , the Assessee has raised a synchronous challenge to the , the Assessee has raised a synchronous challenge to the jurisdiction of the Assessing Officer (AO), asserting that the notices jurisdiction of the Assessing Officer (AO), asserting that the notices jurisdiction of the Assessing Officer (AO), asserting that the notices issued under the substituted Section 148 of the Act were barred by issued under the substituted Section 148 of the Act were barred by issued under the substituted Section 148 of the Act were barred by limitation. The Assesse limitation. The Assessee’s contention rests squarely upon the e’s contention rests squarely upon the "survival period" theory as elucidated by the Hon’ble Supreme Court "survival period" theory as elucidated by the Hon’ble Supreme Court "survival period" theory as elucidated by the Hon’ble Supreme Court in Union of India vs. Rajeev Bansal (supra) Union of India vs. Rajeev Bansal (supra) and submitted that and submitted that

Late Anil Kumar Aggarwal, Late Anil Kumar Aggarwal, 6 ITA Nos.9043, 9044 & 9045/MUM/2026

notices have been issued under the amended provisions of section have been issued under the amended provisions of section have been issued under the amended provisions of section 148 are beyond the su beyond the survival period.

8.

Before us the Assessee submitted a comprehensive timeline the Assessee submitted a comprehensive timeline the Assessee submitted a comprehensive timeline demonstrating that the impugned notices, dated 30.07.2022 30.07.2022, were demonstrating that the impugned notices, dated issued after the expiry of the time issued after the expiry of the time-window permitted by the window permitted by the interplay of TOLA and the new reassessment regime. The relevant interplay of TOLA and the new reassessment regime. The interplay of TOLA and the new reassessment regime. The data as presented in the Assessee’s chart is extracted below: data as presented in the Assessee’s chart is extracted below: data as presented in the Assessee’s chart is extracted below:

“Chart elucidating the dates of notices and timelines to establish that Chart elucidating the dates of notices and timelines to establish that Chart elucidating the dates of notices and timelines to establish that the notice issued under section 148 dated 30 the notice issued under section 148 dated 30-07-2022 was issued beyond 2022 was issued beyond the surviving period the surviving period Sr. Particulars Date/Days Date/Days Date/Days No. (AY 2016-17) (AY 2016 (AY 2017-18) 1 Date of deemed show cause notice u/s. Date of deemed show cause notice u/s. 11-06-2021 2021 11-06-2021 148A(b) 2 Last Last date date for for issuing issuing notice notice u/s u/s 148 148 30-06-2021 2021 30-06-2021 considering extension under TOLA considering extension under TOLA. 3 No. of days which were which were otherwise available 20 20 with the AO to issue notice u/s 148 issue notice u/s 148. 4 Date on which two Date on which two weeks expired for filing 08-06-2022 2022 08-06-2022 reply (as no reply was filed by the assessee) (as no reply was filed by the assessee). 5 Surviving time period ends on Surviving time period ends on - after adding the 28-06-2022 2022 28-06-2022 no. of days which were no. of days which were otherwise available to the AO (3) to the above the AO (3) to the above date (4). 30-07-2022 6 Date on which the notice under Section 148 Date on which the notice under Section 148 30-07-2022 2022 was issued by the Assessing Officer was issued by the Assessing Officer. 9. We have meticulously examined the documentary evidence, We have meticulously examined the documentary evidence, We have meticulously examined the documentary evidence, including the notices issued under Section 148A(b), the orders including the notices issued under Section 148A(b), the orders including the notices issued under Section 148A(b), the orders passed under Section 148A(d), and the consequential notices under passed under Section 148A(d), and the consequential notices under passed under Section 148A(d), and the consequential notices under Section 148 for both Assessment Years, as contained in the Section 148 for both Assessment Years, as contained in the Section 148 for both Assessment Years, as contained in the aper Book. The Hon’ble Supreme Court in Rajeev Assessee’s Paper Book. The Hon’ble Supreme Court in aper Book. The Hon’ble Supreme Court in Bansal (supra) held that while TOLA 2020 extends the time limits held that while TOLA 2020 extends the time limits held that while TOLA 2020 extends the time limits

Late Anil Kumar Aggarwal, Late Anil Kumar Aggarwal, 7 ITA Nos.9043, 9044 & 9045/MUM/2026

for the Revenue, it does not provide a for the Revenue, it does not provide a carte blanche carte blanche extension. The Hon’ble High Court established a "stop Court established a "stop-the-clock" mechanism where clock" mechanism where the period during which proceedings were stayed or paused the period during which proceedings were stayed or paused the period during which proceedings were stayed or paused (pursuant to the Ashish Agarwal Ashish Agarwal ruling) must be added back to the ruling) must be added back to the surviving limitation period. surviving limitation period.

9.1 As per the computation above, As per the computation above, which we find to be factually which we find to be factually accurate: (i)The Revenue had a residual window of accurate: (i)The Revenue had a residual window of 20 days 20 days to issue the notice when the clock was paused. (ii) Upon the resumption of the notice when the clock was paused. (ii) Upon the resumption of the notice when the clock was paused. (ii) Upon the resumption of proceedings post-Ashish Agarwal (supra) Ashish Agarwal (supra), the Assessee’s time to , the Assessee’s time to (iii) Adding the residual 20 days to reply expired on 08.06.2022 08.06.2022. (iii) Adding the residual this date, the mandate for the AO was to issue the Section 148 this date, the mandate for the AO was to issue the Section 148 this date, the mandate for the AO was to issue the Section 148 notice on or before 28.06.2022 28.06.2022. Since the impugned notices for both . Since the impugned notices for both assessment years were issued only on assessment years were issued only on 30.07.2022, they are clearly , they are clearly hit by the bar of lim hit by the bar of limitation. The delay, even if by a few weeks, is itation. The delay, even if by a few weeks, is fatal to the jurisdiction of the AO. fatal to the jurisdiction of the AO.

10.

Consequently, the notices issued under Section 148 for Consequently, the notices issued under Section 148 for Consequently, the notices issued under Section 148 for AY 2016-17 and AY 2017 AY 2017-18 are hereby quashed. As a corollary, the . As a corollary, the subsequent subsequent subsequent reassessment reassessment reassessment proceedings proceedings proceedings and and and the the the resulting resulting resulting assessment orders are declared assessment orders are declared null and void null and void for want of jurisdiction. In view of the disposal of these appeals on the jurisdiction. In view of the disposal of these appeals on the jurisdiction. In view of the disposal of these appeals on the jurisdictional threshold, the grounds raised on the merits of the jurisdictional threshold, the grounds raised on the merits of jurisdictional threshold, the grounds raised on the merits of additions are rendered additions are rendered infructuous.

Late Anil Kumar Aggarwal, Late Anil Kumar Aggarwal, 8 ITA Nos.9043, 9044 & 9045/MUM/2026

11.

In the result, all In the result, all the three appeals of the assessee are allowed. three appeals of the assessee are allowed.

Order pronounced in the open Court on ounced in the open Court on 28/04/2026. /04/2026.

Sd/- Sd/ Sd/- (ANIKESH BENERJEE) (ANIKESH BENERJEE (OM PRAKASH KANT OM PRAKASH KANT) JUDICIAL MEMBER JUDICIAL MEMBER ACCOUNTANT MEMBER ACCOUNTANT MEMBER Mumbai; Dated: 28/04/2026 M. Ranganath Vittal , Sr. P.S. M. Ranganath Vittal , Sr. P.S. Copy of the Order forwarded to Copy of the Order forwarded to : 1. The Appellant 2. The Respondent. 3. CIT 4. DR, ITAT, Mumbai 5. Guard file.

BY ORDER, BY ORDER, //True Copy// (Assistant Registrar) (Assistant Registrar) ITAT, Mumbai ITAT, Mumbai

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