PBA INFRASTRUCTURE LIMITED ,MUMBAI vs. DCIT CENTRAL CIRCLE 5(1), MUMBAI

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ITA 4065/MUM/2025Status: DisposedITAT Mumbai23 June 2026AY 2005-0615 pages
AI SummaryPartly Allowed

What did the Tribunal hold?

The Tribunal dismissed the quantum appeals due to substantial and unexplained delays, noting the casual approach in filing condonation petitions. However, the penalty appeals were allowed as the notices issued under section 271(1)(c) were found to be omnibus and lacked specificity, thus vitiating the penalty proceedings.

What were the facts?

The assessee filed appeals before the ITAT with significant delays for assessment years 2005-06 and 2014-15. The delay was attributed to the company's impression that their consultant had filed the appeals on time. The revenue opposed the condonation of delay, citing lack of sufficient cause.

What were the issues?

Whether the delay in filing appeals can be condoned, and whether penalty proceedings under Section 271(1)(c) are valid when the notice issued is omnibus.

Which sections of the Income-tax Act were involved?

Section 250,Section 143(3),Section 153A,Section 271(1)(c),Section 274

AI-generated summary — verify with the full judgment below

Income Tax Appellate Tribunal, MUMBAI BENCH “C”, MUMBAI

Before: SHRI ANIKESH BANERJEE & SHRI MAKARAND VASANT MAHADEOKAR

For Appellant: Shri Nishit Gandhi
For Respondent: Shri R.A. Dhyani (CIT DR) & Shri V.S. Mahajan (Sr. DR)
Hearing: 14/05/2026Pronounced: 23/06/2026

Heard together (2 matters)

ITA No.4065/Mum/2025
ITA No.4210/Mum/2025

Read from the judgment's own cause title. This page is filed under one of them.

IN THE INCOME TAX APPELLATE TRIBUNAL MUMBAI BENCH “C”, MUMBAI BEFORE SHRI ANIKESH BANERJEE, JUDICIAL MEMBER AND SHRI MAKARAND VASANT MAHADEOKAR, ACCOUNTANT MEMBER ITA No.3828/Mum/2025 (Assessment year: 2014-15) ITA No.4065/Mum/2025 (Assessment year: 2005-06) ITA No.4268/Mum/2025 (Assessment year: 2005-06) ITA No.4210/Mum/2025 (Assessment year: 2014-15)

PBA Infrastructure Ltd. vs DCIT, C.C-5(1), Mumbai 611/3, Prakash, V.N. Purav Aayakar Bhavan, Churchgate, Marg, Chembur, Mumbai- Mumbai -400020 400071 PAN:AAACP7564K APPELLANT RESPONDENT Assessee by : Shri Nishit Gandhi Revenue by : Shri R.A. Dhyani (CIT DR) & Shri V.S. Mahajan (Sr. DR) Date of hearing : 14/05/2026 Date of pronouncement : 23/06/2026 O R D E R Per Bench: A bunch of appeals pertains to the same assessee filed against the order of the Ld. Commissioner of Income Tax (Appeals)-53 [for brevity the “Ld. CIT(A)”], order passed under section 250 of the Income Tax Act 1961 (for brevity ‘the Act’) for Assessment Year 2005-06 and 2014-15 date of order 22.07.2019 and 30.12.2020 respectively. Both the impugned orders emanated from the order of

2 ITA Nos.3828, 4065, 4268, 4210/Mum/2025 PBA Infrastructure Ltd. the Ld. Deputy Commissioner of Income Tax Officer- C.C-53, Mumbai (for brevity the ‘Ld. AO’) order passed under section 143(3) of the Act date of order 29.12.2016 for A.Y. 2014-15 and Ld. DCIT-CC-36, Mumbai order passed u/sec. 143(3) r.w.s. 153A date of order 22.07.2019. Further the orders passed by the Ld. Commissioner of Income Tax (Appeals)-53, Mumbai order passed u/sec. 250 of the Income Tax 1961 date of order 18.03.2025 for A.Y. 2005-06 and A.Y. 2014-15. Both the orders emanated from the order of the Ld. DCIT-CC-51, Mumbai order passed u/sec. 271(1)(c) of the Act date of order 11.03.2022 for both the assessment years.

2.

All the appeals pertain to the same assessee and arise out of a common set of facts. ITA Nos. 3828/Mum/2025 and 4065/Mum/2025 relate to the quantum appeals, whereas ITA Nos. 4210/Mum/2025 and 4268/Mum/2025 pertain to appeals against the levy of penalty under section 271(1)(c) of the Act. Since the issues involved in these appeals are interconnected and arise from substantially similar facts, all the appeals were heard together. Accordingly, for the sake of convenience and brevity, they are being disposed of by this consolidated order with the consent of both the parties. ITA No. 3828/Mum/2025, relating to the quantum appeal for A.Y. 2014-15, and ITA No. 4210/Mum/2025, relating to the appeal against the penalty under section 271(1)(c) of the Act for A.Y. 2014-15, are taken as the lead cases for the purpose of adjudication and decision rendered there in shall be applied mutatis mutandis to the rest of the appeals for AY 2005- 06. 3. The Registry has reported that all the appeals have been filed before the Tribunal with a delay. In response, the assessee has filed duly notarized affidavits

3 ITA Nos.3828, 4065, 4268, 4210/Mum/2025 PBA Infrastructure Ltd. along with separate petitions seeking condonation of delay, explaining the reasons that prevented the timely filing of the appeals. The details of the delay in filing each appeal are summarized in the following tabular statement: Sr. ITA No. Delay AY Nature of Effective date of delay as per NO. addition order of Hon’ble Supreme Court Suo Moto WP No.3 1 3828/Mum/2025 1552 2014-15 Quantum 1186 2 4065/Mum/2025 2079 2005-06 Quantum 1374 3 4210/Mum/2025 25 2014-15 Penalty 25 4 4268/Mum/2025 27 2005-06 Penalty 27

ITA Nos. 3828 & 4065/Mum/2025 4. The Ld. AR contended that for explanation of the delay in filing appeal for A.Y. 2014-15 in quantum appeal the Managing Director of the assessee-company, Mr. Narain P. Belani filed the petition seeking condonation of delay. The relevant part of the prayer is reproduced as below: “1. That I Mr. Narain P. Belani, Managing Director of PBA Infrastructure Limited aged 77 years, am authorised to file the petition for condonation of delay. 2. That I, the above named petitioner, am well conversant with the facts stated below. 3. That the income tax appeal for the assessment year 2014-2015 of the petitioner has been completed by the Honorable Commissioner of Income Tax (Appeals) 53, Mumbai vide order dated 30-12-2020 4. That the time for filing of the appeal before the ITAT (Appeal) was to expire in 60 days. 5. That the petitioner was under the impression that the Income Tax Consultant of the Company had filed the appeal before the Honorable Income Tax Appellant Tribunal against the order passed by the Honorable CIT (A) in time and the hearing and order was awaited. But, it was

4 ITA Nos.3828, 4065, 4268, 4210/Mum/2025 PBA Infrastructure Ltd. realised recently that the appeal was not filed by the Consultant resulting in great hardship to the Company which is already a stressed company and has been declared as an NPA. 6. That this Appeal has been filed before the Honorable ITAT along with this Request for condonation of delay. I do hereby verify that the contents of the above petition are true to my personal knowledge and nothing material has been concealed or falsely stated.”

5.

The same petition seeking condonation of delay related to A.Y. 2005-06 has been submitted by the Managing Director of the assessee company. The relevant part of the petition is reproduced as below: “1. That I Mr. Narain P. Belani, Managing Director of PBA Infrastructure Limited aged 77 years, am authorised to file the petition for condonation of delay. 2. That I, the above named petitioner, am well conversant with the facts stated below. 3. That the income tax appeal for the assessment year 2005-2006 of the petitioner has been completed by the Honorable Commissioner of Income Tax (Appeals) 53, Mumbai vide order dated 22-7-2019 4. That the time for filing of the appeal before the ITAT (Appeals) was to expire in 60 days. 5. That the petitioner was under the impression that the Income Tax Consultant of the Company had filed the appeal before the Honorable Income Tax Appellant Tribunal against the order passed by the Honorable CIT (A) in time and the hearing and order was awaited. But, it was realised recently that the appeal was not filed by the Consultant resulting in great hardship to the Company which is already a stressed company and has been declared as an NPA. 6. That this Appeal has been filed before the Honorable ITAT along with this Request for condonation of delay.” I do hereby verify that the contents of the above petition are true to my personal knowledge and nothing material has been concealed or falsely/stated.”

5 ITA Nos.3828, 4065, 4268, 4210/Mum/2025 PBA Infrastructure Ltd. 6. The Ld. DR strongly opposed the condonation of delay in filing the appeals. The Ld. DR contended that the assessee had failed to demonstrate any sufficient cause for the inordinate delay in preferring the appeals before the Tribunal. Accordingly, he prayed that the appeals be dismissed as barred by limitation.

7.

We have heard the rival submissions and perused the material available on record. Insofar as the quantum appeals for A.Ys. 2005-06 and 2014-15 are concerned, we find that the effective delay in filing the appeals is 1,374 days and 1,186 days, respectively. Even after granting the benefit arising from the order of the Hon’ble Supreme Court in Suo Motu Writ Petition (C) No. 3 of 2020 dated 10.01.2022, the assessee has failed to furnish any cogent explanation or sufficient cause for the substantial delay in filing the appeals. We further note that the Ld. AR filed only a condonation petition on a non-judicial stamp paper without supporting the same by way of a duly sworn and notarized affidavit. The manner in which the condonation petition has been filed reflects a casual approach towards compliance with the procedural requirements for seeking condonation of delay before the Tribunal. We have carefully considered the submissions of the Ld. DR and examined the record. It is a settled principle of law that where an appeal is presented beyond the prescribed period of limitation, the appellant must satisfactorily explain the existence of a “sufficient cause” that prevented him from approaching the appellate forum within the stipulated time. The expression “sufficient cause” signifies an adequate and reasonable cause which is beyond the control of the litigant and which prevented the timely institution of proceedings.

6 ITA Nos.3828, 4065, 4268, 4210/Mum/2025 PBA Infrastructure Ltd. 8. In this regard, reliance may be placed on the judgment of the Hon’ble Supreme Court in the case of Basawaraj Vs. Land Acquisition Officer reported in (2013) 14 SCC 81, held that. "9. Sufficient cause is the cause for which the defendant could not be blamed for his absence. The meaning of the word "sufficient" is "adequate" or "enough", inasmuch as may be necessary to answer the purpose intended. Therefore, the word "sufficient" embraces no more than that which provides a platitude, which when the act done suffices to accomplish the purpose intended in the facts and circumstances existing in a case, duly examined from the viewpoint of a reasonable standard of a cautious man. In this context, "sufficient cause" means that the party should not have acted in a negligent manner or there was a want of bona fide on its part in view of the facts and circumstances of a case or it cannot be alleged that the party has "not acted diligently" or "remained inactive". However, the facts and circumstances of each case must afford sufficient ground to enable the court concerned to exercise discretion for the reason that whenever the court exercises discretion, it has to be exercised judiciously. The applicant must satisfy the court that he was prevented by any "sufficient cause" from prosecuting his case, and unless a satisfactory explanation is furnished, the court should not allow the application for condonation of delay. The court has to examine whether the mistake is bona fide or was merely a device to cover an ulterior purpose. (See Manindra Land and Building Corpn. Ltd. v. Bhutnath Banerjee [AIR 1964 SC 1336], Mata Din v. A. Narayanan[(1969) 2 SCC 770], Parimal v. Veena [(2011) 3 SCC 545] and Maniben Devraj Shah v. Municipal Corpn. of Brihan Mumbai [(2012) 5 SCC 157 ].)" Respectfully following the aforesaid judgment of the Hon’ble Supreme Court and considering the facts of the present case, we are of the view that the assessee has failed to establish any sufficient or reasonable cause for the inordinate delays of 1,374 days and 1,186 days in filing the respective appeals. In the absence of a satisfactory explanation, we are not inclined to condone the delay and admit the appeals for adjudication on merits. Accordingly, the quantum appeals for A.Ys. 2005-06 and 2014-15 are dismissed as time-barred.

7 ITA Nos.3828, 4065, 4268, 4210/Mum/2025 PBA Infrastructure Ltd. ITA 4268/Mum/2025 for A.Y. 2005-06 and ITA 4210/Mum/2025 for A.Y. 2014- 15 9. The Ld. AR submitted that the appeals for the relevant assessment years were filed with delays of 25 days and 27 days, respectively. In support of the request for condonation, the Ld. AR filed duly supported condonation petitions explaining the circumstances that constituted sufficient cause for the marginal delay in filing the appeals within the prescribed period of limitation. The Ld. DR, however, opposed the condonation petitions and contended that the assessee had failed to establish adequate grounds warranting condonation of the delay.

10.

We have considered the rival submissions and perused the material available on record. We note that the delays involved are only 25 days and 27 days, respectively, and are not inordinate in nature. The reasons furnished in the condonation petitions constitute sufficient cause within the meaning of the law and demonstrate that the delay was neither deliberate nor attributable to any mala fide intention. It is well settled that where a litigant has acted bona fide and the delay is of a short duration, a liberal approach should be adopted in the interest of substantial justice. Considering the facts and circumstances of the case, we are satisfied that the assessee was prevented by sufficient cause from filing the appeals within the prescribed time. Accordingly, the delays in filing both the appeals are condoned, and the appeals are admitted for adjudication on merits.

8 ITA Nos.3828, 4065, 4268, 4210/Mum/2025 PBA Infrastructure Ltd. 11. The Ld. AR contended that assessee had filed the additional ground by challenging the jurisdiction of Ld. AO for issuance of defective notice u/sec. 274 r.w.s. 271(1)(c) of the Act in both the assessment years. Related to A.Y. 2014-15 the additional ground is reproduced as below: “1. In the facts and circumstances of the case and in law, the Learned CIT(A) erred in confirming the imposition of penalty u/s 271(1)(c) levied by the Ld. AO despite the same being void, bad in law and without jurisdiction. 2. While affirming the said order imposing penalty, the Ld. CIT(A) failed to appreciate that: a. The notices u/s 271(1) (c) of the Act was itself invalid in as much as it contained both the charges being concealment of particulars of income as well as furnishing inaccurate particulars of income, and the irrelevant charge was not struck off which vitiated the notice and so also the entire proceeding. b. Even otherwise the penalty was initiated for furnishing inaccurate particulars of income but ultimately levied for concealment of particulars of income, rendering the order imposing penalty invalid and bad in law. 3. In the facts and circumstances of the case and in law, the order imposing penalty so levied deserves to be quashed and it is prayed accordingly. 4. The Appellant craves leave to add, alter, delete or modify all or any the above ground at the time of hearing.”

12.

The Ld. AR submitted the two notices issued by the Ld. AO u/sec. 274 u/sec. 271 (1)(c) on 29.12.2016 and 01.02.2022 for hearing. The Ld. AR argued that the in both the notices for A.Y. 2014-15 the Ld. AO had not specified the limb whether notice is issued for concealment or inaccurate particular of such income. The notice on 29.12.2016 is duly issued by the Ld. AO is reproduced as below:

9 ITA Nos.3828, 4065, 4268, 4210/Mum/2025 PBA Infrastructure Ltd.

13.

The Ld. AR contended that the assessee filed the return by declaring total loss amount to Rs.72,42,383/-. The assessment was completed u/sec. 143(3) in A.Y. 2014-15 by determining total income amount to Rs.19,05,12,197/- as against return income amount to (Rs.72,42,383/-) by making various additions. The Ld. AO had initiated the penalty proceedings 271(1)(c) of the Act. But finally the Ld. AO confirmed the penalty at the rate of 100% of tax sought to be evaded which

10 ITA Nos.3828, 4065, 4268, 4210/Mum/2025 PBA Infrastructure Ltd. comes amount to Rs.1,75,95,659/-. The aggrieved assessee filed an appeal before the Ld. CIT(A). The Ld. CIT(A) rejected the appeal of the assessee and confirmed the penalty order. Being aggrieved assessee filed an appeal before us and challenged the legal ground related to issuance of notice u/sec. 271(1)(c) without specifying the limb in the alleged notices.

14.

The Ld.AR contended that the Ld.AO in the impugned assessment order noted that “Penalty notice u/s 271(1)(c) of the Act is being issued hereby seperatly.”, but did not specify the limb for initiation of penalty proceedings neither in the assessment order nor in the notices issued u/s 274 r.w.s 271(1)(c) of the Act. He stated that the Act is very specific for concealment or for furnishing of inaccurate particulars of income. So any one of the limbs should be specified. The Ld.AR respectfully relied on the order of jurisdictional High Court in the case of Mohammad Farhan A Shaikh vs ACIT (2021) 125 taxmann.com 253 (Bom). The relevant paras 187 to 191 are reproduced below: - “187 In Dilip N. Shroff case (supra), for the Supreme Court, it is of "some significance that in the standard Pro-forma used by the assessing officer in issuing a notice despite the fact that the same postulates that inappropriate words and paragraphs were to be deleted, but the same had not been done". Then, Dilip N. Shroff case (supra), on facts, has felt that the assessing officer himself was not sure whether he had proceeded on the basis that the assessee had concealed his income or he had furnished inaccurate particulars

188.

We may, in this context, respectfully observe that a contravention of a mandatory condition or requirement for a communication to be valid communication is fatal, with no further proof. That said, even if the notice contains no caveat that the inapplicable portion be deleted, it is in the interest of fairness and justice that the notice must be precise. It should give no room for ambiguity. Therefore, Dilip N. Shroff Case (supra) disapproves of the routine,

11 ITA Nos.3828, 4065, 4268, 4210/Mum/2025 PBA Infrastructure Ltd. ritualistic practice of issuing omnibus show-cause notices. That practice certainly betrays non- application of mind. And, therefore, the infraction of a mandatory procedure leading to penal consequences assumes or implies prejudice.

189.

In Sudhir Kumar Singh, the Supreme Court has encapsulated the principles of prejudice. One of the principles is that "where procedural and/or substantive provisions of law embody the principles of natural justice, their infraction per se does not lead to invalidity of the orders passed. Here again, prejudice must be caused to the litigant, except in the case of a mandatory provision of law which is conceived not only in individual interest but also in the public interest".

190.

Here, section 271(1)(c) is one such provision. With calamitous, albeit commercial, consequences, the provision is mandatory and brooks no trifling with or dilution. For a further precedential prop, we may refer to Rajesh Kumar v. CIT [2007] 27 SCC 181, in which the Apex Court has quoted with approval its earlier judgment in State of Orissa v. Dr. Binapani Dei AIR 1967 SC 1269. According to it, when by reason of action on the part of a statutory authority, civil or evil consequences ensue, principles of natural justice must be followed. In such an event, although no express provision is laid down on this behalf, compliance with principles of natural justice would be implicit. If a statue contravenes the principles of natural justice, it may also be held ultra vires Article 14 of the Constitution.

191.

As a result, we hold that Dilip N. Shroff Case (supro) treats omnibus show-cause notices as betraying non-application of mind and disapproves of the practice, to be particular, of issuing notices in printed form without deleting or striking off the inapplicable parts of that generic notice.”

15.

He further respectfully relied on the order of Hon’ble Supreme Court in the case of CIT(LTU) vs State Bank of India [2024] 169 taxmann.com 305(SC). The relevant para 2 is reproduced below: -

12 ITA Nos.3828, 4065, 4268, 4210/Mum/2025 PBA Infrastructure Ltd. “2. Having regard to the peculiar facts of this case inasmuch as the High Court has followed CIT Manjunatha Cotton and Ginning Factory (2013) 35 taxmann.com 250/218 Taxman 423 359 ITR 565 (Karn). we are not inclined to interfere in the matter. The reason being that the aforesaid judgment in Manjunatha Cotton and Ginning Factory case (supra) has been relied upon by the High Court in CIT v. SSA'S Emerald Meadows [2016] 73 taxmann.com 241 (Karnataka) and the said judgment has been sustained by this Court in CIT v. SSA’S Emerald Meadows [2016] 73 taxmann.com 248 /242 Taxman 180 (SC) /[SLP (Civil)……….No.11485/2016 vide order dated 05.08.2016] inasmuch as the said special leave petition was dismissed.”

16.

The counsel laid down that in the absence of such specific notice, the notice would be invalid. As held in various judicial pronouncements including the decision of Hon’ble Karnataka High Court in CIT V/s SAS’s Emerald Meadows (73 Taxmann.com 241) against which Special Leave Petition (SLP) filed by the department stood dismissed by Hon’ble Supreme Court which is reported as 73 Taxmann.com 248. The notice u/s 274/271(1)(c) of the Act is not carrying the specific limb. Therefore, this is a case where both the parts of the offences i.e., concealment of income as well as furnishing of inaccurate particulars of income were involved.

17.

The Ld. DR supported the orders of the Ld. AO and the Ld. CIT(A). The Ld. DR submitted that the quantum additions forming the basis of the penalty proceedings have already been confirmed by the Ld. CIT(A), thereby establishing the concealment of income and furnishing of inaccurate particulars by the assessee. Accordingly, the levy of penalty under section 271(1)(c) of the Act was fully justified. The Ld. DR further contended that the mere defect in the notice issued under section 274 r.w.s. 271(1)(c) of the Act, or the non-striking off of an

13 ITA Nos.3828, 4065, 4268, 4210/Mum/2025 PBA Infrastructure Ltd. inappropriate limb in the notice, cannot by itself be a ground for deleting the penalty when the assessment order and the penalty order clearly bring out the charge against the assessee. According to the Ld. DR, such procedural defects do not invalidate the penalty proceedings when the assessee was aware of the allegations and had been afforded adequate opportunity to defend its case. The Ld. DR therefore urged that the penalty levied under section 271(1)(c) of the Act be sustained and the order of the learned CIT(A) be upheld.

18.

However, when confronted with the judicial precedents relied upon by the assessee, particularly those holding that failure to specify the exact charge in the notice issued under section 274 r.w.s. 271(1)(c) vitiates the penalty proceedings, the Ld. DR was unable to distinguish the facts of the present case or place any contrary binding judicial precedent on record. Nor could the Ld. DR rebut the applicability of the judicial authorities relied upon by the assessee in support of its contention that the impugned penalty proceedings were legally unsustainable.

19.

We have heard the rival submissions, perused the material placed on record, and carefully considered the judicial precedents relied upon. The primary contention of the assessee is that the notices issued under section 274 r.w.s. 271(1)(c) of the Act suffer from a fundamental defect inasmuch as the Assessing Officer failed to specify the particular limb—whether the penalty proceedings were initiated for “concealment of income” or for “furnishing inaccurate particulars of income.” It is well-settled by the Hon’ble Bombay High Court in Mohammad Farhan A. Shaikh (supra) as well as by the Hon’ble Karnataka High Court in SSA’s Emerald Meadows (supra), affirmed by the Hon’ble Supreme

14 ITA Nos.3828, 4065, 4268, 4210/Mum/2025 PBA Infrastructure Ltd. Court, that such omnibus notices betray non-application of mind and vitiate the penalty proceedings. In the present case, a perusal of the assessment order as well as the penalty notices dated 29/12/2016 and 01/02/2022 reveals that the Ld. AO has mechanically referred to “concealing of income and/or furnishing of inaccurate particulars of income” without striking off the irrelevant portion. This ambiguity clearly violates the mandatory requirement of law and the principles of natural justice. We are therefore unable to accept the contention of the revenue that such defect is a mere technicality, particularly when penalty provisions under section 271(1)(c) of the Act carry severe and penal consequences. The Ld. DR was unable to controvert the arguments advanced by the Ld. AR by placing on record any contrary judicial precedent. Respectfully following the ratio laid down in the above judicial precedents, we hold that the penalty order passed under section 271(1)(c) of the Act is not sustainable in law. Accordingly, we set aside the order of the appellate authority and direct the Ld. AO to delete the penalty of Rs. 1,75,95,659/-. As we decided the issue In the result, the Additional Grounds has taken by the assessee are allowed. All other Grounds of assessee’s appeal are rendered academic and kept open. 20. In the result, the appeal of the assessee bearing ITA Nos.3828/Mum/2025 and 4065/Mum/2025 are dismissed and ITA Nos.4210/Mum/2025 and 4268/Mum/2025 are allowed. Order pronounced in the open court on 23rd day of June 2026. Sd/- Sd/- (MAKARAND VASANT MAHADEOKAR) (ANIKESH BANERJEE) ACCOUNTANT MEMBER JUDICIAL MEMBER Mumbai,िदनांक/Dated: 23/06/2026

15 ITA Nos.3828, 4065, 4268, 4210/Mum/2025 PBA Infrastructure Ltd. SAUMYASr.PS Copy of the Order forwarded to: 1. अपीलाथ�/The Appellant , 2. �ितवादी/ The Respondent. 3. आयकरआयु� CIT 4. िवभागीय�ितिनिध, आय.अपी.अिध., मुंबई/DR, ITAT, Mumbai 5. गाड�फाइल/Guard file. BY ORDER, //True Copy// (Asstt. Registrar), ITAT, MUMBAI

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