CARE DETERGENTS PRIVATE LIMITED,KANPUR NAGAR vs. ACIT, CIRCLE 2(1)(1), KANPUR, CIVIL LINES, KANPUR

IN THE INCOME TAX APPELLATE TRIBUNAL LUCKNOW ‘A’ BENCH, LUCKNOW BEFORE SH. SUDHANSHU SRIVASTAVA, JUDICIAL MEMBER AND SH. NIKHIL CHOUDHARY, ACCOUNTANT MEMBER ITA No.414/LKW/2025 A.Y. 2017-18 Care Detergents Private Limited, vs. ACIT, 113/174-A, Swaroop Nagar, Circle-2(1)(1), Kanpur Kanpur, U.P. PAN: AACCC1365M (Appellant) (Respondent) Assessee by: Sh. Malay Gupta, C.A. Revenue by: Sh. Amit Kumar, DR Date of hearing: 14.01.2026 Date of pronouncement: 10.04.2026 O R D E R PER NIKHIL CHOUDHARY, A.M.: This is an appeal filed by the assessee against the orders of the ld. Addl/JCIT(A)-1, Visakhapatnam under section 250 of the Income Tax Act, 1961 dated 20.05.2025, wherein the ld. First Appellate Authority has dismissed the appeals of the assessee against the order passed by the Assessing Officer under section 143(3) for the A.Y. 2017-18, on 20.12.2019. The grounds of appeal are as under:- “1. That the CIT(A) has erred on facts and in law in applying Rule 14A read with Rule 8D without proper appreciation of the provisions of Section 14A and Rule 8D. 2. That the CIT(A) has erred in upholding the disallowance made by the AD of Rs. 9,38,601/- without recording the reasons of his dissatisfaction regarding the correctness of the claim made by assessee in relation to the exempt income u/s 14A of the Act read with rule 8D. which is not according to the provisions of the income tax act. 3. That the Authorities below ignored the fact that the Assessee Company does not have any borrowed funds for making investment for earning exempt / tax free income. Thereby, provisions of section 14A shall not be applicable. The addition by the AO and uphold by the CIT(A) be deleted.

ITA No.414/LKW/2025 A.Y. 2017-18 Care Detergents Pvt. Ltd. 4. That the appeal order dated 20.05.2025 is not based on facts of the case, is bad in law against the provisions of law liable to be quashed. 5. That the assessee appellant craves to allow any other relief as may be deemed fit.”

ITA No.414/LKW/2025 A.Y. 2017-18 Care Detergents Pvt. Ltd. year. Therefore, he held that the provisions of section 14A of the Income Tax Act were applicable in the case of the assessee. The ld. AO held that the assessee had common infrastructure and common personnel for earning income under various heads and was using its administrative, managerial and infrastructural set up for earning income which did not form part of total income under the Act. As decisions of investment were crucial and complicated, the company’s manpower was being utilized for the same and therefore, the ld. AO recorded his dissatisfaction with the correctness of the claim made by the assessee that no expenditure was incurred for earning such income. He, therefore, applied the provisions of Rule 8D(2) and added back an amount equal to one half percent of average value of investment in the balance sheet on the first day and last day of the previous year, the income from which did not or would not form part of the total income. Accordingly, a sum of Rs. 9,38,601/- was added back to the income of the assessee and penalty proceedings were initiated under section 270A of the Income Tax Act. 3. Aggrieved with the said assessment order, the assessee filed an appeal with the NFAC, which was subsequently allotted to the Addl/JCIT(A)-1, Visakhapatnam. Before the ld. First Appellate Authority, it was submitted that the assessee company did not incur any direct expenses in making the investments in mutual funds. The indirect expenses relating to investment were claimed on estimate basis and were added to the income as per provisions of section 14A of the Act in the return of income filed by the assessee. Since, the assessee had made very few transactions for investment / redemption of units as compared to the overall transactions made by it, negligible time and resources had been utilized for the purpose. It was further submitted that without appreciating this, the ld. AO had made a disallowance of Rs. 9,38,601/- by applying the provisions of section 14A r.w.r. 8D(2)(iii). It was submitted that the AO had presumed that the assessee, “must” have incurred expenses to earn such income. Furthermore, the entire investment in mutual funds had been made out of own surplus funds, fee reserves and internal accruals. There were no borrowed funds. No interest had been paid or claimed as expenditure. It

ITA No.414/LKW/2025 A.Y. 2017-18 Care Detergents Pvt. Ltd. was further submitted that the increase in the value of mutual funds was partly on account of accrual of dividend and partly on account of fresh investments made. The total amount of dividend earned was Rs. 17,42,801/-, which had been claimed exempt under section 10(33) of the Act. As the Company had not incurred any expenditure in earning this income, only a token addition had been made. The ld. AO had not been able to point out a single particular expenditure that had been incurred for earning of tax-exempt income. He had not given any reason for making the disallowance. It was further held, that if no borrowed funds had been invested to earn tax free income, no disallowance need be made. For the same, reference was invited to the decisions of the Hon’ble Delhi High Court in Pr. CIT vs. DLF Home Developers Limited (ITA No. 1453/2018 dated 18.12.2018), decisions of the Delhi Tribunal in the case of ACIT vs. India Bulls Real Estate Limited (ITA Nos. 6602/DEL/2016 and 6603/DEL/2016 dated 11.03.2020 and ACIT vs. Eicher Limited (2006) 101 TTJ (Delhi-Trib) 369. It was also pointed out that in the case of CIT vs. Syndicate Bank (2020) 115 taxman.com 287 (Karnataka), the Hon’ble High Court had held that where the assessee had not incurred any expenditure in earning dividend income, disallowance for the expenditure in respect of administrative or financial cost in accordance with section 14A could not be sustained. It was submitted that there were no findings in the assessment order that the accounts maintained were not correct and did not reflect the true state of affairs. There was no finding that the claim of the assessee that no expenditure had been incurred, was incorrect. It was submitted that the AO could not proceed to determine the amount of expenditure incurred in relation to exempt income without recording a finding that he was not satisfied with the correctness of the claim of the assessee. That was a condition precedent. It was further submitted that in Rule 8D only came into play when the AO recorded a finding that he was not satisfied with the assessee’s method of accounting and the AO would have to show why he was not satisfied with the correctness of the assessee’s claim. It was only then that Rule 8D could be invoked. Reference was invited to the decision of the Hon’ble Supreme Court in the case of Maxopp Investment Ltd. vs. CIT (2018) 402 ITR 640 and the decision of the Hon’ble 4

ITA No.414/LKW/2025 A.Y. 2017-18 Care Detergents Pvt. Ltd. Supreme Court in the case of Godrej & Boyce Manufacturing Company Ltd. vs. DCIT (2017) 394 ITR 449. Reference was also invited to the Hon’ble Delhi High Court in the case of Pr. CIT vs. Vedanta Ltd. (2019) 102 taxman.com 95 and Eicher Motors Ltd v. Commissioner of Income Tax (2017) 398 ITR 51. The attention of the ld. First Appellate Authority was also invited to the decisions in the case of PCIT vs. U.K. Paints (India) (P.) Ltd. (2017) 392 ITR 552 Delhi; Punjab Tractors Limited vs. CIT (2017) 393 ITR 223 P&H and CIT vs. Taikisha Engineering Limited (2015) 370 ITR 338. References were also invited to other decisions which relied upon the decision of the Hon’ble Delhi High Court in the case of Taikisha Engineering India Limited (supra). 4. The ld. First Appellate Authority considered these submissions of the assessee and held that it was a well-known fact that a company could not earn dividend without its existence and management. Investment decisions were very complex in nature. They required substantial market research, day to day analysis of market trends and decisions with regard to acquisition, retention and sale of shares / mutual funds at the most appropriate time. Therefore, it could not be said that dividend income or exempt income could be earned without incurring any or nominal expenditure. He held that it was difficult to accept that a company could earned dividend income without incurring any expenses including management or administrative expenses as investments decisions were generally taken in the meetings of the Board of Directors for which administrative expenses incurred. He pointed out that in the case of Godrej & Boyce Manufacturing Company Ltd. vs. DCIT (supra), the Hon’ble Bombay High Court had held that section 14A supersedes the principle of law that in the case of a composite business, expenditure incurred towards tax free income could not be disallowed and it incorporated an implicit theory of apportionment of expenditure between taxable and non-taxable income. Once a proximate cause for disallowance was established, a disallowance under section 14A had to be effected. Further, the Court had held that disallowance under section 14A r.w.r. 8D was required to be made even if the investments pertain to an

ITA No.414/LKW/2025 A.Y. 2017-18 Care Detergents Pvt. Ltd. earlier year. The ITAT in the case of ITO vs. Daga Capital (Special Bench) had held that section 14A had overriding effect and applied to all expenditure in relation to exempt income, even though such expenditure would have been allowable under other provisions such as section 36(1)(iii). Further, it had held that the words, “in relation to” in section 14A encompass not only the direct expenses but also the indirect expenses which had any relation to the exempt income. The argument that the words contemplated a, “direct and immediate connection” between an expenditure and the exempt income could not be accepted. The ld. First Appellate Authority held that the theory of apportionment of expenditure between taxable and non-taxable income had been widened in principle under section 14A and when read in juxtaposition with sections 15 to 59, it could be concluded that section 14A referred to expenditures for which allowances were otherwise provided for. The ld. First Appellate Authority held that it was reasonable to presume that an investment of this nature would require the deployment of the assessee’s intellectual, physical and financial resources. He also rejected the contention of the assessee that the AO had not recorded any reason / finding before proceeding to apply Rule 8D, as the AO had clearly specified the reasons in para 7 of the assessment order. He had pointed out that the assessee had common infrastructure and common personnel for earning income under various heads and was using its administrative, managerial and infrastructural setup for taking the crucial decisions relating to investment that yielded exempt income. It was, therefore, inbuilt in the case of the assessee and debited under various heads of the profit and loss account because as per the provisions of section 14A of the Income Tax Act, the term, “expenditure” would take in its ambit not only direct expenditure but also all forms of expenditure regardless of whether they were fixed, variable, direct, indirect, administrative, managerial or financial. In view of the same, he held that the AO was justified in making the addition by disallowing the expenditure under section 14A r.w.r. 8D and he confirmed the addition of Rs. 9,38,601/- on this account.

ITA No.414/LKW/2025 A.Y. 2017-18 Care Detergents Pvt. Ltd. 5. The assessee is aggrieved at this order of the ld. First Appellate Authority and has accordingly come in appeal before us. Sh. Malay Gupta, C.A. (hereinafter referred to as the ld. AR), arguing on behalf of the assessee company submitted that the company had outsourced all its mutual funds investments to mutual fund agents and it did not pay the mutual fund agent anything for the making of such investment decisions. The mutual fund agent was paid for by the mutual fund (by way of commission). All the investments had been made out of the reserves and surplus funds of the company and there was no day-to-day monitoring or seeking of advice from the Directors of the company, by such agents for mutual fund transactions. Thus, it could not be said that any part of the company’s infrastructure had been utilized towards the earning of such exempt income. It was further pointed out that the ld. AO had failed to point out any expenditure that could have been incurred for the earning of this income. The ld. AR further submitted that even as per the provisions of Rule 8D, only those assets could be considered which actually yielded exempt income and he pointed out that of the total investments of Rs. 26,39,41,979/-, only investments worth Rs. 2,59,71,752/- were in the nature of dividend bearing mutual funds i.e. only these mutual funds yielded any exempt income. All other mutual funds were those which would yield capital gains on sale. Accordingly, they could not be considered for the purposes of the disallowance and therefore, even assuming that a disallowance ought to be made, it had to be restricted to the value of mutual funds that actually yielded exempt income. The ld. AR also referred us to a written synopsis submitted earlier, wherein it was pointed out that Rule 8D only came into play when the AO records a finding that he was not satisfied with the claim made by the assessee regarding the expenditure incurred in relation to exempt income. The AO would have to show why he was not satisfied and that satisfaction could only be reached when the claim of the assessee was verified. Therefore, the correct sequence was to first examine the assessee’s claim of having incurred or not incurred any expenditure in relation to exempt income. Reliance was placed on the decisions of the Hon’ble Supreme Court in the case of Maxopp Investment Ltd. vs. CIT (TS-5170-SC-2018-O), PCIT vs. Vedanta Limited 7

ITA No.414/LKW/2025 A.Y. 2017-18 Care Detergents Pvt. Ltd. (TS-7245-HC-2018-Delhi-O), CIT vs. Sociedade De Fomento Industrial (P.) Ltd. (2021) 123 taxman.com 38 (Bom) and Godrej & Boyce Manufacturing Company Ltd. vs. DCIT (2017) 394 ITR 449 SC. It was submitted that the ld. CIT(A) had erred in upholding the disallowance of Rs. 9,38,601/- made by the AO without recording the reasons of his dissatisfaction regarding the correctness of the claim made by the assessee as there were no findings in the assessment order that the accounts maintained were not correct and did not reflect the true state of affairs and furthermore as the expression, “expenditure incurred” in section 14A referred to actual expenditure and not some imagined expenditure. Therefore, section 14A could not be invoked. Furthermore, it was argued that the assessee company did not have any borrowed funds for making investments for earning exempt / tax free income. There were no loans or advances taken by the company and the company had after tax profit of Rs. 21,11,02,582/- which was the source of these investments. Since, the entire investment in mutual funds had been made out own of its’ surplus funds, free reserves and internal accruals, reliance was placed on the following cases to argue that if no borrowed funds have been invested to earn tax free income, no disallowance need be made. i. CIT vs. Taikisha Engineering India Limited (2015) 229 taxman 143 (Delhi) ii. CIT vs. Gujarat Narmada Value Fertilizers Co. Limited (2014) 31 ITR 668 (Ahd) iii. PCIT vs. DLF Home Developers Limited (ITA No. 1453/2018) iv. CIT vs. Syndicate Bank (2020) 115 taxman.com 287 (Karnataka) v. Gujarat State Energy Generation Limited vs. ACIT (2020) 117 taxman.com 58 (Ahmedabad-Trib) It was further argued that the assessee had actually not incurred any direct or indirect expenses for earning exempt income during the year. However, a sum of Rs. 10/- was added Suo Moto to the computation of income on estimate basis, by the assessee company while filing the return of income. Without prejudice to the above, it was argued that the average value of investment which yielded exempt 8

ITA No.414/LKW/2025 A.Y. 2017-18 Care Detergents Pvt. Ltd. funds was only Rs. 2,59,71,752/- and therefore, the extent of disallowance could only be Rs. 1,29,860/-. For this, reliance was placed on the decision of the ITAT in the case of ACIT vs. Vireet Investments Pvt. Ltd. vs. ACIT (165) ITD 27 Del and M/s Indeco Ventures Limited vs. DCIT (ITA No. 1081 & 1082/CHNY/2018). Therefore, it was prayed that the disallowance/addition of Rs. 9,38,601/- may be deleted. 6. Responding to the said arguments of the ld. AO, Sh. Amit Kumar, Sr. DR (hereinafter referred to as the ld. DR) argued that in this case, the assessee company had made investment in shares / mutual funds at Rs. 26,39,41,979/- as on 31.03.2017 as compared to Rs. 11,14,98,475/- in the preceding year and claimed exempted income from these investments in the form of dividend. Further, it had been noticed that the assessee claimed Rs. 10/- of disallowance under section 14A of the Act. The assessee had been asked to substantiate the estimate of expenditure made by the assessee company of Rs. 10/- as disallowable expenditure under section 14A of the Act. In response, the assessee had submitted that no direct expenditure was incurred for earning exempt income and so far as indirect expenses were concerned, the company had duly estimated the expenditure relatable in investments and no employee of the company engaged in activities relating to investment in mutual funds. The Director, looking after finance, takes decision to invest on spare funds in a particular scheme of mutual fund. Ld. Sr. DR submitted that the ld. AO had recorded his dissatisfaction with the aforesaid explanation on page 4 of the assessment order wherein he had stated that the assessee had common infrastructure and common personnel for earning income under various heads and was therefore, using its administrative, managerial and infrastructural setup for earning income, which did not form part of total income under the Act. The ld. AO had pointed out that the expenditure in relation to income not includable in total income was inbuilt in the case of the assessee and was debited under various heads of the profit and loss account because the manpower of the company was involved in taking the crucial and complicated decisions regarding the investments which had yielded exempt income. The ld. DR submitted

ITA No.414/LKW/2025 A.Y. 2017-18 Care Detergents Pvt. Ltd. that even if the Director had only given advice or concurrence to the mutual fund’s agents, the company’s utilities had been utilized and since there was no basis to estimate the expenditure at Rs. 10/- therefore, it could not be said that the AO had not recorded his dissatisfaction with the accounts maintained by the assessee. The ld. Sr. DR submitted that once the ld. AO arrived at the satisfaction in accordance with section 14A(2), then was he was necessarily obliged to compute the disallowance as per the provisions of Rule 8D. The ld. AR further submitted that section 14A(3) applied to situations where no expenditure had been incurred and the assessee was repeatedly claiming that no expenditure had been incurred. The sum of Rs. 10/- had only been offered to escape the provisions of section 14A(3) and without basis. Hence, the provisions of Rule 8D was attracted in the instant case. The ld. Sr. DR thereafter, placed reliance on the following case laws to show that once exempt income was earned, the disallowance had to be under Rule 8D if the AO records his dissatisfaction. i. Maxopp Investment Ltd. vs. CIT (2018) 402 ITR 640 (SC) ii. J.M. Financial & Investment Consultancy Services Pvt. Ltd. vs. DCIT (ITA No. 1652/MUM/2012) iii. Godrej & Boyce Manufacturing Company Ltd. vs. DCIT (2017) 394 ITR 439 (SC) iv. CIT vs. Abhishek Industries Limited (2006) 286 ITR 1 (P&H HC) v. ACIT vs. Vireet Investment Pvt. Ltd. (ITA No. 502/DEL/2012) 7. We have duly considered the facts and circumstances of the case. We note that for all practical purposes, the assessee claims that it has not made any expenditure direct or indirect on the earning of exempt income and it has offered the sum of Rs. 10/- as an estimated disallowance after considering the fact that the amount of time spent by the management on taking investment/redemption decisions was minimal as compared to the overall activities of the Directors in the sale, purchase and other cash / banking transactions entered into by the company. The gist of the assessee’s arguments is that the entire activities are undertaken by 10

ITA No.414/LKW/2025 A.Y. 2017-18 Care Detergents Pvt. Ltd. mutual fund agents, who are paid for by the mutual funds and not by the assessee and since the funds that had been utilized are out of the assessee’s own reserves, there were no direct expenditures incurred for the investment in the mutual funds, that fetched exempt income. It appears from the submissions of the ld. Sr. DR and the perusal of the assessment order that the assessee was specifically asked to substantiate the estimate of expenditure made by the assessee company of Rs. 10/- as disallowable expenditure under section 14A of the Act and the assessee could not submit any basis for estimating the expenditure at Rs. 10/- other than to state that, in fact it incurred no expenditure because it had no personnel devoted to mutual funds and the mutual funds were basically managed by mutual fund agents in coordination with the Director, Finance. Since the number of mutual funds transactions were negligible as compared to the overall transactions of the assessee company, a token amount of Rs. 10/- was estimated. To our mind, this cannot constitute a justification for a particular amount being offered for disallowance. If it were the stand of the assessee that no expenditure whatsoever had been incurred then there was no occasion to offer the token amount of Rs. 10/- for disallowance and if it were the stand of the assessee company that indirect expenditure had been incurred then the disallowance of the indirect expenditure should have taken place on a scientific basis of apportionment, which has clearly not been done. Therefore, we cannot find fault with the decision of the ld. AO to reject the claim of the assessee with regard to the expenditure of Rs. 10/- offered in its books as disallowable on account of the same being related to the earning of exempt income. As such, the case laws cited by the assessee pointing out that the AO had to point out his dissatisfaction before he could invoke Rule 8D, have no relation to the facts of the case when the assessee was not able to substantiate the amount which itself had disallowed. 8. It is observed that the Hon’ble Madras High Court in the case of Polaris Consulting and Services Ltd v. PCIT (2020) 119 taxmann.com 387 (Mad) held that the assessee’s contention that no expenditure was incurred by them for earning

ITA No.414/LKW/2025 A.Y. 2017-18 Care Detergents Pvt. Ltd. exempt income could not be substantiated before the lower authorities or before the Tribunal. Noting that, where the CIT(A) and the Tribunal had found that investment during the year had increased from the opening balance and the value of assets had increased and thereafter applied Rule 8D and made additions under section 14A, no fault could be found with the decision of the order of the ld. AO. Thus, the primary onus to establish that expenditure has not been incurred or that it has been incurred for a particular value is that on the assessee and in the present case, we note that the assessee has not been able to substantiate that the amount of Rs. 10/- was the correct estimate of expenditure incurred towards earning of exempt income. We further note that the Chennai Bench of the ITAT in the case of M/s. Sundaram Bnp Paribas Home Finance Ltd v. The Deputy Commissioner of Income Tax (2022) 141 taxman.com 250 (Chennai-Trib) has held that when the assessee had maintained common books of accounts for taxable and exempt income, the possibility of incurring common expenditure for both segments could not be ruled out and therefore, there is no error in the reasons given by the AO to invoke Rule 8D to compute disallowance under section 14A. We note that in the present case, the ld. CIT(A) while affirming the order of the AO in invoking Rule 8D on account of the use of the common manpower and common infrastructure of the assessee company pointed out that the expenditure in relation to income not included in total income is inbuilt in the case of the assessee and debited under various heads of the profit and loss account. Thus, the dissatisfaction was clearly recorded. We cannot accept that the argument of the assessee that the entire work was done by mutual fund agents because the mutual fund agents can advise and facilitate with regard to investments and redemption but the actual decision making of what investments to make and what funds to redeem could not be taken by them but by the authorized person in the company. In the instant case, we are talking about investment equivalent to two thirds of the company’s annual profits. It is inconceivable that such a major decision could be taken without consultation with the company officials and even within the company. Possibly such huge investments would require clearance by the Board of Directors. Thus, the number 12

ITA No.414/LKW/2025 A.Y. 2017-18 Care Detergents Pvt. Ltd. of transactions are not an accurate barometer to judge the time and effort taken towards the making of such investment decisions. Even if the attention and effort towards this was comparatively less in terms of the overall responsibilities of that person, in view of the common accounting, it could not be said that no expenditure should be apportioned for the same and therefore, we are in agreement with the ld. AO and the ld. First Appellate Authority on the invocation of Rule 8D for determining the expenditure incurred with relation to earning of exempt income. Ground Nos. 1 & 2 are accordingly dismissed. 9. However, with regard to the disallowance of Rs. 9,38,601/-, we observe that the ld. AO, while computing the average value of investments has taken the figure at Rs. 18,77,20,227/-, while the average value of dividend bearing investments were only Rs. 2,59,71,752/-. Thus, the computation of the disallowance at Rs. 9,38,601/- is clearly an error and as held that by the various Courts is to be computed with reference to only those investments which yield exempt income. In the case of ACIT vs. Vireet Investment Pvt. Ltd. [2017] 165 ITD 27 (Delhi - Trib.) (SB), the Tribunal held that only those investments were to be considered for computing average value of investments with yielded exempt income during the year. In the case of M/s Indeco Ventures Limited vs. DCIT (ITA No. 1081 & 1082/CHNY/2018), the ITAT Chennai Bench followed the order of the ITAT Special Bench in the case of ACIT vs. Vireet Investment Pvt. Ltd., (supra) and ordered that the issue be reconsidered, to consider only those investments which yielded exempt income for both assessment years, for computing the disallowance under section 14A of the Act. This position has also been reiterated by the Chennai Bench of the Tribunal in the case of M/s. Sundaram Bnp Paribas Home Finance Ltd v. The Deputy Commissioner of Income Tax (supra). Therefore, in view of the above, we hold that the disallowance under Rule 14A could only be with reference to the average value of investment that yielded exempt income i.e. Rs. 2,59,71,752/-. Accordingly, the AO is directed to recompute the disallowance and ground no. 2 is held to be partly allowed. Since, there is no allegation of any direct expenditure, the

ITA No.414/LKW/2025 A.Y. 2017-18 Care Detergents Pvt. Ltd. fact that the company did not make the investment out of borrowed funds is not relevant to decide the issue at hand. Ground No. 3 is accordingly dismissed as infructuous. Ground no. 4 is a plea to quash the assessment order as it is not based on the facts of the case and bad in law. The same has already been modified to the extent as required in ground no. 2, accordingly, this ground of appeal is also dismissed as infructuous. Ground no. 5 does not require a decision. Accordingly, the appeal of the assessee is held to be partly allowed. 10. In the result, the appeal of the assessee is partly allowed. Order pronounced in the open court on 10.04.2026. Sd/- Sd/- [SUDHANSHU SRIVASTAVA] [NIKHIL CHOUDHARY] JUDICIAL MEMBER ACCOUNTANT MEMBER DATED: 10/04/2026 Sh Copy forwarded to: 1. Appellant – 2. Respondent – 3. CIT DR , ITAT, 4. CIT, 5. The CIT(A) By order Sr. P.S.