KARMESHWAR EXIM P LTD,SURAT vs. DCIT, CIRCLE 1(1)(1), SURAT

आयकर अपीलीय अिधकरण, सूरत �ायपीठ, सूरत IN THE INCOME TAX APPELLATE TRIBUNAL SURAT BENCH, SURAT BEFORE MS. SUCHITRA KAMBLE, JUDICIAL MEMBER AND SHRI B.M. BIYANI, ACCOUNTANT MEMBER ITA No.935/SRT/2025 (AY: 2013-14) ITA No.936/SRT/2025 (AY: 2013-14) ITA No.939/SRT/2025 (AY: 2015-16) ITA No.940/SRT/2025 (AY: 2016-17) ITA No.941/SRT/2025 (AY: 2017-18) M/s. Karmeshwar Exim बनाम/ DCIT, Circle 1(1)(1), P. Ltd., Room # 108, Vs. A/3/2, Hojiwala Aayakar Bhavan, Industrial Estate Majuragate, Sachin, Surat, Palsana Road, Gujarat Sachin, Surat Gujarat (Assessee/Appellant) (Revenue/Respondent) PAN: AADCK9523E Assessee by Shri Suresh K. Kabra, CA Revenue by Shri Ravikant Gupta, CIT (DR) & Shri Ashish Kumar, Sr. DR Date of Hearing 25.06.2026 Date of Pronouncement 30.06.2026 आदेश / O R D E R Per B.M. Biyani, AM:

The captioned five (5) appeals are filed by same assessee; the counsels representing in all matters are same and the issues are also identical,

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. hence they are being disposed of by this consolidated order for the sake of convenience.

ITA 935/SRT/2025 – AY 2013-14:

(i) The assessee-company filed its return of income of AY 2013-14 declaring a total income of Rs. Nil u/s 139 which was duly assessed through an assessment-order dated 09.03.2016 u/s 143(3).

(ii) Subsequently, on the basis of information in his possession from the CRIU/VRU High Risk Cases revealing certain financial transactions undertaken by assessee, the AO issued initial notice dated 21.05.2021 u/s 148 to re-open assessee’s case u/s 147 on the strength of the time-limit extended by The Taxation and Other Laws (Relaxation and Amendment of Certain Provisions) Act, 2020 [“TOLA”]. Since a new set

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. of provisions for re-assessment u/s 147 was introduced in Income-tax Act w.e.f. 01.04.2021, there arose controversies with regard to the issuance of notices u/s 148 after 01.04.2021 and the litigation travelled to Hon’ble Supreme Court in Ashish Agarwal (2022 SCC Online SC 543) dated 04.05.2022 in which the Hon’ble Supreme Court gave certain directions. Accordingly, after considering the decision of Ashish Agarwal, the Ld. AO issued a fresh notice dated 24.07.2022 u/s 148 to assessee for making assessment u/s 147 [after completing the procedure of section 148A(d)], which culminated into passing of an order of re-assessment dated 29.05.2023. By this order of re-assessment, the Ld. AO re-assessed assessee’s total income at Rs. 30,40,76,039/-.

(iii) Aggrieved by aforesaid order of re-assessment, the assessee carried matter in first-appeal whereupon the Ld. CIT(A) dismissed assessee’s appeal for non-prosecution and did not grant any relief.

(iv) Now, the assessee has come in next appeal before us.

“1. The Ld. Jurisdiction Assessing Officer has erred and was not just and proper on the facts of the case and in law in reopening the case and issuing notice u/s 148 despite the same being time barred under the provisions of the Act reference to the decision of Rajeev Bansal by Hon'ble SC. 2 The Ld. CIT, NFAC has erred and was not just and proper on the facts of the case and in law in confirming the addition of 30,40,76,039/- u/s.69A of the Income-tax Act.”

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. 6. By means of Ground No. 1, the assessee is challenging the legality of re-assessment framed by Ld. AO u/s 147. The assessee is claiming that the notice issued by AO u/s 148 to frame assessment u/s 147 was time-barred.

Subsequently, in Union of India Vs. Rajeev Bansal (2024) 469 ITR 8. 46 (SC) dated 03.10.2024, the Hon’ble Supreme Court further held that

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. the order u/s 148A(d) was required to be passed as well as the new notice u/s 148 was required to be issued within the “surviving time” available as per outer time-limit available under Income-Tax Act, 1961 read with TOLA (i.e. available upto 30.06.2021). Ld. AR explained that since the original notice u/s 148 of the Act was issued on 21.05.2021, the Ld. AO had only 40 days “surviving time” available upto 30.06.2021. Therefore, new notice u/s 148 of the Act was required to be issued within the survival period of 40 days from the last date on which the assessee was required to file reply to the notice u/s 148A(b) issued by AO. Since in present case, the AO issued notice u/s 148A(b) to assessee on 27.05.2022, the assessee was having two weeks’ time to file reply uptill 10.06.2022. Thereafter, the Ld. AO was having time period to issue notice u/s 148 uptill 20.07.2022 [10.06.2022 + 40 days]. That means, the AO could new/subsequent notice u/s 148 by 20.07.2022 only. However, the Ld. AO has issued new/subsequent notice u/s 148 dated 24.07.2022 which is barred by limitation and hence invalid. Consequently, the assessment-order passed by Ld. AO is also invalid.

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. 11. In rejoinder, Ld. AR submitted that all notices issued by Ld. AO have been filed by him in Paper-Book. Further, he has also compiled the chart of chronology of events taking into account those notices as well as the law settled by Hon’ble Supreme Court in Ashish Agarwal (supra) and Rajeev Bansal (supra). Hence, there is no purpose in remanding this matter to AO. He requested the bench to decide this matter and quash the assessment- order passed by AO.

. 14. We find that the identical controversy involving similar facts has already been decided by Co-ordinate Bench of ITAT, Surat in ITA 479 & 480/SRT/2025, Kanchan Devi Agarwal Vs. ITO, order dated 23.12.2025 wherein the Co-ordinate Bench has accepted assessee’s claim. We re-produce below the relevant portion of order of ITAT for an immediate reference:

“10. The contention of the assessee is that the Assessing Officer was required to pass order under Section 148A(d) of the Act and also issue notice under Section 148 of the Act within the surviving period of three days (which was extended to seven days) of filing its reply on 06.06.2022. Thus, the Assessing Officer had time limit till 14.06.2022 only to take these actions. However, the order under Section 148A(d) of the Act and the notice under Section 148 of the Act was issued on 25.07.2022 i.e. beyond the period of seven days from its reply on 06.06.2022 and thus the notice was barred by limitation. 11. The Hon’ble Supreme Court, in the case of Ashish Agarwal (supra), had directed that all the notices u/s 148 of the Act issued under the old provision shall be treated as show cause notice issued u/s 148A(b) of the Act of the new provisions. Further, the Hon’ble Court had directed the assessing officers to supply the assesses with the relevant material and information relied upon by the Revenue within thirty days from the date of the judgment. The effect of this direction was summarized by the Apex Court in the case of Rajeev Bansal [2024] 167 taxmann.com 70/301 Taxman 238/469 ITR 46 (SC) as under: 106. …..To summarize, the combined effect of the legal fiction and the directions issued by this Court in Ashish Agarwal (supra) is that the show cause notices that were deemed to have been issued during the period between 1 April 2021 and 30 June 2021 were stayed till the date of supply of the relevant information and material by the assessing officer to the assessee. After the supply of the relevant material and information to the assessee, time begins to run for the assesses to respond to the show cause notices. [Emphasis supplied.] 12. The Hon’ble Court had held that only the time surviving under the Income Tax Act read with TOLA will be available to the Revenue to complete the remaining proceedings in furtherance of such deemed notice, including issuance of notice u/s 148 of the new regime. The surviving or balance time limit was required to be calculated by computing the number of days between the date of issuance of deemed

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. notice and 30th June, 2021. The reasoning and the relevant part of the judgement of the Court is as under: 110. The effect of the creation of the legal fiction in Ashish Agarwal (supra) was that it stopped the clock of limitation with effect from the date of issuance of Section 148 notices under the old regime [which is also the date of issuance of the deemed notices]. As discussed in the preceding segments of this judgment, the period from the date of the issuance of the deemed notices till the supply of relevant information and material by the assessing officers to the assesses in terms of the directions issued by this Court in Ashish Agarwal (supra) has to be excluded from the computation of the period of limitation. Moreover, the period of two weeks granted to the assesses to reply to the show cause notices must also be excluded in terms of the third proviso to Section 149. 111. The clock started ticking for the Revenue only after it received the response of the assesses to the show causes notices. After the receipt of the reply, the assessing officer had to perform the following responsibilities: (i) consider the reply of the assessee under Section 149A(c); (ii) take a decision under Section 149A(d) based on the available material and the reply of the assessee; and (iii) issue a notice under Section 148 if it was a fit case for reassessment. Once the clock started ticking, the assessing officer was required to complete these procedures within the surviving time limit. The surviving time limit, as prescribed under the Income Tax Act read with TOLA, was available to the assessing officers to issue the reassessment notices under Section 148 of the new regime. 112. Let us take the instance of a notice issued on 1 May 2021 under the old regime for a relevant assessment year. Because of the legal fiction, the deemed show cause notices will also come into effect from 1 May 2021. After accounting for all the exclusions, the assessing officer will have sixty-one days [days between 1 May 2021 and 30 June 2021] to issue a notice under Section 148 of the new regime. This time starts ticking for the assessing officer after receiving the response of the assessee. In this instance, if the assessee submits the response on 18 June 2022, the assessing officer will have sixty one days from 18 June 2022 to issue a reassessment notice under Section 148 of the new regime. Thus, in this illustration, the time limit for issuance of a notice under Section 148 of the new regime will end on 18 August 2022. 113. In Ashish Agarwal (supra), this Court allowed the assesses to avail all the defences, including the defence of expiry of the time limit specified under Section 149(1). In the instant appeals, the reassessment notices pertain to the assessment years 2013-2014, 2014-2015, 2015-2016, 2016-2017, and 2017- 2018. To assume jurisdiction to issue notices under Section 148 with respect to the relevant assessment years, an assessing officer has to: (i) issue the

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. notices within the period prescribed under Section 149(1) of the new regime read with TOLA; and (ii) obtain the previous approval of the authority specified under Section 151. A notice issued without complying with the preconditions is invalid as it affects the jurisdiction of the assessing officer. Therefore, the reassessment notices issued under Section 148 of the new regime, which are in pursuance of the deemed notices, ought to be issued within the time limit surviving under the Income Tax Act read with TOLA. A reassessment notice issued beyond the surviving time limit will be time- barred. [Emphasis supplied.] 13. The Hon’ble Supreme Court had thus categorically held that the assessing officers were required to issue the reassessment notice under Section 148 of the new regime within the time limit surviving under the Income Tax Act read with TOLA and that all notices issued beyond the surviving period were time barred and liable to be set aside. This time line was also demonstrated in para 112 of the order with an illustration. In the present case, the original notice u/s 148 of the Act was issued on 28.06.2021 which was treated as deemed notice u/s 148A(b) of the Act. Since this notice was issued on 28.06.2021, the surviving time period available to the Assessing Officer to complete the further proceedings, including the issue of notice u/s 148 of the Act, was three days only, which was extended to seven days. Accordingly, the Assessing Officer was required to pass the order a u/s 148A(d) of the Act and also to issue notice u/s 148 of the Act in this case within a period of seven days from the date of receipt of reply of the assessee. As the assessee had filed its reply on 06.06.2022, the time limit available to the Assessing Officer to issue the notice u/s 148 of the Act was till 08.07.2022 only. As the notice in the present case was issued on 25.07.2022, the same is found to be beyond the limitation period. 14. Identical issue was decided by the Hon’ble Gujarat High Court in the case of Dhanraj Govindram Kella [2025] 177 taxmann.com 194 (Gujarat). The findings given by the Hon’ble Court on this issue are reproduced below: 65. The alternative contention of the petitioner as to whether notices would be valid notice or invalid notice considering 'surviving time' between the date of the issuance of notices under TOLA and 30th June, 2021 or not is required to be considered and for that each matter has to be considered separately on the basis of the facts of case considering the date of issuance of notices under section 148 under TOLA by the Revenue and thereafter date of supplying information to the assessee and date of passing of order under section 148A(d) and date of issuance of notice under section 148 of the Act so as to consider whether issuance of notice under section 148 of the Act is within 'surviving time' as per the direction of Hon'ble Apex Court in case of Rajeev Bansal (supra) or not. 66. So far as Assessment Years 2013-2014 and 2014-2015 are concerned, the period of three years from the end of the assessment year would be over prior

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. to 20.03.2020 and the period of six years would be over between 20.03.2020 and 30.06.2021. Therefore, the notices issued under section 148 of the Act under old regime between 01.04.2021 and 30.06.2021 as per TOLA, will be a valid notice if the notice under section 148 of the Act under new regime is issued within the period of 'surviving time' as per the directions issued by Hon'ble Apex Court in case of Rajeev Bansal (supra). For the Assessment Years 2016-2017 and 2017-2018 are concerned, the notice issued under section 148 of the Act under old regime between 01.04.2021 and 30.06.2021 under TOLA would be considered to be issued within three years from the end of the relevant assessment year as three years would complete within the period of 20.03.2020 and 30.06.2021. 67. Therefore, in facts of these petitions, following data is required to be considered to find out 'surviving time' to decide as to whether the impugned notices under section 148 of the Act issued under the new regime as per the decision of Hon'ble Apex Court in case of Ashish Agarwal (supra) would be valid notice or not in view of the decision of the Hon'ble Apex Court in case of Rajeev Bansal (supra):

SCA NO AY Date of notice No of days of Date of under section surviving time providing 148 under available information TOLA 30.06.2021 under section 148A(b)

6387/2023 2013-2014 17.06.2021 13 26.05.2022 5688/2023 2014-2015 09.06.2021 21 23.05.2022

22260/2022 2016-2017 30.06.2021 I 23.05.2022

996/2023 2017-2018 2017-2018 I 24.05.2022

SCA NO Date of order Last date for Due date of Due date of filing reply reply:- under section issuance of 148A(d) and notice under notice under section 148 as section 148:- per surviving time:-

6387/2023 29.07.2022 22.06.2022 09.06.2022 04.06.2022 5688/2023 27.07.2022 27.06.2022 06.06.2022 -

22260/2022 30.07.2022 14.06.2022 07.06.2022 06.07.2022

996/2023 19.07.2022 18.06.2022 11.06.2022 10.06.2022

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. Hon’ble Supreme Court and Hon’ble Jurisdictional High Court of Gujrat referred therein, we are inclined to hold that the impugned notice dated 24.07.2022 issued by Ld. AO u/s 148 is time-barred and therefore invalid. Consequently, the impugned assessment-order passed by Ld. AO u/s 147 does not survive and the same is hereby quashed. The legal ground raised by assessee is thus allowed.

ITA 936/SRT/2025 – AY 2013-14 - Penalty u/s 271(1)(c):

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. 20. Since we have already quashed the foundational assessment-order in earlier paras while adjudicating ITA 935/SRT/2025, the penalty u/s 271(1)(c) which is consequence to assessment-order, cannot survive. In that view of matter, the penalty-order passed by Ld. AO is also quashed.

ITA 940/SRT/2025 – AY 2016-17:

. 24. Thus, in this year also, the notice u/s 148 is time-barred. Hence, the adjudication made by us in ITA 935/SRT/2025 will apply mutatis mutandis. Accordingly, the impugned assessment-order passed by Ld. AO u/s 147 is hereby quashed. The legal ground raised by assessee is allowed.

ITA 941/SRT/2025 – AY 2017-18:

. 29. Thus, in this year also, the notice u/s 148 is time-barred. Hence, the adjudication made by us in ITA 935/SRT/2025 will apply mutatis mutandis. Accordingly, the impugned assessment-order passed by Ld. AO u/s 147 is hereby quashed. The legal ground raised by assessee is allowed.

ITA 939/SRT/2025 – AY 2015-16:

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. para 19(f) of Rajeev Bansal is re-produced below for an immediate reference:

"19. (f) The Revenue concedes that for the assessment year 2015-2016, all notices issued on or after April 1, 2021 will have to be dropped as they will not fall for completion during the period prescribed under the Taxation and other Laws (Relaxation and Amendment of Certain Provisions) Act, 2020." 34. Ld. AR for assessee submitted that following the above decision of Hon’ble Supreme Court in Rajeev Bansal, the Hon’ble Gujrat High Court has also quashed the notices issued by assessing authorities u/s 148 in (i) Mayur Kumar Babubhai Patel Vs. Assistant Commissioner of Income- tax (2025) 176 taxmann.com 25 (Gujrat) and (ii) Sorathia Mahesh Veljibhai HUF Vs. Income-tax Officer (2025) 179 taxmann.com 54 (Gujrat). The relevant paras of Sorathia Mahesh Veljibhai are re-produced below:

“8. The matter was carried to Hon'ble Supreme Court. Hon'ble Supreme Court in case of Union of India v. Rajeev Bansal [2024] 167 taxmann.com 70/301 Taxman 238/469 ITR 46 (SC) decided the issues raised with regard to delay as per the provisions of section 149 of the Act which has come into operation after 01.04.2021 as well as validity of sanction granted under section 155 of the Act. 9. During the course of hearing before the Hon'ble Apex Court, Revenue conceded to the effect that so far as Assessment Year 2015-2016 is concerned, Revenue could not have issued the notices under section 3(1) of TOLA as considering the time period as prescribed under section 149 of the Act with effect from 01.04.2021, three years would be over on 31.03.2019 which is prior to coming into force of TOLA and six years would be completed on 31.03.2022 which is after operation of TOLA. In such circumstances, notices for Assessment Year 2015- 2016 are held to be invalid by Hon'ble Apex Court in case of Rajeev Bansal (supra). 10. The Hon'ble Apex Court followed the decision of Rajeev Bansal(supra) in case of Deepak Steel and Power Ltd v. Central Board of Direct Taxes [2025] 174 taxmann.com 144/305 Taxman 169/476 ITR 369 (SC) and after recording the concession of the learned advocate for the department and in view of the concession given before the Apex Court by learned advocate appearing for the Revenue as recorded in para 19(f) of the judgment in case of Rajeev Bansal (supra), has quashed and set aside the notice issued after 31.03.2021 under TOLA for A.Y. 2015-16 as under: "1. Leave granted.

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. 2. These appeals arise from the order passed by the High Court of Orissa at Cuttack in Writ Petition (C) Nos. 2446 of 2023, 2543 of 2023 dated 1.2.2023 and 2544 of 2023 dated 10.02.2023 respectively by which the High Court disposed of the original writ petitions in the following terms:- "1. The memo of appearance filed by Mr. S. S. Mohapatra, learned Senior Standing Counsel for Revenue Department on behalf of Opposite Parties is taken on record. 2. In view of the order passed by this Court on 1st December, 2022 in a batch of writ petitions of which W.P.(C) No.9191 of 2022 (Kailash Kedia v. Income Tax Officer) was a lead matter and the subsequent order dated 10th January, 2023 passed in W.P.(C) No.36314 of 2022 (Shiv Mettalicks Pvt. Ltd., Rourkela v. Principal Commissioner of Income Tax, Sambalpur), the Court declines to entertain the present writ petition, but leaves it open to the Petitioner to raise all grounds available to the Petitioner in accordance with law including the grounds urged in the present petition at the appropriate stage as explained by the Court in those orders. 3. The writ petition is disposed of in the above terms." 3. We heard Mr. Saswat Kumar Acharya, the learned counsel appearing for the appellants(assessee) and Mr. Chandrashekhar, the learned counsel appearing for the revenue. 4. The learned counsel appearing for the revenue with his usual fairness invited the attention of this Court to a three judge bench decision of this Court in Union of India and Ors. v. Rajeev Bansal, reported in 2024 SCC OnLine SC 2693, more particularly, paragraph 19(f) which reads thus:- "19. (f) The Revenue concedes that for the assessment year 2015- 2016, all notices issued on or after April 1, 2021 will have to be dropped as they will not fall for completion during the period prescribed under the Taxation and other Laws (Relaxation and Amendment of Certain Provisions) Act, 2020." 5. As the revenue made a concession in the aforesaid decision that is for the assessment year 2015-2016, all notices issued on or after 1st April, 2021 will have to be dropped as they would not fall for completion during the period prescribed under the taxation and other laws (Relaxation and Amendment of certain Provisions Act, 2020). Nothing further is required to be adjudicated in this matter as the notices so far as the present litigation is concerned is dated 25.6.2021. 6. In view of the aforesaid, in such circumstances referred to above the original writ petition nos.2446 of 2023, 2543 of 2023 and 2544 of 2023 respectively filed before the High Court of Orissa at Cuttack stands allowed. 7. The impugned notice therein stands quashed and set aside. 8. The relief in terms of prayer (a) is granted. 9. The appeals stand disposed of in the above terms. 10. Pending application(s), if any, stand disposed of." 11. Similar orders are also passed by the Apex Court in the following cases: 1) Asstt. CIT v. Nehal Ashit Shah [Special Leave Petition (Civil) Diary No. 57209

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. OF 2024, dated 4-4-2025]; 2) ITO v. R.K.Build Creations (P.) Limited [SLP (Civil) Diary No. 59625 OF 2024, DATED 17-1-2025]. 12. The Delhi High Court has also passed the similar order in following cases: 1) Bhagwan Sahai Sharma v. Dy. CIT [2025] 174 taxmann.com 14 (Delhi) 2) Lalit Gulati v. Asstt. CIT [2025] 174 taxmann.com 273/305 Taxman 11 (Delhi); 13. The Punjab and Haryana High Court has taken similar decision in case of Jay Jay Agro Industries v. ITO [CWP No. 7405 of 2025, dated 19-3-2025] 14. Rajasthan High Court has also taken similar decision in case of Shreyansh Mehta v. ITO [Civil Writ Petition No. 3299 of 2023, dated 12-2-2025]. 15. Karnataka High Court has also taken similar decision in case of Siddaiah Gurappaji v. Asstt. CIT [Writ Petition No. 20292 of 2023, dated 17-4-2025]. 16. This Court also in case of Mayurkumar Babubhai Patel v. Asstt. CIT [2025] 176 taxmann.com 25 (Gujarat)/Special Civil Application No.3154 of 2022 and allied matters) has held as under: "15. Considering the facts of the case, it is not in dispute that the respondent-Assessing Officer has issued the notice under section 148A(b) of the Act after the period of six years were over on 31.03.2022. As observed by the Hon'ble Apex Court in case of Deepak Steel and Power Ltd(supra) and in view of the concession made by the Revenue before the Apex Court for the Assessment Year 2015-16, all the notices issued on or after 01.04.2021 will have to be dropped as they would not fall for completion during the period prescribed under the Taxation and Other Laws (Relaxation and Amendment of Certain Provisions) Act, 2020 and therefore, nothing further is required to be adjudicated in the matters as the notice so far as the present petitions are concerned, though dated 31.03.2021, admittedly have been issued after 01.04.2021. 16. It is also not in dispute that the notices under section 148A(b) have been issued pursuant to the decision of the Hon'ble Apex Court in Ashish Agarwal (supra) dated 04.05.2022 admittedly after 31.03.2022. Therefore, on both counts, the notices issued under section 148 of the Act dated 27/28/29.07.2022 would be time barred." 17. In view of above, for the foregoing reasons, the petition is allowed. The impugned notice issued under section 148 of the Act for Assessment Year 2015-2016 is held to be invalid as same was issued during the extended period from 01.04.2021 to 30.06.2021 under TOLA. 18. Petition is accordingly disposed off.” 35. Thus, we find that the issue is no longer res integra. The Hon'ble Supreme Court in Rajeev Bansal (supra) has recorded the Revenue's concession in para 19(f) that all notices issued on or after 01.04.2021 for AY 2015-16 are liable to be dropped. Further, the Hon'ble Gujarat High Court in Mayurkumar Babubhai Patel (supra) and Sorathia Mahesh Veljibhai

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. HUF (supra), following Rajeev Bansal and Deepak Steel & Power Ltd., has held that notices issued after 01.04.2021 for AY 2015-16 are barred by limitation. Admittedly, in the present case, the original notice u/s 148 was issued on 18.06.2021 and the consequential notice after the decision in Ashish Agarwal was issued on 26.07.2022. Therefore, respectfully following the aforesaid binding precedents, we hold that the impugned re- assessment proceedings are barred by limitation and without jurisdiction. Accordingly, the impugned assessment-order passed by Ld. AO u/s 147 is hereby quashed. The legal ground raised by assessee is allowed.

Order pronounced in open court on 30/06/2026

Sd/- Sd/- (SUCHITRA KAMBLE) (B.M. BIYANI) JUDICIAL MEMBER ACCOUNTANT MEMBER Surat िदनांक /Dated : 30/06/2026 *Kishore, Sr. PS Copies to: (1) The appellant (2) The respondent (3) CIT (4) CIT(A) (5) Departmental Representative (6) Guard File By order

UE COPYAssistant Registrar/Sr. PS Income Tax Appellate Tribunal Surat Bench, Surat

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