AMOL SURESH SINKAR,PUNE vs. ITO WARD 1(2) JALGAON, JALGAON

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ITA 3146/PUN/2025Status: DisposedITAT Pune26 May 2026AY 2019-2015 pages
AI SummaryAllowed

What did the Tribunal hold?

The Tribunal held that the penalty notice issued by the AO did not specify the exact limb of Section 270A(9) under which the penalty was levied. Following previous judgments, the Tribunal found the penalty not in accordance with law.

What were the facts?

The assessee claimed a deduction of Rs. 2 lakhs under Section 80G/80GGC. The Assessing Officer (AO) reopened the assessment and initiated penalty proceedings under Section 270A for under-reporting of income due to mis-reporting of Rs. 2 lakhs. The AO imposed a penalty of Rs. 83,200.

What were the issues?

Whether the penalty levied under Section 270A is valid when the penalty notice fails to specify the exact clause of Section 270A(9) under which the penalty is imposed.

Which sections of the Income-tax Act were involved?

Section 270A,Section 80G,Section 80GGC

AI-generated summary — verify with the full judgment below

Income Tax Appellate Tribunal, PUNE BENCH “A”, PUNE

Before: SHRI R. K. PANDA & Ms. ASTHA CHANDRA

For Appellant: Shri Vinay Kawadia (virtually)
For Respondent: Shri Madhan Thirmanpalli, Addl. CIT

PER ASTHA CHANDRA, JM:

This appeal filed by the assessee is directed against the order dated 10.11.2025 of the Ld. CIT(A) / NFAC, Delhi relating to assessment year 2019-20. 2. Facts of the case, in brief, are that the assessee is an individual. For assessment year 2019-20 the assessee filed his return of income on 19.07.2019 declaring total income of Rs.5,68,450/- after claiming deduction of Rs.4,49,484/- including therein Rs.2 lakhs u/s 80G/80GGC of the Income Tax Act, 1961 (hereinafter referred to as ‘the Act’). The assessee subsequently revised his return of income on 07.09.2019 declaring total income of Rs.5,17,990/- after claiming deduction of Rs.4,49,484/- u/s 80G / 80GGC of the Act. The Ld. Assessing

2 Officer (“AO") after recording reasons reopened the assessment as per the provisions of section 147 of the Act and accordingly issued a notice u/s 148 of the Act on 10.04.2023 in response to which the assessee filed his return of income on 10.05.2023 declaring total income of Rs.7,39,080/-. The assessment was completed u/s 147 r.w.s. 144B of the Act on 13.12.2024 determining the total income of the assessee at Rs.7,39,080/-. The penalty proceedings u/s 270A(9) of the Act were initiated against the assessee on account of under-reporting of income as a consequence of mis-reporting of Rs.2 lakhs. Notice u/s 270A of the Act was issued to the assessee on 13.12.2024 followed by a show cause notice issued on 26.03.2025. The assessee filed his replies to the said notices which is taken on record in para 3 of the assessment order by the Ld. AO. However, the Ld. AO did not find the reply of the assessee acceptable and proceeded to complete the penalty proceedings u/s 270A of the Act on account of under-reporting of income as a consequence of mis-reporting amounting to Rs.2 lakhs and imposed penalty of Rs.83,200/- (@ 200% of tax of the amount payable on under-reporting income of the assessee for assessment year 2019-20 as per the provisions of section 270A(9) of the Act).

3.

On appeal before the Ld. CIT(A) / NFAC, the assessee raised various contentions challenging the penalty imposed by the Ld. AO which are reproduced in para 3 of the impugned order of the Ld. CIT(A) / NFAC. Before the Ld. CIT(A)/ NFAC the assessee inter-alia¸ raised a contention that the impugned penalty order is unsustainable in law as the Ld. AO did not specify the exact clause

3 of section 270A(9) of the Act under which the impugned penalty is imposed. The Ld. CIT(A) / NFAC however, did not consider this contention and rejecting the various contentions raised by the assessee, the Ld. CIT(A) / NFAC dismissed the appeal of the assessee by observing as under:

4.

Aggrieved with such order of the Ld. CIT(A) / NFAC, the assessee is in appeal before the Tribunal by raising the following grounds: 1) On the facts and in the circumstance of the case and in law, exact nature of under reporting as contemplated under S. 270A(2) or mis-reporting u/s 270A(9) of the Act was not specified either in the assessment order or notice issued u/s 270A of the Act on 13.12. 24. Accordingly, the penalty

4 order passed u/s 270A on the basis of vague/invalid penalty notice u/s 270A dt. 13.12.2024 is bad in law and therefore liable to be quashed. 2) On the facts and in the circumstance of the case and in law, the Id. AO has grossly erred in levying penalty of Rs.83,200/- for alleged misreporting of income without specifying exact nature of under reporting as contemplated under S.270A(2) or mis reporting u/s 270A(9) of the Act. Accordingly, penalty order passed without specifying the exact limb of section 270A(2)/ 270A(9) which has been allegedly violated by the assessee is liable to be quashed. 3) On the facts and in the circumstance of the case and in law, the CIT(A), NFAC has erred in confirming the penalty of Rs.83,200/- levied u/s 270A(9) of the Act for the alleged underreporting/ misreporting of income u/s 270A without considering the bona fide explanation of the assessee within the meaning of S. 270A(6)(a) of the Act. 4) The appellant craves the permission to add, amend, modify, alter, revise, substitute, delete any or all grounds of appeal, if deemed necessary at the time of hearing of the appeal.

5.

The Ld. Counsel for the assessee, referring to the penalty notice placed at page 17 of the paper book, issued by the Ld. AO submitted that the notice itself is invalid as it has not specified the relevant limb under sub-clause (9) of section 270A of the Act. Relying on the following decisions of the Coordinate Bench of the Tribunal, the Ld. Counsel for the assessee submitted that since the Ld. AO has not mentioned under which clause of section 270A of the Act the impugned penalty has been levied and it is not levied in accordance with law and hence, liable to be deleted: taxmann.com 133 (Pune-Trib.) iii) Tejas Shivaji Adsul vs. ITO vide ITA No.59/PUN/2025, order dated 30.10.2025 iv) Mustafa Alihusain Sunelwala vs. ITO vide ITA No.1396/PUN/2025 order dated 16.02.2026

5

6.

The Ld. DR on the other hand supported the orders of the Ld. AO and the Ld. CIT(A) / NFAC.

7.

We have heard the representatives of the parties and perused the material available on record as well as paper book filed by the Ld. AR on behalf of the assessee and the judicial precedents cited before us. It is a matter of fact that the penalty notice issued by the Ld. AO (reproduced below) does not mention which limb of section 270A(9) of the Act is attracted.

6

8.

If that be so, the decisions (supra) cited by the Ld. AR squarely apply to the facts of the assessee’s case in hand.

9.

We find that the Co-ordinate Bench of the Pune Tribunal in the case of Chakradhar Contractors and Engineers P. Ltd. (supra) in turn relying on the decision of the Hon’ble Delhi High Court in the case of Schneider Electric Sought taxmann.com 665 (Delhi) and several other decisions of the Pune Tribunal has dismissed the appeal of the Revenue observing that where neither in the assessment order nor in the notice issued u/sec.274 r.w.s.270A the Assessing Officer has specified as to under which limb of provisions of sec.270A(2) or 270A(9) the case of the assessee falls, then in that case, no penalty u/sec.270A is leviable. The relevant observation and findings of the Tribunal is reproduced below :

“7. We have heard the rival arguments made by both the sides and perused the material available on record. We have also considered the various decisions cited before us by both the sides. We find the Assessing Officer in the instant case completed the assessment u/sec.143(3) determining the total income of the assessee at Rs.32,18,44,630/- as against the returned income of Rs.23,83,97,010/-, wherein he made an addition of Rs.8,33,51,448/- to the income determined u/sec.143(1)(a) by making addition of the difference between the profit estimated @ 10% and the profit declared by the assessee @ 7.37% of the total turnover. Since the Assessing Officer, neither in the assessment order nor in the penalty notice, has specified as to whether penalty is proposed for any of the conditions mentioned in sec.270A(2)(a) to 270A(2)(g) by virtue of which the income of assessee is held as underreported or in sec.270A(9)(a) to sec.270A(9)(f) by virtue of which the assessee has mis-reported it’s income, the Ld. CIT(A) deleted the penalty. The detailed reasoning given by him has already been reproduced in the preceding paragraphs.

7.1.

We do not find any infirmity in the order of the Ld. CIT(A) in deleting the penalty so levied by the Assessing Officer. It is an admitted fact that the Assessing Officer in the assessment order has not specified as to under which limb of provisions of sec.270A(2) or 270A(9), the assessee has misreported or under-reported it’s income, we find the Assessing Officer in 7 the body of the assessment order has mentioned as under after making the addition : “In light of the above, the amount of Rs.8,33,51,480/- is added to the total income of the assessee company for A.Y. 2020-21. Penalty proceedings u/s 270A of the Income Tax Act, 1961 is initiated separately for underreporting in consequence of mis- reporting of income.”

7.1.

Similarly, we find the notice issued u/sec.274 r.w.s.270A dated 30.09.20222, copy of which, is placed at page-12 of the paper book, reads as under :

7.2.

Similarly, the second notice issued u/sec.270A dated 05.01.2023 reads as under :

7.3.

We find the Hon’ble Delhi High Court in the case of Schneider Electric South East Asia (HQ) PTE Ltd. v. ACIT reported in (2022) 443 ITR 186 (Del) has held that when there is not even a whisper as to which limb of 8 sec.270A is attracted and how the ingredient of sub-sec.(9) of sec.270A is satisfied, the action of the Assessing Officer is contrary to the legislative intent. The relevant observations of Hon’ble High Court reads as under :

“6. Having perused the impugned order dt. 9th March, 2022, this Court is of the view that the respondents' action of denying the benefit of immunity on the ground that the penalty was initiated under s.270A of the Act for misreporting of income is not only erroneous but also arbitrary and bereft of any reason as in the penalty notice the respondents have failed to specify the limb "underreporting" or "misreporting" of income, under which the penalty proceedings had been initiated.

7.

This Court also finds that there is not even a whisper as to which limb of s.270A of the Act is attracted and how the ingredient of sub- s.(9) of s.270A is satisfied, In the absence of such particulars, the mere reference to the word "misreporting" by the respondents in the assessment order to deny immunity from imposition of penalty and prosecution makes the impugned order manifestly arbitrary.”

7.4.

We find the Coordinate Bench of the Tribunal in the case of ACIT v. Kedari Redekar Shikshan Sanstha in ITA No.559/PUNE/2024] vide order dated 05.07.2024 while deciding an identical issue deleting the penalty levied u/sec.270A has observed as under :

“9. We have carefully considered the rival submissions and perused the records. The assessee is a charitable trust registered u/s 12A of the Act and engaged in educational activities whose income is exempt from tax. It is manifest from para 4 of the assessment order that on perusal of Schedule EC of the ITR, the Ld. AO noticed that the assessee had claimed capital expenditure of Rs.2,40,02,040/-. Vide notice u/s 142(1) of the Act he required the assessee to furnish headwise and naturewise bifurcation of said capital expenditure. It was in reply thereof that the assessee submitted revised computation showing capital expenditure of Rs.97,47,772/- for which explanation was submitted. On consideration of such explanation, the Ld. AO observed in para 4.5 of the assessment order that the assessee has obtained fresh loans of Rs.1,42,54,268/- from bank during AY 2018-19. Accordingly, since the assessee has pleaded that fresh loan has been obtained for capital expenditure on assets which has been claimed as capital expenditure in the ITR and now assessee submits request to reduce its claim of capital expenditure for the assets on which loan has been taken in next years. According to the Ld. AO, the plea of the assessee is found acceptable. Not only this the Ld. AO went on to observe further that in this way, the assessee had saved itself from the double deduction on same capital assets on which loan is availed in coming years whose repayment may have been claimed by the assessee in subsequent AYs. It was in the above backdrop of the factual matrix that the Ld. AO disallowed the excess claim of capital expenditure of Rs.1,42,54,268/-. In our considered view there is no intentional misrepresentation of expenditure as alleged. By no stretch of imagination it can be said to be a case of attempted tax evasion as even after revision of computation, the taxable income remained Nil which is same as returned income of the assessee. In the assessment order there is no whisper that there is under-

9 reporting on total income as a consequence to misreporting as envisaged u/s 270A(8) and (9) of the Act.

10.

None-the-less the notice dated 27.12.2019 u/s 274 r.w.s. 270A of the Act states : "it appears to me under-reporting/misreporting of income". Obviously, the initiation of penalty itself is based on suspicion and surmise. Nowhere it has been pinpointed - either in the penalty notice or in the impugned order of penalty as to under which stipulated specific clauses (a) to (f) to subsection (9) r.w. sub- section (8) of section 270A of the Act, the assessee has committed default attracting "underreporting" as a consequence of "mis- reporting". In such a scenario the Co-ordinate Bench of the Tribunal in the case of Mahavir Realties (supra) held that not only Hon'ble Bombay High Court's Full Bench landmark decision in Mohd. Farhan A. Shaikh Vs. ACIT (2021) 434 ITR 1 (Bom.) applies wherein it is held that such a failure on the Assessing Officer's part indeed vitiates the entire penal proceedings (in old scheme), but also the very principle applies qua this new scheme of section 270A applicable w.e.f. 01.04.2017 for AY 2017-18 onwards as per

13.

In the result, the appeal of the Revenue is dismissed.”

7.5.

We find the Pune Bench of the Tribunal in the case of Kasat Prakash M. HUF vs. ITO in ITA No.1328/PUNE/2023 vide order dated 19.06.2024 while deciding an identical issue deleting penalty levied u/sec.270A has observed as under :

“4. We have given our thoughtful consideration to the assessee's forgoing legal issue raised in the instant appeal that the impugned penalty proceedings stand vitiated on account of the Assessing Officer's failure to pinpoint the relevant clauses (a) to (f) to sub- section (9); while initiating the proceedings herein u/s.270A(8) of the Act, thereby alleging under reporting of income as a sequence of misreporting. Faced with this situation, we find no merit in Revenue's arguments placing reliance on M/s. Veena Estate Pvt. Ltd. (supra) once the issue before their lordships was that of the concerned appellant seeking to frame an additional substantial question of law in section 260A proceedings whereas the law regarding the tribunal's juri iction to entertain such a pure question of law, not requiring any further detailed investigation on facts, is already settled in NTPC Ltd. Vs. CIT (1998) 229 ITR 383 (SC). That being the case, we are of the considered view that going by the 10 foregoing judicial precedent, this tribunal is very much entitled to entertain and decide such a pure legal plea for the first time in section 254(1) proceedings. We accordingly reject the Revenue's instant technical arguments to conclude in light of section 270A (8) & (9) r.w. clauses (a to f) that the learned Assessing Officer's failure to pinpoint the corresponding default of assessee's part indeed vitiates the entire proceedings as per (2022) 443 ITR 186 (Del) Schneider 15,54,736/- stands deleted in very terms.

5.

This assessee's appeal is allowed.”

7.6.

The various other decisions relied on by the Learned Counsel for the Assessee also supports his case to the proposition that where neither in the assessment order nor in the notice issued u/sec.274 r.w.s.270A the Assessing Officer has specified as to under which limb of provisions of sec.270A(2) or 270A(9) the case of the assessee falls, then in that case, no penalty u/sec.270A is leviable. We, therefore, uphold the order of the Ld. CIT(A) and the grounds raised by the Revenue are dismissed.”

10.

Similar view has been taken by the Co-ordinate Bench of the Tribunal in the case of Tejas Shivaji Adsul vs. ITO (supra) wherein it has been held as under :

“11. Before us by way of an additional ground the Ld. AR has submitted that in the notice u/s 274 r.w.s 270A of the Act, the exact limb of section 270A(9) has not been specified and hence the penalty order passed u/s 270A in consequence of such notice becomes null and void in law.

12.

We find some force in above contention of the Ld. Counsel for the assessee. We have perused the order of the Co-ordinate Bench of this Tribunal in the case of Smita Virendra Lodha (Supra) and find that under the identical set of facts, the Tribunal relying on the case of Kishor Digambar Patil Vs. ITO (ITA No. 54 & 55/PUN/2023 dated 30.03.2023) deleted the penalty levied u/s 270A of the Act on account of non mentioning of any of the specified limbs u/s 270A(9) of the Act. The relevant findings and observations of the Tribunal in the case of Smita Virendra Lodha as under:-

10.

We have heard the rival arguments made by both the sides and perused the orders of the Assessing Officer and Ld. CIT(A)/NFAC. We find the Assessing Officer completed the assessment u/s 147 2.w.s. 1448 of the Act on a total income of Rs.18,74,800/- which was the income returned by the assessee in response to the notice u/s 148 of the Act. We find the Assessing Officer levied the penalty of Rs.6,37.912/- u/s 270A of the Act on account of under-reporting of income in consequence of mis- reporting. We find the Ld. CIT(A)/NFAC upheld the action of the Assessing Officer, the reasons of which have already been reproduced in the preceding paragraphs. It is the submission of the 11 Ld. Counsel for the assessee that the penalty notice issued by the Assessing Officer is silent about the clause under which the assessee has under-reported or mis-reported the income.

11.

We find some force in the above arguments of the Ld. Counsel for the assessee. We find the Co-ordinate Bench of the Tribunal in the case of Kishor Digambar Patil vs. ITO (supra) while deciding an identical issue has quashed the penalty levied u/s 270A for failure of the Assessing Officer in quoting any of the six limbs as mentioned in section 270A(9) of the Act. The relevant observations of the Tribunal from para 4 onwards read as under:

"

4.

Both the learned representatives vehemently reiterated their respective stands against and in support of the impugned penalties. The assessee more particularly argued that both the learned lower authorities have erred in law and on facts in imposing sec.270A penalties in issue without even specifying the relevant limb under sub-section (9) thereof pertaining to "misreporting of income". Learned counsel quoted the erstwhile earlier penalty mechanism provided u/sec.271(1)(c) of the Act wherein the law stood duly settled in light of Mohd. Farhan A Shaikh vs. ACIT [2021] 434 ITR 1 (Bom.) (FB); CIT vs. M/s. SSA's Emerald Meadows [2016] 386 Factory (2013) 359 ITR 565 (Kar) (HC) that an assessing authority has to specify the corresponding limb in the show cause notice to be issued u/sec.274 of the Act. Learned counsel's case is that the legal position would hardly be any different wherein the ature has now prescribed clauses (a) to (f) in sec.270A (9) of the Act only to "rationalise and bring objectives, certainty and clarity in the penalty previsions as per the CBDT's circular no.3/2017 [F.No.370142/20/2016 TPL]. Mr. Sonawane strongly argued in tune thereof that the very line of reasoning is required to be adopted herein as well whilst dealing with penalty proceedings under this new scheme of u/s.270A introduced by the legislature by the Finance Act, 2016 w.e.f. 01.04.2017

5.

Mr. Murkunde on the other hand strongly supported the learned lower authorities action imposing the impugned penalties. He took us to the Assessing Officer's corresponding assessments, penalty orders as well as the lower appellate discussion extracted in the preceding paragraphs that the rigor of sub-section (9) stands duly complied with once it has been categorically concluded that this is a fit case to impose penalty u/sec.270A of the Act for "under reporting which is in consequence of misreporting of income". His further contention is that such a penalty @ 200% is levied u/sec. 2700(8) of the Act reading as under: Sec.270A(8)-Notwithstanding anything contained in subsection (6) or sub-section (7), where under-reported income

12 is in consequence of any misreporting thereof by any person, the penalty referred to in sub-section (1) shall be equal to two hundred per cent of the amount of tax payable on underreported income."

5.1.

Mr. Murkunde lastly sought to buttress the point that section 270A(8) nowhere makes it mandatory to include any of the clause "(a) to (f)" provided in sub-section (9) thereof. He further submitted that various judicial precedents quoted at the assessee's behest in the preceding paragraphs are no more applicable once the legislature has amended the penalty provision. i.e., sec.271 itself.

6.

I have given my thoughtful consideration to the vehement rival stands and find no merit in the Revenue's arguments. It is made clear that the assessee's case law indeed relates to the earlier penalty provision ie, sec.271(1)(c) of the Act only wherein various hon'ble higher judicial forums had settled the law that the Assessing Officer ought to specify as to whether the concerned taxpayer had concealed or furnished inaccurate particulars of his taxable income during the course of assessment. I am of the view that the very line of judicial precedents would squarely apply even for the amended penalty provision i.e., sec.270A of the Act as well wherein the legislature has not only prescribed twin limbs of "under reporting of income as well as misreporting of income", but also, unlike the earlier provision u/sec.271, this time it has stipulated specific deeming illustrations under both the twin foregoing heads of the "under reported income" and "misreporting of income" in sub-sections (2) and (9) (a to f) respectively. In my considered opinion, once the instant twin appeals involve levy of penalty @ 200% of the taxes sought to be evaded and the learned lower authorities have held the assessee to have "under-reported his taxable income in consequence to misreporting", the latter limb of misreporting containing six "sub- limbs" in clauses (a to f) under sub-section- (9) deserve to be read as an extension of sub- section (8) to section 270A only. This indeed seems to be the only possible view as the legislature has incorporated the non-obstante clause "Notwithstanding anything contained in sub-sec (6) or sub-sec(7)" thereby not including the sub- section (9) envisaging the Instances defining "misreporting of income” in section 270A of the Act.

6.1.

Mr. Murkunde could further not dispute the fact that right from the Assessing Officer's twin assessments to his Impugned penalty orders as well the NFAC detailed discussion, the learned lower authorities have nowhere specified the corresponding "sub-limbs" (a to D in sub-sec.(9) of sec.270 of the Act. That being it explicitly clear that these six clauses (a to f) would indeed form part of sub-section (supra) making (8) to sec.270A as under: "62.10 The rate of penalty shall be fifty per cent of the tax payable on under-reported income. However in a case where under reporting of income results from misreporting of income by the assessee, the person shall be liable for penalty at the 13 rate of two hundred per cent of the tax payable on such misreported income. The cases of misreporting of income have been specified as under: (i) misrepresentation or suppression of facts; (ii) non-recording of investments in books of account: (iii) claiming of expenditure not substantiated by evidence; (iv) recording of false entry in books of account; (v) failure to record any receipt in books of account having a on total income; (vi) failure to report any international transaction or deemed international transaction under Chapter X of the Income tax Act."

6.2.

Faced with the situation and in light of overwhelming material strongly supporting the assessee's case and going by stricter interpretation as per Commissioner of Customs (Imports), Mumbai vs. Dilipkumar And Co. & Ors. 2018 (9) SCC 1 (SC) (FB), I am of the view that the above stated judicial precedents regarding the "limb theory" would squarely apply even in case of failure of the Assessing Officer to quote any of the six sub-limbs as well prescribed in sec.270A(9) (a) to (f) of the Act introduced by the legislature in order to rationalize and bring objectivity, certainty and clarity in the penalty provisions". And that his noncompliance to this clinching effect would not only defeat the legislative mandate but also it renders the amending provisions an otiose. I accordingly hold in these peculiar facts and circumstances that both the impugned penalties deserve to be quashed as not sustainable in the eye of law. Ordered accordingly.

12.

Since the Assessing Officer in the instant case has admittedly not mentioned as to under which limb of sub-section (9) of section 270A he has levied the penalty, therefore, respectfully following the decision of the Co-ordinate Bench of the Tribunal in the case of Kishor Digambar Patil vs. ITO (supra), we hold that the penalty so levied by the Assessing Officer u/s 270A is not in accordance with law. We, therefore, set aside the order of the Ld. CITTA)/NFAC and direct the Assessing Officer to delete the penalty. The grounds raised by the assessee are accordingly allowed.

13.

In light of the facts of the case and legal position enumerated above and respectfully following the decision of the co-ordinate bench of the Tribunal in the case of Smita Virendra Lodha (supra), we hold that the penalty of Rs. 19,14,842/- imposed u/s 270A of the Act is not sustainable in law for the reason that the penalty notice issued by the Ld. AO is silent

14 on the relevant clause of sub-section 9 of section 270A of the Act under which the assessee has under reported/mis-reported his income. We, therefore, set aside the order of the Ld. CIT(A)/NFAC and direct the AO to delete the impugned penalty. We hold and direct accordingly. The additional grounds raised by the assessee are accordingly allowed. Since we have decided the additional grounds in favour of the assessee, the other grounds raised by the assessee become academic in nature requiring no adjudication.”

11.

The case of the assessee also finds support from the decision of the Coordinate Bench of the Tribunal in the case of Mustafa Alihusain Sunelwala (supra).

12.

On the aforesaid facts and in the circumstances of the case and following the decisions (supra) of the Co-ordinate Bench of the Tribunal, we hold that the impugned penalty is not exigible which we hereby vacate. The effective grounds raised by the assessee are accordingly allowed.

13.

In the result, the appeal of the assessee is allowed.

Order pronounced in the open Court on 26th May, 2026. (R. K. PANDA) JUDICIAL MEMBER पुणे Pune; दिन ांक Dated : 26th May, 2026 GCVSR Gajjala Chinna Chinna Venkata Subba Venkata Subba Reddy Date: 2026.05.26 18:16:50 Reddy +05'30'

15 आदेश की प्रतितिति अग्रेतिि/Copy of the Order is forwarded to: अपील र्थी / The Appellant; 1. 2. प्रत्यर्थी / The Respondent

3.

The concerned Pr.CIT, Pune

4.

DR, ITAT, ‘A’ Bench, Pune 5. ग र्ड फ ईल / Guard file. आदेशानुसार/ BY ORDER, ////

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