SWISS RE ASIA PTE LTD,MUMBAI vs. DEPUTY COMMISSIONER OF INCOME TAX, (INTERNATIONAL TAXATION) CIRCLE - 4(2)(2), MUMBAI

IN THE INCOME TAX APPELLATE TRIBUNAL “I” BENCH MUMBAI BEFORE HON’BLE SHRI SANDEEP GOSAIN, JUDICIAL MEMBER & HON’BLE SHRI PRABHASH SHANKAR, ACCOUNTANT MEMBER ITA No. 8808/Mum/2025 (Assessment Year: 2023-24)

Swiss Re Asia Pte Ltd Vs. Deputy Commissioner C/O Ernst and Young LLP, of Income Tax, 14th Floor, The Ruby, 29, (International Taxation) Senapati Bapat Marg, Dadar Circle – 4 (2)(2) (West), Room No. 627, 6th Mumbai- 400028 Floor, Kautilya Bhavan, C-41 to C-43, G Block, BKC Bandra (E), Mumbai - 400051 PAN/GIR No. AAXCS8364P (Applicant) (Respondent) Assessee by Shri Nikhil Tiwari Revenue by Shri Krishna Kumar (SR. DR) Date of Hearing 18.02.2026 Date of Pronouncement 27.04.2026 आदेश / ORDER PER SANDEEP GOSAIN, JM: The present appeal has been filed by the assessee challenging the impugned order 29.09.2025 passed u/s 144C (5) of the Income Tax Act, 1961 (‘the Act’), by the Income Tax Department CIT(DRP-2), for the assessment year 2023-24. The following grounds are reproduced below: “1. Ground 1

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The learned AO erred in law by not passing the Final Assessment Order within the time limit prescribed under section 153 of the Act which is the outer time limit for passing the final assessment order and hence, the Final Assessment Order dated 16 October 2025 which is passed after 31 March 2025 (being the time limit as per the provisions of Section 153 of the Act) is time barred and liable to be quashed. 2. Ground 2 The learned AO has, on the facts and circumstances of the case and in law, and based on the directions of the Hon'ble DRP, erred in assessing the total income of the Appellant at INR 3,630,845,439, as against INR 72,705,000 reported by the Appellant in its return of income. 3. Ground 3 The learned AO has, on the facts and circumstances of the case and in law, erred in holding that in relation to the reinsurance premium amounting to INR 2,656,778,753 earned by the Appellant from its Indian cedents, the Appellant has a business connection in India as per the provisions of section 9(1)(i) of the Act and a Permanent Establishment (PE) in India as per Article 5 of the India-Singapore tax treaty (IS treaty). 4. Ground 4 The learned AO has, on the facts and circumstances of the case and in law, erred in holding that the Appellant has a business connection in India as per the provisions of section 9(1)(i) of the Act and PE in India as per Article 5 of the IS treaty in relation to the retrocession premium amounting to INR 27,736,675,707 earned by the Appellant from Swiss Reinsurance Company Ltd, India Branch (SRIB). 5. Ground 5 Without prejudice to Grounds of appeal No. 3 and 4, the learned AO has, on the facts and circumstances of the case and in law, and based on the directions of the Hon'ble DRP, erred in determining the amount of INR 2,647,094,763 as profits attributable to the alleged PE of the Appellant. 6. Ground 6 Without prejudice to Grounds of appeal No 3, 4 and 5, the learned AO has, on the facts and circumstances of the case and in law, and based on the directions of the Hon'ble DRP,

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erred in adopting inappropriate and unjust mechanism while determining the profits attributable to the alleged PE of the Appellant 7. Ground 7 The learned AO has, on the facts and circumstances of the case and in law, erred in holding that the income earned by the Appellant from rendering of various support services to SRIB amounting to INR 527,205,180 and to Swiss Reinsurance Global Business Solutions India Private Limited (SRGBS) amounting to INR 383,840.496 which aggregates to INR 911,045,676, are taxable in India as Fees for Technical Services (FTS) under Article 12 of the IS treaty. 8. Ground 8 Without prejudice to Ground 7, the learned AO has, on the facts and circumstances of the case and in law, erred in taxing the income from FTS amounting to INR 911,045,676, at the rate of 10.92 percent which leads to erroneous levy of surcharge and health and education cess on the FTS income instead of restricting the tax rate to 10 percent as per Article 12 of the IS treaty. 9. Ground 9 The learned AO has, on the facts and circumstances of the case and in law, erred in granting short credit of Taxes deducted at Source (TDS) amounting to INR 99,421. 10. Ground 10 The learned AO has, on the facts and circumstances of the case and in law, erred in levying consequential interest under section 234B of the Act. 11. Ground 11 Without prejudice to ground number 10 above, the learned AO erred in considering 'total interest and fee payable of INR 111,682,195 at sr no. 42 of the Computation Sheet to the Assessment Order while interest levied under section 2348 of the Act is only INR 6,799,199. 12. Ground 12 The learned AO erred in initiating penalty proceedings under section 270A of the Act for under-reporting and misreporting of income for the captioned Assessment Year.

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The Appellant craves leave to add, alter, vary, omit, substitute or amend any or all of the above grounds of appeal, at any time before or at, the time of the appeal, so as to enable the Hon'ble Income-tax Appeliate Tribunal to decide this appeal according to law.” 2. Ground No. 1 is academic in nature and therefore does not require any adjudication.

Relevant extract of [TAT order for the AY 2020-21 and AY 2021-22: "21. We have carefully considered the rival submissions and perused the orders of the authorities below, the material placed on record and the case law cited at the bar. We have also minutely examined the earlier orders of the co ordinate benches in the assessee's own case for assessment years 2018-19 and 2019-20 and the series of decisions in the case of Swiss Reinsurance Company Limited and RGA International Reinsurance Company Designated Activity Company.

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into the shoes of SRCL for the remaining tenure of those treaties and continued to bear the risk and maintain requisite capital in Singapore. No fresh reinsurance contracts have been entered into by the assessee directly with Indian cedents after January 2018. 29. The second stream is the retrocession business, where SRIB, which writes new reinsurance business in India in its own name and for its own account, retrocedes a portion Of its assumed risk to the assessee under a retrocession agreement. The contractual relationship in the retrocession arrangement is solely between SRIB and the assessee, each dealing with the other on a principal to principal basis. The terms and conditions of retrocession, including pricing and extent of risk transfer, are negotiated and agreed between these two parties directly. The assessee assumes risk from SRE and maintains 23 ITA No.3178/Mum/2025 & 409VMum/2025 Swiss Re Asia Pte Ltd., capita/ in Singapore to support that risk. At all times, SRIB remains directly and solely liable to the Indian cedents under the reinsurance treaties written in India. 30. Parallel to this, SRIB and SRGBS in India render support services to the assessee under intra group service agreements. These services cover administrative, operational, information technology and similar support functions. They are remunerated at arm's length on a cost plus basis. The decisions regarding their own operations are taken by their respective managements. Their employees are employed by them, are on their payrolls and are subject to Indian regulatory and tax laws. There is no material on record to show that any employee of the assessee has been seconded to India or that the assessee has any right to occupy or use the premises of SRIB or SRGBS as its own place of business. 31. On these facts, we find ourselves in complete agreement with the reasoning of the co ordinate benches in earlier years that no fixed place permanent establishment of the assessee exists in India. A fixed place PE requires that the foreign enterprise has a place of business at its disposal in the source country through which its business is carried on. The offices of SRIB and SRGBS in India belong to them and are used by them to carry on their own business as service providers. The mere rendering of services by associated enterprises in their own premises does not automatically confer disposal or control of such premises on the foreign enterprise. This

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proposition has been clearly laid down in the Swiss Re and RGA decisions and we see no basis to take a different view. 32. Likewise, there is no service permanent establishment of the assessee in India. Article 5 of the India Singapore treaty contemplates a service PE where an enterprise furnishes services in India through its employees or other personnel for a stipulated duration. The assessee does not furnish any services in India. It is on the contrary the recipient of services from SRIB and SRGBS. No employees or personnel of the assessee have rendered services in India to any third party. Occasional stewardship visits, if any, by personnel of the assessee or group level officials are only for oversight and protection of investment and do not amount to furnishing of services to a customer in India. The essential condition for existence of a service PE is, therefore, conspicuously absent. 33. The allegation that SRIB and SRGBS constitute a dependent agency permanent establishment of the assessee is equally unsustainable. For a dependent agent PE to arise, the agent in the source country must habitually conclude contracts on behalf of the foreign enterprise or habitually play the principal role leading to the conclusion of contracts which are routinely concluded without material modification by the enterprise. In the present case, the run off portfolio consists of contracts that were concluded in the past by SRCL Singapore branch. Subsequent to their transfer to the assessee there is no evidence that any Indian entity has participated in conclusion or renegotiation of those contracts on behalf of the assessee. For fresh reinsurance business, the contracts are entered into by SRIB in its own name and on its own account. The retrocession contract, as we have already noted, is directly between SRIB and the assessee and there is no evidence that SRIB or SRGBS habitually conclude contracts for the assessee with any Indian cedent. 34. The entire business origination function in relation to Indian cedents is either carried out in Singapore, in the case of the run off portfolio, or in India by SRIB in its own right as a cedent, in the case of fresh reinsurance business. There is nothing to show that SRIB or SRGBS act as brokers, agents or legal representatives of the assessee in relation to Indian cedents. To the contrary, the material on record confirms that SRIB and SRGBS are independent service providers which do not have authority to secure or conclude contracts on behalf of the assessee. In these circumstances, the essential

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ingredients of a dependent agent permanent establishment are not satisfied. 35. We also note that the Assessing Officer has not set out any separate reasoning for treating the assessee as having a business connection in India under section 9(1)(i) in relation to retrocession business. The reasoning proceeds on the assumption that presence of associated enterprises in India by itself suffices to create a business connection and permanent establishment. This approach has already been rejected in the decisions of the co ordinate benches in Swiss Reinsurance Company Limited and in RGA International Reinsurance Company. Those decisions emphasise that where the core business of assuming risk and deploying capital is carried on outside India, and where Indian affiliates are remunerated at arm's length for their support services, no further income can be said to accrue or arise in India either by way of business connection or permanent establishment attribution. 36. For all these reasons, we respectfully follow the earlier decisions and reiterate that the assessee does not have any permanent establishment in India in relation to its reinsurance business in the form of the run off portfolio or its retrocession business with SRIB. Consequently, the reinsurance premium from Indian cedents and the retrocession premium from SR/B are not taxable in India as business profits under Article 7 of the India Singapore tax treaty. The additions made by the Assessing Officer and sustained by the Dispute Resolution Panel on this account for both years under appeal cannot, therefore, be sustained and ate liable to be deleted. ….. 52. To recapitulate, we have first taken note of the fact that the issues in these appeals are fully coveted in favour of the assessee by co ordinate bench decisions in the assessee's own case for assessment years 2018-19 and 2019-20 and by the consistent line of authority in the cases of Swiss Reinsurance Company Limited and RGA International Reinsurance Company Designated Activity Company. We have then independently examined the factual matrix and the applicable law and have found that the business model, the nature of activities and the contractual framework remain unchanged in the years under appeal. On both counts, therefore, the revenue's case does not survive.

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the Assessment Officer in terms of section 144C(13). The case now set up by the revenue, even if assumed to be meriting consideration, is contrary to the finding returned by the DRP. The revenue is not in appeal against the order passed by the DRP as after omission of section 253(2A) by the Finance Act, 2016 with effect from 1-6-2016, no appeal can be filed by the Assessing Officer against the order passed by DRP giving directions under section 144C(5). Since for the Assessment Year 2018-19 Assessing Officer is not permitted to challenge the findings returned by the DRP in appeal before the Tribunal, the revenue cannot be permitted to set up a case against the directions passed by the DRP. Therefore, taking a view consistent with the view taken by the Tribunal in the case of SRCL in order dated 04-07-2017, passed in appeal for the Assessment Year 2013-14 (ITA No. 2759/Mum/2017), the additions made by the Assessing Officer are deleted in view of the finding returned by the DRP that the 'impugned addition already stand adjudicated by the Tribunal in the case of a sister concern in identical facts and circumstances'. Other contentions dealing with the merits, having been rendered academic, are not adjudicated upon and are, therefore, left open. [Para 7.8] ……. In view of the above, additions made by the Assessing Officer are deleted. [Para 9] In result, the appeal preferred by the assessee is allowed.[Para 10]" 8. As there is a categorical mention by the DRP that the material facts remain the same, therefore respecfully following the decision of the Co-ordinate Bench, we direct the AO to delete the impugned additions. Accordingly, Ground No. 2 to 7 are allowed. " Hon'ble Mumbai ITAT rulings in the case of SRCL (i.e. Appellant's sister concern) We wish to submit that the decisions of the Hon'ble Mumbai I TAT for 26. AY 2010-11 in the case of SRCL conclude the issue that arises in the present appeal too. The Tribunal, in the aforesaid decision, had to consider a similar issue where the Revenue had alleged that Swiss Re Services India Private Limited, a wholly-owned Indian subsidiary of SRCL which provided SRCL with basic market intelligence and admin support services in India was a business connection as well as a PE.

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The Tribunal negated this argument and held that SRCL neither has a business connection in India in light of Explanation 2 to section 9(1) of the Income-tax Act, 1961 ('Act') nor does it have a PE in India under the provisions of India- Switzerland tax treaty and, therefore, no income earned by SRCL from Indian cedents is taxable in India. The relevant extract of the order of the Tribunal for AY 2010-11 is reproduced below: "2. Briefly stated, the facts are as under: Swiss Re-insurance Company Limited i.e. the assessee is a company incorporated in Switzerland which receives income from providing reinsurance to various Cedants in India. The re-insurance premium received by the assessee is claimed as business income and it is further claimed that in absence of any Permanent Establishment (PE) in India the entire business income is not taxable in India. 2.1 During the course of assessment proceedings, the assessee filed necessary details and information in support of its claim. After carefully going through the information/details furnished by the assessee the AO observed that the business of the assessee is to provide reinsurance services to the clients in India. The AO further observed that in the course of such business Swiss Re-Services India Pvt. Ltd. (SRS/PL), which is an Indian Company and wholly owned subsidiary of the assessee is a PE of the assessee in India. The AO further noticed that the assessee through its Singapore Branch has entered into service agreement since 01/04/2009 with SRS/PL for obtaining risk assessment services, market insurance and administrative support in India and in turn remunerate/compensate SRS/PL on a cost + 12% margin. The AO was of the opinion that since the assessee has remunerated SRS/PL and al/ its employees on a cost + basis, it is clear that the personnel and staff have rendered services to the assessee as de-facto employees. The AO was of the firm belief that the Indian subsidiary SRS/PL provides technical and core reinsurance services, therefore, Dependent Agency Permanent Establishment(DAPE) comes into play. The AO further noted that as per the domestic Income Tax Act, 1961, since the income of the assessee is being earned from India on a regular and continuous basis, the income of the assessee is taxable in India in terms of section 9(1)(i) of the Act The assessee has regular flow of income emanating from India, hence, the assessee has clear cut business connection in India.

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2.2 The AO gave the assessee an opportunity to substantiate its claim that the reinsurance premium receipts of the company are not taxable in India. The assessee filed a detailed reply explaining the nature of activities of the assessee. It was explained and strongly contended that services provided by SRS/PL do not create existence of a PE in India. It was explained that SRS/PL is a separate legal entity and its entire control and management is in India. The decisions regarding its business are taken and executed in India. It is both legally and functionally independent company. It was explained that the employees of SRS/PL render services to SRS/PL and not to the assessee, either as assessee's employees or on behalf of SRS/PL. It was pointed out to the AO that the pricing between SRS/PL and the assessee is at arm's length. The profit earned by SRS/PL belongs to it and cannot be treated as profits of the assessee and such profits are assessed to tax in India in the hands of SRS/PL. ……… 5.6 Considering the services rendered by SRSIPL in the light of the OECD commentary, SRSIPL cannot be considered as PE of the assessee. The decision relied upon by Ld. DR do not support the Revenue on the facts of the present case, like in the case of Delhi Bench of the Tribunal in the case of Motorola Inc. (supra, the facts were that the employees of the assessee had worked both for the assessee as well as its Indian subsidiary. The employees also had the right to enter the office of the Indian subsidiary either for the purpose of working for Indian subsidiary or for the purpose of working for the assessee and the Indian subsidiary provided perquisite to the employees of the assessee and the assessee paid salaries to the employees, on these facts the Indian subsidiary was considered as place of business. However, facts of the case in hand clearly show that the employees of the SRSIPL has only provided services to SRSIPL and there is no noting on record to prove that the employees had provided services to the assessee or the assessee is paying their salaries or perquisites. The decision of the Hon 'ble Supreme Court in the case of Morgan Stanley (supra) has been duly considered by the Hon'ble Delhi High Court in the case of EFunds IT Solutions (supra). The decision in the case of Jebon Corporation of Indi(supra) is not at all relevant on the facts of the case in hand.

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5.6 To sum up, the assessee does not have any business connection in India in the light of Explanation-2 to section 9(1) of the Act. The assessee does not have any PE in India. The facts on record show that there is neither Service PE nor Agency PE in the form of SRSIPL. Considering the facts in totality in the light of the relevant provisions of the law and the DTAA and the judicial decisions referred to herein above, we have no hesitation in setting aside the assessment order and accordingly we direct the AO not to treat the income of the assessee as taxable under the Act. With this Ground No. 1, 2 and all its sub-grounds are allowed. .. 27. Further, the Hon'ble Mumbai I TAT has followed the above mentioned decision of AY 2010-11 for subsequent years as well i.e., from AY 2011-12 to AY 2017-18 6 in case of SRCL. 28. In addition to the judicial precedents relied by the Appellant in the objections filed by it before the DRP, the Appellant also wishes to place reliance on the following judgments for reinsurance and retrocession business:  RGA International Reinsurance Company Designated Activity Company vs. DCIT- ITA Nos. 803 & 2330/MUM/2022 dated 06 September 2023 (Mumbai Tribunal) - A Y 2018-19 and AY 2019-20  RGA International Reinsurance Company Designated Activity Company, Ireland vs. DCIT - ITA No.3254/Mum/2023 dated 31 January 2024 (Mumbai Tribunal) - A Y 2020-21  RGA International Reinsurance Company Designated Activity Company, Ireland vs. DCIT - ITA No. 4693/Mum/2023 dated 22 May 2024 (Mumbai Tribunal) - A Y 2021-22  RGA International Reinsurance Company Designated Activity Company, Ireland vs. DCIT- ITA No. 1092/Mum/2025 dated 25 June 2025 (Mumbai Tribunal)  ADIT v. E-funds IT Solution Inc. [20171399 ITR 34 (SC) - Referpara 12 and para 21.  Varian India Private Limited [2013] 142 ITD 692 (Mum Trib.) - Refer para 29 and para 30

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SRAPL in India under the IS Tax Treaty are grossly erroneous and not in accordance with the facts or law.

Respectfully following the doctrine of binding precedent and maintaining judicial consistency, particularly when identical additions made on similar facts have been deleted by the Coordinate Benches, we direct the Assessing Officer to delete the impugned additions and pass the order accordingly.

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ground is also squarely covered by the decision of Coordinate Bench of ITAT in assessee's own cases for AY 2018-19 (ITA No. 1492/Mum/2022), AY 2019-20 (ITA No. 1995/Mum/2022), AY 2020-21 (ITA No. 3178/MUM/2023) and AY 2021-22 (ITA No. 4092/MUM/2023). The Coordinate Bench of ITAT has held:

Relevant extract of ITAT order for the AY 2020-21 and 2021- 22: "40. The co-ordinate bench, in the assessee's own case for assessment years 2018-19 and 2019-20, has already applied this principle to the very same agreements and to the very same categories of services rendered by the assessee to SR/B and SRGBS. It has held, after detailed analysis, that while the services may assist SR/B and SRGBS in their operations, they do not equip the Indian entities to perform such functions by themselves without the assessee's ongoing involvement. The Assessing Officer had not identified any specific technology, process or know how that was transferred, nor had he shown that SR/B or SRGBS could dispense with the assessee's services and continue to apply such technology independently. On that basis, the co ordinate bench held that the income in question does not qualify as FTS under ArticIe 12 and deleted the corresponding additions. 41. The reasoning of the co ordinate bench is fully consistent with the decision of the Hon 'ble Bombay High Court in Shell India Markets Private Limited, where the Court dealt with a similar make available provision in the India United Kingdom treaty and held that consultancy services which assist the recipient in its business do not become FTS unless there is an actual transfer of technical know how or processes. The Court emphasised that the continuous rendering of services over a long period is, in fact, an indicator that the underlying technology has not been transferred, because if the recipient had truly acquired the know how, there would ordinarily be no need for such continued dependence. 29 ITA No.3178/Mum/2025 & 4092/Mum/2025 Swiss Re Asia Pte Ltd., The same approach has been followed in the decisions of the Mumbai bench in

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nature of activities and the contractual framework remain unchanged in the years under appeal. On both counts, therefore, the revenue's case does not survive. 53...We further hold that the service income received by the assessee from SRIB and SRGBS does not qualify as Fees for Technical Services under Article 12 of the India Singapore tax treaty and is also not taxable as business income in the absence of any permanent establishment. " Relevant extract of ITAT order for the AY 2018-19: "8.1 ...In view of the aforesaid, the conclusion drawn by the Assessing Officer that the services under consideration qualify as fee for technical services in terms of Article 12 of the DTAA cannot be sustained. During the course of hearing, the Appellant had placed reliance on the decision of the Tribunal in the case of Jefferies LLC v. DCIT (ITA NO. 5674/MUM/2017), wherein it was held by the Tribunal that services provided by the group entities or holding companies to its subsidiaries as day to day management and support services to run their business would not be regarded as fees for technical services in case, such services do not make available technical knowledge, skill or experience. 9. In view of the above, addition of INR 59,26, 89, 532/- (held by the Assessing Officer to be business income) and addition of INR 10, 77,82,884/- (held by the Assessing Officer to be Fee for Technical Services) are deleted. " Relevant extract of ITAT order for the AY 2019-20: "7. We find that in the earlier A Y, the Co-ordinate Bench in ITA No. 1492/Mum/2022 vide order dated 17/01/2024 has held as under:- As regards the taxability of fee received by the appellant from SRCL-IB/SGB is concerned, it is noted that Assessing Officer had concluded that the services provided to SRCL-IB and SRGBS were to be chargeable to tax in India in terms of article 12 as the services are highly technical in nature which have made available the technology to SRCL1B and SGB for further exploitation and use as income generating inputs. The DRP also observed that services provided were of enduring nature and were being provided continuously on a year-on- year basis. Hence, the same were liable to be treated as Fee for Technical Services. [Para 8] It is noted that while examining the applicability of provisions contained in section 9(1)(vii) read with Explanation 2, the Assessing Officer had noted that even the rendering of any

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services by a technical or other personnel without any technology being transferred would also fall within the ambit of fee for technical services. At the same time, in the Final Assessment Order while examining the applicability of provisions contained in section 12(4) of DTAA, the Assessing Officer has noted that in order to satisfy the requirement of 'make available' contained therein the recipient of service should be in a position to utilize the knowledge or know how in future on his own. However, on perusal of the Assessment Order, it is found that the Assessing Officer has brought nothing on record to show that the services rendered made available any technical knowledge, know-how, skill, expertise to SRCL-IB/SGB which enables SRCL-IB/SGB to independently perform their function without support of the appellant in the future. The findings returned by the Assessing Officer that the services provided by the appellant enable SRCL-IB/SGB to provide onwards services cannot lead to an automatic conclusion/inference that some technical knowledge, skill or experience was made available by the appellant to SRCL-IB/SGB. In view of the aforesaid, the conclusion drawn by the Assessing Officer that the services under consideration qualify as fee for technical services in terms of article 12 of the DTAA cannot be sustained. [Para 8.1] In view of the above, additions made by the Assessing Officer are deleted. [Para 91 In result, the appeal preferred by the assessee is allowed.[Para 10]" 9. In view of the above discussion we hold that the support services rendered by the assessee to SRIB/ SRGBS are not taxable as FTS under the IS Tax Treaty and in the absence of a PE of SRAPL in India, the said income arising to the assessee from support services rendered to SRIB/ SRGBS is not taxable in India under Article 7 of the IS Tax Treaty.

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Respectfully following the doctrine of binding precedent and maintaining judicial consistency, particularly when identical additions made on similar facts have been deleted by the Coordinate Benches, we direct the Assessing Officer to delete the impugned additions and pass the order accordingly.

Order pronounced in the open court on 27.04.2026

Sd/- Sd/- (PRABHASH SHANKER) (SANDEEP GOSAIN) JUDICIAL MEMBER ACCOUNTANT MEMBER Mumbai, Dated 27/04/2026 RY, Sr. PS आदेश की प्रतितिति अग्रेतिि/Copy of the Order forwarded to :

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अपीलार्थी / The Appellant 1. प्रत्यर्थी / The Respondent. 2. संबंधित आयकर आयुक्त / The CIT(A) 3. 4. आयकर आयुक्त(अपील) / Concerned CIT धिभागीय प्रधतधिधि, आयकर अपीलीय अधिकरण,मुम्बई/ DR, ITAT, Mumbai 5. 6. गार्ड फाईल / Guard file. आदेशानुसार/BY ORDER, सत्याधपत प्रधत //True Copy//

उि/सहायक िंजीकार ( Asst. Registrar) आयकर अिीिीय अतिकरण, मुम्बई / ITAT, Mumbai