RVN PAPER & BOARDS PVT. LTD.,MUMBAI vs. INCOME TAX OFFICER WARD 11(1)(1), MUMBAI, MUMBAI

IN THE INCOME TAX APPELLATE TRIBUNAL, MUMBAI BENCH “D”, MUMBAI BEFORE SHRI CHALLA NAGENDRA PRASAD, JUDICIAL MEMBER And SHRI RAKESH KUMAR LODHA, ACCOUNTANT MEMBER ITA No.5723/MUM/2026 AND ITA No. 5724/MUM/2026 Assessment Year: 2017-2018 RVN PAPER AND BOARDS INCOME TAX OFFICER PRIVATE LIMITED WARD 11(1)(1)

A1, North Bombay CHSL, Opp Aayakar Bhawan, Vs. JW Marriot, Juhu Tara Road Mumbai 400 020 Mumbai, Juhu S.O, Maharastra Mumbai 400 049 Maharastra PAN- AADCR8736L

(Appellant) (Respondent)

Assessee Represented by : Shri Samyak Lohade C.A Revenue Represented by : Shri Prasamma Prakash Tewari – SR DR Date of Hearing : 31.08.2026 Date of Pronouncement : 29.09.2026 O R D E R

ITA NO. 5723 & 5724-MUM-2026 RVN PAPER & BOARDS PRIVATE LIMITED 2017-2018 PER : Shri Rakesh Kumar Lodha, Accountant Member:

These appeals have been filed by the Assessee against the orders under section 250 of the Income Tax Act, 1961 (in short „the Act‟) passed by the National Faceless Appeal Center, Delhi, dated 27th March 2026, for the assessment year 2017-2018, relating to the quantum assessment order under section 144 and penalty order under section 270A of the Act.

I. On refusal to condone the delay in filing of appeal 1. That on the facts and in the circumstances of the case and in law, the Ld. CIT(A) erred in dismissing the appeal of the Appellant in limine on the sole ground of delay of 465 days in filing of appeal, without condoning the said delay and without adjudicating the grounds of appeal on merits. 2. That on the facts and in the circumstances of the case and in law, the Ld. CIT(A) erred in failing to appreciate that the Appellant had demonstrated “sufficient cause” within the meaning of Section 249(3) of the Income-tax Act, 1961 (“the Act”) for the delay in filing of appeal. II. On the reopening of the assessment 3. That on the facts and in the circumstances of the case, the reassessment proceedings are void ab initio since the jurisdiction under section 148 of the Act was assumed solely on borrowed satisfaction, without the Ld. AO independently examining or forming his own belief that income chargeable to tax had escaped assessment for AY 2017-18. 4. That on the facts and in the circumstances of the case, the Ld. AO failed to establish any live nexus between the alleged Insight Portal information, the alleged dummy companies, the appellant's purchase transactions, and escapement of income chargeable to tax.

ITA NO. 5723 & 5724-MUM-2026 RVN PAPER & BOARDS PRIVATE LIMITED 2017-2018 5. That on the facts and in the circumstances of the case, the Ld. AO erred in law in treating unverified third-party information as material evidence capable of sustaining reassessment, without carrying out even basic verification of the alleged suppliers, transactions, books of account, invoices, payments, stock movement, consumption, or corresponding sales. 6. That on the facts and in the circumstances of the case, the impugned proceedings are vitiated since the Appellant was not supplied the complete material allegedly relied upon for reopening, namely the basis of the Insight Portal entry, supplier-wise details, statements, bank trail, enquiry report, or other material connecting the Appellant with alleged bogus purchases. 7. That on the facts and in the circumstances of the case, the order under section 148A(4) of the Act is non-speaking, mechanical and contrary to law, as it proceeds on the basis that the information received from DDIT, Vapi was to be “assumed to be correct”, instead of independently deciding whether it was a fit case for issuance of notice under section 148. 8. That on the facts and in the circumstances of the case, the notice issued u/s 148 of the Act is without jurisdiction since the conditions of section 149(1)(b), i.e. the material relied upon did not constitute books of account, documents or evidence revealing that income chargeable to tax, represented in the form contemplated by section 149(1)(b), had escaped assessment and amounted to or was likely to amount to Rs. 50 lakhs or more. III. On the merits of the addition of Rs. 1,44,21,446 under Section 37 of the Act 9. That on the facts and in the circumstances of the case, the Ld. AO erred in disallowing u/s 37 of the Act, the cost incurred by the Appellant towards purchase of raw material for its business, amounting to Rs. 1,44,21,446 on the ground that the same is not for the purpose of the business. 10. That on the facts and in the circumstances of the case and in law, the Ld. AO grossly erred in treating the purchases from the said seven parties as bogus solely on the ground that the said seven parties did not respond to the notices issued under Section 133(6) of the Act within the short time granted by the Ld. AO, without appreciating that the Appellant had submitted sufficient information for identification of the parties and that the Appellant had no control over third-party compliance with statutory notices issued by the Ld. AO.

ITA NO. 5723 & 5724-MUM-2026 RVN PAPER & BOARDS PRIVATE LIMITED 2017-2018 11. That on the facts and in the circumstances of the case and in law, the alleged purchase value Rs. 1,44,21,446 could not ipso facto be treated as income escaping assessment, especially where the purchases were recorded in the books and there was no independent finding that the corresponding sales / consumption were fictitious. IV. Other Grounds 12. That on the facts and in the circumstances of the case and in law, the impugned assessment order dated 23.05.2023 is in gross violation of the principles of natural justice, inasmuch as the show-cause notice dated 08.05.2023 proposing the addition of Rs. 1,44,21,446 was issued calling for the Appellant's response by 12.05.2023, thereby affording a window of merely three working days, which was manifestly inadequate and unreasonable for the Appellant to procure confirmations and supporting records from seven supplier-parties situated at remote locations. 13. That on the facts and in the circumstances of the case and in law, the Ld. AO grossly erred in initiating penalty proceedings under Section 270A read with Section 274 of the Act. The Appellant craves leave to, add to or alter, by deletion, substitution, or otherwise, any or all of the foregoing grounds of appeal at or before the hearing, and to submit such statements, documents, and papers as may be considered necessary either at or before the appeal hearing. 3. Further, grounds taken against penalty order under Section 270A of the Act, in ITA NO. 5724/MUM/2026:

I. On refusal to condone the delay in filing of appeal 1. That on the facts and in the circumstances of the case and in law, the Ld. CIT(A) erred in dismissing the appeal of the Appellant in limine on the sole ground of delay of 590 days in filing of appeal, without condoning the said delay and without adjudicating the grounds of appeal on merits. 2. That on the facts and in the circumstances of the case and in law, the Ld. CIT(A) erred in failing to appreciate that the Appellant had demonstrated “sufficient cause” within the meaning of Section 249(3) of the Income-tax Act, 1961 (“the Act”) for the delay in filing of appeal.

ITA NO. 5723 & 5724-MUM-2026 RVN PAPER & BOARDS PRIVATE LIMITED 2017-2018 II. On the unsustainability of the penalty under Section 270A of the Act 3. That on the facts and circumstances of the case and in law, the Ld. CIT(A) has erred in confirming the action of the Ld. Faceless Assessing Officer (“the Ld. FAO”) levying penalty of Rs. 23,84,072/- invoking the provision of section 270A read with section 274 of the Act. 4. That on the facts and circumstances of the case and in law, the Ld. CIT(A) has erred in confirming the penalty levied by the Ld. FAO despite the Ld. FAO failing to specify specific clause under Section 270A(2) per which the income of the Appellant has been allegedly underreported or the clause under Section 270A(9) by virtue of which the Appellant has allegedly mis-reported its income. 5. That on the facts and in the circumstances of the case and in law, the Ld. CIT(A) erred in upholding the penalty levied by the Ld. FAO under section 270A of the Act, as the penalty order is vitiated by patent ambiguity, inherent contradictions, and non-application of mind regarding the specific charge levied against the Appellant. 6. That on the facts and in the circumstances of the case and in law the Ld. CIT(A) failed to appreciate that the order passed u/s 270A of the Act is vitiated since it has been passed in a mechanical manner and without application of mind, inasmuch as the the Ld. FAO issued the show-cause notice for 'under-reporting of income', recorded a final conclusion of default for 'misreporting of income, and computed the penalty at the rate of 50% under the nomenclature of misreporting. 7. That on the facts and in the circumstances of the case and in law, the Ld. CIT(A) erred in confirming the impugned penalty, without appreciating that the Ld. FAO passed the penalty order mechanically, failing to record any independent, objective findings or bring any corroborative material on record during the penalty proceedings to establish the specific default. 8. That on the facts and in the circumstances of the case and in law, the Ld. CIT(A) failed to appreciate that no penalty under section 270A is legally sustainable when the underlying quantum additions, consequent to which the penalty was imposed, were framed solely on the basis of unverified third-party allegations/information, without any independent enquiry, corroborating evidence, or independent verification by the Ld. FAO. 9. That on the facts and circumstances of the case and in law, the Ld. CIT(A) has erred in confirming penalty levied by the Ld. FAO ignoring the contention of the Appellant that the addition on which penalty has been levied by the Ld. FAO are itself untenable in law. 5

ITA NO. 5723 & 5724-MUM-2026 RVN PAPER & BOARDS PRIVATE LIMITED 2017-2018 10. That on the facts and circumstances of the case and in law, the Ld. CIT(A) erred in confirming the penalty without appreciating that the quantum additions, which form the sole foundation of the impugned penalty, are presently under challenge and have not reached finality. 11. That on the facts and circumstances of the case, the learned CIT(A) has erred both on facts and in law in confirming the penalty even though there was neither misreporting of income nor under reporting of income. The Appellant craves leave to, add to or alter, by deletion, substitution, or otherwise, any or all of the foregoing grounds of appeal at or before the hearing, and to submit such statements, documents, and papers as may be considered necessary either at or before the appeal hearing. 4. The brief relevant facts of the case are that, the Assessee is a private limited company, filed its return of income on 07/11/2017, declaring total income of Rs. NIL/-.

ITA NO. 5723 & 5724-MUM-2026 RVN PAPER & BOARDS PRIVATE LIMITED 2017-2018 treated as a return in compliance with notice under Section 148 of the Act.

ITA NO. 5723 & 5724-MUM-2026 RVN PAPER & BOARDS PRIVATE LIMITED 2017-2018 was that the directors are old age persons, and their assessment proceedings were being handled by their tax consultants, and he did not responded properly. The directors of assessee company were also unaware of the passing of an order containing addition/ disallowance of Rs.1,44,21,446/- in the ex-parte assessment order, meanwhile penalty u/s 270A also levied. Subsequently, when the recovery notices reached to assessee, at that point of time, they came to know about such ex parte assessment order and additions made there in.

ITA NO. 5723 & 5724-MUM-2026 RVN PAPER & BOARDS PRIVATE LIMITED 2017-2018 14. Before us, the learned authorized representative of assessee, submitted a detailed affidavit elaborating the complete facts of the case, reasons for the lapse and non-prosecution by the consultant, resulting in reassessment order and dismissal of first appeal.

ITA NO. 5723 & 5724-MUM-2026 RVN PAPER & BOARDS PRIVATE LIMITED 2017-2018 5. That thereafter, the case of the Appellant was sought to be reopened by the Ld. Assessing Officer (“the Ld. AO”) on the ground that information allegedly suggesting that income has escaped assessment emanating from the office of the Deputy Director if Income-tax (Investigation)-1, Vapi, in the form of a TEP, wherein it was alleged that the Appellant was engaged in the business of purchase of waste paper from “dummy” private limited companies, was taking bogus purchase bills aggregating Rs. 4,50,00,000 and was issuing cheques against such purchases in exchange of cash. 6. That most of the directors of the Appellant are only Higher Secondary Certificate holders, and all the directors of the Appellant are not well versed with the provisions of the Act. A. Background: 7. The Appellant Company had filed its return of income for Assessment Year 2017-18 on 07.11.2017, declaring Nil income. Thereafter, reassessment proceedings were initiated against the Appellant on the basis of an anonymous tax evasion petition filed with the Income-tax Department. 8. That during the reassessment proceedings, various notices and communications were received on the Income-tax e-filing portal. The said proceedings were conducted electronically and the notices and communications uploaded on the portal required regular professional attention and appropriate responses from time to time. 9. That the tax and assessment matters of the Company were, at the relevant time, being handled by the Company‟s erstwhile tax consultant CMA Vijay Solanki. The Directors of the Company were dependent upon the professional consultant for attending to the Income-tax proceedings, examining the notices and orders uploaded on the portal, advising the Company regarding their consequences, and taking such further appellate or other remedial action as may be required. The Appellant and its Directors, in the ordinary course, relied upon the said consultant to keep them informed of material developments in the proceedings and to take the procedural steps required under the Act within the prescribed timelines. 10. That during the assessment proceedings, the erstwhile tax consultant filed initial replies but due to reasons unknown to the Appellant, failed to file any reply to show cause notices issued by the Ld. AO. Consequently, the reassessment proceedings continued without the Appellant‟s responses to the said show-cause notices being placed before the Ld. AO. The Appellant had no knowledge of this lapse, even though the matter had been entrusted to and was being handled by the erstwhile tax consultant. 10

ITA NO. 5723 & 5724-MUM-2026 RVN PAPER & BOARDS PRIVATE LIMITED 2017-2018 7. That on 23.05.2023, the Re-assessment Order was passed bearing DIN ITBA/AST/S/147-2023-24/1053074381(1), whereby an addition of Rs.1,44,21,446/- was made to the income of the Appellant. The said addition resulted in a substantial tax demand and therefore required immediate examination of the appellate remedies available to the Appellant. 8. That immediately upon receipt of the Re-assessment Order on email, Appellant forwarded the same to the erstwhile tax consultant on 23.05.2023, with the understanding that he would examine the order, advise the Appellant regarding the appropriate appellate proceedings and take the necessary steps for preparing and filing an appeal in Form No. 35 before the learned Commissioner of Income-tax (Appeals) within the prescribed period of limitation. A copy of the e-mail dated 23.05.2023 wherein the Re-assessment Order was forwarded to the erstwhile tax consultant, is enclosed as Enclosure 1. 9. That upon examining the matter, the erstwhile tax consultant advised the Appellant that, in order to properly prepare and file an appeal against the Re-assessment Order, ledger confirmations from the suppliers whose purchases formed the subject matter of the addition would be required. The Appellant acted upon the said professional advice and took steps to obtain the relevant ledger confirmations from the concerned suppliers. Once the Appellant was able to obtain the ledger confirmations from the suppliers, the same were shared with the erstwhile tax consultant for the purpose of taking the necessary further action and filing the appeal against the Re- assessment Order. 10. Having forwarded the Re-assessment Order and thereafter supplied the documents specifically sought by the consultant for preparing the appeal, the Appellant and its Directors were under the bona fide belief that the necessary steps to institute appellate proceedings would have been taken by the erstwhile tax consultant. 11. That the Appellant had never accepted the addition made in the Re-assessment Order and had at no point taken any conscious decision to abandon or not pursue its statutory right of appeal. On the contrary, the aforesaid steps taken by the Appellant, including obtaining the supplier confirmations on the specific advice of the tax consultant and furnishing the same to him, demonstrate the Appellant‟s intention throughout to challenge the Re-assessment Order. 12. That on 09.09.2024, the Appellant received a recovery communication bearing DIN ITBA/RCV/F/17/2024-25/1068464262(1), calling upon the Appellant to pay the outstanding demand arising from the Re-assessment Order. A copy of the said recovery communication dated 09.09.2024 is enclosed as Enclosure 2. 11

ITA NO. 5723 & 5724-MUM-2026 RVN PAPER & BOARDS PRIVATE LIMITED 2017-2018 13. That upon noticing the aforesaid recovery communication, the Appellant immediately made enquiries regarding the status of the appeal which, as understood by the directors of the Appellant, was to have been filed by the erstwhile tax consultant. It was only upon such enquiry that it came to my knowledge that no appeal had in fact been filed by the erstwhile tax consultant against the Re-assessment Order. Therefore, upon discovery of such act of negligence by the tax consultant, the Appellant took immediate steps for filing of the appeal and responding to the aforementioned recovery notice. 14. Specifically, the Appellant filed a reply to the recovery communication dated 09.09.2024 on 17.09.2024 and requested the Ld. AO to keep the outstanding demand in abeyance, specifically pointing out that the Appellant was in the process of filing an appeal against the Re-assessment Order. A copy of the acknowledgement evidencing filing of the reply dated 17.09.2024 is enclosed as Enclosure 3. 15. That thereafter, the Ld. AO issued another communication dated 23.09.2024 bearing DIN ITBA/RCV/F/17/2024-25/1068990642(1), whereby the request of the Appellant for keeping the demand in abeyance was rejected and the Appellant was directed to pay the outstanding tax demand. A copy of the said communication dated 23.09.2024 is enclosed as Enclosure 4. 16. The Appellant simultaneously filed the quantum appeal in Form No. 35 before the Ld. CIT(A) on 29.09.2024. On the very same day, the Appellant also filed a reply in relation to the communication dated 23.09.2024 rejecting the request for stay of demand. A copy of the acknowledgement of the reply filed on 29.09.2024 is enclosed as Enclosure 5, and a copy of Form No. 35 is enclosed as Enclosure 6. 17. Further, the Appellant then took the decision to remove CMA Vijay Solanki as the tax consultant of the Appellant and thereafter all tax matters were entrusted to CMA Sutiyan Khalifa for review and necessary advice. 18. That the actions of the Appellant from the receipt of the recovery communication dated 09.09.2024 to the filing of the quantum appeal on 29.09.2024 shows that, immediately upon the Appellant discovering that the appeal entrusted to the erstwhile tax consultant had not been filed, the Appellant acted continuously and without avoidable delay to change its professional advisor, address the recovery proceedings and file the appeal in Form No. 35. C. Penalty Order and circumstances relating to delayed filing of the penalty appeal:

ITA NO. 5723 & 5724-MUM-2026 RVN PAPER & BOARDS PRIVATE LIMITED 2017-2018 19. That consequent to the initiation of the penalty u/s 270A r.w.s 274 of the Act in the Quantum Order, the Penalty Order was passed by the Ld. Faceless Assessing Officer (“the Ld. FAO”) on 08.03.2024. This came to the notice of the newly appointed tax consultant, CMA Sutiyan Khalifa, during a review of the Income-tax e-filing portal shortly after his appointment, and he advised the Appellant that filing a separate appeal before the first appellate authority against the Penalty Order would be futile/fruitless until the quantum appeal had been filed and adjudicated, since the penalty arose entirely out of the quantum addition and, in the event the quantum addition was deleted in appeal, the very foundation of the penalty would cease to survive. 20. That the directors of the Appellant, being lay persons in matters of income-tax procedure and acting upon the professional advice received from the newly appointed tax consultant, were therefore under the bona fide belief that a separate penalty appeal was not required to be filed at that stage and could await the outcome of the quantum appeal. The non-filing of the penalty appeal at that stage was thus not deliberate, mala fide or attributable to any intention to abandon the statutory remedy but arose from the professional advice on which the Appellant bona fide relied. 21. That during the course of the quantum appeal proceedings before the Ld. CIT(A), a notice u/s 250 of the Act dated 06.08.2025 was issued to the Appellant. Considering the importance of the said proceedings, the Appellant had appointed a Chartered Accountant, M/s S S S R & associates LLP (erstwhile Sanjay Rane & Associates LLP), Chartered Accountants, to represent it in the proceedings for the quantum appeal. When M/s S S S R & associates LLP enquired regarding the date of service of the quantum order, the tax consultant shared, inter alia, the penalty order received by the Appellant issued u/s 270A dated 08.03.2024. 22. That on further enquiry by the Chartered Accountant firm, the Appellant‟s tax consultant informed them about the existence of the Penalty Order and also explained that a separate penalty appeal had not been filed in view of the earlier professional advice that the penalty matter could await the outcome of the quantum appeal. 23. That M/s S S S R & associates LLP thereafter advised the Directors of the Appellant that, notwithstanding the pendency of the quantum appeal and notwithstanding the penalty being consequential to the quantum addition, a separate statutory appeal ought to be filed against the Penalty Order so that the Appellant‟s independent challenge to the penalty was preserved. 24. That acting upon the aforesaid advice, the Appellant entrusted the penalty appellate proceedings also to M/s S S S R & associates LLP. 13

ITA NO. 5723 & 5724-MUM-2026 RVN PAPER & BOARDS PRIVATE LIMITED 2017-2018 The relevant penalty records were thereafter reviewed and the necessary grounds of appeal, statement of facts and condonation material were prepared. The appeal in Form No. 35 against the Penalty Order was thereafter filed on 18.11.2025. 25. That the delay in filing the penalty appeal therefore arose from the bona fide professional advice received by the Appellant that the penalty appeal need not be independently pursued until the quantum appeal was dealt with. Once the Chartered Accountant firm handling the quantum appeal advised that a separate penalty appeal should nevertheless be filed, the Appellant accepted such advice and entrusted the penalty appeal to the said firm for necessary action. D. Bona fide conduct of the Appellant and sufficient cause for the respective delays: 26. That the circumstances leading to the delayed filing of the quantum appeal and the penalty appeal are distinct in their immediate cause, but both arose while the Appellant was acting through and relying upon professional tax advisers. In the quantum matter, despite the reassessment order having been forwarded on the very date of its passing and the supplier confirmations having thereafter been obtained and furnished on the consultant‟s advice, the appeal was inadvertently not filed by the erstwhile consultant. In the penalty matter, although the penalty order was received on 08.03.2024, no appeal was filed by the Appellant under the bona fide professional advice of the tax consultant that an appeal against the Penalty Order would not be fruitful at this stage and thus no action is required till the completion of the quantum appellate proceedings. 27. That there was no deliberate omission, malafide intention or conscious decision on the part of the appellant or its directors to allow the statutory periods to expire in either of the two proceedings. It is submitted that the appellant had nothing to gain by delaying the either appeal. On the contrary, the delay exposed the appellant to recovery of the disputed quantum demand and to the consequences of the Penalty Order. 15. The Assessee also submitted a screenshot of an email communication delivered from the Income Tax Department on 23rd May 2023, containing information of an order under Section 147 of the Act. This email communication was immediately forwarded to the tax consultant, Mr. Vijay Kumar Solanki, within 30 minutes of time at his 14

ITA NO. 5723 & 5724-MUM-2026 RVN PAPER & BOARDS PRIVATE LIMITED 2017-2018 email ID, cmavijay.solanki@gmail.com, and asked him to take necessary steps for further required proceedings against that order.

ITA NO. 5723 & 5724-MUM-2026 RVN PAPER & BOARDS PRIVATE LIMITED 2017-2018 167 ITR 471 (SC), wherein, it had laid down six principles. For the purpose of convenience, the principles laid down by the Apex Court are reproduced hereunder: (1) Ordinarily, a litigant does not stand to benefit by lodging an appeal late. (2) Refusing to condone delay can result in a meritorious matter being thrown at the very threshold and cause of justice being defeated. As against this, when delay is condoned, the highest that can happen is that a cause would be decided on merits after hearing the parties. (3) „Every day‟s delay must be explained‟ does not mean that a pedantic approach should be made. Why not every hour‟s delay, every second‟s delay? The doctrine must be applied in a rational, commonsense and pragmatic manner. (4) When substantial justice and technical consideration are pitted against each other, the cause of substantial justice deserves to be preferred, for the other side cannot claim to have vested right in injustice being done because of a non deliberate delay. (5) There is no presumption that delay is occasioned deliberately, or on account of culpable negligence, or on account of mala fides. A litigant does not stand to benefit by resorting to delay. In fact, he runs a serious risk. (6) It must be grasped that the judiciary is respected not on account of its power to legalise injustice on technical grounds but because it is capable of removing injustice and is expected to do so. The Madras High Court in the case of Sreenivas Charitable Trust (2006) 280 ITR 357 (Mad) held that no hard and fast rule can be laid down in the matter of condonation of delay and the Court should adopt a pragmatic approach and the Court should exercise their discretion on the facts of each case keeping in mind that in construing the expression “sufficient cause” the principle of advancing substantial justice is of prime importance and the expression “sufficient cause” should receive a liberal construction. Therefore, this Judgment of the Madras High Court (supra) clearly says that in order to advance substantial justice which is of prime importance, the expression “sufficient cause” should receive a liberal construction.

ITA NO. 5723 & 5724-MUM-2026 RVN PAPER & BOARDS PRIVATE LIMITED 2017-2018 The Mumbai Bench of this Tribunal in the case of Bajaj Hindusthan Ltd. v. Jt. CIT (AT) (277 ITR 1) has condoned the delay of 180 days when the appeal was filed after the pronouncement of the Judgment of the Apex Court. Furthermore, the Revenue has not filed any counter-affidavit opposing the application of the assessee for condonation of delay. 20. In view of afore mentioned discussion and judgment of the Hon‟ble Apex Court and others, we find that reasons for delay in filing of appeal by the Assessee company before the Ld. CIT(A), were reasonable and sufficient to, as assessee was completely having reliance on the tax consultant, thus, it was not intentional in defiance of the law.

ITA NO. 5723 & 5724-MUM-2026 RVN PAPER & BOARDS PRIVATE LIMITED 2017-2018 ITA No. 5724/MUM/2026:

Order pronounced in the open court on 29.09.2026. Sd/- Sd/- (CHALLA NAGENDRA PRASAD) (RAKESH KUMAR LODHA) JUDICIAL MEMBER ACCOUNTANT MEMBER

ITA NO. 5723 & 5724-MUM-2026 RVN PAPER & BOARDS PRIVATE LIMITED 2017-2018

Mumbai, Dated: 29.09.2026. Sharath, PS. Copy to: The Appellant The Respondent The CIT, Concerned, Mumbai The DR Concerned Bench

//True Copy// By Order Dy/Asstt. Registrar, ITAT, Mumbai.