VINOD KUMAR GOENKA,MUMBAI vs. DY. COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE 8(1), MUMBAI., MUMBAI

आदेश / O R D E R PER AMIT SHUKLA (J.M): The aforesaid appeal has been preferred by the assessee against the order dated 11.02.2026 passed by the learned Commissioner of Income-tax (Appeals)-47, Mumbai [“CIT(A)”], for Assessment Year 2021-22, arising out of the assessment order dated 27.12.2022 passed under section 143(3) of the Income-tax Act, 1961 (“the Act”). The principal issue arising for our consideration relates to the substantive addition of

2 ITA No. 5149/Mum/2026 Vinod Kumar Goenka ₹3,61,00,000 made under section 69A of the Act as alleged unexplained money, stated to represent cash generated from sale of certain agricultural lands and ultimately received by the assessee. The assessee has challenged the said addition, inter alia, on the ground that it rests substantially upon statements recorded during the course of search which contain material inconsistencies and are not supported by independent evidence establishing generation and actual receipt of the alleged cash by him. The applicability of section 69A on these facts has also been challenged. The assessee had filed his return of income on 30.12.2021 declaring total income of ₹27,12,250, which, consequent to the impugned addition, came to be assessed at ₹3,88,12,250.

3 ITA No. 5149/Mum/2026 Vinod Kumar Goenka Awande, had been acquired in earlier years in the names of employees/ex-employees of the group. Shri Atkur, in his statement recorded under section 132(4), stated that funds for acquisition of these lands had been provided through K.G. Enterprises, a group concern, and that the purchases had been made at the instance of late Shri Krishnamurthy Goenka. The Assessing Officer also referred to an Excel sheet found in the laptop containing particulars of loans advanced to certain employees and their family members and noticed that the loan amounts corresponded with the acquisition cost of the agricultural lands. This, coupled with the original land documents being kept at Dynamix House, was treated by the Assessing Officer as indicating that the employees/ex- employees were holding the lands for the Goenka family.

4 ITA No. 5149/Mum/2026 Vinod Kumar Goenka which approximately 31.5 acres were sold to Ms. Suzan Homann and her relatives, 17 acres to Shri Nandlal Narang and approximately 31 acres to Ms. Sarita Sahu, while another 5 acres proposed to be sold to Shri Nandlal Narang remained to be registered. He described his role as one of finding buyers, visiting the land sites with brokers and completing the agreements. Thereafter, in reply to Question No.30, when specifically asked why land was sold to Ms. Suzan Homann and her family members and at what price, Shri Atkur stated that she had spoken to the assessee and that he himself had only been asked to complete the documentation; importantly, he further stated that the amount paid by Ms. Suzan Homann and her family members was at the market rate and that “no cash was involved in the transaction.”

5 ITA No. 5149/Mum/2026 Vinod Kumar Goenka transactions. He clarified that cash was involved only in transactions pertaining to approximately 42 acres; that approximately 5 acres were still pending due to area correction; and that, according to his knowledge, there was no cash involved in approximately 36 acres sold to Suzan, Nicole and Araujo. Finally, when asked in Question No.38 where the cash was kept, Shri Atkur stated that cash of ₹3.61 crore had been generated from the aforesaid land transactions and “the same was given to Mr. Vinod Goenka.” Thus, the Revenue’s allegation as to generation and delivery of ₹3.61 crore in cash principally emanates from this sequence of answers, particularly Questions Nos.35 to 38.

6 ITA No. 5149/Mum/2026 Vinod Kumar Goenka in cash. In Question No.44, Shri Atkur further stated that Shri Kanak Shah had been called to the office and informed about the amount which he would receive and the amount which was required to be returned, and that ₹8 lakh out of such amount had been paid to him. The Assessing Officer also verified that Shri Kanak Shah had made a donation of ₹3 lakh to one of the Goenka family trusts and treated this as another circumstance supporting Shri Atkur’s narration. The Assessing Officer further referred to the ready-reckoner rate appearing in the capital-gain working found in Shri Atkur’s laptop and compared the same with the stated sale consideration. According to him, this comparison indicated involvement of a cash component. Since Shri Atkur had maintained the transaction-related data and was directly involved in finding purchasers and completing the transactions, the Assessing Officer regarded him as the person having intimate knowledge of both the cheque and alleged cash components of the consideration.

7 ITA No. 5149/Mum/2026 Vinod Kumar Goenka to Question No.38 that he understood its contents, but qualified his response by stating that he would answer the specific questions put to him and that only such answers would constitute his confirmation. Thereafter, in Question No.39, the assessee was asked to read the answers given by Shri Atkur to Questions Nos.28 to 40 and state whether they were correct. The assessee confirmed that the total land area was approximately 295 acres and that approximately 79 acres had been sold by Shri Atkur; he, however, expressly denied those portions of Shri Atkur’s answers which suggested that the lands standing in the names of employees were held on his behalf, stating that although he had instructed Shri Atkur to sell the lands, the lands had originally been purchased by his father. In the same answer, however, he stated: “I also confirm that the cash of amount 3.61 Cr was received on the sale of the said lands held by my employees.” It is this part of the assessee’s answer which has been treated by the Assessing Officer, and thereafter by the learned CIT(A), as a direct admission corroborating Shri Atkur’s statement regarding the alleged cash component.

8 ITA No. 5149/Mum/2026 Vinod Kumar Goenka subsequently discarded his mobile phone before reaching his residence; in his statement, he referred to cash-related conversations concerning TDR and agricultural land transactions. In reply to Question No.20 concerning a TDR transaction with Jade Construction Pvt. Ltd., he stated that, apart from the recorded consideration, ₹83 lakh had been received in cash, delivered to him at Dynamix House and thereafter handed over by him to the assessee. The Assessing Officer treated this material as lending further credibility to Shri Atkur’s narration regarding his role in handling cash transactions. He also placed emphasis upon what he perceived to be the assessee’s control over the overall arrangement: the lands had originally been acquired in the names of employees/ex-employees with funds advanced by K.G. Enterprises at the instance of the assessee’s father; original documents remained at Dynamix House; the assessee had admittedly instructed Shri Atkur to find buyers; Shri Atkur was an old and trusted employee having experience in land and TDR matters; and the balance amounts remaining with some employee-holders after payment of capital-gain tax were stated to have been transferred to family trusts as donations. These circumstances, taken cumulatively, led the Assessing Officer to infer that the assessee exercised effective control over the process of disposal of the lands and was the

9 ITA No. 5149/Mum/2026 Vinod Kumar Goenka ultimate beneficial owner of the alleged cash generated therefrom.

10 ITA No. 5149/Mum/2026 Vinod Kumar Goenka had not been discharged. On an overall appreciation of the statements, digital material, funding arrangement, custody of original documents, conduct and role of Shri Atkur, alleged pecuniary benefits, movement of recorded consideration and the assessee’s own answer to Question No.39, the Assessing Officer concluded that the assessee was the beneficial owner of the alleged cash component and, having failed to satisfactorily explain its nature and source, made a substantive addition of ₹3,61,00,000 as unexplained money under section 69A.

11 ITA No. 5149/Mum/2026 Vinod Kumar Goenka registered documents relating to 11 transactions, as reconciled by the assessee from the assessment order itself, came to ₹2,06,37,560. The assessee further emphasised that Shri Atkur had categorically stated in Questions Nos.30 and 37 that no cash was involved in approximately 36 acres sold to Ms. Suzan Homann, Nicole Araujo and related persons. According to the assessee’s reconciliation of the table reproduced by the Assessing Officer, the registered consideration for these transactions aggregated to ₹56,77,560, yielding an average documented rate of approximately ₹1.58 lakh per acre, whereas the registered consideration for the remaining approximately 42 acres aggregated to ₹1,49,60,000, yielding an average documented rate of approximately ₹3.56 lakh per acre. The assessee thus questioned the basis for attributing a substantial cash component to the latter transactions when their documented average consideration itself was substantially higher than that pertaining to the transactions which Shri Atkur had expressly stated to be at market rate and involving no cash.

12 ITA No. 5149/Mum/2026 Vinod Kumar Goenka regarded the material relating to acquisition and sale of the agricultural lands, capital-gain workings and funding trail as assessee’s incriminating evidence and considered the admission under section 132(4) to possess substantial evidentiary value. He further held that the subsequent retraction was delayed and unsupported by contemporaneous material demonstrating coercion or establishing that the original admission was factually incorrect. The inconsistencies pointed out regarding acreage, consideration and rates were regarded by him as ancillary and insufficient to dilute the specific assertion regarding ₹3.61 crore, particularly when the same stood confirmed by the assessee himself. The learned CIT(A) also rejected the grievance regarding cross-examination, proceeding on the observation of the Assessing Officer that no such request had been made during assessment proceedings and holding, in any event, that the addition did not rest exclusively upon Shri Atkur’s statement but was also supported by the seized material and the assessee’s own admission. He further held that physical seizure of cash was not an indispensable condition for invoking section 69A and that, on the cumulative material, the assessee could be regarded as having been found to be the owner of the money. He accordingly upheld the substantive addition of ₹3,61,00,000 under section 69A.

13 ITA No. 5149/Mum/2026 Vinod Kumar Goenka 11. Before us, the learned counsel for the assessee assailed the addition both on its factual foundation and on the applicability of section 69A. At the outset, she submitted that the assessee’s case should not be understood merely as resting upon subsequent retraction of the statements recorded during search. According to her, even if the statements as originally recorded are taken into consideration, the addition cannot survive when they are read in their entirety and tested against the contemporaneous documentary material, the registered sale transactions and the figures recorded by the Assessing Officer himself. She submitted that the digital material found in Shri Atkur’s laptop may contain particulars relating to the agricultural lands, their acquisition, the persons in whose names they stood, loans advanced by K.G. Enterprises and workings relating to capital gains; however, neither the Assessing Officer nor the learned CIT(A) has identified any material which independently records that ₹3.61 crore was received in cash from the purchasers and thereafter delivered to the assessee. According to her, the Revenue has treated material establishing the existence, acquisition and sale of the lands as though it also established the distinct fact of generation and receipt of ₹3.61 crore in cash, whereas the latter allegation emanates essentially from Shri Atkur’s statement

14 ITA No. 5149/Mum/2026 Vinod Kumar Goenka and the answer subsequently obtained from the assessee when that statement was put to him.

15 ITA No. 5149/Mum/2026 Vinod Kumar Goenka described in the immediately preceding answers from which that amount is said to have arisen.

16 ITA No. 5149/Mum/2026 Vinod Kumar Goenka 14. The learned counsel further submitted that the discrepancy assumes greater significance when Shri Atkur’s answer to Question No.35 is compared with the registered conveyances themselves. While Shri Atkur stated that approximately 79 acres had been sold for total consideration of ₹1,78,39,000, the registered consideration in respect of the 11 transactions reproduced by the Assessing Officer, according to the assessee’s reconciliation, aggregated to ₹2,06,37,560. She also referred to Questions Nos.30 and 37, wherein Shri Atkur twice stated that no cash was involved in approximately 36 acres sold to Ms. Suzan Homann, Nicole Araujo and related persons. The registered consideration for these transactions aggregated to ₹56,77,560, giving an average documented consideration of approximately ₹1.58 lakh per acre, whereas the registered consideration for the remaining approximately 42 acres aggregated to ₹1,49,60,000, yielding an average documented consideration of approximately ₹3.56 lakh per acre. Her submission was that if the transactions at the lower documented average rate were themselves described by Shri Atkur as being at market rate and without any cash component, the allegation that transactions reflected at a substantially higher documented average rate nevertheless involved a very substantial cash component required cogent transaction-specific corroboration, which, according to her, was absent.

17 ITA No. 5149/Mum/2026 Vinod Kumar Goenka 15. Coming then to the digital material recovered from Shri Atkur’s laptop, the learned counsel submitted that its evidentiary reach has to be distinguished from the inference ultimately drawn from it. She did not dispute that the laptop contained material relating to the agricultural lands, including particulars of the persons in whose names they stood, loans advanced by K.G. Enterprises, capital-gain workings and other details pertaining to their acquisition and sale. Her contention, however, was that neither the Assessing Officer nor the learned CIT(A) has identified any Excel sheet, cash ledger, notation, receipt, communication, buyer confirmation or other contemporaneous entry which records receipt of ₹3.61 crore in cash from the identified purchasers or its subsequent delivery to the assessee. The capital-gain working, correspondence between the loans and acquisition cost, custody of original documents at Dynamix House, Shri Atkur’s receipt of pecuniary benefits of ₹10.50 lakh, the payment of ₹8 lakh through the accounts of his relatives, the donation of ₹3 lakh by Shri Kanak Shah to a family trust and the assessee’s role in directing Shri Atkur to find purchasers may, according to her, establish the relationship of the group with the lands and Shri Atkur’s involvement in their disposal; but none of these circumstances independently establishes that ₹3.61 crore was paid in cash by the purchasers and ultimately delivered to the assessee. Likewise, the ready-

18 ITA No. 5149/Mum/2026 Vinod Kumar Goenka reckoner values and capital-gain working could at best furnish a basis for further enquiry into the adequacy of the recorded consideration, but could not establish the actual payment and receipt of the precise amount of ₹3.61 crore in the absence of transaction-wise material.

19 ITA No. 5149/Mum/2026 Vinod Kumar Goenka underlying computation of that very figure does not reconcile with the acreage, stated rate, cheque consideration and registered documents, the answer cannot be viewed in isolation from those objective inconsistencies. She therefore submitted that the assessee’s answer is undoubtedly relevant evidence, but cannot dispense with examination of whether the precise amount so stated is independently borne out from the underlying transactions.

20 ITA No. 5149/Mum/2026 Vinod Kumar Goenka possibility of cash dealings elsewhere cannot fill the evidentiary gap in establishing the quantum, source and actual delivery of the alleged cash arising from these particular land transactions.

21 ITA No. 5149/Mum/2026 Vinod Kumar Goenka 05.04.2022 retracting the statements recorded during search, though the learned CIT(A) has questioned whether the affidavits were actually lodged with the Investigation Directorate or the jurisdictional Assessing Officer on that date. She, however, emphasised that the assessee does not seek deletion merely on the strength of the retraction; even if the original statements are accorded their due evidentiary weight, the precise allegation of receipt of ₹3.61 crore, according to her, does not withstand verification against the underlying figures and objective material. As regards cross- examination, she specifically controverted the observation in the assessment order that no such request had been made and drew our attention to the assessee’s reply dated 20.12.2022, wherein it was expressly stated that no opportunity to cross-examine Shri Atkur had been afforded and that the assessee had not been permitted to confront him regarding the alleged delivery of cash. She submitted that the factual premise adopted by the Assessing Officer on this aspect was therefore contrary to the written response forming part of the assessment proceedings. Nevertheless, she treated both retraction and denial of cross-examination as additional circumstances and maintained that the more fundamental infirmity lay in the absence of independent evidence establishing the alleged cash receipt itself.

22 ITA No. 5149/Mum/2026 Vinod Kumar Goenka 20. In support of the aforesaid submissions, the learned counsel also referred to the judicial authorities cited in the written submissions concerning the evidentiary use of disputed third-party statements, the requirement of cross- examination where such statements are relied upon adversely, and the conditions for invoking section 69A. Reliance was placed, inter alia, upon CIT v. Ravi Kumar in the context of the statutory requirement that the assessee must be found to be the owner of the money sought to be assessed, and upon Andaman Timber Industries and Odeon Builders Pvt. Ltd. in support of the contention regarding reliance upon third-party material without affording an effective opportunity to test its correctness. The learned counsel accordingly submitted that, considered either on the evidentiary material or on the requirements of section 69A, the addition of ₹3.61 crore could not be sustained.

23 ITA No. 5149/Mum/2026 Vinod Kumar Goenka transactions. The original documents remained at Dynamix House; Shri Atkur was admittedly an old and trusted employee entrusted with finding purchasers and completing the transactions; the assessee himself admitted that he had instructed Shri Atkur to sell the lands; and the material regarding pecuniary benefits paid to Shri Atkur and movement of certain amounts towards a family trust further demonstrated, according to him, the assessee’s effective control over the arrangement. The learned DR also relied upon Shri Atkur’s conduct in discarding his mobile phone and his statements regarding other cash transactions as circumstances lending credibility to his narration. According to him, these were not isolated pieces of evidence but formed a coherent chain which had to be appreciated cumulatively.

24 ITA No. 5149/Mum/2026 Vinod Kumar Goenka consciously accepted certain portions of Shri Atkur’s statement and expressly disagreed with others. In particular, while denying that the lands standing in the names of employees were held on his behalf, he nevertheless stated that he had instructed Shri Atkur to sell those lands and specifically confirmed that cash of ₹3.61 crore was received on their sale. According to the learned DR, the selective nature of the answer itself demonstrates that the assessee understood the questions and was capable of accepting or denying individual allegations; consequently, his specific confirmation regarding ₹3.61 crore could not subsequently be treated as an inadvertent or mechanically recorded answer.

25 ITA No. 5149/Mum/2026 Vinod Kumar Goenka breakup between cheque and cash were not sufficient to discredit the central assertion regarding receipt of cash, particularly when that assertion had subsequently been confirmed by the assessee himself. According to the learned DR, the transactions involved numerous parcels standing in the names of different employees/ex-employees and sold to different purchasers and, therefore, some variation in narration could not be treated as determinative when weighed against the cumulative material emerging from the search.

26 ITA No. 5149/Mum/2026 Vinod Kumar Goenka not displace the original sworn admission unless the assessee first demonstrated through cogent material that what had originally been admitted was incorrect.

27 ITA No. 5149/Mum/2026 Vinod Kumar Goenka as an integrated whole and that the addition of ₹3.61 crore deserved to be sustained.

28 ITA No. 5149/Mum/2026 Vinod Kumar Goenka material found during search, the registered transactions and the surrounding circumstances relied upon by the Revenue, it can reasonably be held that the specific sum of ₹3.61 crore was in fact generated as unaccounted cash from the identified agricultural-land transactions and was thereafter received and owned by the assessee so as to sustain the addition under section 69A. It is from this perspective that the evidence has to be examined.

29 ITA No. 5149/Mum/2026 Vinod Kumar Goenka finding buyers, visiting the sites and completing the transactions and had also received pecuniary benefits in connection with the sale process. Thus, the material brought on record does establish a substantial nexus of the assessee/group with the agricultural lands, the manner in which they had originally been acquired and controlled, the assessee’s role in their subsequent disposal and Shri Atkur’s active involvement in effecting the transactions. These are material circumstances and we do not propose to dilute their evidentiary significance.

30 ITA No. 5149/Mum/2026 Vinod Kumar Goenka assessee. No purchaser has been shown to have independently confirmed payment of the alleged cash, nor has any buyer-wise or transaction-wise material been referred to which quantifies the cash component attributable to the individual sale transactions. The material relating to K.G. Enterprises, custody of the original documents, capital-gain workings and the assessee’s role in directing the sales undoubtedly corroborates the surrounding arrangement and the assessee’s connection with the lands; but corroboration of those facts cannot, without a further evidentiary link, automatically become corroboration of the distinct proposition that precisely ₹3.61 crore of unaccounted cash was generated and ultimately received by the assessee. This, in our view, is the principal evidentiary distinction which requires to be kept in perspective.

31 ITA No. 5149/Mum/2026 Vinod Kumar Goenka that cash of ₹3.61 crore was received on sale of the said lands. We are conscious that this answer constitutes the strongest circumstance in favour of the Revenue. The assessee had selectively accepted certain portions of Shri Atkur’s statement and expressly disagreed with others, which itself indicates that his answer cannot simply be regarded as a mechanical affirmation of everything stated by Shri Atkur. We have, therefore, accorded due evidentiary weight to this admission and do not discard it merely because the assessee subsequently sought to retract therefrom. At the same time, the figure of ₹3.61 crore appearing in the assessee’s answer is the very figure originating from Shri Atkur’s preceding statement; it is not shown to have been independently derived from any document, account or computation furnished by the assessee. An admission is undoubtedly evidence of considerable weight, but where a precisely quantified sum is sought to be brought to tax, its probative value has necessarily to be considered together with the objective transaction material from which that amount is stated to have arisen.

32 ITA No. 5149/Mum/2026 Vinod Kumar Goenka After reducing the stated cheque consideration of ₹1,19,25,000, the balance works out to ₹3,42,75,000 and not ₹3.61 crore; conversely, ₹1,19,25,000 together with the alleged cash component of ₹3.61 crore aggregates to ₹4,80,25,000, which exceeds the consideration arrived at by applying the stated rate. Further, Shri Atkur had stated that approximately 79 acres altogether were sold for ₹1,78,39,000, whereas the registered consideration in respect of the 11 transactions, as reconciled from the material reproduced in the assessment order, aggregates to ₹2,06,37,560. Even the show-cause notice referred to an apportioned amount of ₹3,57,59,359, whereas the ultimate addition was made at ₹3.61 crore. We hasten to add that these discrepancies, by themselves, neither justify rejection of Shri Atkur’s statement in its entirety nor establish that no cash whatsoever could have passed in the transactions. Statements recorded during search may contain approximations and every variation in acreage or consideration cannot be elevated into a fatal contradiction. Their relevance here is narrower: where the addition is for a specific quantified sum and the figures from which that amount is stated to arise do not themselves fully reconcile, independent transaction-specific corroboration of the precise amount assumes greater importance. It is in this context, and not as an exercise in finding defects in individual answers, that these discrepancies have been considered by us.

33 ITA No. 5149/Mum/2026 Vinod Kumar Goenka

34 ITA No. 5149/Mum/2026 Vinod Kumar Goenka control over the transactions. They were undoubtedly sufficient to warrant a detailed investigation into whether the recorded consideration represented the entirety of the transactions. However, none of these circumstances independently identifies or quantifies ₹3.61 crore as the cash component actually paid by the purchasers and delivered to the assessee.

35 ITA No. 5149/Mum/2026 Vinod Kumar Goenka consideration are shown, on the material brought on record, to have generated the specific sum of ₹3.61 crore which was thereafter received and owned by the assessee. On this precise aspect, the corroborative material, though substantial as regards the surrounding arrangement, does not extend to independent corroboration of the amount assessed.

36 ITA No. 5149/Mum/2026 Vinod Kumar Goenka referred to; and the precise figure emerging from the statements does not fully reconcile with the transaction figures. The statements, particularly the assessee’s answer to Question No.39, undoubtedly constitute material against him, but the surrounding documentary evidence principally establishes the assessee’s nexus with and control over the land transactions rather than the separate fact of receipt and ownership of this specific sum. Thus, the difficulty is not merely that the cash was not physically found; it is that the cumulative material does not adequately bridge the evidentiary gap between control over the underlying transactions and ownership of the particular money sought to be assessed.

37 ITA No. 5149/Mum/2026 Vinod Kumar Goenka contemporaneous material establishing coercion. We need not carry that controversy further. Even if, for the purpose of examining the Revenue’s case at its highest, the retraction is kept aside and the original statements are taken at their full evidentiary worth, the central difficulty remains that the precise cash receipt of ₹3.61 crore is not independently borne out from the transaction material and its quantification itself does not fully reconcile with the underlying figures. Conversely, had the particular cash receipt been independently and convincingly corroborated, neither the subsequent retraction nor the mere absence of physical cash would by itself have justified deletion. Our conclusion, therefore, rests upon cumulative appreciation of the substantive evidence and not upon any isolated procedural or evidentiary infirmity.

38 ITA No. 5149/Mum/2026 Vinod Kumar Goenka unaccounted cash from the identified transactions and thereafter received and owned by the assessee. The documentary material does not independently record such receipt; no transaction-wise trail of payment and delivery has been identified; the registered transactions do not furnish independent corroboration of the alleged cash component; and the precise quantum emerging from the statements itself does not fully reconcile with the underlying transaction figures. The assessee’s answer to Question No.39 has received our particular consideration and has been accorded due evidentiary weight, but the reiteration of the same figure originating from Shri Atkur’s underlying statement cannot, in the absence of adequate transaction-specific corroboration, by itself supply the missing link in the evidentiary chain. There is, in our considered view, a material distinction between circumstances which legitimately warrant an enquiry and evidence sufficient to sustain a substantive addition of a precisely quantified amount under a deeming provision. While the former is clearly present in the present case, the latter, insofar as the specific sum of ₹3.61 crore is concerned, remains inadequately established. We accordingly hold that the addition of ₹3,61,00,000 made under section 69A cannot be sustained on the material brought on record.

39 ITA No. 5149/Mum/2026 Vinod Kumar Goenka section 69A is directed to be deleted. Ground No.2 raised by the assessee is accordingly allowed. Ground No.1, being general in nature and no separate jurisdictional infirmity having been pressed before us, does not call for independent adjudication; Ground No.3, being general and residuary, also requires no separate adjudication.

Order pronounced on 28th September, 2026.

Sd/- Sd/- (ARUN KHODPIA) (AMIT SHUKLA) ACCOUNTANT MEMBER JUDICIAL MEMBER Mumbai; Dated 28/09/2026 KARUNA, sr.ps

Copy of the Order forwarded to : 1. The Appellant 2. The Respondent. 3. CIT 4. DR, ITAT, Mumbai 5. Guard file. BY ORDER, //True Copy//

(Asstt. Registrar) ITAT, Mumbai