DCIT CEN. CIR. - 40, MUMBAI vs. M/S. DOLPHIN OFFSHORE ENTERPRISES LTD., MUMBAI

IN THE INCOME TAX APPELLATE TRIBUNAL MUMBAI BENCH “D”, MUMBAI

BEFORE SHRI AMIT SHUKLA, HON'BLE JUDICIAL MEMBER AND SHRI S. RIFAUR RAHMAN, HON'BLE ACCOUNTANT MEMBER

IT(SS)A NO.680/MUM/2003 (BLOCK PERIOD 01.04.19990 TO 16.01.2001) DCIT – Central Circle – 40 V. M/s. Dolphin Offshore Enterprises (I) Ltd., 1001, Raheja Centre Old CGO Bldg. Annexe, 6th Floor 214, Nariman Point Room No. 606, M.K. Road Mumbai - 400021 Mumbai PAN: AAHFN4619F (Appellant) (Respondent)

IT(SS)A NO.3/MUM/2019 (BLOCK PERIOD 01.04.19990 TO 16.01.2001) ACIT – Central Circle – 3(1)(1) V. M/s. Dolphin Offshore Enterprises (I) Ltd., 1001, 10th Floor, Raheja Centre Room No. 607, 6th Floor 214, Nariman Point Aayakar Bhavan, M.K. Road Mumbai - 400021 Mumbai - 400020 PAN: AAHFN4619F (Appellant) (Respondent)

Assessee Represented by : None Department Represented by : Shri T. Shankar

Date of Hearing : 10.10.2022 Date of Pronouncement : 04.01.2023

2 IT(SS)A NO.680/MUM/2003 IT(SS)A NO.3/MUM/2019 M/s. Dolphin Offshore Enterprises (I) Ltd., O R D E R PER S. RIFAUR RAHMAN (AM)

3 IT(SS)A NO.680/MUM/2003 IT(SS)A NO.3/MUM/2019 M/s. Dolphin Offshore Enterprises (I) Ltd., Since none appeared on behalf of the assessee, the bench decided to go ahead with the case with the assistance of the Ld.DR.

4 IT(SS)A NO.680/MUM/2003 IT(SS)A NO.3/MUM/2019 M/s. Dolphin Offshore Enterprises (I) Ltd., o CIT(A) has accepted that all other entries are found recorded. o CIT(A) has categorically accepted: "In that light there is a strength in AO's observation that the same could be treated as unexplained expenditure and addition would be called for u/s 69C of the Act". o However, only in view of the proviso to S.69C inserted w.e.f. 01.04.1999, he has allowed the expenditure as business income by holding that "it means that the unexplained business expenditure of Rs.75 lacs even if it is disallowed u/s 69C the same would be allowable as business expenditure and the net effect of addition to the total income would be nil for the earlier period". o The above finding that it is allowable as business expenditure is not sustainable as the assessee has a heavy burden to show that it is actually allowable u/s.37. In the case of Swadeshi Cotton Mills Ltd., 63 ITR 57, the Hon'ble Apex Court has held as under: "The question as to whether an amount claimed as expenditure was laid out or expended wholly and exclusively for the purpose of such business, profession or vocation has to be decided on the facts and in the light of the circumstances of each case". In the case of Premier Breweries Ltd., 279 ITR 51, 196 CTR 496 (Ker HC), it has been held that: "In order to be eligible for an allowance under section 37, certain conditions are to be fulfilled for deduction of expenditure wholly and exclusively for the purpose of business: (i) The expenditure must not be governed by the provisions of sections 30 to 36 and 80VV (B) The expenditure must have been laid out wholly and exclusively for the purpose of business of the assessee. (ii) The expenditure must not be personal in nature. (iv) The expenditure must not be capital in nature. It is well settled that burden of proving the above mentioned ingredients is on the assessee. Before the assessee could become entitled to allowance under section 37, assessee must satisfy the assessing authority the entire purpose for which the amount is spent" In the case of Siddho Mal & Sons, 122 ITR 839, the Hon'ble Delhi HC has held as under: "4. The word "wholly" in the above provision refers to the quantum of expenditure but the word "exclusively" appears to refer to the motive, objective and propose of the expenditure and in our opinion gives jurisdiction to the concerned authorities to examine the expenditure from this stand point... Thus, allowance of Rs.75

5 IT(SS)A NO.680/MUM/2003 IT(SS)A NO.3/MUM/2019 M/s. Dolphin Offshore Enterprises (I) Ltd., lakhs as allowable business expenditure is not tenable, as the evidence for the same has to be led by the assessee. Ground No.2  Under dispute: Rs. 1,37,68,229 addition  AO order: Page 8-9, para (vii)  CIT(A) order: para 9 and sub-paras in pages 18-27 o In para 9.21, the CIT(A) has upheld the additions to the extent of Rs.36,46,167/- by holding the same as peak balance.  The AO's order is fully relied upon. The ground raised is also self-explanatory. IT(SS) No. 03/Mum/2019 [Penalty] Ground No.1 & 2: Inter-linked  CIT(A) has confirmed the penalty only to the extent of additions confirmed by him. He has ignored that Hon'ble ITAT has confirmed the action of the AO and that the restoration of appeal pursuant to MA filed by the assessee is no good ground for deletion of penalty  Once the above quantum appeal is decided and contentions of Revenue are accepted, the penalty ought not to have been deleted by the CIT(A)  The grounds of the AO are relied upon.  PRAYER: It is humbly prayed that the appeals of the Revenue be allowed.”

“1) On the facts and in circumstances of the case and in law the Ld.CIT(A) erred in deleting the disallowance of 75 lakhs made for the

6 IT(SS)A NO.680/MUM/2003 IT(SS)A NO.3/MUM/2019 M/s. Dolphin Offshore Enterprises (I) Ltd., A.Y.1998-99 covered in the block assessment considering the facts that the reasons for which he has confirmed the similar disallowance of the incriminating nature of entries pertaining to Rs.30 lakhs, the same equally holds good for incriminating nature of entries of Rs.75 lakhs also. There is no necessity of invoking proviso to Sec.69 C to sustain the additions, the main sec.69C is sufficient to support the additions. 2) On the facts and circumstances of the case, and in law the Ld.CIT(A) erred in deleting addition of Rs.1,37,68,229/- which were based on the entries found in the diary seized during the course of search action and considering the facts that plea taken by the assessee before the Ld.CIT(A) was after thought and different then stating during the course of the search. wherein it was explained that the entries mentioned in the diary are covered under disclosure of Rs.3 crores made by them. Further the assessee has failed to produce the evidence to prove the contention that the payments were made by way of advances and no such expenditure was done, although the terms used in the diary are "receipt & payments". The assessee neither could prove the source of receipt nor could they prove the genuineness of the expenses. 3) The Appellant prays that the order of the CIT(A) on the above grounds be set aside and that of the Assessing Officer be restored. 4) The Appellant craves to amend or alter any grounds or add new grounds which may be necessary.”

7 IT(SS)A NO.680/MUM/2003 IT(SS)A NO.3/MUM/2019 M/s. Dolphin Offshore Enterprises (I) Ltd., relating to the period 1.4.98 to 31.10.98. It was submitted that these are cost center reports of the relevant periods of the contract relating to Samudra Sarvekshaka (ship) which the assessee was managing for ONGC. It was submitted that all the figures in those statements tallied with the books of the company excepting for two figures, one relating to the miscellaneous expenditure and the other relating to financing cost. It was explained that these two papers are prepared essentially for submission of tenders for renewal of contract of the said Samudra Sarvekshaka (Ship) from April, 1999 onwards. These figures are estimates and are in round figures. It was further explained that these are probable expenditure to be incurred in case the contract is awarded for future work. But the actual numbers recorded in the books are smaller figures and not matching with the estimated figures considered in the tender. However, in the statement recorded with the Joint Managing Director of the company wherein he has disowned the above papers and he is not the person who prepared the same. It was also submitted that for the other tenders the expenses were recorded at ₹.75 lakhs which is similar to the submissions made for the tender. However, Assessing Officer did not accept the submissions of the assessee and disallowed the miscellaneous expenditure and financial expenditure which was shown in the above said seized papers.

8 IT(SS)A NO.680/MUM/2003 IT(SS)A NO.3/MUM/2019 M/s. Dolphin Offshore Enterprises (I) Ltd., 7. Aggrieved assessee preferred an appeal before the Ld.CIT(A) and Ld.CIT(A) after considering the submissions of the assessee gave a relief to the assessee with the following observations: - “6.15 If there was any unexplained expenditure made the same could have had several implications. It could have lead to creation of unexplained, undisclosed assets or abstentious/luxurious living on the part of the directors etc. or creation of bogus assets etc. The search operation or the post search investigation has not brought out any such finding, atleast the same is not available on record. The AO it seems has not tried to link his propositions on the issue with any factual findings of the search or post search enquiry as corroborative evidence to justify the addition. 6.16 One may also refer to the provisions of the block assessment as give in 158BB(1) wherein it is stated that the undisclosed income for the block period has to be determined on the basis of evidence found as a result of search or any other material or information that are with the AO gathered relatable to such evidence. In the instant case the evidence found relates to those two entries of Rs.30 lacs and Rs.75 lacs which was not available in the regular books. These evidences should have per se led to further inquiry/investigation which would have unearthed its implication which may be in form of undisclosed assets etc., as detailed in the earlier paragraph. But such is not the finding of the AO but the AO have preferred the easier option of straightway linking it to the disclosure of income made during the course of search. He had preferred simply to ignore the explanation and other things that were furnished or available to him. Such an action on the part of the AO seems to be not justified. These nothings had to be considered in light of the circumstantial evidence, the strongest circumstantial evidence in favour of the assessee being the assessee not having debited same to the accounts which were filed along, with the tax return. The normal probability would support the contention that if the assessee would have incurred such expenditure the same would have been booked for claim of deduction. Excepting for the statement of Shri. Satpal Singh at the time of search operation there is nothing available on record to suggest that these expenditure were disallowable under Income Tax Act. Since these entries were quite large the AO atleast should have attempted to decipher and link it to any such alleged disallowable expenditure. Nothing is also available on record in support of the said proposition. In that light the preponderance of probabilities was in favour of the assessee that such an expenditure was not there and

9 IT(SS)A NO.680/MUM/2003 IT(SS)A NO.3/MUM/2019 M/s. Dolphin Offshore Enterprises (I) Ltd., these were mere estimate, particularly when there is no corroborative material to support the finding of the AO that these entries represented factual expenditure. In this connection the assessee had relied upon following decisions ITAT: 1. Pooja Bhatt vs. ACIT 73 ITD 205 (Mumbai) 2. S.K.Gupta vs. DCIT 63 TTJ 532 (Delhi) 3. Deepchand & Co., vs. ACIT 51 TTJ 421 (Mumbai) 4. ACIT vs. Sushiladevi S.Agarwal 50 ITD 524 (Ahmedabad) 6.17 Secondly, the AO found from scrutiny that all the entries in the said cost center report tallied with the figures of the books of accounts excepting the figure relating to the said misc., expenditure. Thus AO was of the view that atleast for the sake of consistency a seized document must be read in one particular fashion and in that light this figure of Rs.30 lacs and Rs.75 lacs should also be considered as misc., expenditure relating to the said project and further more the same were treated as unexplained expenditure for the respective period. 6.18 Coming to this particular reasoning of the AO that the entire documents have to be read in a particular fashion and accordingly the entries of Rs.75 lacs and Rs.30 lacs should be considered as expenditure in the same way as other expenditures that are available in the said cost center report, it is observed that these two figures are different in several ways. First of all, as explained by the assessee these figures are in round figures whereas all other entries are in odd figures. Secondly as per the audited balance sheet the figure of misc., expenses was in the order of Rs.14,000 to Rs.15,000/-. Thirdly, it is also noticed that this particular entry relating to misc.. expenditure did not have an account code or cost center sub code and it was in round figure. The financing cost was also having similar characteristic of not having any account code or cost center sub code yet the AO preferred to keep silent on the same. It is not clearly understood as to whether the AO accepted the assessee's explanation on the issue of debitability of financing cost and preferred to reject the explanation of the assessee on the issue allowability/deductibility of the said misc., expenditure. 6.19 Coming to the explanation of the assessee that the cost center report relates to particular project and the account sub heads are relating to specific heads of expenditure relating to the project and the financing cost and miscellaneous expenditure (without accounting heads or sub-heads) are apportioned over different projects undertaken by the assessee on certain basis, the same appears to be logical and reasonable. The same explanation as was filed before me was filed before the AO. However, the AO has not

10 IT(SS)A NO.680/MUM/2003 IT(SS)A NO.3/MUM/2019 M/s. Dolphin Offshore Enterprises (I) Ltd., commented on the correctness or reasonableness of the explanation filed but has preferred to ignore the same or atleast remain silent on the issue. The assessee's explanation that the tender was floated some times in November'98 and consequently the assessee had to draw the accounts upto October'98 to complete its financial bid appears to be reasonable and an acceptable proposition. In that light the assessee's explanation should have been examined/evaluated instead of simply glossing over the same. Since the expenditure involved was to the extent of Rs.75 lacs and Rs.30 lacs the AO atleast should have collected or mustered certain corroborative evidence conducting necessary enquiry and investigation, but the AO preferred solely to rely on the statement of Shri. Satpal Singh taken during the search operation. This action of the AO looks logically inconsistent to be acceptable.”

11 IT(SS)A NO.680/MUM/2003 IT(SS)A NO.3/MUM/2019 M/s. Dolphin Offshore Enterprises (I) Ltd., and the peak positive balance was of ₹.4,42,882/- as on 24.01.1998. It was submitted that though the transactions were for genuine business purposes and the assessee's explanation of giving of advances, and receiving of vouchers etc., describes correct factual position yet the assessee to avoid further dispute offered the peak negative balance for taxation as undisclosed income for the block period. However, Assessing Officer rejected the same and the receipt totaling to ₹.1,74,14,396/- be treated as assessee's undisclosed income and accordingly Assessing Officer brought to tax entire sum of set off above.

“9.7 It is a fact that these advances, are rotating and these debit, credits are linked and the resultant fluctuating balance are both negative as well as positive. It has record of ail balance as well. This depend on the quantum of the money advanced as also the adjustment of the same at particular point of time. It means that the debits and the credits do explain cash others existence in turn. It may mean that the payments manning dido by advances are from the receipts of money received from any possible sources such as scrap sale etc. It may be that these advances do get adjusted against receipts of vouchers/salary receipt/bills etc. It was also a matter of record that the diary for the relevant period starts with a negative cash balance of little over Rs 11 lacs and as the advances are given the so called negative balance keeps on increasing and subsequently

12 IT(SS)A NO.680/MUM/2003 IT(SS)A NO.3/MUM/2019 M/s. Dolphin Offshore Enterprises (I) Ltd., on receipt of vouchers or money the negative balances are reduced. In this particular fashion the entries/balances of the diary moves along and has a peak negative balance of Rs 36,46,167/-. It is also a matter of record that these entries could not be explained on 1 to 1 basis and the excess outgo of the cash in form of these negative balance could not be explained to the satisfaction of the AO. However the peak negative balance has been offered as undisclosed income. This negative balance is an intangible asset which is available for explaining any subsequent credit. The respective figures of such subsequent credit were much lesser than the said peak negative balance. This fact was somehow not appreciated by the AO. All the negative entries prior to the peak negative entry can be explained to be part of the peak negative balance as the entries are rotating. If one looks at the diary such negative peaks of earlier period in turn will explain all other credit of the earlier period. More over the perusal of the diary indicates that there are lot of contra entries meaning thereby the advances have been given and voucher have been received and accounts have been squared off on the sue day in respect of the said entry. In that light the AO's observation on the explainability of credits in name of Shri. Navpreet and others do not reflect the correct position. It was submitted that this was what was explained to the authorities below but somehow the AO preferred to disbelieve the explanation. It is well settled principle that the explanation of the assessee should be accepted if there is no material to disbelieve it. It was further submitted that the inability of the AO to verify the correctness of the submission of the appellant will not entitle him to reject the explanation of the assessee on the issue. 9.8 As indicated earlier these payments/receipts are related to the regular business of the assessee particularly to the issue of advances given to the crew members, certain other misc,, expenditure and receipts. It is not clearly understood what evidence was required by the AO which would have satisfied him that these advances were no actual expenditure considering that the trade of the assessee required payment of such advances to the crow member and the same requires subsequent adjustments also. The control have to be maintained by the concerned employee by keeping informal record of the same. Having explained the position that the entries are rotating it is not clearly understood how the AO has taken the same to be receipt of money from various persons The entries in the later part the diary relating to Satpal, Navpreet has lot of contra entries. It was also explained that Shri Navpreet Singh being the person incharge of finance, was proving the accounting of these advances given so most of the entries on receipts side are recorded against his name. Since in his absence the same was being managed by Shri.

13 IT(SS)A NO.680/MUM/2003 IT(SS)A NO.3/MUM/2019 M/s. Dolphin Offshore Enterprises (I) Ltd., Satpal and Others, certain entries in the receipts side wore also recorded against their names also. This theory of advances, the adjustments and the rotating balance has been the stand of the assessee before the investigation wing, the AO as well as before the undersigned. Consistently the assessee was maintaining that this was a rotating account and the so called payment and receipt are in circulation and intricately licked. The squaring up off account after each entry indicated that these debit credits are intricately linked and related to a common phenomena and has to be read together. It is also matter of record the assessee has taken a consistent stand that it would not be possible to link these receipts/ payments with the figures of regular books on 1 to 1 basis. But the fact remains that the maximum unexplained amount could only be the peak negative balance of that Rs 36,46,167- which is the maximum possible outgo and this in turn would explain any possible discrepancy. In that connection the AD have to view the account of the diary as a whole both debit/credit taken together which includes lot of entries indicating lot of outgo and lot of inflow relating to several persons. It cannot be compartmentalized personwise like Navpreet, Satpal etc. To that extent it was argued that the AO's observation that Shri. Navpreet Singh has received Its. 1,32,90,460/- is misplaced. Since it was not the case of mere receipt of money as understood by the AO no way it could be explained as to where from the same would have come. In fact the alleged receipts are contra entries against the advances given. Similar is the position with regard to the account of Satpal, Kohli etc. In that light it was argued that the AO has based his conclusion on wrong appreciation of the issue and lack of understanding of the assessee's explanation in proper prospective. 9.9 it was further submitted that the receipts from sale of scrap, sale of car etc., would have been verified from the books of the assessee which was available in the back up CD taken during the course of search operation by the AO preferred to base his conclusion on conjecture and surmise rather making any effort to verify these entries. It was submitted that the AO’s comment and the plea of the appellant under appeal may be summarized as given below: Assessee’s Plea under S.No Comments as per Assessing Officer appeal 1) There is a negative cash balance of Rs. 11,35,731.30 as The balance is the amount of the payments given increases the balance while the advance given still be accounted receipts decrease the balance. for or cash to be returned. Advances given, which are shown as payments, increase the balance. Cash returned, or statement of expenses incurred/salary advanced receipts returned to the office,

14 IT(SS)A NO.680/MUM/2003 IT(SS)A NO.3/MUM/2019 M/s. Dolphin Offshore Enterprises (I) Ltd., Assessee’s Plea under S.No Comments as per Assessing Officer appeal reduce the advance and are shown as receipts. 2) In the statement given by Shri Satpal Singh has explained Shri Satpal Singh is the joint the entries therein and the negative cash balance is the Managing Director (Technical) shortfall in the main cashbook. and as such is responsible for the execution of contracts. He is not responsible for the accounts and book keeping functions of the company, and therefore has insufficient knowledge in these matters. It is incorrect that there is any negative balance or that there is any shortfall in cash in the main cash book. The balance is the amount of advances still to be accounted for, and the balance in the diary will always be less then the cash on hand as per the main cash book. This can be checked for any date. 3) What is important in the dairy is the receipt of money Shri Navpreet Singh is the Joint from various persons, the source of which has not been Managing Director (Finance) proved. For example, amounts aggregating to Rs. and is responsible for the 1,32,90,460/- have been received from Shri Navpreet Finance and accounting Singh. But how and where he has arranged this money functions of the company. As has not been explained. Same is the position in regard to such, all statement of expenses, receipts shown from Shri Satpal, Adm. K. Singh, salary advances etc are required Miscellaneous, Kolhi and withdrawals etc. to be approved by Shri Navpreet Singh. After he has approved the same, he hands over all the vouchers to the Cashier, who records the amount of advances, adjusted and authorised by the person submitting the vouchers. In most cases it is Shri Navpreet Singh. However, in his absence, this would be done by Shri Adm. K. Singh, Chairman and Managing Director, or Shri Satpal Singh who is also, the Joint Managing Director. Entries in the names of other individuals would normally indicate that they have returned the cash back that they have with them. With regard to the source of money, it may be noted that these are actually receipts in the nature of contra entries, and

15 IT(SS)A NO.680/MUM/2003 IT(SS)A NO.3/MUM/2019 M/s. Dolphin Offshore Enterprises (I) Ltd., Assessee’s Plea under S.No Comments as per Assessing Officer appeal accordingly there is no source of money coming in. A review of the diary would clearly indicate some of these contra entries. 9.10. The Appellant has furnished before the undersigned certain relevant extracts from its cash books to substantiate its claim that the receipt of money shown in the diary was nothing but adjustment by way of vouchers submitted by employees who had been advanced money earlier, out of payments shown in the diary. It is just to explain the similar claim made by the Joint Managing Director before the Dy. Director of Income Tax (Investigation) and also the submissions made before the Assessing Officer during the course of assessment proceedings. It was submitted that the details furnished before the undersigned have been called from the books of accounts regularly maintained by the appellant and also produced before the Assessing Officer from time to time during the course of assessment proceedings. This, therefore, cannot be treated to be an additional evidence. The details have been furnished only to buttress the claim made during the course of search proceedings and during the assessment proceedings. 9.11 The appellant, therefore, submitted that the diary does not contain any undisclosed receipts, but merely is an account of advances given and accounted for. It is for this reason, that the balance has been brought down to nil, when all advances have been accounted for or recovered. It was accordingly submitted that the Assessing Officer's decision to add Rs. 1,74,14,396/- as undisclosed income was erroneous and should be reversed. 9.12 It was also submitted that the particular document has to be read and understood as an indivisible whole. The present diary has both credit and debit entries. The credit entries are as correct or as erroneous as the debit entries. Even otherwise, the fact remaining that the entries are rotating the credit and debit entries have no independent existence. It also may mean that if the credit entries the sum total of them is receipt of money then the debit entries, the sum total of them are payments. If the receipts are taken to be the correct amount of money which has been there into assessee's business and considered as income, in that eventuality the AO cannot ignore the existence of the debit entries as a whole. In that light the AO would be authorized to tax only the difference between incoming and outgoing more so when the entries are intricately related. In that eventuality the difference which is less than sum of Rs.2 lacs can be taxed as undisclosed income. This figure would well be covered by

16 IT(SS)A NO.680/MUM/2003 IT(SS)A NO.3/MUM/2019 M/s. Dolphin Offshore Enterprises (I) Ltd., the disclosure of Rs.36,46,167/- that has been made by the assessee against the same diary. 9.13 In view of the above it was contended that the assessee's explanation should be accepted and addition over Rs.36,46,167/- should be deleted.”

17 IT(SS)A NO.680/MUM/2003 IT(SS)A NO.3/MUM/2019 M/s. Dolphin Offshore Enterprises (I) Ltd., are advances for the different purposes highlighted by the assessee, due to difficulty in correlating the entries in the diary and the Books of Accounts of the assessee and to find peace, assessee itself offered a peak negative balance of ₹.36,46,167/- as undisclosed income. However, Assessing Officer without appreciating the transactions entry by entry he proceeded to consider only the receipt totaling ₹.1,74,14,396/- and not considered the payment. In our considered view when the seized statement is considered the content in the seized document should be appreciated as per the contents and nature of the seized paper. Assessing Officer has considered only the receipt overlooking the payments. Therefore, we are inclined to accept the findings of the Ld.CIT(A) who has sustained only the peak negative balance. Therefore, there is no prejudice caused to the revenue and we are inclined to accept the findings of the Ld.CIT(A). Accordingly, ground raised by the revenue are dismissed.

IT(SS) NO. 03/MUM/2019

18 IT(SS)A NO.680/MUM/2003 IT(SS)A NO.3/MUM/2019 M/s. Dolphin Offshore Enterprises (I) Ltd., appeal filed by the Revenue. Aggrieved with the deletion of penalty by the Ld.CIT(A) with the observation that the quantum appeal is pending before ITAT. Since we have decided the issue in favour of the assessee and against the revenue we are inclined to dismiss the penalty appeal filed by the Revenue. Therefore, the appeal filed by the revenue is dismissed.

Order pronounced in the open court on 04th January, 2023

Sd/- Sd/- (AMIT SHUKLA) (S. RIFAUR RAHMAN) JUDICIAL MEMBER ACCOUNTANT MEMBER Mumbai / Dated 04/01/2023 Giridhar, Sr.PS

19 IT(SS)A NO.680/MUM/2003 IT(SS)A NO.3/MUM/2019 M/s. Dolphin Offshore Enterprises (I) Ltd., Copy of the Order forwarded to: 1. The Assessee 2. The Respondent. 3. The CIT(A), Mumbai. 4. CIT 5. DR, ITAT, Mumbai 6. Guard file.

//True Copy// BY ORDER

(Asstt. Registrar) ITAT, Mum