ACIT-4(1)(1), MUMBAI, MUMBAI vs. ETHAN CONSTRUCTIONS PRIVATE LIMITED, MUMBAI

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ITA 2115/MUM/2026Status: DisposedITAT Mumbai07 October 2026AY 2017-1812 pages
AI SummaryDismissed

What did the Tribunal hold?

The Tribunal held that the CIT(A) was justified in quashing the reassessment proceedings. For AY 2017-18, where the notice under Section 148 was issued on 30.07.2022, and the escaped income exceeded Rs. 50 lacs, the proceedings fell under Section 149(1)(b) of the Act, requiring approval from the authority specified in Section 151(ii). This specified authority is the Principal Chief Commissioner or Principal Director General. In this case, the approval was obtained from the Principal Commissioner of Income-tax, which is not the competent authority as defined under Section 151(ii). The Tribunal found no infirmity in the CIT(A)'s finding that the approval was obtained from the authority specified under Section 151(i) instead of Section 151(ii) of the new regime. In the absence of approval from the competent authority, the notice under Section 148 was held void ab initio, and consequently, the reassessment proceedings were quashed. The CIT(A) rightly followed the decision of the Jurisdictional High Court in Alag Property Construction (P) Ltd, which considered the Supreme Court's decision in Rajeev Bansal. The appeal filed by the Revenue was dismissed.

What were the facts?

The Revenue filed an appeal against the order of the CIT(A) for Assessment Year (AY) 2017-18. The assessee had filed its return of income declaring Nil income. Following search actions in other cases, information was received by the Assessing Officer (AO) indicating the assessee obtained accommodation entries amounting to Rs. 3,29,16,627/- and Rs. 3,03,000/-. Reasons were recorded, and a notice under Section 148 was issued on 21.04.2021. Subsequently, in compliance with the Supreme Court's decision in Union of India vs. Ashish Agarwal, the information was provided to the assessee as a notice under Section 148A(b) dated 27.05.2022. The AO passed an order under Section 148A(d) on 30.07.2022, holding that income of Rs. 1,00,85,689/- had escaped assessment. Approval for this order and the subsequent notice under Section 148 (issued on 30.07.2022) was obtained from the Principal Commissioner of Income-tax. The assessee filed its return, and the AO made additions of Rs. 1,36,66,235/- under Section 68. The CIT(A) quashed the reassessment proceedings.

What were the issues?

1. Whether, on the facts and in law, the CIT(A) was justified in holding that the approval for issuance of notice under section 148 obtained from the Principal Commissioner of Income-tax after 30.06.2021 was void, ignoring the Supreme Court judgment in Union of India v. Ashish Agarwal and the transitional reassessment provisions? 2. Whether the CIT(A) was justified in holding the approval void, ignoring CBDT Instruction No. 1/2022, which clarified the specified authority for AY 2017-18 under the new law? 3. Whether the CIT(A) erred in retrospectively applying the ratio of Union of India v. Rajeev Bansal to invalidate reassessment proceedings initiated under the old regime and saved by the Supreme Court? 4. Whether the CIT(A) exceeded his jurisdiction by annulling reassessment proceedings without adjudicating the merits of additions under section 68, despite material on accommodation entries? 5. Whether reassessment proceedings could be held void ab initio solely due to alleged infirmity in sanction, when tangible material suggested escapement of income exceeding the monetary threshold? 6. Whether the CIT(A) erred in not appreciating the legislative intent behind sections 148, 148A, and 151, read with TOLA, to protect reassessment actions initiated during COVID-19? Revenue's arguments: The CIT(A) erred in voiding the approval, overlooking the Supreme Court's decision in Ashish Agarwal and the transitional provisions. CBDT Instruction No. 1/2022 supports the AO's action. The decision in Rajeev Bansal should not be applied retrospectively. The CIT(A) should have adjudicated the merits of additions. The proceedings are not void ab initio, and the legislative intent was to protect reassessment actions. Assessee's arguments: The approval for reopening was obtained from an incorrect authority under Section 151(ii) of the Act, as the reassessment was initiated after more than 3 years from the end of the relevant assessment year, requiring approval from the Principal Chief Commissioner of Income Tax, not the Principal Commissioner of Income Tax. Reliance was placed on Union of India vs Rajeev Bansal.

Which sections of the Income-tax Act were involved?

Section 148,Section 148A,Section 149,Section 151,Section 68

AI-generated summary — verify with the full judgment below

Income Tax Appellate Tribunal, “E” BENCH; MUMBAI

Hearing: 14.07.2026Pronounced: 07.10.2026

IN THE INCOME TAX APPELLATE TRIBUNAL “E” BENCH; MUMBAI BEFORE SMT. BEENA PILLAI, JUDICIAL MEMBER AND SHRI VIKRAM SINGH YADAV, ACCOUNTANT MEMBER ITA No. 2115/Mum/2026 (Assessment Year: 2017-18)

ACIT-4(1)(1), Mumbai Ethan Constructions Private Room No. 642, 6th Floor, Limited Aayakar Bhavan, M. K. Road, vs. 6th Floor, Neelkanth, NS Road, Mumbai-400020. Todi Park Marine Drive, Mumbai, Kalbadevi H.O. Mumbai-400002.

PAN: AACCE2711P (Appellant) (Respondent) For Revenue : Shri Dheeraj Singh Baghel, JCIT For Assessee : Shri Neeraj Mangla, CA (Virtually appear) Date of Hearing : 14.07.2026 Date of Pronouncement : 07.10.2026 O R D E R PER VIKRAM SINGH YADAV, A.M :

This is an appeal filed by the Revenue against the order of the Learned Commissioner of Income Tax (Appeals)-National Faceless Appeal Centre (NFAC), Delhi [‘Ld.CIT(A)’], dated 09.12.2025, pertaining to Assessment Year (AY) 2017-18, wherein the Revenue has taken the following grounds of appeal:

“1. Whether on the facts and in the circumstances of the case and in law, the Ld. CIT(A) was justified in holding that the approval for issuance of notice under section 148 obtained from the Principal Commissioner of Income- tax after 30.06.2021 was void, ignoring the binding effect and correct interpretation of the judgment of the Hon'ble Supreme Court in

ITA No. 2115/Mum/2026; A.Y. 2017-18 Ethan Constructions Private Limited Union of India v. Ashish Agarwal (2022) and the scheme of transitional reassessment provisions? 2. Whether on the facts and in the circumstances of the case and in law, the Ld. CIT(A) was justified in holding that the approval for issuance of notice under section 148 obtained from the Principal Commissioner of Income- tax after 30.06.2021 was void, ignoring the CBDT Instruction No. 1/2022 dated 11.05.2022 wherein vide para 6.2(ii) it has been clarified that the specified authority u/s 151 of the new law for A.Y. 2017-18 shall be the authority prescribed under clause (i) of that section? 3. Whether on the facts and in the circumstances of the case and in law the Ld. CIT(A) erred in law in applying the ratio of Union of India v. Rajeev Bansal (2024) retrospectively to invalidate reassessment proceedings which were initiated under the old regime and subsequently saved by the directions of the Hon'ble Supreme Court? 4. Whether on the facts and in the circumstances of the case and in law the Ld. CIT(A) exceeded his jurisdiction in annulling the reassessment proceedings without adjudicating the merits of the additions made under section 68 of the Act, despite detailed material and findings recorded by the Assessing Officer regarding accommodation entries and bogus share transactions? 5. Whether on the facts and in the circumstances of the case and in law, the reassessment proceedings could be held to be void ab initio merely on account of alleged infirmity in sanction, when the Assessing Officer had tangible material suggesting escapement of income exceeding the prescribed monetary threshold? 6. Whether on the facts and in the circumstances of the case and in law the Ld. CIT(A) erred in not appreciating that the legislative intent behind sections 148, 148A and 151, read with TOLA, was to protect reassessment actions initiated during the COVID-19 period and not to invalidate them on hyper-technical grounds?”

2.

Briefly, the facts of the case are that the assessee has filed its return of income on 05.03.2018, declaring total income at Nil. The return was processed under section 143(1) on 09.03.2018. Subsequently, pursuant to search action under section 132 in case of Jignesh Shah and Sanjay Shah on 11.09.2018, the Assessing Officer received information that these persons are managing and controlling multiple companies/ concerns who are involved in providing accommodation entries of various kinds and the assessee has been a beneficiary of obtaining accommodation entry by trading in scrips, namely, Padmanabh

ITA No. 2115/Mum/2026; A.Y. 2017-18 Ethan Constructions Private Limited Industries Ltd., Ideal Optics ltd. and Dhvanil Chemicals Ltd. amounting to Rs. 3,29,16,627/- being bogus transactions. Further, the Assessing Officer referred to another information received pursuant to search in case of Naresh Jain, wherein it was found that the assessee has obtained accommodation entry by way of trading in scrips, namely, Monotype India Limited amounting to Rs. 3,03,000/-. On the basis of analysis of said information, reasons were recorded and notice under section 148 was issued to the assessee on 21.04.2021. Subsequently, pursuant to Hon'ble Supreme Court decision in case of Union of India vs Ashish Agarwal in Civil Appeal No. 3005/2022 dated 04.05.2022 and in compliance thereof, the material/ information, basis which the notice was earlier issued, was provided to the assessee and the same was considered to be notice issued under section 148A(b) of the Act dated 27.05.2022 requiring the assessee to show cause as to why notice under section 148 should not be issued and the assessee was provided two weeks’ time to reply to the said notice. In compliance, the assessee filed its submissions vide letter dated 11.06.2022 submitting its reasons as to why no notice under section 148 is required to be issued and proceedings be dropped.

3.

The submissions so filed by the assessee were considered but not found acceptable, and the Assessing Officer proceeded and passed the order under section 148A(d) dated 30.07.2022 holding that bogus entries in respect of fictitious profits/losses taken by the assessee amounting to Rs. 1,00,85,689/- has escaped assessment and there is definite, reliable and tangible information with him, especially given that such information has been flagged by risk management strategy formulated by the Central Board of Direct Taxes, that is actionable information under the head High Risk CRIU/VRU cases’ for A.Y. 2017-18, and therefore it is a fit case for issuance of notice under section 148 of the Act.

ITA No. 2115/Mum/2026; A.Y. 2017-18 Ethan Constructions Private Limited 4. The Assessing Officer further stated that necessary approval for passing order under section 148A(d) and issuance of notice under section 148 has been taken from the specified authority, i.e, Pr. CIT-4, Mumbai vide reference no. Pr. CIT-4/148A(d)/Approval/2022-23, dated 28.07.2022 in accordance with provisions of section 151(i) read with para 6.2(ii) of Instruction 01 of 2022 issued by Central Board of Direct Taxes and simultaneously, notice under section 148 was issued on 30.07.2022.

5.

In compliance to the said notice, the assessee filed its return of income on 09.11.2022. Thereafter, notices under section 143(2) and 142(1) were issued calling for necessary information and documentation, and taking into consideration the submissions filed by the assessee but not finding the same acceptable, an amount of Rs. 1,36,66,235/- was brought to tax and assessed income was determined at Rs. 1,36,66,235/-

6.

As per the Assessing Officer, both the companies, namely, Ideal Optics ltd. and Padmanabh Industries Ltd. are conduits for providing accommodation entries, and the transaction in the form of sales undertaken by the assessee are sham transactions as admitted by Shri Sanjay S. Shah and reported in inspector report, and therefore, the said proceeds/credit received from these two entities are in the nature of unexplained credits as the genuineness of the sale transaction cannot be established in the present case, and the said credits were brought to tax as unexplained credits under section 68 of the Act.

7.

The assessee thereafter carried the matter in appeal before the ld. CIT(A), and as part of its grounds of appeal challenged the validity of the proceedings initiated under section 148 of the Act and in particular, lack of approval from the Competent authority under section 151 of the Act. During the course of appellate proceedings, it was submitted that since more than 3 years have lapsed from the end of the relevant assessment year, the approval of the Competent authority has to be obtained in terms

ITA No. 2115/Mum/2026; A.Y. 2017-18 Ethan Constructions Private Limited of provisions of Section 151(ii) of the Act, that is from the Principal Chief Commissioner of Income Tax. However, in the present case, the Assessing Officer has obtained approval from Principal Commissioner of Income Tax vide approval dated 28.07.2022 and since the approval has been obtained from the authority other than the authority specified under section 151(ii) of the Act, the reopening of assessment proceedings is vitiated and therefore, the order passed by the Assessing Officer under section 148A(d) as well as notice issued under section 148 deserve to be quashed and reliance was placed on the decision of Hon'ble Supreme Court in case of Union of India vs Rajeev Bansal, [2024] 167 taxmann.com 70 (SC).

8.

The submissions so filed by the assessee were considered by the ld. CIT(A) and after considering the provisions of section 151, the decision of the Hon'ble Supreme Court in case of Union of India vs Rajeev Bansal (supra) and the Hon'ble Bombay High Court in case of Alag Property Constructions Private Limited vs ACIT, [2025] 179 taxmann.com 578 (Bom.), the ld CIT(A) has held that in the instant case, 3 years from end of the relevant assessment year expired on 31.03.2021, and therefore, the approval under section 151 was to be obtained as per the provisions of section 151(ii) and not 151(i) of the Act and in view of the same, given that in the present case, the approval has been obtained from the authority specified under section 151(i) of the new regime instead of the authority specified under section 151(ii) of the new regime, the notice under section 148 issued by the Assessing Officer is void ab initio and reassessment proceeding is liable to be quashed and without going into the merits of the case, holding the same as academic in nature, the appeal of the assessee was allowed.

9.

Against the said order and the findings of the ld. CIT(A), the Revenue is in appeal before us.

ITA No. 2115/Mum/2026; A.Y. 2017-18 Ethan Constructions Private Limited 10. During the course of hearing, the ld. DR submitted that the ld. CIT(A) was not justified in holding that the approval for issuance of notice under section 148 obtained from the Principal Commissioner of Income Tax was void, ignoring the binding effect and correct interpretation of the judgment of the Hon'ble Supreme Court in Union of India vs Ashish Agarwal (supra) and scheme of transitional reassessment provisions. It was further submitted that the ld. CIT(A) has erred in holding that the notice under section 148 was void, ignoring the CBDT instruction no. 1/2022 dated 11.05.2022, wherein vide para 6(ii), it has been clarified that the specified authority under section 151 of the new law for A.Y. 2017-18 shall be the authority prescribed under clause (i) of that section. It was further submitted that the ld. CIT(A) erred in law in applying the ratio of Union of India vs Rajeev Bansal (supra) retrospectively to invalidate reassessment proceedings which were initiated under the old regime and subsequently saved by the directions of the Hon'ble Supreme Court. It was accordingly submitted that the findings of the ld. CIT(A) be set aside and given that there is no finding on the merits of the case, the matter may be remitted to the file of ld. CIT(A) for adjudication on merits.

11.

The ld. AR has been heard, who has relied on the order passed by the ld. CIT(A) and our attention was drawn to the decision of Hon'ble Supreme Court in case of Union of India vs Rajeev Bansal (supra), wherein the relevant findings are contained in paras 75 to 78 of its judgement, which reads as under: "75. After 1 April 2021, the new regime has specified different authorities for granting sanctions under section151. The new regime is beneficial to the assessee because it specifies a higher level of authority for the grant of sanctions in comparison to the old regime. Therefore, in terms of Ashish Agarwal (supra), after 1 April 2021, the prior approval must be obtained from the appropriate authorities specified under section 151 of the new regime. The effect of Section 151 of the new regime is thus: (i) If income escaping assessment is less than Rupees fifty lakhs: (a) a reassessment notice could be issued within three years after obtaining the prior approval of the Principal Commissioner, or Principal

ITA No. 2115/Mum/2026; A.Y. 2017-18 Ethan Constructions Private Limited Director or Commissioner or Director; and (b) no notice could be issued after the expiry of three years; and (ii) If income escaping assessment is more than Rupees fifty lakhs: (a) a reassessment notice could be issued within three years after obtaining the prior approval of the Principal Commissioner, or Principal Director or Commissioner or Director; and (b) after three years after obtaining the prior approval of the Principal Chief Commissioner or Principal Director General or Chief Commissioner or Director General. 76. Grant of sanction by the appropriate authority is a precondition for the assessing officer to assume jurisdiction under section 148 to issue a reassessment notice. Section 151 of the new regime does not prescribe a time limit within which a specified authority has to grant sanction. Rather, it links up the time limits with the jurisdiction of the authority to grant sanction. Section 151(ii) of the new regime prescribes a higher level of authority if more than three years have elapsed from the end of the relevant assessment year. Thus, non-compliance by the assessing officer with the strict time limits prescribed under section 151 affects their jurisdiction to issue a notice under section 148. 77. Parliament enacted TOLA to ensure that the interests of the Revenue are not defeated because the assessing officer could not comply with the pre conditions due to the difficulties that arose during the COVID-19 pandemic. Section 3(1) of TOLA relaxes the time limit for compliance with actions that fall for completion from 20 March 2020 to 31 March 2021. TOLA will accordingly extend the time limit for the grant of sanction by the authority specified under section 151. The test to determine whether TOLA will apply to Section 151 of the new regime is this: if the time limit of three years from the end of an assessment year falls between 20 March 2020 and 31 March 2021, then the specified authority under section 151(i) has an extended time till 30 June 2021 to grant approval. In the case of Section 151 of the old regime, the test is: if the time limit of four years from the end of an assessment year falls between 20 March 2020 and 31 March 2021, then the specified authority under section 151(2) has time till 31 March 2021 to grant approval. The time limit for Section 151 of the old regime expires on 31 March 2021 because the new regime comes into effect on 1 April2021. 78. For example, the three year time limit for assessment year 2017-2018 falls for completion on 31 March 2021. It falls during the time period of 20 March 2020 and 31 March 2021, contemplated under section 3(1) of TOLA. Resultantly, the authority specified under section 151(i) of the new regime can grant sanction till 30June 2021. G. Conclusions 114. In view of the above discussion, we conclude that: d) TOLA will extend the time limit for the grant of sanction by the authority specified under section151. The test to determine whether TOLA will apply to Section 151 of the new regime is this: if the time limit of three years from the end of an assessment year falls between 20 March 2020 and 31March 2021,

ITA No. 2115/Mum/2026; A.Y. 2017-18 Ethan Constructions Private Limited then the specified authority under section 151(i) has extended time till 30 June 2021 to grant approval;”

12.

It was submitted that the Hon'ble Apex Court in Para 75 of its decision has held that sanction u/s 151 of the Act has to be accorded as per the provisions of law contained in new regime. Further, in Para 77, it was held that if the time limit of three years from the end of an assessment year falls between 20 March 2020 and 31 March 2021, then the specified authority under section 151(i) has an extended time till 30 June 2021 to grant approval. Further, it was submitted that in the illustration in Para 78 it has been unambiguously held that since three year’s time limit for A.Y. 2017-18 falls for completion on 31/03/2021, the authority specified u/s 151(i) of new regime can grant approval till 30/06/2021. Thus, thereafter, an approval has to be obtained from authority specified u/s 151(ii) of new regime.

13.

It was submitted that in the case of assessee, it is evident that approval has been obtained from ld. PCIT on 28/07/2022 for issue of notice u/s 148 of the Act. It was submitted that since, the approval is obtained after 30/06/2021 it should have been obtained from authority specified under Section 151(ii) of new regime i.e. from Principal Chief Commissioner or Principal Director General or Chief Commissioner or Director General. However, the approval has been obtained from Ld. Pr. Commissioner of Income Tax, i.e., authority specified u/s 151(i) of the Act; the reopening of assessment proceedings itself is vitiated and thus, the order passed by Ld. AO u/s 148A(d) of the Act as well as the notice issued u/s 148 of the Act deserves to be set-aside.

14.

We have heard the rival contentions and perused the material available on record. Firstly, there cannot be any manner of dispute that it is at the relevant point in time when the Assessing officer seeks to issue the notice u/s. 148 that he has to determine whether the period of

ITA No. 2115/Mum/2026; A.Y. 2017-18 Ethan Constructions Private Limited limitation falls under three years from the end of the relevant assessment year or beyond three years from the end of the relevant assessment year and basis such determination, he has to seek approval from the Competent authority u/s 151 of the Act. For the purposes of determining the said period of limitation, the AO has to necessarily take into consideration and give effect to the provisos to section 149 of the Act. In terms of first proviso, he has to see and adhere to the limitation under the erstwhile law given the assessment year 2017-18 involved in the instant case. In terms of third proviso to section 149, the time allowed to the assessee to respond to the show cause issued under 148A(b) has to be necessarily excluded for the purposes of computing the period of limitation. Once the AO reaches the said stage and determine the period of limitation, he has to reach out to the appropriate authority as so defined in section 151 of the Act. The applicability of section 151 in terms of determining the appropriate authority to seek necessary approval will therefore arise once the period of limitation is determined and crystallised by the AO u/s 149 of the Act and therefore, has to be seen and understood in consonance with section 149 of the Act.

15.

In the instant case, the assessment year under consideration is assessment year 2017-18 and the notice under section 148 was issued on 30.07.2022, under the amended law effective from 01-04-2021, basis reasons that the income to the extent of Rs. 1,00,85,689/-has escaped assessment.

16.

In terms of first proviso to section 149(1), the time limit of six years from the end of the relevant assessment year 2017-18 under the erstwhile law (section 149)(1)(b)) needs to be seen given the escaped income of Rs. 1,00,85,689/- and which expires on 31.03.2024 and therefore, as on the date of issuance of notice on 30.07.2022, the said time limit under the

ITA No. 2115/Mum/2026; A.Y. 2017-18 Ethan Constructions Private Limited erstwhile law had not expired and the notice so issued by the Assessing officer is not barred in terms of first proviso to section 149(1) of the Act.

17.

Now, coming to limitation in terms of main provisions of section 149(1) of the Act, the relevant dates under consideration are the date of issuance of show case u/s. 148A(b) dated 27.05.2022, the time period of two weeks allowed to the assessee to respond to the show-cause and considering the response filed by the assessee, the date of finally passing of the order u/s. 148A(d) dated 30.07.2022 and simultaneous issuance of notice u/s 148 dated 30.07.2022. Therefore, in the instant case, the period starting from 27.05.2022 till 11.06.2022 has to be excluded by the AO for the purposes of computing the period of limitation under sub- section (1) to section 149 for the purpose of issuance of notice u/s. 148 of the Act. Secondly, one need to see the quantum of escaped income which has been determined by the AO at Rs 1,00,85,689/- which exceeds the prescribed threshold of Rs 50 lacs and allows extended period of limitation beyond 3 years from the end of the relevant assessment year. We therefore find that the matter falls under clause (b) to sub-section (1) to section 149 as the notices have been issued on 30-07-2022 i.e, well after the expiry of three years from the end of the relevant assessment year.

18.

In such a case where the notice u/s 148 has been issued after the expiry of three years from the end of the impugned assessment year 2017-18, where we look at the specified authority in terms of section 151 whose approval is required before issuance of notice u/s 148, the specified authority as defined in terms of clause (ii) to section 151 of the Act shall be the Principal Chief Commissioner or Principal Director General or where there is no Principal Chief Commissioner or Principal Director General, Chief Commissioner or Director General. In the instant case, admittedly, the approval has been taken from and sanction has

ITA No. 2115/Mum/2026; A.Y. 2017-18 Ethan Constructions Private Limited been accorded by the Ld. Principal Commissioner of Income Tax(IT)-4, Mumbai, vide his order dt. 28-07-2022 which is clearly not the competent authority as so defined in the statute under section 151(ii) of the Act.

19.

Given the extended period of limitation and higher threshold of escaped income, where the legislature has provided for seeking approval from a higher authority and where the language so provided is clear and ambigious, one needs to accede to the higher wisdom as it leaves no doubt of any interpretation. It is a settled proposition that where the statue provides for certain acts to be done in a particular manner, the authorities have to act in the manner so provided and there is no discretion which is left with the authorities but to act in the manner so provided.

20.

We therefore don’t find any infirmity in the findings of ld CIT(A) where he has rightly held that the approval has been obtained from the authority specified under section 151(i) of the new regime instead of the authority specified under section 151(ii) of the new regime and in absence of approval of the competent authority, the notice under section 148 issued by the Assessing Officer was held void ab initio and consequent reassessment proceeding were quashed. And while holding so, the ld CIT(A) has followed and rightly so, the decision of the Hon’ble Jurisdictional High Court in case of Alag Property Construction (P) Ltd (supra) wherein the decision of the Hon’ble Supreme Court in case of Rajeev Bansal (supra) has been duly considered.

21.

In the result, the appeal filed by the Revenue is dismissed. Order pronounced in the Open Court on 07.10.2026

Sd/- Sd/- BEENA PILLAI VIKRAM SINGH YADAV (JUDICIAL MEMBER) (ACCOUNTANT MEMBER)

ITA No. 2115/Mum/2026; A.Y. 2017-18 Ethan Constructions Private Limited

Mumbai, Dated: 07.10.2026 Karishma J. Pawar, SR. PS

Copy to : 1) The Appellant 2) The Respondent 3) The CIT concerned 4) The D.R, ITAT, Mumbai 5) Guard file

By Order ABHINAV ANANT Digitally signed by ABHINAV ANANT GAVANDE GAVANDE Date: 2026.10.16 10:20:37 +05'30' Dy./Asst. Registrar I.T.A.T, Mumbai

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