DCIT 2.3.1, MUMBAI vs. PORTESCAP INDIA PVT. LTD., MUMBAI

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

BEFORE SHRI SAKTIJIT DEY, VICE PRESIDENT AND SHRI GIRISH AGRAWAL, ACCOUNTANT MEMBER

ITA No. Assessment Year 5972/Mum/2025 2011-12 5973/Mum/2025 2012-13 5976/Mum/2025 2013-14 5977/Mum/2025 2014-15 5978/Mum/2025 2015-16

Portescap India Private Limited The Dy. CIT, Circle 2(3)(1) Unit No. 101, Tower II, SEEPZ SEZ, AayakarBhawan, Mumbai -400020 Vs. Andheri (E), Seepz S.O. Mumbai-400096 PAN/GIR No. AAACK 4896 K (Assessee) : (Revenue)

ITA No. Assessment Year 6217/Mum/2025 2011-12 5974/Mum/2025 2012-13 5975/Mum/2025 2013-14

The Dy. CIT, Circle 2(3)(1) Portescap India Private Limited AayakarBhawan, Mumbai -400020 Unit No. 101, Tower II, SEEPZ Vs. SEZ, Andheri (E), Seepz S.O. Mumbai-400096 PAN/GIR No. AAACK 4896 K (Revenue) : (Assessee)

Assessee by : Shri J. D. Mistri, Sr. Adv. a/w Shri Fenil Bhat Revenue by : Shri Rajdeep Singh, CIT DR

Date of Hearing : 29.07.2026 : 16.10.2026 Date of Pronouncement

O R D E R Per Bench:

Captioned are bunch of 8 appeals relating to the same assessee and arising out of

separate orders of National Faceless Appeal Centre (‘NFAC’ for short), Delhi. While

there are three sets of cross appeals, pertaining to Assessment Years (A.Y. for short)

2 ITA Nos. 5972/Mum/2025 & others (A.Ys. 2011-12 to 2015-16) Portescap India Private Limited 2011-12, 2012-13 and 2013-14, appeals pertaining to the A.Ys. 2014-15 and 2015-16 are

by the assessee alone. However, all the appeals are, more or less, on a common issue,

hence, they have been clubbed together and disposed of in a consolidated order.

of claim of deduction/exemption u/s. 10AA of the Income Tax Act, 1961 (‘the Act’ for

short). Whereas, the department is aggrieved with the decision of learned first appellate

authority, accepting assessee’s alternative claim of exemption u/s. 10A of the Act. Since,

the facts relating to the issue in dispute are more or less common in all the appeals, we

deem it appropriate to take up the cross appeals relating to A.Y. 2011-12, being ITA No.

5972/Mum/2025 and ITA No. 6217/Mum/2025, respectively by the assessee and the

department, as the lead appeals.

the business of manufacturing of special purpose motors and sub-assemblies thereof for

electronic industries. For the assessment year under dispute, the assessee filed its return

of income on 30.11.2011, declaring income of Rs.43,41,69,344/-. The return of income

filed by the assessee was selected for scrutiny.

noticed that the assessee has furnished Form No. 56F claiming deduction/exemption u/s.

10A of the Act for its unit located at SEEPZ, Mumbai. On further verification of Form

No. 56F, he found that the manufacturing activities were commenced by the unit on

14.07.2003 falling in the previous year 2003-04 corresponding to A.Y. 2004-05.

Whereas, in course of assessment proceedings it was submitted by the assessee that in the

3 ITA Nos. 5972/Mum/2025 & others (A.Ys. 2011-12 to 2015-16) Portescap India Private Limited impugned assessment year, the assesse is claiming deduction/exemption u/s. 10AA of the

Act as a Special Economic Zone (‘SEZ’ for short) unit. When called upon to justify its

claim, the assessee submitted that the place where the unit was earlier located was a free

trade zone, which was converted to SEZ by Notification dated 01.11.2000. Accordingly,

the assessee having commenced its manufacturing activities in 2003 and had started

claiming deduction u/s. 10A(1A) of the Act from A.Y. 2004-05 onwards. It was submitted by the assessee that the impugned assessment year is the 8th year of claim of

deduction. It was further submitted that since after introduction of section 10AA of the

Act, the assessee, being an SEZ unit, is eligible to claim deduction u/s. 10AA of the Act,

it has started claiming deduction under the said provision in the impugned assessment

year. The A.O., however, was not convinced with the submissions of the assessee.

Referring to sub section (1) of section 10AA of the Act, he observed that a unit

commencing manufacturing and production of articles or things in any assessment year

commencing on or after 01.04.2006 can only qualify for deduction/exemption u/s. 10AA

of the Act. Since, the assessee had commenced its manufacturing/production activities

prior to 01.04.2006, according to the A.O. the assessee is not eligible to claim

deduction/exemption u/s. 10AA of the Act. Accordingly, he disallowed assessee’s claim.

Proceeding further, he held that the alternative claim of deduction u/s. 10A of the Act

made by the assessee cannot be entertained, as such claim was not made either in the

original return of income or through a revised return of income. Thus, he completed the

assessment accordingly.

learned first appellate authority. While deciding the appeal, though, learned first appellate

4 ITA Nos. 5972/Mum/2025 & others (A.Ys. 2011-12 to 2015-16) Portescap India Private Limited authority upheld the decision of A.O. disallowing deduction/exemption u/s. 10AA of the

Act, however, he allowed assessee’s alternative claim of deduction u/s. 10A(1A) of the

Act.

assessee drew our attention to sub section (1A) of section 10A of the Act. He submitted

that units located in SEZ/free trade zone and commencing manufacturing or production activities after the 1st day of April, 2003 were eligible to claim deduction u/s. 10A of the

Act for a cumulative period of 10 years though at various percentages. He submitted,

after the notification of Special Economic Zone Act, 2005, a special provision in the form

of section 10AA of the Act was introduced to the Income Tax Act. He submitted, after

introduction of SEZ Act, manufacturing units earlier enjoying deduction u/s. 10A(1A) of

the Act were debarred from enjoying such benefit under the said provision. On the

contrary, the SEZ units were made eligible for deduction/exemption under section 10AA

of the Act introduced w.e.f. 10.02.2006. Referring to section 10AA of the Act, ld.

Counsel submitted, an existing unit which has begun its manufacturing/production activities prior to 1st day of April, 2006 is also eligible to claim deduction/exemption u/s.

10AA of the Act. Referring to the language of section 10AA(1) of the Act, he submitted,

the AO has taken a extremely narrow view while disallowing assessee's claim of

deduction/exemption u/s.10AA of the Act. He submitted, the expression “begins to

manufacture or produce articles or things” used in sub-section (1) of Section 10AA of the

Act cannot be construed in a manner to exclude units existing in SEZ and who have

commenced their manufacturing and production activities prior to April, 2006. Drawing

5 ITA Nos. 5972/Mum/2025 & others (A.Ys. 2011-12 to 2015-16) Portescap India Private Limited our attention to the first proviso under sub-section (3) of Section 10AA and sub-section

(4) of Section 10AA of the Act, learned counsel submitted these provisions make it very

much clear that existing units are also eligible to claim deduction/exemption u/s. 10AA

of the Act. He submitted, the entire provision contained u/s.10AA of the Act has to be

read as a whole and cannot be restricted to sub-section (1) of Section 10AA of the Act

alone. Thus, he submitted, the interpretation of the AO is erroneous. He submitted, by

virtue of section 10A(7B) of the Act, the assessee is disentitled to claim deduction

u/s.10A of the Act, while making it eligible u/s.10AA of the Act. Therefore, the assessee

certainly can claim deduction u/s.10AA of the Act for the unexpired period as provided

u/s.10AA(1) clauses (i) and (ii) of the Act.

brought by the SEZ Act, 2005, it is necessary to look into the provisions of the said Act.

Drawing our attention to section 2(k) of SEZ Act, 2005, he submitted, “existing Special

Economic Zone” means every Special Economic Zone which is in existence on or before

the commencement of the SEZ Act. Whereas, Section 2(i) of the Act defines “existing

Unit” to mean every Unit which has been set up on or before the commencement of the

SEZ Act in an existing Special Economic Zone. Referring to section 2(zc) of the SEZ

Act, 2005, he submitted, “Unit” as per the definition includes an existing Unit, whether

established before or after the commencement of the Act. Thus, he submitted, an existing

unit is also covered under the definition of SEZ Act 2005. Referring to Section 27 of the

SEZ Act, 2005, he submitted, the provisions under the Income Tax Act, 1961, shall apply

in relation to entrepreneurs carrying on authorised operations in SEZ, subject to

modifications specified in Second Schedule of SEZ Act 2005, which introduced Section

6 ITA Nos. 5972/Mum/2025 & others (A.Ys. 2011-12 to 2015-16) Portescap India Private Limited 10AA to the Income Tax Act. Thus, he submitted, the deduction/exemption claimed

u/s.10AA of the Act, having been provided by virtue of a special provision brought into

the Income Tax Act by SEZ Act, 2005, it will override the general provisions of the Act.

Hence, assessee's claim of deduction u/s.10AA of the Act has to be allowed for the

unexpired term as provided u/s.10AA(1) of the Act. In support of such contention,

learned counsel relied upon the following judicial precedents: 1. ITO vs. Last Peak Data (P.) Ltd. [2015] 63 taxmann.com 45 (Kolkata-Trib.) 2. Classic Linens International (P.) Ltd. vs. Dy. CIT [2020] 113 taxmann.com 590 (Chennai-Trib.) 3. M/s. Sahajanand Laser Technology Ltd. vs. ITO (in ITA Nos. 15 & 16/Ahd./2020 vide order dated 01.01.2026)

assessee's claim of deduction/exemption u/s.10AA of the Act in A.Ys. 2016-17 and 2017-

assessment completed u/s.143(3) of the Act.

Representative (‘ld. DR’ for short) submitted that as per the language used in subsection

(1) of Section 10AA of the Act, a unit commencing activities of manufacturing or

production after 01.04.2006 is eligible to claim deduction/exemption under the said

provision. He submitted, the language of the provision itself debars all existing units

which commenced manufacturing or production activities prior to 01.04.2006. Therefore,

assessee's claim of deduction u/s.10AA of the Act has rightly been rejected. Insofar as,

allowance of assessee's claim of deduction u/s. 10A of the Act, ld. DR submitted, the

claim having not been made either in the original return of income or through a revised

7 ITA Nos. 5972/Mum/2025 & others (A.Ys. 2011-12 to 2015-16) Portescap India Private Limited return of income, learned First Appellate Authority could not have allowed assessee's

claim. In support of such contention, he relied upon the following decisions: 1. Jay Bharat Co. op. Housing Society Ltd. vs. ITO [2010] 125 ITD 90 (Mum) 2. Shriram Investments vs. CIT [2024] 167 taxmann.com 139 (SC) 3. Coromandel International Ltd. vs. Dy. CIT [2026] 184 taxmann.com 532 (Hyd.-

Trib.) 4. CIT vs. M/s. Dilip Kumar and Company &Ors. (AIR 2018 SC 3606)

upon and perused the materials on record. Undisputedly, the assessee had set up a unit in

a SEZ/free trade zone in the year 2003 and commenced its activities of

manufacturing/production in financial year 2003-04, corresponding to A.Y.2004-05. For

units set up in SEZ, section 10A(1A) of the Act provided deduction in the following

manner:

(i) First five consecutive assessment 100% of the profits and gains derived years, including the assessment year from the export of such articles or wherein the unit begins to things manufacture or produce articles or things (ii) Following two consecutive Deduction at the rate of 50% of the assessment years profits and gains derived from export. (iii) For the next three consecutive amount not exceeding 50% of the profit assessment years debited to the profit and loss account of the previous year, in respect of which deduction is to be allowed and credited to a reserve account, to be termed as Special Economic Zone Re-investment Allowance Reserve Account, in the mode and manner laid down in sub- section (1B) of section 10A of the Act.

from A.Y. 2004-05 and was allowed the benefit for seven consecutive assessment years

8 ITA Nos. 5972/Mum/2025 & others (A.Ys. 2011-12 to 2015-16) Portescap India Private Limited till A.Y. 2010-11. The impugned assessment year is the eighth year of claim of

deduction. However, in the impugned assessment year, though, the assessee furnished

Form No. 56F, which is meant for claiming deduction u/s. 10A of the Act, however,

assessee did claim deduction u/s. 10AA of the Act.

absence of any prescribed form for claiming deduction u/s. 10AA of the Act, the assessee

was compelled to furnish Form No. 56F of the Act, prescribed for claiming deduction u/s.

10A of the Act. Admittedly, assessee's claim of deduction u/s. 10AA of the Act has been

rejected by the departmental authorities, primarily and only on the ground that as per

Section 10AA(1) of the Act, a unit which begins its manufacturing or production

activities after 1st April, 2006 is entitled for the benefit provided in the provision. In

other words, according to the departmental authorities, a unit already in existence and

commenced manufacturing or production activities prior to 1st April, 2006, is ineligible

to claim deduction/exemption u/s. 10AA of the Act. Keeping in perspective the reasoning

of the departmental authorities, it is necessary to explore the history of Section 10AA of

the Act.

having commenced activities of manufacturing or production after 01.04.2003, was

eligible to claim deduction u/s.10A(1A) of the Act for the prescribed period.

Subsequently, SEZ Act, 2005 was notified on 23.06.2005, having been made effective

from 10.02.2006. Thus, the Special Economic Zones for promotion of exports and for

matters connected therewith were brought under the purview of SEZ Act, 2005. As per

Section 2(k) of the SEZ Act, “existing Special Economic Zone” means every Special

9 ITA Nos. 5972/Mum/2025 & others (A.Ys. 2011-12 to 2015-16) Portescap India Private Limited Economic Zone which is in existence on or before the commencement of the SEZ Act.

Whereas, Section 2(l) of the Act defines “existing Unit” to mean every Unit which has

been set up on or before the commencement of the SEZ Act in an existing Special

Economic Zone. In other words, the definition of Unit under SEZ Act, 2005 encompasses

an unit existing prior to commencement of the SEZ Act. Section 27 of the SEZ Act 2005

read with the Second Schedule therein provides for application of provision of Income

Tax Act, 1961, with certain modification in relation to developers and entrepreneurs

located in SEZ. By virtue of second schedule to SEZ Act 2005, section 10AA of the Act

was introduced to the Income Tax Act. Thus, it becomes clear that Ssection 10AA of the

Act is a special provision brought into the Income Tax Act through a special statute and

not through the Finance Act. Therefore, section 10AA of the Act, being a special

provision, would override the general provisions in the Income Tax Act 1961.

Section 10AA of the Act, which reads as under:

Special provisions in respect of newly established Units in Special Economic Zones. 10AA. (1) Subject to the provisions of this section, in computing the total income of an assessee, being an entrepreneur as referred to in clause (j) of section 228 of the Special Economic Zones Act, 2005, from his Unit, who begins to manufacture or produce articles or things or provide any services during the previous year relevant to any assessment year commencing on or after the 1st day of April, 2006, a deduction of— (i) hundred per cent of profits and gains derived from the export, of such articles or things or from services for a period of five consecutive assessment years beginning with the assessment year relevant to the previous year in which the Unit begins to manufacture or produce such articles or things or provide services, as the case may be, and fifty per cent of such profits and gains for further five assessment years and thereafter; (ii) for the next five consecutive assessment years, so much of the amount not exceeding fifty per cent of the profit as is debited to the profit and loss account of the previous year in respect of which the deduction is to be allowed and credited to a reserve account (to be called the "Special Economic Zone Re-investment Reserve Account") to be created and utilized for the purposes of the business of the assessee in the manner laid down in sub- section (2).

set up in SEZ, which begins to manufacture or produce during the previous year in

10 ITA Nos. 5972/Mum/2025 & others (A.Ys. 2011-12 to 2015-16) Portescap India Private Limited relation to the assessment year on or before 1st April, 2006 shall be eligible for

deduction. Thus, the catchwords are ‘begins to manufacture or produce articles or

things during the previous year, relevant to assessment year commencing on or before 01.04.2006’. The departmental authorities have interpreted the provision to say

that the units located in SEZ, which have commenced manufacturing or production

activities after 01.04.2006 are eligible to claim deduction. Meaning thereby, the existing

units, though located in SEZs, having commenced their production or manufacturing

activities prior to 2006 would not be eligible for claiming deduction under the said

provision. The rationality of the aforesaid interpretation needs to be examined.

Section 10AA of the Act, the deduction has to be allowed for a consecutive period of 15

years in the following manner:

(i) First five years beginning with the 100% of profits and gains assessment year, wherein the manufacturing or the production activities commenced (ii) Next five assessment years 50% of such profits and gains (iii) Last five assessment years Amount not exceeding 50% of the profit debited to the profit and loss account of the previous year in respect of which the deduction is allowed and credited to the reserve account, termed as Special Economic Zone Re-investment Allowance Reserve Account as per the mode and manner prescribed in sub-section (2) of section 10AA of the Act.

other conditions are akin to sub section (1A) of section 10A of the Act. Sub-section (2) of

section 10AA of the Act lays down the conditions for claim of deduction for the last five

11 ITA Nos. 5972/Mum/2025 & others (A.Ys. 2011-12 to 2015-16) Portescap India Private Limited years of the cumulative period of 15 years. Whereas, the first proviso to sub-section (3)

of section 10AA of the Act provides that if with the introduction of sub-section (7B) of

Section 10A of the Act, a SEZ unit has been deprived of claiming deduction u/s.10A of

the Act for the entire period of ten consecutive assessment years, it shall be eligible to

claim deduction u/s.10AA of the Act for the unexpired period and, thereafter it will be

eligible for deduction under clause (ii) of section 10AA(1) of the Act. Meaning thereby,

for another five years subject to the conditions of sub-section (2) and (3) of section 10AA

of the Act. Explanation under sub-section (3) clarifies that if an existing SEZ unit has

already claimed deduction u/s.10A of the Act for ten consecutive assessment years, it

shall not be eligible for deduction u/s.10AA of the Act. The second proviso to sub-

section (3) of section 10AA of the Act provides that a Unit initially located in any free trade

zone or export processing zone, which subsequently comes within SEZ by reason of conversion of such free trade zone or export processing zone into a SEZ, the period of ten consecutive assessment years referred to above shall be reckoned from the assessment year relevant to the previous year in which the Unit begins to manufacture or produce or process such articles or things or services in such free trade zone or export processing zone. The third

proviso to sub-section (3) of section 10AA of the Act provides that a existing Unit located

earlier in a free trade zone or export processing zone, which subsequently gets converted to SEZ and if such unit has completed ten consecutive assessment years, it shall not be

eligible for deduction from income for the last five years as provided under clause (ii) of

sub-section (1) with effect from the 1st day of April, 2006. Sub-section (4) of section

10AA of the Act lays down the conditions for eligibility u/s.10AA of the Act. Clause (i)

of sub-section (4) of Section 10AA reads as under:

12 ITA Nos. 5972/Mum/2025 & others (A.Ys. 2011-12 to 2015-16) Portescap India Private Limited Section 10AA (4) (i) it has begun or begins to manufacture or produce articles or things or provide services during the previous year relevant to the assessment year commencing on or after the 1st day of April, 2006 in any Special Economic Zone;

section 10AA of the Act, as it uses the words ‘has begun or begins to manufacture or

produce article or things’ similar to language used in section 10A(7B) of the Act. Thus,

in our considered opinion, to provide a true meaning to the provisions contained

u/s.10AA of the Act, the entire provision has to be read as whole and construed

harmoniously and not on piecemeal basis. Sub-section (1) of section 10AA of the Act

cannot be considered on a standalone basis to interpret the entire provision. Though, sub-

section (1) of section 10AA of the Act uses the words ‘begins to manufacture….’,

however, the provisos under sub-section (3) of section 10AA of the Act and the condition

of sub-section (4)(i) of section 10AA of the Act makes it clear that even an existing SEZ

unit commencing manufacturing/production prior to 01.04.2006 is also eligible to claim

deduction/exemption, subject of-course to the other conditions laid down in the said

provision.

20 At this stage, we must also note that upon commencement of SEZ Act, 2005 and

introduction of section 10AA of the Act, sub section (7B) was inserted to section 10A of

the Act, w.e.f.10.02.2006, which specifically debarred applicability of section 10A of the

Act to a unit referred to in clause (zc) of section 2 of SEZ Act, 2005. Meaning thereby,

the SEZ units enjoying exemption u/s.10A of the Act would henceforth be able to claim

deduction under section 10AA of the Act for the unexpired period after the introduction

of SEZ Act, 2005. This is so because the SEZ Act, 2005 itself provides for deduction for

units referred to in clause (zc) of SEZ Act, 2005 with the introduction of section 10AA of

13 ITA Nos. 5972/Mum/2025 & others (A.Ys. 2011-12 to 2015-16) Portescap India Private Limited the Act. As discussed earlier, ‘Unit’ referred to in section (2)(zc) of SEZ Act, 2005

includes an existing SEZ/free trade zone unit, hence, covered under the provisions of

section 10AA of the Act. Thus, upon conjoint reading of SEZ Act, 2005, section

10A(1A), sub section (7B) of section 10A and section 10AA of the Act, we are of the

view that the assessee hitherto is covered u/s.10AA of the Act, hence, eligible to claim

deduction as provided under sub-section (1) of section 10AA of the Act.

assessee would be eligible for deduction u/s.10AA of the Act. Admittedly, the assessee

has enjoyed deduction u/s.10A of the Act for seven consecutive assessment years,

commencing from A.Y. 2004-05 till A.Y. 2010-11. This is the eighth year of claim. Thus,

going by the provisions of section 10AA(1) of the Act, read with sub-section (3) of

section 10AA of the Act, the assessee would be eligible for the unexpired period

u/s.10A(1A) of the Act, i.e., three years out of ten years eligible therein and additional

five years under clause (ii) of Section 10AA(1) of the Act, as per the first proviso under

sub-section (3) of Section 10AA of the Act. In our view, the third proviso to sub section

(3) of section 10AA of the Act would not be applicable to the assessee, as the said

proviso would be applicable to SEZ units, which have completed the period of ten

consecutive assessment years on or before 01.04.2006. The ratio laid down in case of

Classic Linens International (P.) Ltd. vs. Dy. CIT(supra) and ITO vs. Last Peak Data (P.) Ltd.(supra) support this view. Further, the view taken by us above gets further fortified by

the fact that in A.Ys. 2016-17 and 2017-18, the department has allowed claim of

deduction u/s. 10AA of the Act. In fact, in A.Y. 2017-18, such claim was allowed in

scrutiny assessment completed u/s. 143(3) of the Act. Thus, we hold that the assessee is

14 ITA Nos. 5972/Mum/2025 & others (A.Ys. 2011-12 to 2015-16) Portescap India Private Limited entitled to claim deduction u/s.10AA of the Act for the remaining period as provided in

section 10AA(1) clauses (i) and (ii) of the Act.

appeal. As stated earlier, the department is aggrieved with the decision of learned first

appellate authority in allowing assessee's claim of deduction u/s.10A of the Act.

Elsewhere in the order, we have discussed that with the insertion of sub section (7B) to

section 10A of the Act, SEZ units are debarred from claiming deduction u/s. 10A of the

Act with the introduction of SEZ Act, 2005 with effect from 10.02.2006. Thus, SEZ units

enjoying deduction u/s. 10A(1A) of the Act are migrated to section 10AA of the Act,

subject to the fulfillment of the conditions therein. That being the case, learned first

appellate authority, in our considered opinion, has misdirected himself while accepting

assessee's alternative claim of deduction u/s.10A of the Act, as there is specific statutory

prohibition introduced under sub-section (7B) of Section 10A of the Act for such

deduction in respect of an SEZ unit. Therefore, to that extent, we reverse the decision of

learned first appellate authority. However, assessee remains eligible to claim deduction

u/s.10AA of the Act. Thus, in view of our observations in the foregoing paragraphs, we

direct the A.O. to allow assessee's claim of deduction u/s.10AA of the Act, subject to

factual verification of the computational aspect. Deduction granted u/s.10A of the Act, if

any, must be withdrawn. The aforesaid decision of ours would apply mutatis mutandis to

rest of the appeals.

interest u/s. 234C of the Act. It is the case of the assessee that interest u/s. 234C of the

Act has to be computed basis the returned income and not the assessed income. The A.O.

15 ITA Nos. 5972/Mum/2025 & others (A.Ys. 2011-12 to 2015-16) Portescap India Private Limited is directed to re-compute interest u/s.234C of the Act, if any, strictly in accordance with

the provision contained u/s. 234C of the Act.

allowed.

Order pronounced in the open court on 16.10.2026

Sd/- Sd/-

(Girish Agrawal) (Saktijit Dey) Accountant Member Vice President Mumbai; Dated :16.10.2026 Roshani, Sr. PS

Copy of the Order forwarded to : 1. The Appellant 2. The Respondent 3. The CIT(A) 4. CIT- concerned 5. DR, ITAT, Mumbai 6. Guard File BY ORDER, ABHINAV ANANT Digitally signed by ABHINAV ANANT GAVANDE GAVANDE Date: 2026.10.24 14:25:10 +05'30' (Dy./Asstt.Registrar) ITAT, Mumbai