VIJAYA PRADEEP DHUMAL,NAVI MUMBAI vs. INCOME TAX OFFICER, WARD 28(3)(1), MUMBAI, VASHI, NAVI MUMBAI
What did the Tribunal hold?
The Tribunal, noting the agreement of both parties, decided to restore the disputed assessment issues directly to the Assessing Officer for fresh adjudication. The Tribunal found that the CIT(A) did not examine the additions on merits and that the controversy required examination of primary documents concerning the investment, payment dates, amounts, and their sources. The Tribunal reasoned that the assertions regarding payments made in the relevant year and the housing loan disbursement in a subsequent year could not be accepted without inquiry. Section 69 concerns investments made in the financial year immediately preceding the assessment year. The Tribunal set aside the impugned appellate order and the assessment on the issues raised in Grounds Nos. 12 to 19 and restored these issues to the file of the Assessing Officer for fresh adjudication. The Assessing Officer was directed to examine the agreement, developer's ledger, receipts, reconciliation of consideration with payments, housing loan disbursement, utilization, husband's contribution, and determine the investment attributable to the assessee and whether its nature and source are explained. The assessee was to be afforded an opportunity to furnish evidence. The Assessing Officer was also to reconsider the addition of bank interest and the claim of deduction under section 80TTA, and determine the applicability of section 115BBE and interest/fee levies afresh. The stay application was dismissed as infructuous because the appeal was disposed of and issues were restored to the Assessing Officer. The appeal was allowed for statistical purposes.
What were the facts?
The assessee, Vijaya Pradeep Dhumal, filed an appeal before the Commissioner of Income-tax (Appeals) [CIT(A)] for Assessment Year 2018-19. The CIT(A) dismissed the appeal in limine due to a delay of 175 days in filing, without adjudicating the merits of the additions made by the Assessing Officer. The Assessing Officer had passed a reassessment order dated 30.03.2023 under section 147 read with section 144 of the Income-tax Act, 1961, making an addition of Rs. 1,14,14,999/-. The assessee also filed a stay application seeking to stay the recovery of the demand arising from this reassessment order. The Tribunal took up both the appeal and the stay application for hearing.
What were the issues?
1. Whether the learned CIT(A)/NFAC erred in dismissing the appellant’s appeal in limine as barred by limitation, without adjudicating any of the grounds raised on the merits of the additions? 2. Whether the learned CIT(A)/NFAC erred in holding that the appellant failed to furnish any explanation for the delay, when the order itself reproduced the explanation? 3. Whether the learned CIT(A)/NFAC erred in rejecting the appellant’s explanation as unsubstantiated without affording an opportunity of hearing on the question of condonation of delay? 4. Whether the learned CIT(A)/NFAC erred in passing the impugned order without fixing a day and place of hearing and without affording an opportunity of being heard, in breach of principles of natural justice? 5. Whether the learned CIT(A)/NFAC erred in exercising discretion vested by the proviso to section 249(3) mechanically and applying limitation with rigour? 6. Whether the learned CIT(A)/NFAC erred in not appreciating that the expression “sufficient cause” is to be construed liberally and that the appellant is a housewife not registered on the e-filing portal? 7. Whether the learned CIT(A)/NFAC erred in relying on certain case laws without noticing they were materially distinguishable and without considering binding authorities? 8. Whether the learned CIT(A)/NFAC erred in not appreciating that no prejudice was caused to the Revenue by the delay, especially when the appeal remained pending for a long period? 9. Whether the learned CIT(A)/NFAC erred in not appreciating that the assessment was framed ex parte, no authority examined the merits of the addition, and dismissal in limine sustained a demand without adjudication? 10. Whether the learned CIT(A)/NFAC failed to appreciate that the impugned order is not a speaking order? 11. On the merits, whether the Assessing Officer erred in treating the entire agreement consideration as unexplained investment under section 69 read with section 115BBE? 12. Whether the Assessing Officer erred in not appreciating that the payment made to the developer during the relevant previous year was less than the total consideration? 13. Whether the Assessing Officer erred in including a housing loan disbursed in a subsequent assessment year? 14. Whether the Assessing Officer erred in disregarding the explanation that the consideration was met partly out of a housing loan and partly out of the husband's contribution? Assessee's arguments: The assessee contended that the CIT(A) erred in dismissing the appeal in limine, citing various procedural and substantive errors in the condonation of delay decision. The assessee argued for a liberal interpretation of 'sufficient cause', highlighted the ex-parte nature of the assessment, and the lack of adjudication on merits. The assessee also raised alternative grounds on the merits of the additions, questioning the treatment of investment, payments, and housing loans. The assessee primarily prayed for remittance of issues to the CIT(A) for adjudication. Revenue's arguments: The judgment does not record specific arguments made by the Revenue on the issues.
Which sections of the Income-tax Act were involved?
Section 147,Section 144,Section 250,Section 249(3),Section 69,Section 115BBE,Section 250(1),Section 250(6),Section 234A,Section 234B,Section 234F,Section 80TTA
AI-generated summary — verify with the full judgment below
Income Tax Appellate Tribunal, MUMBAI BENCHES, MUMBAI
Before: SHRI SAKTIJIT DEY & SHRI MAKARAND VASANT MAHADEOKAR
PER MAKARAND VASANT MAHADEOKAR, ACCOUNTANT MEMBER: The appeal filed by the assessee is directed against the order dated 27.07.2026 passed by the Commissioner of Income-tax (Appeals), National Faceless Appeal Centre, Delhi [the CIT(A)], under section 250 of the Income-tax Act, 1961 [the Act], for assessment year 2018-19. By the impugned order, the CIT(A) declined to condone the delay of 175 days in filing the first appeal and dismissed it in limine. The connected stay application seeks stay of recovery of the demand arising from the reassessment order dated 30.03.2023 passed under section 147 read with section 144 of the Act.
During the hearing of the stay application, the learned Authorized Representative (AR) explained the circumstances concerning the delay in pursuing the appellate remedies and also drew our attention to the dispute underlying the demand. Having regard to the nature of the controversy, the appeal itself was taken up for hearing with the consent of both parties. Both parties were heard on the question of limitation and on the proposal to restore the disputed issues to the Assessing Officer for fresh adjudication. The appeal and the stay application are accordingly disposed of by this common order.
The grounds of appeal are reproduced below:- A. GROUNDS RELATING TO THE DISMISSAL OF THE APPEAL IN LIMINE 1. On the facts and in the circumstances of the case and in law, the learned CIT(A)/NFAC erred in dismissing the appellant’s appeal in limine as barred by limitation, without adjudicating any of the grounds raised on the merits of the additions. 2. On the facts and in the circumstances of the case and in law, the learned CIT(A)/NFAC erred in holding at paragraph 2.5 of the impugned order that the appellant had “failed to furnish any explanation whatsoever” for the delay of 175 2
S.A. No. 1491/M/2026 (In ITA No. 9399/MUM/2026) VIJAYA PRADEEP DHUMAL days, when the same order at paragraph 2.3 reproduces the explanation furnished by the appellant. The finding is self-contradictory, contrary to the record and perverse. 3. On the facts and in the circumstances of the case and in law, the learned CIT(A)/NFAC erred in rejecting the appellant’s explanation as “unsubstantiated” without ever calling upon the appellant to substantiate it by evidence, and without affording any opportunity of hearing on the question of condonation of delay. 4. On the facts and in the circumstances of the case and in law, the learned CIT(A)/NFAC erred in passing the impugned order without fixing a day and place of hearing and without giving the appellant an opportunity of being heard, in breach of section 250(1) and of the principles of natural justice, the impugned order itself recording “Present for the appellant: Not Applicable”. 5. On the facts and in the circumstances of the case and in law, the learned CIT(A)/NFAC failed to consider the appellant’s written submission dated 07.01.2025 and the material filed therewith, which were on record before him, and thereby passed the impugned order in ignorance of material available on the record. 6. On the facts and in the circumstances of the case and in law, the learned CIT(A)/NFAC erred in exercising the discretion vested by the proviso to section 249(3) in a mechanical manner, and in applying limitation with rigour in a case where the delay was neither deliberate, nor contumacious, nor actuated by any benefit to the appellant. 7. On the facts and in the circumstances of the case and in law, the learned CIT(A)/NFAC failed to appreciate that the expression “sufficient cause” is to be construed liberally so as to advance substantial justice, and that the appellant is a housewife who was not registered on the e-filing portal, a fact recorded by the Assessing Officer himself at paragraph 7 of the assessment order. 8. On the facts and in the circumstances of the case and in law, the learned CIT(A)/NFAC erred in relying on CIT v. Ram Mohan Kabra, Mohd. Ashfaq v. State Transport Appellate Tribunal and P.K. Ramachandran v. State of Kerala without noticing that those decisions are materially distinguishable, and without considering the binding line of authority beginning with Collector, Land Acquisition, Anantnag v. Mst. Katiji. 9. On the facts and in the circumstances of the case and in law, the learned CIT(A)/NFAC failed to appreciate that no prejudice whatsoever was caused to the Revenue by a delay of 175 days, particularly when the appeal thereafter remained pending before him from 21.10.2023 to 27.07.2026, a period exceeding thirty-three months. 10. On the facts and in the circumstances of the case and in law, the learned CIT(A)/NFAC failed to appreciate that the assessment itself was framed ex parte under section 144; that no authority has at any stage examined the merits of the 3
S.A. No. 1491/M/2026 (In ITA No. 9399/MUM/2026) VIJAYA PRADEEP DHUMAL addition of Rs.1,14,14,999/-; and that the dismissal in limine has the effect of sustaining a demand of Rs.1,89,68,786,/- of which Rs.1,01,50,700/- is interest and fee, without any adjudication on merits at any level. 11. On the facts and in the circumstances of the case and in law, the impugned order is not a speaking order within the meaning of section 250(6) inasmuch as it does not state the points for determination arising from the appellant’s explanation, nor the decision thereon, nor the reasons for that decision. B. PROTECTIVE AND ALTERNATIVE GROUNDS ON THE MERITS The grounds in this Part B are raised without prejudice to Part A and purely by way of protection, so that the appellant’s challenge on merits is not treated as having been abandoned. The appellant does not invite this Hon’ble Tribunal to adjudicate these grounds in the first instance; the appellant’s primary prayer is that they be remitted to the learned CIT(A) for adjudication. They are set out here only to preserve them and to demonstrate the existence of a prima facie case. 12. On the facts and in the circumstances of the case and in law, the Assessing Officer erred in treating the entire agreement consideration of Rs.1,14,14,999/- as unexplained investment under section 69 read with section 115BBE in Assessment Year 2018-19, when section 69 permits the assessment only of an investment actually made in the financial year in question. 13. On the facts and in the circumstances of the case and in law, the Assessing Officer erred in not appreciating that the payment actually made to the developer during the previous year 2017-18 was Rs.6,88,885/- and not Rs.1,14,14,999,/- and that the balance consideration was payable and paid in later years. 14. On the facts and in the circumstances of the case and in law, the Assessing Officer erred in including in Assessment Year 2018-19 the housing loan of Rs.63,66,834/- disbursed by the State Bank of India, when the loan was sanctioned on 27.10.2020 and disbursed in Assessment Year 2021-22, and no part of it was received or applied in Assessment Year 2018-19. 15. On the facts and in the circumstances of the case and in law, the Assessing Officer erred in disregarding the explanation placed on record by the appellant’s submission dated 06.03.2023 that the consideration was met partly out of a housing loan and partly out of the contribution of the appellant’s husband, a non- resident deriving salary income in the Kingdom of Saudi Arabia. 16. On the facts and in the circumstances of the case and in law, the Assessing Officer erred in assessing the whole of the investment in the hands of the appellant alone, without considering that the property was acquired in the joint names of the appellant and her husband. 17. On the facts and in the circumstances of the case and in law, the Assessing Officer erred in invoking section 115BBE and in charging tax at 60% together with surcharge at 25%, thereby determining a tax liability of Rs.88,18,086,/- no case for the application of that section having been made out.
S.A. No. 1491/M/2026 (In ITA No. 9399/MUM/2026) VIJAYA PRADEEP DHUMAL 18. On the facts and in the circumstances of the case and in law, the Assessing Officer erred in assessing interest income of Rs.2,514/- under the head Income from Other Sources without appreciating that the aggregate income chargeable at normal rates was Rs.2,510,/- which is below the maximum amount not chargeable to tax, and without allowing the deduction available under section 80TTA. 19. On the facts and in the circumstances of the case and in law, the Assessing Officer erred in charging interest of Rs.48,49,900/- under section 234A and Rs.52,90,800/- under section 234B, and fee of Rs.10,000/- under section 234F, aggregating to Rs.1,01,50,700,/- which are consequential to the additions and are disputed. C. GENERAL 20. The appellant craves leave to add to, alter, amend, substitute, modify, delete or withdraw any of the grounds of appeal at or before the hearing of the appeal. Facts of the Case 4. The assessee is an individual. No original return of income was filed for the year under consideration. As recorded in the assessment order, information was flagged on the Insight Portal concerning purchase of immovable property for Rs.1,14,14,999/- and receipt of bank interest of Rs.2,514/-. Following proceedings under section 148A, an order under section 148A(d) and a notice under section 148 were issued on 31.03.2022. No return was filed in response to that notice.
The case was transferred to the Faceless Unit on 17.08.2022 and was subsequently transferred back to the jurisdictional Assessing Officer under section 144B(8) on 27.10.2022. Paragraph 7 of the assessment order records that the assessee was not registered on the e-filing portal and was unable to comply with the notices issued by the Faceless Unit. Thereafter, notices under section 142(1) were issued on 14.01.2023, 04.02.2023 and 24.02.2023.
The Assessing Officer has recorded that, by a reply dated 06.03.2023, the assessee furnished Form 26AS, a copy of the agreement relating to the immovable property and a ledger extract of payments against its consideration. The assessee explained that the consideration had been met 5
S.A. No. 1491/M/2026 (In ITA No. 9399/MUM/2026) VIJAYA PRADEEP DHUMAL partly from a housing loan and partly by her husband. The Assessing Officer considered the response incomplete and noted that supporting documents, including the bank loan certificate, had not been furnished. A further notice dated 07.03.2023 required compliance by 10.03.2023. According to the assessment order, no response to that notice was received.
The Assessing Officer accordingly completed the reassessment under section 147 read with section 144 on 30.03.2023. The entire consideration of Rs.1,14,14,999/- was added as unexplained investment under section 69 read with section 115BBE. Bank interest of Rs.2,514/- was also assessed, resulting in total assessed income of Rs.1,14,17,513/-. The stay papers state that the original demand was Rs.1,89,68,786/-, comprising tax, surcharge and cess of Rs.88,18,086/-, interest under sections 234A and 234B aggregating to Rs.1,01,40,700/-, and fee under section 234F of Rs.10,000/-.
The assessee filed her first appeal on 21.10.2023. The CIT(A) recorded that the assessment order had been served on 30.03.2023 and that the appeal was delayed by 175 days. In the explanation furnished in Form No. 35, the assessee attributed the delay to collection of necessary documents and family problems. The CIT(A), in paragraph 2.3, reproduced that explanation but held that no supporting documentary evidence had been furnished. In paragraph 2.5, however, the CIT(A) stated that the assessee had failed to furnish any explanation whatsoever. Ultimately, the delay was not condoned under section 249(3), and the appeal was dismissed without adjudication of the grounds on merits.
Before us, the learned AR relied on the petition and supporting affidavit explaining the circumstances of the delay before the CIT(A). It was submitted that the assessee was a housewife unfamiliar with income-tax procedure; that the family had shifted from the address appearing in the departmental records; and that, upon becoming aware of the notices, she 6
S.A. No. 1491/M/2026 (In ITA No. 9399/MUM/2026) VIJAYA PRADEEP DHUMAL engaged a tax consultant through her brother. The assessment order and connected communications received around 30.03.2023 and 01.04.2023 were forwarded for necessary action. An SMS dated 17.04.2023 confirming submission of an adjournment request in the penalty proceedings reinforced her belief that the professional engaged by her was attending to the matter.
The learned AR further submitted that the assessee travelled to Saudi Arabia on 04.05.2023 to attend to her husband, returned on 15.06.2023, and travelled there again on 20.07.2023. The assessee's explanation was that throughout the material period she believed that her appellate remedy was being attended to. On noticing a further departmental communication in September 2023, she followed up through her brother, and the appeal was thereafter filed on 21.10.2023. The affidavit acknowledges that the fuller explanation had not been set out in Form No. 35. It also acknowledges that the medical records relied upon bear dates subsequent to the filing of the first appeal and are not contemporaneous medical evidence covering the period of delay.
On merits, the learned AR submitted that the property was acquired jointly by the assessee and her husband under an agreement registered on 31.10.2017 for Rs.1,14,14,999/-. According to the assessee, the total consideration was funded by her husband's contribution of Rs.50,48,165/- and a State Bank of India housing loan disbursement of Rs.63,66,834/-. It was submitted that the loan was sanctioned on 27.10.2020 and disbursed in the previous year relevant to assessment year 2021-22, whereas the amount paid to the developer during the previous year relevant to assessment year 2018-19 was only Rs.6,88,885/-. The learned AR contended that the agreement consideration had been assessed in its entirety without proper examination of the year-wise payments, the housing loan, or the husband's contribution. Although the written prayer sought restoration to the CIT(A),
S.A. No. 1491/M/2026 (In ITA No. 9399/MUM/2026) VIJAYA PRADEEP DHUMAL at the hearing the learned AR agreed that the matter required verification by the Assessing Officer and requested restoration to that authority.
The learned Departmental Representative (DR) was heard on the explanations for delay and the issues arising from the assessment. On the proposal to restore the disputed issues to the Assessing Officer for examination of the relevant evidence and fresh adjudication, the learned DR agreed to such restoration.
We have considered the rival submissions and perused the material on record. In respect of the delay before the CIT(A), the issue is whether the circumstances explained by the assessee constitute sufficient cause under section 249(3). The conclusion cannot rest merely on the existence of an arguable case on merits or on the absence of an objection by the Revenue. The explanation for the delay must itself be examined.
The explanation now placed before us is materially more detailed than the brief entry in Form No. 35. It identifies the engagement of a consultant, forwarding of the assessment communications for action, the assessee's belief arising from the communication concerning penalty proceedings, her travel to Saudi Arabia, and the subsequent follow-up leading to filing of the appeal. The medical documents bearing later dates cannot establish that she was prevented by her husband's illness from acting throughout the earlier period. Nor does travel abroad, by itself, explain every day of delay. Nevertheless, the explanation rests cumulatively on the assessee's reliance on professional assistance, her family circumstances and the steps taken when she became aware that the appeal had not been filed. Her non- registration on the e-filing portal also finds support in the assessment order itself.
S.A. No. 1491/M/2026 (In ITA No. 9399/MUM/2026) VIJAYA PRADEEP DHUMAL 15. In N. Balakrishnan v. M. Krishnamurthy, (1998) 7 SCC 123, the Hon'ble Supreme Court observed: “Length of delay is no matter, acceptability of the explanation is the only criterion.” This does not dispense with the requirement to establish sufficient cause. It requires consideration of the explanation in the context of the conduct and circumstances of the litigant. Applying that test, we find the explanation for the delay of 175 days acceptable in the facts of the present case. The steps narrated in the affidavit indicate pursuit of the tax proceedings, albeit without adequate procedural understanding, rather than an intention to abandon the appellate remedy or to secure an advantage by delaying it.
We also find that the statement in paragraph 2.5 of the impugned order that no explanation whatsoever had been furnished is inconsistent with paragraph 2.3, which reproduces and considers an explanation. The requirement of sufficient cause is not diluted by this inconsistency, but the matter must be decided on the explanation actually offered and the fuller circumstances now placed before us. Upon such independent consideration, we are satisfied that sufficient cause existed for the delay. We accordingly condone the delay of 175 days in filing the appeal before the CIT(A) and set aside the rejection of that appeal on limitation. Grounds Nos. 1 to 11 are allowed to this extent; separate adjudication of the remaining procedural objections in those grounds is unnecessary in view of the relief granted.
Turning to the disputed additions, the assessment order itself acknowledges that the assessee had explained the broad sources of the property consideration and had furnished the agreement and a payment ledger. The Assessing Officer nevertheless found the supporting evidence insufficient. The CIT(A) did not examine the additions on merits. The present controversy thus requires examination of primary documents concerning the investment, the dates and amounts of payments, and their
S.A. No. 1491/M/2026 (In ITA No. 9399/MUM/2026) VIJAYA PRADEEP DHUMAL sources. The assertions that only Rs.6,88,885/- was paid in the relevant previous year and that the housing loan was disbursed in a subsequent year cannot be accepted as established merely on the basis of the submissions before us.
Section 69 concerns investments made in the financial year immediately preceding the assessment year and the explanation of their nature and source. The date of registration, the terms of the agreement, the payment obligations, and the actual funding therefore require examination together. The agreement consideration cannot, without that inquiry, be assumed to establish the amount of unexplained investment attributable to this assessee in the relevant year. Equally, the fact of joint ownership, by itself, does not determine the extent of the investment attributable to either co-owner. The respective contributions and the supporting financial records require verification.
In these circumstances, and having regard to the agreement of both parties at the hearing, we consider it appropriate to restore the disputed assessment issues directly to the Assessing Officer rather than require another consideration of the merits by the CIT(A) before the necessary factual verification. This course is warranted because the material inquiry concerns the original investment and funding records, which the Assessing Officer must examine in the first instance. We accordingly set aside the impugned appellate order and the assessment on the issues raised in Grounds Nos. 12 to 19, and restore those issues to the file of the Assessing Officer for fresh adjudication in accordance with law.
The Assessing Officer shall examine the registered agreement, the developer's ledger and receipts, and a reconciliation of the consideration with the year-wise payments. The date of sanction and actual disbursement of the housing loan, its utilization towards the property, and the claimed 10
S.A. No. 1491/M/2026 (In ITA No. 9399/MUM/2026) VIJAYA PRADEEP DHUMAL contribution of the assessee's husband shall be verified from the relevant loan statements, bank statements, remittance records and other supporting evidence. The Assessing Officer shall determine, with reasons, the investment, if any, attributable to the assessee in the previous year relevant to assessment year 2018-19 and whether its nature and source are satisfactorily explained. The claim that payments relate to later years shall be specifically examined. The assessee shall be afforded a reasonable opportunity to furnish the evidence relied upon, including documents not previously examined, and to respond to any material proposed to be used against her.
The Assessing Officer shall also reconsider the addition of bank interest of Rs.2,514/- and the claim of deduction under section 80TTA, after verifying the nature of the interest and satisfaction of the statutory conditions. The applicability of section 115BBE and the levy and computation of interest under sections 234A and 234B and fee under section 234F shall be determined afresh in accordance with law in the light of the findings on the restored issues. The remand is confined to the issues arising in this appeal for assessment year 2018-19. We express no opinion on their merits. The assessee shall extend necessary cooperation and furnish the requisite particulars within the time reasonably allowed by the Assessing Officer. A reasoned order shall be passed after affording an effective opportunity of hearing. Grounds Nos. 12 to 19 are accordingly allowed for statistical purposes. Ground No. 20 is general and requires no separate adjudication.
In the stay application, the assessee has sought stay of the original demand of Rs.1,89,68,786/- and consequential demand. The detailed stay papers state that the outstanding demand, as reflected in the departmental communication dated 23.01.2025, was Rs.1,98,60,844/-. The document filed
S.A. No. 1491/M/2026 (In ITA No. 9399/MUM/2026) VIJAYA PRADEEP DHUMAL under the description of departmental rejection orders is, in substance, the assessee's request dated 24.01.2025 for stay; the detailed stay application and affidavit state that no order disposing of that request had been communicated. Since the appeal has now been disposed of and the disputed assessment issues have been restored to the Assessing Officer, the application for stay pending disposal of this appeal does not survive. It is dismissed as infructuous. No separate direction granting stay or requiring security is called for.
In the result, ITA No. 9399/Mum/2026 is allowed for statistical purposes in the terms indicated above, and SA No. 149/Mum/2026 is dismissed as infructuous.
Order pronounced in the open court on 27.10.2026.
Sd/- Sd/- SAKTIJIT DEY MAKARAND VASANT MAHADEOKAR VICE PRESIDENT ACCOUNTANT MEMBER Mumbai Dated: 27.10.2026 Tarun Kushwaha Sr. P.S.
S.A. No. 1491/M/2026 (In ITA No. 9399/MUM/2026) VIJAYA PRADEEP DHUMAL
Copy to: VIJAYA PRADEEP DHUMAL, FLAT NO. 508, BUILDING R2, AURUM, PLOT GEN 4/1, Q RESIDENCE CHS, 1 TTC INDUSTRIAL AREA, GHANSOLI, THANE-400701, MAHARASHTRA INCOME TAX OFFICER, WARD 28(3)(1), MUMBAI, 2 IT-OFFICE, VASHI RAILWAY STATION BUILDING, NAVI MUMBAI, THANE-400703, MAHARASHTRA 3 THE PCIT / CIT, 4 THE D.R., ITAT, MUMBAI BENCH 5 GUARD FILE
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