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Income Tax Appellate Tribunal, MUMBAI BENCH “G” MUMBAI
Before: SHRI OM PRAKASH KANT & SHRI RAHUL CHAUDHARY
PER OM PRAKASH KANT, AM
This appeal has been preferred by the Revenue against the order dated 18th January 2021 passed by the Ld. Commissioner of Income Tax (Appeals) – 48, Mumbai [in short, ‘the Ld. CIT(A)’] for A.Y. 2012-13, raising following grounds:
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“1. "Whether on the facts and in circumstances of case, the Ld. 1. "Whether on the facts and in circumstances of case, the Ld. 1. "Whether on the facts and in circumstances of case, the Ld. CIT(A) erred in quashing the assessment order us 147 by CIT(A) erred in quashing the assessment order us 147 by CIT(A) erred in quashing the assessment order us 147 by relying on the order of settlement commission without the order of settlement commission without appreciating the fact that the issue of unsecured loans received appreciating the fact that the issue of unsecured loans received appreciating the fact that the issue of unsecured loans received by assessee from MIs European Trust and Infrastructure by assessee from MIs European Trust and Infrastructure by assessee from MIs European Trust and Infrastructure Investment Trust was not put forward in the settlement Investment Trust was not put forward in the settlement Investment Trust was not put forward in the settlement commission proceedings of AY 2012 commission proceedings of AY 2012-13?"
"Whether on the facts and in circumstances of case, the Ld. 2. "Whether on the facts and in circumstances of case, the Ld. 2. "Whether on the facts and in circumstances of case, the Ld. CIT(A) erred in not adjudicating the disallowance us 68 CIT(A) erred in not adjudicating the disallowance us 68 CIT(A) erred in not adjudicating the disallowance us 68 amounting to amounting to Rs.88,03,50,000/- made by assessing officer made by assessing officer without appreciating the facts that the assessee could not prove without appreciating the facts that the assessee could not prove without appreciating the facts that the assessee could not prove the creditworthiness and the creditworthiness and genuineness of the transaction?” genuineness of the transaction?”
Briefly the facts of the case are that the assessee company had Briefly the facts of the case are that the assessee company had Briefly the facts of the case are that the assessee company had filed its original return filed its original return of income for the year under consideration of income for the year under consideration on 28.09.2012 declaring total income at Rs. NIL. The return was on 28.09.2012 declaring total income at Rs. NIL. The return was on 28.09.2012 declaring total income at Rs. NIL. The return was processed u/s. 143(1) of the Income Tax Act, 1961 [in short, “the processed u/s. 143(1) of the Income Tax Act, 1961 [in short, “the processed u/s. 143(1) of the Income Tax Act, 1961 [in short, “the Act”]. Later, a search and seizure action u/s. 132 of the Act was Act”]. Later, a search and seizure action u/s. 132 of the Act was Act”]. Later, a search and seizure action u/s. 132 of the Act was initiated on GTL Group Group on 28.09.2010. Further, the assessee filed . Further, the assessee filed application before the Hon’ble Income Tax Settlement Commission, before the Hon’ble Income Tax Settlement Commission, before the Hon’ble Income Tax Settlement Commission, Bombay Bench who vide order u/s. 245D(6) of Bombay Bench who vide order u/s. 245D(6) of the Act determined the Act determined loss of Rs.47,78,49,815/ 47,78,49,815/-. Subsequently, a search was also carried . Subsequently, a search was also carried out in the case of M/s. European Trust and M/s. Infrastructure out in the case of M/s. European Trust and M/s. Infrastructure out in the case of M/s. European Trust and M/s. Infrastructure
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Investment Trust regarding very high turnover in the account Investment Trust regarding very high turnover in the account Investment Trust regarding very high turnover in the account within a very short span of time and found that the said Trusts within a very short span of time and found that the said Trusts within a very short span of time and found that the said Trusts received loan from various parties during the F.Y. 2011 n from various parties during the F.Y. 2011-12 and the n from various parties during the F.Y. 2011 same had been further given to the assessee company. In view same had been further given to the assessee company. In view same had been further given to the assessee company. In view thereof, the Assessing Officer reopened the case for A.Y. 2012-13 thereof, the Assessing Officer reopened the case for A.Y. 2012 thereof, the Assessing Officer reopened the case for A.Y. 2012 relevant to F.Y. 2011 relevant to F.Y. 2011-12 by issuing notice u/s. 148 of the Act dated 12 by issuing notice u/s. 148 of the Act dated 30.03.2019. In response to the notice u/s. 148 of the Act, the .2019. In response to the notice u/s. 148 of the Act, the .2019. In response to the notice u/s. 148 of the Act, the assessee filed the return of income on 24.04.2 assessee filed the return of income on 24.04.2019 declaring total 019 declaring total loss of Rs.47,78,49,815/ 47,78,49,815/-. In the assessment completed, the . In the assessment completed, the Assessing Officer made the addition of Rs. 88,03,50,000/- u/s. 68 Assessing Officer made the addition of Rs. 88,03,50,000/ Assessing Officer made the addition of Rs. 88,03,50,000/ in respect of the loans taken from M/s. European Trust amounting pect of the loans taken from M/s. European Trust amounting pect of the loans taken from M/s. European Trust amounting to Rs. 30,19,50,000/ to Rs. 30,19,50,000/- and M/s. Infrastructure Investment Trust and M/s. Infrastructure Investment Trust amounting to Rs. 57,84,00,000/ amounting to Rs. 57,84,00,000/- as the assessee failed to discharge as the assessee failed to discharge its onus casted u/s. 68 of the Act. Aggrieved by the reopening of the its onus casted u/s. 68 of the Act. Aggrieved by the reopening of its onus casted u/s. 68 of the Act. Aggrieved by the reopening of assessment for A.Y. 2012 assessment for A.Y. 2012-13 and the additions made by the 13 and the additions made by the Assessing Officer, the assessee preferred appeal before the ld. CIT(A) Assessing Officer, the assessee preferred appeal before the ld. CIT(A) Assessing Officer, the assessee preferred appeal before the ld. CIT(A) who quashed the reopening of the assessment for the year under who quashed the reopening of the assessment for the year under who quashed the reopening of the assessment for the year under consideration for the reason that consideration for the reason that as per the provisions of s as per the provisions of section 245D of the Act, if any order is obtained by fraud or 245D of the Act, if any order is obtained by fraud or 245D of the Act, if any order is obtained by fraud or
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misrepresentation of the facts, the Hon’ble Settlement Commission misrepresentation of the facts, the Hon’ble Settlement Commission misrepresentation of the facts, the Hon’ble Settlement Commission shall declare the said order as void and the Assessing Officer has no shall declare the said order as void and the Assessing Officer has no shall declare the said order as void and the Assessing Officer has no jurisdiction under the law to reopen the case for A.Y. 2012-13. jurisdiction under the law to reopen the case for A.Y. 2012 jurisdiction under the law to reopen the case for A.Y. 2012 Accordingly, the Ld. CIT(A) held that the reopening of the d. CIT(A) held that the reopening of the d. CIT(A) held that the reopening of the assessment u/s. 147 is bad in law and hence, no decided the issue assessment u/s. 147 is bad in law and hence, no decided the issue assessment u/s. 147 is bad in law and hence, no decided the issue on merits of the case. Aggrieved by the order passed by the ld. on merits of the case. Aggrieved by the order passed by the ld. on merits of the case. Aggrieved by the order passed by the ld. CIT(A), the revenue is in appeal before us. CIT(A), the revenue is in appeal before us.
The ground no.1 The ground no.1 relates to challenging the order of the ld. relates to challenging the order of the ld. CIT(A) for quashing the reassessment order passed u/s. 147 by CIT(A) for quashing the reassessment order passed u/s. 147 by CIT(A) for quashing the reassessment order passed u/s. 147 by relying on the order of the Hon’ble Settlement Commission without relying on the order of the Hon’ble Settlement Commission without relying on the order of the Hon’ble Settlement Commission without appreciating the fact that the issue of amount received by the appreciating the fact that the issue of amount received by the appreciating the fact that the issue of amount received by the assessee from M/s. E assessee from M/s. European Trust and Infrastructure Investment uropean Trust and Infrastructure Investment Trust was not put forward in the Settlement Commission Trust was not put forward in the Settlement Commission Trust was not put forward in the Settlement Commission proceedings for A.Y. 2012 proceedings for A.Y. 2012-13. In this regard, Ld Ld. Departmental Representative for the revenue argued that the relevant issue of Representative for the revenue argued that the relevant issue of Representative for the revenue argued that the relevant issue of alleged alleged amounts amounts received received from from M/s. M/s. European European Trust Trust and and Infrastructure Investment Trust was never the subject matter before Infrastructure Investment Trust was never the subject matter before Infrastructure Investment Trust was never the subject matter before the Hon’ble Settlement Commission. Neither in the the Hon’ble Settlement Commission. Neither in the application filed application filed
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by the assessee u/s. 245C(1) of the Act before the Hon’ble Income by the assessee u/s. 245C(1) of the Act before the Hon’ble by the assessee u/s. 245C(1) of the Act before the Hon’ble Tax Settlement Commission Settlement Commission [in short, “ITSC”] nor the nor the Rule 9 report issued by the Pr. Commissioner of Income Tax issued by the Pr. Commissioner of Income Tax refers to refers to the alleged issue of amount received from European Trust and Infrastructure issue of amount received from European Trust and Infrastructure issue of amount received from European Trust and Infrastructure Investment Trust in the year under consideration. Hence, this could Investment Trust in the year under consideration. Hence, this could Investment Trust in the year under consideration. Hence, this could not be said to be the matter which has been settled by the Hon’ble he matter which has been settled by the Hon’ble he matter which has been settled by the Hon’ble ITSC. As a corollary, although the A.Y. 2012 ITSC. As a corollary, although the A.Y. 2012-13 was before the 13 was before the ITSC, but the matter involved of alleged loans/share application ITSC, but the matter involved of alleged loans/share application ITSC, but the matter involved of alleged loans/share application money received from Trusts money received from Trusts was never brought on record by way of was never brought on record by way of submission of any details or explanations or justification ny details or explanations or justification ny details or explanations or justification before the Hon’ble ITSC. Accordingly, the ld. Departmental Representative for Hon’ble ITSC. Accordingly, the ld. Departmental Representative for Hon’ble ITSC. Accordingly, the ld. Departmental Representative for the revenue submitted that the averment of the ld. CIT(A) in para the revenue submitted that the averment of the ld. CIT(A) in para the revenue submitted that the averment of the ld. CIT(A) in para 6.7 of his order that the details of share application etc. received by 6.7 of his order that the details of share application etc. received 6.7 of his order that the details of share application etc. received the assessee from the two Trusts were also part of the details the assessee from the two Trusts were also part of the details the assessee from the two Trusts were also part of the details submitted by the appellant before the Hon’ble ITSC is incorrect. submitted by the appellant before the Hon’ble ITSC is incorrect. submitted by the appellant before the Hon’ble ITSC is incorrect. Further, in para 6.11 of his order, the ld. CIT(A) has stated that the Further, in para 6.11 of his order, the ld. CIT(A) has stated that the Further, in para 6.11 of his order, the ld. CIT(A) has stated that the Assessing Officer had written a letter to the Hon’ble ITSC Assessing Officer had written a letter to the Hon’ble Assessing Officer had written a letter to the Hon’ble mentioning the relevant facts of the case and subsequent mentioning the relevant facts of the case and subsequent mentioning the relevant facts of the case and subsequent investigation carried out by the Investigation Wing and issues investigation carried out by the Investigation Wing and issues investigation carried out by the Investigation Wing and issues
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relating to above two Trusts relating to above two Trusts. However, the ld. Departmental . However, the ld. Departmental Representative during the course of hearing specifically denied of Representative during the course of hearing specifically denied of Representative during the course of hearing specifically denied of any such request to have been made by the Assessing Officer to the such request to have been made by the Assessing Officer to the such request to have been made by the Assessing Officer to the Hon’ble ITSC.
The Ld. Counsel of the assessee on other hand argued that . Counsel of the assessee on other hand argued that . Counsel of the assessee on other hand argued that once the case of the assessee for a particular year is settled by the once the case of the assessee for a particular year is settled by the once the case of the assessee for a particular year is settled by the Hon’ble ITSC then the same cannot be disturbed. In this regard, he Hon’ble ITSC then the same cannot be disturbed. In this regard, he Hon’ble ITSC then the same cannot be disturbed. In this regard, he relied on the order of the ld. CIT(A) and following case laws: relied on the order of the ld. CIT(A) and following case laws: relied on the order of the ld. CIT(A) and following case laws:
(i) Neetu Agarwal (Smt.) v. UOI (2011) 330 ITR 422 (All HC) Neetu Agarwal (Smt.) v. UOI (2011) 330 ITR 422 (All HC) Neetu Agarwal (Smt.) v. UOI (2011) 330 ITR 422 (All HC) (ii) CIT v. Diksha Singh (2013) 350 ITR 157 (All HC) CIT v. Diksha Singh (2013) 350 ITR 157 (All HC) CIT v. Diksha Singh (2013) 350 ITR 157 (All HC) (iii) Omaxe v. DCIT (2014) 3 Omaxe v. DCIT (2014) 364 ITR 423 (Delhi HC) 64 ITR 423 (Delhi HC) (iv) Komalkant Fakirchand Sharma v. DCIT (2019) 417 ITR Komalkant Fakirchand Sharma v. DCIT (2019) 417 ITR Komalkant Fakirchand Sharma v. DCIT (2019) 417 ITR 11 (Guj HC) 11 (Guj HC)
We have heard the rival contentions and perused the material We have heard the rival contentions and perused the material We have heard the rival contentions and perused the material on record. On a close perusal of the Paper Book containing 1 to 274 on record. On a close perusal of the Paper Book containing on record. On a close perusal of the Paper Book containing pages filed by the assessee, we find th pages filed by the assessee, we find that there is no submission of at there is no submission of any details or explanations or justification in regard to the alleged any details or explanations or justification in regard to the alleged any details or explanations or justification in regard to the alleged share application money received from the abovementioned two share application money received from the abovementioned two share application money received from the abovementioned two Trusts in the application filed before the Hon’ble ITSC or in any Trusts in the application filed before the Hon’ble ITSC or in any Trusts in the application filed before the Hon’ble ITSC or in any
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Rule 9 report of the Ld Ld. Commissioner of Income Tax or in the final ssioner of Income Tax or in the final order of the Hon’ble ITSC passed u/s. 245D(4) for the year under order of the Hon’ble ITSC passed u/s. 245D(4) for the year under order of the Hon’ble ITSC passed u/s. 245D(4) for the year under consideration. Hence, apparently, the issue does not appear to have consideration. Hence, apparently, the issue does not appear to have consideration. Hence, apparently, the issue does not appear to have been dealt with by the Hon’ble ITSC. However, the decisions relied been dealt with by the Hon’ble ITSC. However, the decisions relied been dealt with by the Hon’ble ITSC. However, the decisions relied upon by the Ld. Co . Counsel of the assessee are in favour of the unsel of the assessee are in favour of the assessee even in such a case. assessee even in such a case. The provisions of section 245I The provisions of section 245I provides that every order of Settlement passed u/s. 245D(4) shall provides that every order of Settlement passed u/s. 245D(4) shall provides that every order of Settlement passed u/s. 245D(4) shall be conclusive as to the matters stated therein and no matter be conclusive as to the matters stated therein and no matter be conclusive as to the matters stated therein and no matter covered by such order sha covered by such order shall, save as otherwise provided in this ll, save as otherwise provided in this Chapter, be reopened in any proceedings under this Act or under Chapter, be reopened in any proceedings under this Act or under Chapter, be reopened in any proceedings under this Act or under any other law for the time being in force. Further, section 245D(6) any other law for the time being in force. Further, section 245D(6) any other law for the time being in force. Further, section 245D(6) provides that the order passed u/s. 245D(4) shall be void if it is provides that the order passed u/s. 245D(4) shall be void if it is provides that the order passed u/s. 245D(4) shall be void if it is subsequently found by the ITSC that it has been obtained by fraud by the ITSC that it has been obtained by fraud by the ITSC that it has been obtained by fraud or misrepresentation of facts. Thus, it is clear that every order of or misrepresentation of facts. Thus, it is clear that every order of or misrepresentation of facts. Thus, it is clear that every order of the Hon’ble ITSC passed u/s. 245D(4) of the Act shall be conclusive the Hon’ble ITSC passed u/s. 245D(4) of the Act shall be conclusive the Hon’ble ITSC passed u/s. 245D(4) of the Act shall be conclusive and no matter covered by such order shall be reopened in any and no matter covered by such order shall be reopened in any and no matter covered by such order shall be reopened in any proceedings under this Act. gs under this Act.
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5.1 In context of the issue involved about “matters stated therein”, In context of the issue involved about “matters stated therein”, In context of the issue involved about “matters stated therein”, we may refer to the relevant extract of the decision of Hon’ble Delhi we may refer to the relevant extract of the decision of Hon’ble Delhi we may refer to the relevant extract of the decision of Hon’ble Delhi High Court in the case of Omaxe Ltd. as under: High Court in the case of Omaxe Ltd. as under:-
“16. It is evident from the rulings of the Suprem “16. It is evident from the rulings of the Suprem “16. It is evident from the rulings of the Supreme Court that orders of Settlement Commission are final and that orders of Settlement Commission are final and that orders of Settlement Commission are final and conclusive as to matters stated therein. The “matters” conclusive as to matters stated therein. The “matters” conclusive as to matters stated therein. The “matters” necessarily could comprehend disputed questions, items necessarily could comprehend disputed questions, items necessarily could comprehend disputed questions, items or heads of income, disallowance, etc. or variants of it, but or heads of income, disallowance, etc. or variants of it, but or heads of income, disallowance, etc. or variants of it, but always with reference to always with reference to a particular assessment year….” a particular assessment year….”
5.2 Gainful reference in this regard can also be made from the Gainful reference in this regard can also be made from the Gainful reference in this regard can also be made from the decision of the Hon’ble Gujarat High Court in the case of Komalkant decision of the Hon’ble Gujarat High Court in the case of Komalkant decision of the Hon’ble Gujarat High Court in the case of Komalkant Fakirchand Sharma v. DCIT (supra) on the interpretation of the Fakirchand Sharma v. DCIT (supra) on the interpretation of the Fakirchand Sharma v. DCIT (supra) on the interpretation of the word “matters stated therein”. word “matters stated therein”. The relevant extract of which is as The relevant extract of which is as under:-
“7.7 An application under An application under section 245C of the Act is akin of the Act is akin to a return of income, wherein the assessee is required to to a return of income, wherein the assessee is required to to a return of income, wherein the assessee is required to make a full and true disclosure of his make a full and true disclosure of his income and the income and the order under section 245D(4) of the Act is in the nature of of the Act is in the nature of an assessment order. Therefore, assessment of the total an assessment order. Therefore, assessment of the total an assessment order. Therefore, assessment of the total income of the assessee for the assessment year in relation income of the assessee for the assessment year in relation income of the assessee for the assessment year in relation to which the Set to which the Settlement Commission has passed the order tlement Commission has passed the order under section 245D(4) section 245D(4) of the Act stands concluded and in of the Act stands concluded and in terms of section 245I section 245I of the Act, such order shall be of the Act, such order shall be
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conclusive as to the matters stated therein and no matter clusive as to the matters stated therein and no matter clusive as to the matters stated therein and no matter covered by such order shall, save as otherwise provided in covered by such order shall, save as otherwise provided in covered by such order shall, save as otherwise provided in Chapter XIX Chapter XIXA, be reopened in any proceeding under the A, be reopened in any proceeding under the Act or under any other law for the time being in force. Act or under any other law for the time being in force. Act or under any other law for the time being in force. Therefore, once an order is pas Therefore, once an order is passed by the Settlement sed by the Settlement Commission under Commission under section 245D(4) of the Act, the same is of the Act, the same is conclusive insofar as the assessment year involved is conclusive insofar as the assessment year involved is conclusive insofar as the assessment year involved is concerned. When the section refers to matters not When the section refers to matters not When the section refers to matters not covered by such order, covered by such order, it refers to matters other it refers to matters other than that covered under the assessment, viz. other than that covered under the assessment, viz. other than that covered under the assessment, viz. other than determination of the total income of the than determination of the total income of the than determination of the total income of the assessee for that assessment year. There may be assessee for that assessment year. There may be assessee for that assessment year. There may be matters in respect of the very assessment year which matters in respect of the very assessment year which matters in respect of the very assessment year which do not touch the determination do not touch the determination of the total income of the total income of the assessee, like non of the assessee, like nonpayment of advance tax or payment of advance tax or the like, which have no direct connection with the the like, which have no direct connection with the the like, which have no direct connection with the determination determination determination of of of the the the total total total income income income for for for that that that assessment year, which would not stand concluded assessment year, which would not stand concluded assessment year, which would not stand concluded by the order of the Settlement Commissio by the order of the Settlement Commission. However, . However, when section 245C section 245C of the Act requires the assessee to of the Act requires the assessee to make a full and true disclosure of his income for the period make a full and true disclosure of his income for the period make a full and true disclosure of his income for the period in respect of which he has made such application, the in respect of which he has made such application, the in respect of which he has made such application, the order under section 245D(4) of the Act would relate to the of the Act would relate to the determination of the total income of the assessee for that determination of the total income of the assessee for that determination of the total income of the assessee for that assessment year and such order is conclusive and cannot assessment year and such order is conclusive and cannot assessment year and such order is conclusive and cannot be reopened except as be reopened except as provided in that Chapter.
[Emphasis supplied externally] [Emphasis supplied externally]
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5.3 In view of the above, it is held that the action of the Assessing In view of the above, it is held that the action of the Assessing In view of the above, it is held that the action of the Assessing Officer in reopening the case for A.Y. 2012 Officer in reopening the case for A.Y. 2012-13 is not valid. However, 13 is not valid. However, it is open to the revenue to move the ITSC for appropriate relief of it is open to the revenue to move the ITSC for appropriate relief of it is open to the revenue to move the ITSC for appropriate relief of declaration that its order u/s. 245D(4) of the Act was void if advised order u/s. 245D(4) of the Act was void if advised order u/s. 245D(4) of the Act was void if advised so that there is misrepresentation of the fact in relation to the share so that there is misrepresentation of the fact in relation to the share so that there is misrepresentation of the fact in relation to the share application money received from the abovementioned two Trusts. application money received from the abovementioned two Trusts. application money received from the abovementioned two Trusts. Accordingly, this ground of appeal of the revenue is dismissed. Accordingly, this ground of appeal of the revenue is dismissed. Accordingly, this ground of appeal of the revenue is dismissed.
The ground no.2 of the appeal relates to the addition of The ground no.2 of the appeal relates to the addition of The ground no.2 of the appeal relates to the addition of Rs.88,03,50,000/- made u/s. 68 of the Act. However, since the made u/s. 68 of the Act. However, since the made u/s. 68 of the Act. However, since the ground no.1 of the revenue is dismissed upholding the of the revenue is dismissed upholding the quashing of of the revenue is dismissed upholding the the reassessment order the reassessment order by the ld. CIT(A), we need not adjudicate , we need not adjudicate the issue on merits. Accordingly, this ground of appeal is dismissed. issue on merits. Accordingly, this ground of appeal is dismissed. issue on merits. Accordingly, this ground of appeal is dismissed.
In the result, the appeal of the In the result, the appeal of the Revenue is dismissed. is dismissed.
Order pronounced under Rule 34(4) Order pronounced under Rule 34(4) of the ITAT Rules, of the ITAT Rules, 1963 on 22/12/2022. /12/2022. Sd/- Sd/ Sd/- (RAHUL CHAUDHARY RAHUL CHAUDHARY) (OM PRAKASH KANT OM PRAKASH KANT) JUDICIAL MEMBER JUDICIAL MEMBER ACCOUNTANT MEMBER ACCOUNTANT MEMBER Mumbai;
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Dated: 22/12/2022 Rahul Sharma, Sr. P.S. Copy of the Order forwarded to Copy of the Order forwarded to : 1. The Appellant 2. The Respondent. 3. The CIT(A)- 4. CIT 5. DR, ITAT, Mumbai 6. Guard file. BY ORDER, BY ORDER, //True Copy// (Sr. Private Secretary) Private Secretary) ITAT, Mumbai ITAT, Mumbai