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Income Tax Appellate Tribunal, MUMBAI BENCH “B” MUMBAI
Before: SHRI OM PRAKASH KANT & SHRI SANDEEP SINGH KARHAIL
PER OM PRAKASH KANT, AM PER OM PRAKASH KANT, AM
This appeal by the Revenue and by the Revenue and Cross-objection by the objection by the assessee are directed against order dated 27.06.2019 passed by assessee are directed against order dated 27.06.2019 passed by assessee are directed against order dated 27.06.2019 passed by the Ld. Commissioner of Income the Ld. Commissioner of Income-tax (Appeals)-4, Mumbai [in 4, Mumbai [in short ‘the Ld. CIT(A)’] for assessment year 2013 CIT(A)’] for assessment year 2013-14.
The grounds raised by the Revenue in its appeal in grounds raised by the Revenue in its appeal in ITA No. The grounds raised by the Revenue in its appeal in ITA No. 5663/M/2019 are reproduced as under: 5663/M/2019 are reproduced as under:
1. On the facts and in the circumstances of the case and in law, On the facts and in the circumstances of the case and in law, On the facts and in the circumstances of the case and in law, the Ld. CIT(A) erred in directing the AO to treat the the Ld. CIT(A) erred in directing the AO to treat the the Ld. CIT(A) erred in directing the AO to treat the loss of Rs.5,90,00,000/ Rs.5,90,00,000/-on account of write-off off of of amounts amounts advanced for production of feature film "Aarakshan" as Short advanced for production of feature film "Aarakshan" as Short advanced for production of feature film "Aarakshan" as Short Term Capital Loss', without appreciating the fact that the Term Capital Loss', without appreciating the fact that the Term Capital Loss', without appreciating the fact that the assessee had never acquired any rights over such film assessee had never acquired any rights over such film assessee had never acquired any rights over such film 2. The appellant prays tha The appellant prays that the order of Ld.CIT(A) on the above t the order of Ld.CIT(A) on the above grounds be set grounds be set-aside and that of the assessing officer be aside and that of the assessing officer be restored. restored.
The grounds raised by the assessee in the cross The grounds raised by the assessee in the cross The grounds raised by the assessee in the cross-objection are reproduced as under: are reproduced as under:
1. Ld. CIT (A) erred in allowing the loss of Rs. 5,90,00,000/ Ld. CIT (A) erred in allowing the loss of Rs. 5,90,00,000/ Ld. CIT (A) erred in allowing the loss of Rs. 5,90,00,000/- as loss under the head " short term capital gains" instead as loss under the head " short term capital gains" instead as loss under the head " short term capital gains" instead under the head " profits & gains from business" as claimed under the head " profits & gains from business" as claimed under the head " profits & gains from business" as claimed by the Respondent by the Respondent
M/s Nadiadwala Entertainment M/s Nadiadwala Entertainment & Technologies 3 & CO NO. 23/M/2021 ITA No. 5663/M/2019 & CO NO. 23/M/2021
Briefly stated, facts of the case are that the assessee filed its Briefly stated, facts of the case are that the assessee filed its Briefly stated, facts of the case are that the assessee filed its return of income for the year under consideration o return of income for the year under consideration o return of income for the year under consideration on 25.09.2013 declaring total income at Rs. Nil. The return of income was declaring total income at Rs. Nil. The return of income was declaring total income at Rs. Nil. The return of income was processed u/s 143(1) of the Income processed u/s 143(1) of the Income-tax Act, 1961 (in short ‘the tax Act, 1961 (in short ‘the Act’). Thereafter, the case was selected for scrutiny and wherein Act’). Thereafter, the case was selected for scrutiny and wherein Act’). Thereafter, the case was selected for scrutiny and wherein the total income was determined at a loss of Rs.52,19 the total income was determined at a loss of Rs.52,19 the total income was determined at a loss of Rs.52,199/- in order u/s 143(3) dated 23.03.2016. u/s 143(3) dated 23.03.2016.
4.1 In the assessment completed, the Assessing Officer In the assessment completed, the Assessing Officer In the assessment completed, the Assessing Officer disallowed the loss on account of operating expenses of Rs.5.90 disallowed the loss on account of operating expenses of Rs.5.90 disallowed the loss on account of operating expenses of Rs.5.90 crores holding that same being in the nature of prior period crores holding that same being in the nature of prior period crores holding that same being in the nature of prior period expenses expenses and and hence hence not not allowable allowable in in the the year year under under consideration. On further appeal, the Ld. CIT(A) however consideration. On further appeal, the Ld. CIT(A) however consideration. On further appeal, the Ld. CIT(A) however characterized the loss as short term capital loss being loss on characterized the loss as short term capital loss being loss on characterized the loss as short term capital loss being loss on purchase of distribution rights. purchase of distribution rights.
Aggrieved, the Revenue is in appeal for allowing claim as Aggrieved, the Revenue is in appeal for allowing claim as Aggrieved, the Revenue is in appeal for allowing claim as short term capital los short term capital loss whereas the assessee is aggrieved for not s whereas the assessee is aggrieved for not treating the same as business loss. treating the same as business loss.
The assessee filed a Paperbook containing paged 1 to 68. The assessee filed a Paperbook containing paged 1 to 68. The assessee filed a Paperbook containing paged 1 to 68.
M/s Nadiadwala Entertainment M/s Nadiadwala Entertainment & Technologies 4 & CO NO. 23/M/2021 ITA No. 5663/M/2019 & CO NO. 23/M/2021
We have heard rival submission of the parties on the issue We have heard rival submission of the parties on the issue We have heard rival submission of the parties on the issue- in-dispute and perused the relevant material on reco dispute and perused the relevant material on reco dispute and perused the relevant material on record. The facts in brief qua, the issue in brief qua, the issue-in-dispute are that the assessee advanced dispute are that the assessee advanced a sum of Rs.8.9 crores to a sum of Rs.8.9 crores to “Prakash Jha Production” on account of a feature film “Arakshan”. feature film “Arakshan”. It was claimed by the assessee that t It was claimed by the assessee that the said investment was made for purchase of dis said investment was made for purchase of distribution rights of tribution rights of the film but the assessee could not fulfil its obligation of the assessee could not fulfil its obligation of the assessee could not fulfil its obligation of financing the further amount for production of the film financing the further amount for production of the film financing the further amount for production of the film and dispute arose between the parties dispute arose between the parties. The Prakash Jha Production he Prakash Jha Production acquired funds from some other parties and assessee w from some other parties and assessee w from some other parties and assessee was settled with a refund of Rs.3 crores. The balance amount was claimed by a refund of Rs.3 crores. The balance amount was claimed by a refund of Rs.3 crores. The balance amount was claimed by the assessee in return of return of income as operating expenses operating expenses written off. The Ld. Assessing Officer disallowed the claim holding that . The Ld. Assessing Officer disallowed the claim holding that . The Ld. Assessing Officer disallowed the claim holding that written off of the loss was in the nature of prior pe loss was in the nature of prior period expenses riod expenses and therefore not allowable. The relevant finding of the Assessing and therefore not allowable. The relevant finding of the Assessing and therefore not allowable. The relevant finding of the Assessing Officer is reproduced as under: Officer is reproduced as under:
“4.2 As explained by the assessee above, the assessee As explained by the assessee above, the assessee had funded a amount of Rs.8,90,00,000/ had funded a amount of Rs.8,90,00,000/- to PJP on account of a Feature Film "Aarakshan". account of a Feature Film "Aarakshan". This particular This particular contract did not fructify and the film was never produced by contract did not fructify and the film was never produced by contract did not fructify and the film was never produced by the assessee. The matter went in to dispute and the the assessee. The matter went in to dispute and the the assessee. The matter went in to dispute and the assessee could recover only Rs.3,00,00,000/ assessee could recover only Rs.3,00,00,000/- - against the M/s Nadiadwala Entertainment M/s Nadiadwala Entertainment & Technologies 5 & CO NO. 23/M/2021 ITA No. 5663/M/2019 & CO NO. 23/M/2021 film funding of Rs.8,90,00,000/ film funding of Rs.8,90,00,000/-. The balance amount of . The balance amount of Rs.5,90,00,00 Rs.5,90,00,000/- was never recovered. It is that amount was never recovered. It is that amount which is written off and claimed as an expenses which is written off and claimed as an expenses which is written off and claimed as an expenses
4.3 The contention putforth by the authorised representative 4.3 The contention putforth by the authorised representative 4.3 The contention putforth by the authorised representative of the assessee has been duly considered but not found of the assessee has been duly considered but not found of the assessee has been duly considered but not found acceptable in view of the following reasons: acceptable in view of the following reasons:
As explained by the assessee above, the film was released explained by the assessee above, the film was released explained by the assessee above, the film was released on 12.08.2011 and the assessee had signed a settlement on 12.08.2011 and the assessee had signed a settlement on 12.08.2011 and the assessee had signed a settlement agreement dated 11th November, 2011. As seen from the agreement dated 11th November, 2011. As seen from the agreement dated 11th November, 2011. As seen from the subject of settlement. agreement, it is amply clear that both subject of settlement. agreement, it is amply clear that both subject of settlement. agreement, it is amply clear that both parties i.e. assessee and Prak parties i.e. assessee and Prakash Jha production has ash Jha production has reached final settlement. Assessee had received the final reached final settlement. Assessee had received the final reached final settlement. Assessee had received the final settlement amount from Prakash Jha production from settlement amount from Prakash Jha production from settlement amount from Prakash Jha production from November 2011 to February 2012; also assessee has not November 2011 to February 2012; also assessee has not November 2011 to February 2012; also assessee has not given any document or evidence to justify that assessee given any document or evidence to justify that assessee given any document or evidence to justify that assessee was trying to was trying to claim additional revenue from film realization claim additional revenue from film realization of movie Aarakshan, which is disputed. Therefore, it is clear of movie Aarakshan, which is disputed. Therefore, it is clear of movie Aarakshan, which is disputed. Therefore, it is clear that said amount cannot be written off in F.Y. 2012 that said amount cannot be written off in F.Y. 2012 that said amount cannot be written off in F.Y. 2012-13: Without prejudice to the above, rule 9A of Income Without prejudice to the above, rule 9A of Income Without prejudice to the above, rule 9A of Income-täx Rules, 1962 is not applicable to asse 1962 is not applicable to assessee since it has not produced ssee since it has not produced movie. Further, assessee has made submission that it is not Further, assessee has made submission that it is not covered by rule 9B too of Income covered by rule 9B too of Income-tax Rules, 1962. tax Rules, 1962.
4.4 Admittedly the expenses being of a prior period and not 4.4 Admittedly the expenses being of a prior period and not 4.4 Admittedly the expenses being of a prior period and not pertaining to the year under consideration cannot be pertaining to the year under consideration cannot be pertaining to the year under consideration cannot be allowed the decisions of the Hon’ble Mumbai Tribunal in the lowed the decisions of the Hon’ble Mumbai Tribunal in the lowed the decisions of the Hon’ble Mumbai Tribunal in the case of Tipco Industries Ltd. V. The ACIT case of Tipco Industries Ltd. V. The ACIT Income Income-tax Act, 1961 No.5708/Mum/2009 1961 No.5708/Mum/2009 - Assessment year Assessment year-2004-05, date of pronouncement: 03.08.2012 is relevant at para 15 date of pronouncement: 03.08.2012 is relevant at para 15 date of pronouncement: 03.08.2012 is relevant at para 15 which is self which is self-explanatory is reproduced below:
We have considered the rival submission and 15. We have considered the rival submission and perused the brders of lower authorities. It is settled perused the brders of lower authorities. It is settled that the deduction can be permitted in respect of only that the deduction can be permitted in respect of only
M/s Nadiadwala Entertainment M/s Nadiadwala Entertainment & Technologies 6 & CO NO. 23/M/2021 ITA No. 5663/M/2019 & CO NO. 23/M/2021 those expenses which are incurred in the relevant those expenses which are incurred in the relevant accounting year for the purpose of computing yearly computing yearly profits and gains. We find that the claim of the profits and gains. We find that the claim of the assessee of expenses pertaining to prior period assessee of expenses pertaining to prior period cannot be accepted as nothing has been brought on cannot be accepted as nothing has been brought on record to substantiate its claim neither before the record to substantiate its claim neither before the lower authorities nor before us. Ground Ground No:3 is accordingly dismissed.
4.5 In the lights of the above findings that the said 4.5 In the lights of the above findings that the said 4.5 In the lights of the above findings that the said expenses are prior period expenses herce not allowable expenses are prior period expenses herce not allowable expenses are prior period expenses herce not allowable W/s. 370) of the Income Tax Act, 1961, the prior period W/s. 370) of the Income Tax Act, 1961, the prior period W/s. 370) of the Income Tax Act, 1961, the prior period expenses are not allowable expenses. Hence, Written off expenses are not allowable expenses. Hence, Written off expenses are not allowable expenses. Hence, Written off loss - being in the nature of prior period expenses of being in the nature of prior period expenses of Rs.5,90,00,000/ Rs.5,90,00,000/- is hereby disallowed and added back to is hereby disallowed and added back to the total income of the assessee. Penalty proceedings u/s. the total income of the assessee. Penalty proceedings u/s. the total income of the assessee. Penalty proceedings u/s. 271(1)(c) of the Income 271(1)(c) of the Income-tax Act, 1261 is initiated separately tax Act, 1261 is initiated separately for furnishing inaccurate pa for furnishing inaccurate particulars of income.” ”
7.1 On further appeal, the Ld. CIT(A) has characterized the loss On further appeal, the Ld. CIT(A) has characterized the loss On further appeal, the Ld. CIT(A) has characterized the loss as short term capital loss as against claim of the assessee as as short term capital loss as against claim of the assessee as as short term capital loss as against claim of the assessee as business loss. The relevant finding of the Ld. CIT(A) is reproduced business loss. The relevant finding of the Ld. CIT(A) is reproduced business loss. The relevant finding of the Ld. CIT(A) is reproduced as under :
“6. I have carefully I have carefully perused the order of the AO and the perused the order of the AO and the submissions made by the AR in support of his arguments. submissions made by the AR in support of his arguments. submissions made by the AR in support of his arguments. After taking into consideration the AO's findings and order After taking into consideration the AO's findings and order After taking into consideration the AO's findings and order sheet notings, as well as the facts of the case, decision on sheet notings, as well as the facts of the case, decision on sheet notings, as well as the facts of the case, decision on the ground raised by assessee is made here the ground raised by assessee is made here under: under:-
6.1 Only effective ground raised by the appellant is against Only effective ground raised by the appellant is against Only effective ground raised by the appellant is against disallowance of a sum or 35.90.00.000/ disallowance of a sum or 35.90.00.000/- being written off being written off as loss by the appellant by the Ld. AO by treating the same as loss by the appellant by the Ld. AO by treating the same as loss by the appellant by the Ld. AO by treating the same
M/s Nadiadwala Entertainment M/s Nadiadwala Entertainment & Technologies 7 & CO NO. 23/M/2021 ITA No. 5663/M/2019 & CO NO. 23/M/2021 as prior period expenses. In para 4 of the assessment order. as prior period expenses. In para 4 of the assessment order. as prior period expenses. In para 4 of the assessment order. Ld. AO h Ld. AO had mentioned that the assessee company had ad mentioned that the assessee company had debited a sum of 25.90.00,000/ debited a sum of 25.90.00,000/- in the Profit & Loss in the Profit & Loss account as cost of operating expenses. During the course of account as cost of operating expenses. During the course of account as cost of operating expenses. During the course of assessment proceedings, Ld. AO asked the appellant to assessment proceedings, Ld. AO asked the appellant to assessment proceedings, Ld. AO asked the appellant to explain the allowability of the expense claime explain the allowability of the expense claime explain the allowability of the expense claimed by it. According to the Ld. AO. the expenses claimed by the According to the Ld. AO. the expenses claimed by the According to the Ld. AO. the expenses claimed by the appellant pertained to prior period and not the year under appellant pertained to prior period and not the year under appellant pertained to prior period and not the year under consideration. Therefore, he disallowed the claim of the consideration. Therefore, he disallowed the claim of the consideration. Therefore, he disallowed the claim of the appellant and added the same to the total taxable income of appellant and added the same to the total taxable income of appellant and added the same to the total taxable income of the assessee Durin the assessee During the course of appellate proceeding, a g the course of appellate proceeding, a written submission was filed which find place in para 5 of written submission was filed which find place in para 5 of written submission was filed which find place in para 5 of this order. The appellant submitted that it's a closely held this order. The appellant submitted that it's a closely held this order. The appellant submitted that it's a closely held Company incorporated with an object to undertake Company incorporated with an object to undertake Company incorporated with an object to undertake production, distribution and funding of films. production, distribution and funding of films. The appellant The appellant further submitted that one of the major share further submitted that one of the major share further submitted that one of the major share-holder and director of the Appellant Company. Mr. Firoz Nadiadwala director of the Appellant Company. Mr. Firoz Nadiadwala director of the Appellant Company. Mr. Firoz Nadiadwala also a proprietor of Base Industries Group (BIG) and also a proprietor of Base Industries Group (BIG) and also a proprietor of Base Industries Group (BIG) and Prakash Jha Production (PJP) jointly produced film Prakash Jha Production (PJP) jointly produced film Prakash Jha Production (PJP) jointly produced film "Aarakshan" for which apa "Aarakshan" for which apart from BIG's contribution, funds rt from BIG's contribution, funds had been contributed through Appellant as it was to get had been contributed through Appellant as it was to get had been contributed through Appellant as it was to get distribution rights of the film. The appellant mentioned that distribution rights of the film. The appellant mentioned that distribution rights of the film. The appellant mentioned that he could recover only Rs. 3.00 Crs as against the film he could recover only Rs. 3.00 Crs as against the film he could recover only Rs. 3.00 Crs as against the film funding of Rs.8.90 Crs and had written off the lo funding of Rs.8.90 Crs and had written off the lo funding of Rs.8.90 Crs and had written off the loss amounting Rs.5.90 Crs us 28(i) of the Income amounting Rs.5.90 Crs us 28(i) of the Income amounting Rs.5.90 Crs us 28(i) of the Income-tax Act, 1961(Act) to the Profit & Loss A/c. The appellant further 1961(Act) to the Profit & Loss A/c. The appellant further 1961(Act) to the Profit & Loss A/c. The appellant further submitted that the LAO disallowed the loss written off submitted that the LAO disallowed the loss written off submitted that the LAO disallowed the loss written off amounting Rs. 5.90 Crs. treating the same as prior period amounting Rs. 5.90 Crs. treating the same as prior period amounting Rs. 5.90 Crs. treating the same as prior period expense giving reason that t expense giving reason that the film was released on he film was released on 12.08.2011 and the Appellant had signed a settlement 12.08.2011 and the Appellant had signed a settlement 12.08.2011 and the Appellant had signed a settlement agreement dated 11th November, 2011. It was further agreement dated 11th November, 2011. It was further agreement dated 11th November, 2011. It was further submitted that the Appellant had received the final submitted that the Appellant had received the final submitted that the Appellant had received the final settlement amount from PJP from November 2011 to settlement amount from PJP from November 2011 to settlement amount from PJP from November 2011 to February 2012. Appellant f February 2012. Appellant further argued that although urther argued that although
M/s Nadiadwala Entertainment M/s Nadiadwala Entertainment & Technologies 8 & CO NO. 23/M/2021 ITA No. 5663/M/2019 & CO NO. 23/M/2021 payments were recovered but issue was not settled finally. payments were recovered but issue was not settled finally. payments were recovered but issue was not settled finally. Therefore, appellant further claimed that the said amount Therefore, appellant further claimed that the said amount Therefore, appellant further claimed that the said amount could not be written off in F. Y.2012 could not be written off in F. Y.2012-13
6.1.1 From perusal of the submission of the appellant it is From perusal of the submission of the appellant it is From perusal of the submission of the appellant it is evident t evident that the expenditure was incurred for production of hat the expenditure was incurred for production of the film Aarakshan. Film was jointly produced by Mr. Firoz the film Aarakshan. Film was jointly produced by Mr. Firoz the film Aarakshan. Film was jointly produced by Mr. Firoz Nadiadwala, Proprietor of Base Industries Group (BIG) and Nadiadwala, Proprietor of Base Industries Group (BIG) and Nadiadwala, Proprietor of Base Industries Group (BIG) and Prakash Jha Production and the assessee company. Since Prakash Jha Production and the assessee company. Since Prakash Jha Production and the assessee company. Since the production of the film the production of the film was a joint work of above three of above three entities and not the assessee company, therefore, it entities and not the assessee company, therefore, it entities and not the assessee company, therefore, it was not the business expenditure of the assessee, rather the the business expenditure of the assessee, rather the the business expenditure of the assessee, rather the assessee made an investment of R8.90 crores for assessee made an investment of R8.90 crores for assessee made an investment of R8.90 crores for purchasing the distribution rights of the film. purchasing the distribution rights of the film. Distribution rights rights are intangible asset, hence, investment of assessee are intangible asset, hence, investment of assessee was for purchasing an intangible asset which was a capital was for purchasing an intangible asset which was a capital was for purchasing an intangible asset which was a capital asset. Film was released on 12.08.2011, therefore, on date asset. Film was released on 12.08.2011, therefore, on date asset. Film was released on 12.08.2011, therefore, on date of release of film distribution rights were came in existence of release of film distribution rights were came in existence of release of film distribution rights were came in existence and for determining the and for determining the purchase value of these rights purchase value of these rights appellant signed settlement agreement dated 11.11.2011 appellant signed settlement agreement dated 11.11.2011 appellant signed settlement agreement dated 11.11.2011 and appellant received the final settlement amount from and appellant received the final settlement amount from and appellant received the final settlement amount from November, 2012 to February, 2012, but still some November, 2012 to February, 2012, but still some November, 2012 to February, 2012, but still some negotiations were going on between the assessee company negotiations were going on between the assessee company negotiations were going on between the assessee company and produ and producer of the film. The final amount was only settled cer of the film. The final amount was only settled during the year under consideration. Therefore, the capital during the year under consideration. Therefore, the capital during the year under consideration. Therefore, the capital loss will be allowed only in the year under consideration. loss will be allowed only in the year under consideration. loss will be allowed only in the year under consideration. Since the loss was incurred for purchasing capital asset, Since the loss was incurred for purchasing capital asset, Since the loss was incurred for purchasing capital asset, therefore, claim of the appe therefore, claim of the appellant regarding allowability of llant regarding allowability of business loss is not accepted rather AO is directed to treat business loss is not accepted rather AO is directed to treat business loss is not accepted rather AO is directed to treat the loss on purchase of distribution rights as a short term the loss on purchase of distribution rights as a short term the loss on purchase of distribution rights as a short term capital loss and not the business loss. capital loss and not the business loss.”
7.2 We find that the assessee has not incurred expenses for We find that the assessee has not incurred expenses for We find that the assessee has not incurred expenses for production of the film whereas, the assessee claim oduction of the film whereas, the assessee claim oduction of the film whereas, the assessee claimed that said
M/s Nadiadwala Entertainment M/s Nadiadwala Entertainment & Technologies 9 & CO NO. 23/M/2021 ITA No. 5663/M/2019 & CO NO. 23/M/2021 investment was made was made for purchase of distribution right of the distribution right of the film which are in the nature of intangible assets and therefore film which are in the nature of intangible assets and therefore film which are in the nature of intangible assets and therefore, investment was for purchase of capital asset and loss incurred on investment was for purchase of capital asset and loss incurred on investment was for purchase of capital asset and loss incurred on the same is in the nature on e same is in the nature on ‘short term capital loss short term capital loss’. In our opinion, finding of the Ld. CIT(A) on the issue opinion, finding of the Ld. CIT(A) on the issue-in-dispute is well dispute is well reasoned and no interference is required in the same. We reasoned and no interference is required in the same. We reasoned and no interference is required in the same. We accordingly uphold the finding of the Ld. CIT(A) on the issue accordingly uphold the finding of the Ld. CIT(A) on the issue accordingly uphold the finding of the Ld. CIT(A) on the issue-in- dispute. The ground raised by the Revenue as well as by the e. The ground raised by the Revenue as well as by the e. The ground raised by the Revenue as well as by the assessee in cross-objection are accordingly dismissed. objection are accordingly dismissed. objection are accordingly dismissed.
In the result, the appeal filed by the Revenue as well as In the result, the appeal filed by the Revenue as well as In the result, the appeal filed by the Revenue as well as cross-objection of the assessee are dismissed. objection of the assessee are dismissed.
Order pronounced under Rule 34(4) of Order pronounced under Rule 34(4) of the ITAT Rules, the ITAT Rules, 1963 on 30/11/2022. /2022. Sd/- Sd/- - (SANDEEP SINGH KARHAIL SANDEEP SINGH KARHAIL) (OM PRAKASH KANT OM PRAKASH KANT) JUDICIAL MEMBER JUDICIAL MEMBER ACCOUNTANT MEMBER ACCOUNTANT MEMBER Mumbai; Dated: 30/11/2022 Rahul Sharma, Sr. P.S. Copy of the Order forwarded to Copy of the Order forwarded to :
1. 1. The Appellant 2. The Respondent.
3. The CIT(A)- 4. CIT 5. DR, ITAT, Mumbai
M/s Nadiadwala Entertainment M/s Nadiadwala Entertainment & Technologies 10 & CO NO. 23/M/2021 ITA No. 5663/M/2019 & CO NO. 23/M/2021