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Income Tax Appellate Tribunal, “B” BENCH, MUMBAI
IN THE INCOME TAX APPELLATE TRIBUNAL “B” BENCH, MUMBAI BEFORE SHRI S RIFAUR RAHMAN, ACCOUNTANT MEMBER & SHRI PAVAN KUMAR GADALE, JUDICIAL MEMBER ITA No. 2469/Mum/2021 (A.Y: 2014-15) & ITA No. 22/Mum/2022 (A.Y: 2015-16) Breach Candy Vs. DCIT, CC5(3) Swimming Bath Trust Room No. 1906, 19th 66, Bhulabhai Desai floor, Air India Bldg, Road, Breach Candy, Nariman Point, Mumbai – 400026. Mumbai – 400021. �थायी लेखा सं./जीआइआर सं./PAN/GIR No. : AAATB0133F Appellant .. Respondent Appellant by : Shri.Rajeev Waglay Adv. AR Respondent by : Shri.Dilip Kumar Shah & Shri.Mahesh Akhade. DR Date of Hearing 18.01.2022 Date of Pronouncement 27.01.2022 आदेश / O R D E R PER PAVAN KUMAR GADALE JM: These are the appeals filed by the assessee against the separate orders of the Commissioner of Income Tax (Appeals)- 53, Mumbai passed u/Sec144 r.w.s147 and 250 of the Act (A.Y.2014-15) and U/sec 143(3)r.w.s147 and 250 of the Income Tax Act, 1961 (A.Y.2015-16). Since the issues involved in these appeals are identical and inter connected, hence are clubbed, heard and consolidated order is passed.
ITA No. 2469/Mum/2021 & ITA No. 22/Mum/2022 Breach Candy Swimming Bath Trust, Mumbai. - 2 -
For the sake of convenience, we shall take ITA No. 22/Mum/2022 for the A.Y 2015-16 as a lead case and facts narrated therein. The assessee has raised the following grounds of appeal.
i. Upholding the addition of interest amounting to Rs. 1,22,81,315/- on the ground that the said interest did not pertain to F.Y 2014-15 inspite of the fact that the said interest was from tax free Govt bonds and in fact pertained to the F.Y 2014-15 only. ii. Upholding the disallowance of Rs. 18,01,500 on account of donation given by the appellant in spite of the fact that the said donation was not claimed by way of deduction by the appellant while computing the income of the appellant and the said amount was just debited to income and expenditure account and hence the order dated 24.12.2021 passed by the CIT(A)-53 upholding the addition of tax free intrest of Rs. 1,22,81,315/- as also the disallowance of donation to the tune of Rs. 18,01,500/- needs to be set aside to the extent.
The brief facts of the case are that, the assessee trust is registered u/s 12A of the Income Tax Act and operating swimming pool and bath club in Mumbai. A notice u/s 148 of the Act was issued on the assessee after recording reasons and the survey operations u/sec133A of the Act conducted at the office premises and further the assessee has not filed the return of income for the A.Y 2015-16. The Assessing officer (A.O.) has reason to believe that there is a income
ITA No. 2469/Mum/2021 & ITA No. 22/Mum/2022 Breach Candy Swimming Bath Trust, Mumbai. - 3 -
escaping the assessment. In compliance to notice u/s 148 of the Act, the assessee has filed the return of income on 14.2.2019 with a total income of Rs.30,18,600/- and unaudited income and expenditure and Balance sheet has been filed by the assessee. Further it was brought on record of the A.O, that there is a dispute between trustees and committee members of the assessee trust and the disputed matter is pending before the Hon’ble High Court of Bombay. The Hon’ble High Court has passed an interim order and appointed special committee referred at Para 4 of the assessment order. The A.O has considered the facts of the assessee’s case for the A.Y 2009-10 referred at Para 5 of the assessment order as under:
Nature of Exemption u/s 11 denied invoking provisions of addition Sec. 2(15) and treated the trust as a Mutual association in the context of cancellation of Registration u/s 12A vide order dated 26.11.2011 Decision of Ld. Ld. CIT(A) upheld the order of AO, holding that CIT(A) claim of exemption u/s 11 is contingent upon granting of registration u/s 12A, which once withdrawn would be eligible for the exemption and since the registration was cancelled, the question of granting exemption does not arise, and stated that assessee be assessed as a mutual association. Decision of The Tribunal held that the provisions of Sec. 2(15)
ITA No. 2469/Mum/2021 & ITA No. 22/Mum/2022 Breach Candy Swimming Bath Trust, Mumbai. - 4 -
Hon’ble ITAT are not applicable to the case of assessee. However, Tribunal set aside the matter to AO to revisit the application of principal of mutuality. Re-assessment The AO finalized assessment u/s 143(3) r.w.s 254 proceedings dated 28.03.2016 applying the principal of mutuality and taxed other income, being interest from Bank, fixed Deposits etc as income from other sources and assessed the income at Rs. 79,46,609/-. Decision of In the meantime the assessee had assailed the Hon’ble ITAT order of cancellation of Registration u/s 12A dated on cancellation 26.12.2011 before the Hon’ble ITAT, F Bench of 12A wherein vide order 30.06.2014 restored the registration registration u/s 12AA vide order dated 30.06.2014 Decision of The order of Hon’ble Tribunal restoring registration Hon’ble High u/s 12AA was challenged by revenue before the Court Hon’ble Bombay High Court, which vide order bearing No. ITA No. 600 of 2015 dated 19.09.2017 dismissed the appeal of Revenue Holding absence of Question of Law as the power to withdraw exemption of Director of Income Tax (Exmp) was granted in terms of amendment introduced by Finance Act, 2010 with effect from 01.06.2010 and that CBDT Circular No. 1/2011 dated 06.04.2011 explains why this amendment will apply for the A.Y 2011-12 and subsequent years.
The A.O. has observed that the assessee cannot claim exemption u/s 11 and 12 of the Act if the return of income is not filed under provisions of Sec. 139 of the Act along with the Audit Report in form 10B. In response to show cause notice, the assessee has filed a letter dated 25-03-2018 mentioning that as per the income and expenditure account, the assessee has disclosed a deficit of Rs. 3,11,74,716/-
ITA No. 2469/Mum/2021 & ITA No. 22/Mum/2022 Breach Candy Swimming Bath Trust, Mumbai. - 5 -
and whereas set off of income has been claimed as per the principle of mutuality. The A.O observed that the assessee is catering only to the members of the club and on perusal of the computation of income, the assessee has disclosed the bank interest, income tax refund interest income, scrap sale and rent from hospital under income from other sources,. Further, the A.O observed that the assessee has received tax free interest income on securities-bonds aggregating to Rs. 4,61,67,132/- and claimed exempt on the concept of mutuality principle. Whereas the A.O is of the opinion that the assessee is not entitled for any exemption or benefit and fall outside the purview of the principle of mutuality and made an addition of interest income. Similarly the A.O. has observed that the assessee has debited donation expenses of Rs. 18,01,500/- in the books of accounts and is not admissible expenditure and with other income of bank interest, scrap sale and rent from hospital the A.O.has assessed the total income of Rs. 5,10,27,130/- and passed the order u/s 143(3) r.w.s 147 of the Act dated 26.12.2019.
ITA No. 2469/Mum/2021 & ITA No. 22/Mum/2022 Breach Candy Swimming Bath Trust, Mumbai. - 6 -
Aggrieved by the order, the assessee has filed an appeal before the CIT(A). The CIT(A) considered the grounds of appeal, submissions of the assessee, findings of the A.O. whereas in respect of addition of interest income on securities-bonds, the CIT(A) has dealt on the findings of the A.O and is of the opinion that the assessee has invested in tax free government securities and the interest earned on securities/bonds is exempt u/s 10(15)(iv) of the Act. The assessee has invested in bonds of the public sector under takings such as NHAI, IRFC, NTPC and IRE etc. The CIT(A) allowed exemption u/s 10(15)(iv) of the Act to the extent of Rs.3,30,98,466/- and deleted the addition and observed that the balance of the interest on securities- bonds does not pertain to the F.Y 2014-15 and confirmed the addition to the extent of Rs.1,22,81,315/- and partly allowed the ground of appeal. 5. In respect of donation expenses claimed in the income and expenditure account, the assessee has filed the explanations referred at Para 5.2 of the CIT(A) order read as under:
ITA No. 2469/Mum/2021 & ITA No. 22/Mum/2022 Breach Candy Swimming Bath Trust, Mumbai. - 7 -
5.2 During the appellate proceedings, the appellant has made the written submissions, which are reproduced as under:- As for the addition on account of donation, it may be noted that it was not claimed by the assessee by way of deduction while computing the total income of the assessee. As such, there was no question of adding the same. And hence, the said addition needs to be deleted. But whilst on this point, the assessee would like to state that some of the donations were eligible for deduction u/s. 80G of the I. T. Act, 1961 (©50%), donation to PMNR fund was eligible for deduction u/s. 80G (@ 100%) and donation to Om Creations Trust was eligible for 100% deduction u/s. 80GGA(2) though not claimed in the return of income by the assessee. The assessee may be allowed to take this ground though not specified in the grounds of appeal by exercising your honour's power u/s. 250(5) of Income Tax Act. 1961. as the assessee was in fact entitled for these deductions which had nothing to do with the principle of mutuality. As such, these deductions may be allowed. (subject to verification by the AO). The xerox copies of the deductible donations made are enclosed.
The CIT(A) however was not convinced with the submissions, whereas, the assessee has the filed the return of income in response to notice u/s 148 of the Act and has not claimed deduction u/s 80-G of the Act and dismissed this ground of appeal and partly allowed the assessee’s appeal. Aggrieved by the CIT(A) order, the assessee has filed an appeal before the Honble Tribunal.
ITA No. 2469/Mum/2021 & ITA No. 22/Mum/2022 Breach Candy Swimming Bath Trust, Mumbai. - 8 -
At the time of hearing, the Ld. AR submitted that the CIT(A) has erred in sustaining addition of partial tax free interest, which the A.O has treated the same as taxable and the CIT(A) observed that it does not pertain to F.Y 2014-15.The Ld.AR submitted that the details of actual interest received falls in F.Y 2014-15 but due to software package the date and month are interchanged. The Ld.AR substantiated the submissions with details of interest income received with the correct dates and corresponding bank credits in the bank account statement of the assessee. On the second disputed issue with respect to donation expenses, the Ld. AR submitted that the assessee has not claimed deduction while computing the total income of the assessee though it was debited in the income and expenditure account and substantiated with the computation of total income filed in the paper book and prayed for allowing the appeal. Contra, the Ld.DR supported the order of the CIT(A) and submitted that the assessee is not eligible for benefit of principle of mutuality.
ITA No. 2469/Mum/2021 & ITA No. 22/Mum/2022 Breach Candy Swimming Bath Trust, Mumbai. - 9 -
We have heard the rival submissions and perused the material available on record. The Ld. AR has made submissions in respect of taxability of tax free interest income which was partly sustained by the CIT(A) as the receipt of interest income does not fall in the F.Y 2014-15. The Ld. AR submitted that on the principle of mutuality only specific income i.e. interest on income tax refund, scrap sale and of bank interest etc is only taxable in the assesses case. The Ld.AR emphasized on the details of tax free interest and the relevant date and credits in bank account statement. The Ld AR demonstrated the computation of total income for the period 01.04.2014 to 31.03.2015 at page 13 & 14 of the paper book, the ld. AR highlighted that as per Audited income and expenditure account, there is a deficit. But while preparing the computation of total income, only Bank interest, interest on income tax refund, scrap sale and rent from hospital are chargeable under income from other sources as the assessee is entitled for exemption u/s 11 of the Act. The Ld.AR also submitted that the tax free interest on bonds cannot be brought under the purview of the taxation and
ITA No. 2469/Mum/2021 & ITA No. 22/Mum/2022 Breach Candy Swimming Bath Trust, Mumbai. - 10 -
referred to the page-8 of the paper book demonstrating tax free interest on bond of NHAI, REC, PFC etc. with Actual dates. Whereas the date was changed due to the typing mistake and the computer system package. Hence the tax free interest on bonds to the extent of Rs. 1,22,81,315/- falls in the F.Y 2014-15 relevant to current assessment year and entitled for exemption u/s 10(15)(iv) of the Act. The Ld. AR submitted that the interest income component was aggregated in the bank account and referred to the bank statements at page 9 to 12 of the paper book. On perusal of these factual aspects discussed above, We find there is a technical error/mistake in computer package which cannot be ruled out. We find the Ld.AR submissions are realistic and duly supported with material evidences in the paper book is appreciated. Accordingly, we direct the Assessing officer to delete the addition of tax free interest on securities-bonds as it pertains to F.Y 2014-15 and the assessee is eligible for exemption u/s 10(15)(iv) of the Act and allow the ground of appeal in favour of the assessee.
ITA No. 2469/Mum/2021 & ITA No. 22/Mum/2022 Breach Candy Swimming Bath Trust, Mumbai. - 11 -
The second disputed issue is with respect to sustaining addition of donation expenses. The Ld. AR submitted that the assessee has not claimed deduction in respect of donation while preparing the computation of income. The Ld. AR emphasized that though donation expenses of Rs.18,01,500/- included under head “Miscellaneous income” was debited to the Audited income and expenditure account but for the purpose of exemption under the provisions of Sec.11 of the Act, the assessee has not claimed it as deduction. The Ld. AR demonstrated the computation statement of income at page 13 of the paper book. We find that the assessee on applying the principles of mutuality has considered only the bank interest, interest on income tax refund, scrap sales and rent from hospital chargeable under income from other sources and the total income disclosed was Rs.30,18,600/-. We find Prima facie the assessee has not claimed the deduction of donation while computing the statement of total income. Accordingly, we find the addition sustained by the CIT(A) is not justified and we direct the Assessing officer to delete
ITA No. 2469/Mum/2021 & ITA No. 22/Mum/2022 Breach Candy Swimming Bath Trust, Mumbai. - 12 -
the addition and allow the ground of appeal in favour of the assessee.
In the result, the appeal filed by the assessee is allowed.
ITA 2469/Mum/2021, A.Y 2014-15
The assessee has filed the appeal against the order of the CIT(A)-53, Mumbai passed u/s 144 r.w.s 147 and 250 of the Act.The assessee has raised the following grounds of appeal.
On the facts and the circumstances of the case, the Ld.CIT(A)-53 Mumbai erred in-
i. denying the benefit of mutuality claimed by the Appellant in respect of its income earned from the members and confirming the addition of Rs. 20,38,45,690. ii. denying the above benefit on the ground that the AO had allowed the expenses incurred on members' activities from the members' income and hence, had correctly applied the principle of mutuality. iii. not considering the true ratio of the Supreme Court judgments in Bangalore Club Vs. CIT - 2020] 427 ITR 260 and State of West Bengal Vs. Calcutta Club Ltd. - 20191 311 CTR 121. iv. not considering the audited accounts of the Appellant for
ITA No. 2469/Mum/2021 & ITA No. 22/Mum/2022 Breach Candy Swimming Bath Trust, Mumbai. - 13 -
the year ended 31.3.2014. & hence, the order dated 24.12.2021 passed by the CIT (A) - 53 Mumbai denying the benefit of mutuality in respect of income earned from the members needs to be set aside in toto by holding that the Appellant's income from the members was not at all taxable under the Principle of Mutuality.
The Brief facts of the case are discussed in A.Y. 2015-16 appeal of the assessee in the above paragraphs. Whereas, the present appeal pertains to A.Y 2014-15.The case was reopened u/s 147 of the Act and the notice u/sec148 of the Act was issued. The reasons were recorded that as per the information with the department, in the ITS details the assessee was engaged in acquiring/selling of shares, invested in infrastructure bonds and collected Tax (TCS). The assessee has not filed the return of income in compliance to notice. Since the assessee has not filed return of income nor any reply to the letters issued by the department, a survey u/sec133A of the Act was conducted on 1/08/2018. The assessee has filed a letter on 04.09.2018 explaining the dispute within the trustees and committee members. The A.O dealt on submissions and the provisions at Para 5 to 9 of the assessment order. The A.O is of the opinion that the
ITA No. 2469/Mum/2021 & ITA No. 22/Mum/2022 Breach Candy Swimming Bath Trust, Mumbai. - 14 -
assessee is not eligible for exemption u/s 11 of the Act. Hence the A,O, based on the information available on record has made Best judgment assessment u/s 144 of the Act and calculated the income assessable as per trial balance, tally back up data for the F.Y 2013-14 and allowed the expenses claimed on activities and calculated surplus as per unaudited income and expenditure account and assessed the total income u/s 144 r.w.s 147 of the Act of Rs. 23,97,12,960/- and passed the order on 27.12.2018.
Aggrieved by the order, the assessee has filed an appeal before the CIT(A), whereas the CIT(A) considered the facts, grounds of appeal, findings of the scrutiny assessment and written submissions filed in the course of appellate proceedings referred at Para 4.2 of the order. Finally theCIT(A) has partly confirmed the addition by excluding the tax free interest income and granted partial relief in other grounds of appeal and partly allowed the assessee appeal. Aggrieved by the CIT(A)order, the assessee has filed a appeal before the Honble Tribunal.
ITA No. 2469/Mum/2021 & ITA No. 22/Mum/2022 Breach Candy Swimming Bath Trust, Mumbai. - 15 -
At the time of hearing, the Ld. AR submitted that the CIT(A) has erred in confirming the partial addition considering the tax free interest. The Ld. AR submitted that the assessee is entitled for exemption u/s 11 of the Act and many expenses have been excluded while calculating the surplus by the A.O. The assessee has cooperated in the appellate proceedings and filed entire details, which the CIT(A) has over looked the valuable facts.The Ld.AR further submitted that the assessee was granted exemption u/s 11 of the Act on principle of mutuality in the earlier and subsequent A.Y. 2010-11 and 2019-20 by the revenue. The Ld.AR demonstrated the orders in the paper book and prayed that the assessee should be granted the benefit of principle of mutuality which was allowed in the earlier and subsequent Assesseement years. Contra, the Ld. DR supported the order of the CIT(A).
We have heard the rival submissions and perused the material on record. Prima-facie, the sole crux of the disputed issue is that the CIT(A) dealt on the facts that there is dispute between committee members and
ITA No. 2469/Mum/2021 & ITA No. 22/Mum/2022 Breach Candy Swimming Bath Trust, Mumbai. - 16 -
the trustees and the best judgment assesseement order is passed under 144 r.w.s147 of the Act. At the time of assessment proceeding, there was no proper accounting principles were applied and the A.O has made an addition after allowing the certain expenditure. whereas in the appellate proceedings before the CIT(A), the assessee has filed the Audited accounts and additional information referred at para 4.2 and 4.3 of the order;
4.2 During the appellate proceedings, the appellant has made its written submissions which is as under:- 1. As mentioned above, the accounts of the assessee could not be audited at the relevant time on account of court dispute and even the return could not be filed. This resulted in the assessment being completed u/s. 144 rws 147 of the I.T. Act, 1961. The accounts have now been audited and signed on 22.10.2019. In this scenario, the assessee would humbly request your honour to allow them to place all the details enclosed herewith on the record of your honour during the hearing of the appellate proceedings before your honour (in terms of Rule 46A(1)(c) of IT. Rules, 1962) since they go to the root of the appeal and would further request your honour to consider the same. 2. As mentioned above, though the assessee is registered under the Bombay Public Trust Act, 1950, it is in fact a Members Club & hence, the assessee's income needs to be computed by applying the principle of mutuality. 3. Under the principle of Mutuality, the income from the members cannot be considered to be taxable income as no entity can make profit out of itself. Thus. while computing the income
ITA No. 2469/Mum/2021 & ITA No. 22/Mum/2022 Breach Candy Swimming Bath Trust, Mumbai. - 17 -
in the present case, assessee has excluded income from the members as also the expenditure incurred. 4. . The concept of mutuality and consequential exemption of income from the members has been reiterated recently by the Supreme Court of India in the casde of Bangalore Club Vs. CIT- 2020 427 ITR 260 (SC) as also in State of West Bengal Vs. Calcutta Club Ltd. —2019 311 CTR 121. 5. . But assessee's other income such as hospital rent, scrap sale, saving bank interest and misc. interest is not earned from the members and hence, it is taxable. 6. The abovesaid concept of mutuality has been accepted by the Dept. in the assessee's own case- a. for the A.Y. 2010-11 as can be seen from the order dated 28.03.2016 passed u/s. 143(3) iws 254 of I. Act, 1961. b. by the CIT(A)-1, Mumbai for the A.Y. 2011-12 vide his order dated 14.11.2014 c. in the assessment order dated 26. 12.2019 for the A. Y. 2015-16 u/s. 143(3) rws 147 of 1.1 Act, 1961. d. in the recent assessment order dated 30.09.2021 for the A. Y, 2019-20 u/s. 143(3) of IT. Act, 1961. 7. Further, during the year, the assessee had earned interest of Rs. 3,20,23,4221- from Govt. bonds. Out of the same, interest of Rs. 6,94,7321- was taxable and balance interest of Rs. 3,13,28,6901- was exempt u/s. 10(15) (iv) being interest on tax free govt. bonds and hence, excluded. 8. From the audited accounts of the assessee, it can be seen that except for Hospital rent, scrap sale, saving bank interest and misc. interest, all other income was earned from the members only and hence, it is not taxable on the ground of mutuality. 9. As such, the gross taxable income of the assessee amounts to Rs. 45,38,5801-. 4.3 The submissions made by the appellant have been considered. During the year, as per the income and expenditure statement for
ITA No. 2469/Mum/2021 & ITA No. 22/Mum/2022 Breach Candy Swimming Bath Trust, Mumbai. - 18 -
F.Y 2013-14, as available in tally back-up impounded during the survey proceedings, the appellant had gross receipts of Rs. 41,08,27,382/-. After allowing the claim of the expenses, the surplus was Rs. 23,97,12,960/-. The appellant has submitted that the appellant is registered under the Bombay Public Trust Act, 1950, and it is a member’s club. Therefore, the Principles of mutuality is applicable in respect of income from members activities. The appellant has submitted that the other income such as hospital rent, scrap sale, saving bank interest and miscellaneous interest, which is not earned from the members is taxable. It amounted to Rs. 45,38,580/-. Further, the interest of Rs. 3,13,28,690/- received from Government bonds is exempt u/s. 10(15)(iv) as tax-free interest.
In the case of the appellant, it has not filed the Return of income u/s. 139(1) of the Act. Even in response to notice u/s. 148 of the Act, the appellant did not file the Return of income. Therefore, the AG has passed the assessment order u/s. 144 of the Act. It is noted by the AG that the appellant had complied to Service Tax, GST and VAT Act and filed respective returns but the appellant did not comply to the provisions of the I.T. Act and has not filed the Return of Income. The AG has allowed the expenses which were incurred on members' activities and has worked out the surplus amount of Rs. 23,97,12,960!-. Therefore, the assessee's argument that the AG has not applied the principles of mutuality is not correct. However, the surplus of Rs. 23,97,12,960!- also include the interest income of Rs. _3,13,28,690/-which is earned from tax-free bonds. The details of such interest have been given during the appellate proceedings. The AG is directed to verify the tax-free interest received from Government bonds and allow interest which is exempt u/s. 10(15)(iv) of the Act. Accordingly, the addition of Rs. 20,83,84,270/- made by the AO is confirmed. In view of the above facts, ground No. 1, 3 & 4 of the appeal are partly allowed.
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The Ld. AR referred to page 34 of paper book where the CIT(A) for the A.Y 2011-12 has granted the benefit of exemption u/s 11 of the Act on the principle of mutuality. Similarly for A.Y 2019-20. The Ld. AR referred to page 49& 50 of the paper book, where the principle of mutuality has been accepted and the benefit was granted and the assessement order u/sec143(3) of the Act was passed on 30-09- 2021. We considering the overall facts, circumstances and the disputes between the trustees and committee members pending before Honble High Court Of Bombay are of the substantive opinion that, on the principles of natural justice the assessee should be provided one more opportunity of hearing before the lower authorities to substantiate the case with the material evidences.Accordingly,theinformation/details submitted before the CIT(A) by the assessee are restored to the file of the A.O to consider afresh and decide on merits and the assessee should be provided adequate opportunity of hearing and shall cooperate in submitting the information expeditiously and allow
ITA No. 2469/Mum/2021 & ITA No. 22/Mum/2022 Breach Candy Swimming Bath Trust, Mumbai. - 20 -
the grounds of appeal of the assessee for statistical purposes.
In the result, the assessee appeal ITA No. 2469/Mum/2021 for the A.Y 2014-15 is treated as allowed for statistical purpose and ITA No.22/Mum/2022 for the A.Y 2015-16 is allowed.
Order pronounced in the open court on 27.01.2022.
Sd/- Sd/- (S RIFAUR RAHMAN) (PAVAN KUMAR GADALE) ACCOUNTANT MEMBER JUDICIAL MEMBER
Mumbai, Dated 27.01.2022
KRK, PS आदेश क� ��त�ल�प अ�े�षत/Copy of the Order forwarded to : 1. अपीलाथ� / The Appellant 2. ��यथ� / The Respondent. 3. संबं�धत आयकर आयु�त / The CIT(A) 4. आयकर आयु�त(अपील) / Concerned CIT �वभागीय ��त�न�ध, आयकर अपील�य अ�धकरण, अहमदाबाद / DR, ITAT, Mumbai 5. 6. गाड� फाईल / Guard file. आदेशानुसार/ BY ORDER, स�या�पत ��त //True Copy// 1. ( Asst. Registrar) ITAT, Mumbai