PREMJI BHURLAL GALA ,MUMBAI vs. ADDL CIT RANG 24(1), MUMBAI
Facts
The assessee's case was reopened based on information from a search and survey action in another entity, which indicated undisclosed moneylending activities. The assessee was alleged to have received a cash loan of Rs. 64,25,000/-. The Assessing Officer (AO) made an addition for this amount under Section 69A and initiated penalty proceedings under Section 271D.
Held
The Tribunal noted that a coordinate bench had previously deleted the addition of Rs. 64,25,000/- in the quantum appeal, finding the entire assessment based on statements of partners of M/s Evergreen Enterprises without other evidence. Relying on this and Apex Court judgments, the Tribunal held that the penalty proceedings initiated under Section 271D do not survive when the assessment order or reassessment proceedings are quashed.
Key Issues
Whether the penalty levied under Section 271D for alleged cash loan is sustainable when the addition on which it is based has been deleted in a prior appeal and the reassessment proceedings are found to be invalid.
Sections Cited
147, 132, 132(4), 69A, 271(1)(c), 271(1)(b), 271D, 269SS, 273B, 68, 151, 271E, 271(1)(c), 68
AI-generated summary — verify with the full judgment below
Income Tax Appellate Tribunal, MUMBAI BENCH “C”, MUMBAI
Before: SHRI NARENDER KUMAR CHOUDHRY & SHRI BIJAYANANDA PRUSETH
IN THE INCOME TAX APPELLATE TRIBUNAL, MUMBAI BENCH “C”, MUMBAI BEFORE SHRI NARENDER KUMAR CHOUDHRY, JUDICIAL MEMBER And SHRI BIJAYANANDA PRUSETH, ACCOUNTANT MEMBER ITA No. 6596/M/2025 Assessment Year: 2016-17 Premji Bhurlal Gala Addl. CIT Range 24(1), B-301, Water Ford, CD Mumbai Barfiwala Road Juhu Fally Kautilya Bhavan, C-41 to C- Vs. Andheri West, Mumbai - 43, G Block, Bandra Kurla 400058 Complex, Bandra (E) Mumbai – 400051 (Appellant) (Respondent) Present for: Assessee by : Shri Vinod Kumar Bindal & Satish Kumar, Ld. A. Rs. Revenue by : Shri Virabhadra Mahajan, SR. D.R. Date of Hearing : 09.12.2025 Date of Pronouncement : 28.01.2026 O R D E R Per : Narender Kumar Choudhry, Judicial Member: This appeal has been preferred by the Assessee against the order dated 23.09.2025, impugned herein, passed by the Ld. Commissioner of Income Tax (Appeals) (in short Ld. Commissioner) u/s 250 of the Income Tax Act, 1961 (in short ‘the Act’) for the A.Y. 2016-17.
In the instant case, the case of the Assessee was reopened under Section 147 of the Act, on the basis of search and survey action under Section 132 of the Act carried out in the case of M/s. Evergreen Enterprises, wherein the statement of the partner in M/s. Evergreen Enterprises, Mr. Nilesh Bharani was recorded under Section 132(4) of the Act, unearthing an undisclosed activity,
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moneylending and borrowing in unaccounted cash being operated at the premises of such enterprises. As per information available, the Assessee has received amount of Rs. 64,25,000/- during the A.Y. under consideration, as cash loan from the alleged party.
Consequently, notice dated 30.03.2021 under Section 148 of the Act was issued to the Assessee, in response to which the Assessee filed his return of income dated 23.04.2021 declaring total income of Rs. 24,62,230/-.
Thereafter, notice dated 10.12.2021 under Section 143(2) was issued to the Assessee by the Jurisdictional Assessing Officer (JAO).
Subsequently, the Assessing Officer initially issued a notice dated 12.01.2022 under Section 142(1) of the Act and therefore show cause notices dated 03.02.2022 and 08.03.2022, however, the Assessee made no compliance to the aforesaid notices and thus in the constrained circumstances and having left no option, the AO completed the reopened assessment under “best judgment“ based on the information collected and available on record and ultimately, made the addition of Rs. 64,25,000/- under Section 69A of the Act being unexplained cash loan received from M/s Evergreen Enterprises.
The Assessing Officer simultaneously also initiated the penalty proceedings under Sections 271(1)(c), 271 (1)(b), and 271D of the Act.
The Assessing Officer in the penalty proceedings u/s 271D of the Act initiated separately, also issued a notice under Section 271D of the Act dated 22.03.2022 and show-caused the Assessee “as to
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why the penalty should not be imposed”. Thereafter, the Assessing Officer issued further notices dated 21.07.2022 and 02.09.2022.
The Assessee though requested the Assessing Officer for keeping in abeyance the penalty proceedings, till the disposal of quantum appeal filed, however, according to the Assessing Officer, Assessee failed to explain the reason for keeping the penalty in abeyance and also failed to present his case on merits. And thus, the Assessing Officer by considering the CBDT Circular No. 10/2016 and limitation period, proceeded for completion of penalty proceedings, rejecting the request of the Assessee for keeping the penalty proceedings in abeyance and ultimately held that the Assessee has violated the provisions of Section 269SS r.w.s. 271D of the Act, whereby the penalty proceedings/penal provision of Section 271D of the Act are attracted and as per the provisions of Section 269SS, no person shall take or accept from any person, any loan or deposit otherwise than by an account payee cheque or account payee bank draft, if the amount/ aggregate of such loan or deposit is Rs. 20,000/- or more. Hence, if any person takes or accepts any loan or deposits in contravention of the provisions of Section 269SS, he shall be liable to pay by way of penalty under Section 271(D) of the Act, a sum equal to the amount of the loan or deposit so taken or accepted. Moreover, after going through the statements of Mr. Nilesh Bharani, Mr. Ashwin Rathod, Mrs. Vibha Sachin Rawate, it is seen that the Assessee has accepted cash loan amounting to Rs. 64,25,000/- during the financial year 2015-16 and since the case of the assessee is not covered by any of the exception, as envisaged in the provisions to Sections 269SS to prove that the Assessee was prevented by sufficient cause within the meaning of Section 273(b), the Assessee has rendered itself liable to penalty under Section 271D of the Act, for violating the provisions of 269SS of the Act.
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The Assessing Officer thus ultimately, on being satisfied that this is a fit case for levy of penalty under Section 271D, levied a penalty of Rs. 64,25,000/- under such section.
The Assessee being aggrieved challenged the said penalty being imposed by the Assessing Officer vide penalty order dated 26.09.2022 by filing the first appeal before the Ld. Commissioner.
Before the Ld. Commissioner the Assessee made following submissions: 3. Submission of the Appellant: The submission made by the appellant is reproduced as under: - "1. Your appellant is an Individual appellant having Income from House Properties, Proprietary Business and other sources. 2. The Return of Income was filed on 10th September 2016 declaring Total Income Rs.24,62,230/- after claiming deduction under Chapter VI A of Rs. 1,60, 148/-. 3. The return for A.Y 2016-17 was selected for reopening of assessment u/s 148 vide Notice dtd. 31-Mar-2021. 4. Your Appellant had filed the Return of Income again on 23rd April 2021 for AY 2016-17 in response to the Notice u/s 148. However there was no change in the return filed on 23rd April 2021 as compared to Original return filed on 10th September 2016 having total Income of Rs. 24,62,230/-. 5. The Case was reopened u/s 148 on basis of information received from Investigation wing stating that during Search & Survey carried out in case of M/s Evergreen Enterprises and Mr. Nilesh Bharani, some documents were found wherein your wherein your appellant concern was alleged to have taken unaccounted cash loan. 6. The Income Tax Officer, NFAC, Delhi, had issued SCN dtd 08/03/2022 Ref DIN ITBA/AST/F/147(SCN)/2021-22/1040464809(1), response due date for which was 11th March 2022, but the assessment proceedings were closed on 10th March 2022. Thus, denying opportunity to your appellant for making submission. 7. Mr. Nilesh Bharani had refuted the statements recorded under un-due pressure in course of Search & Survey vide his letter dtd 14th Oct 2017 addressed to Commissioner of Income tax (Investigation)-2, Mumbai. 8. The Income Tax Officer, NFAC, Delhi passed order adding alleged Cash Loan of Rs.64.25,000/- to Income assessed and initiated penalty proceedings u/s 271(1)(c) and 271D. 9. The Appellant filed appeal with Commissioner of Income tax (Appeals) against arbitrary order passed by the AO against addition of Income and requested stay of penalty proceedings against the order till the appeal is heard.
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The Appellant filed appeal with Commissioner of Income tax (Appeals) against arbitrary order passed by the AO against addition of Income and requested stay of penalty proceedings against the order till the appeal is heard. 11 The Appellant again reiterated that he has not received any alleged cash loan from M/s. Evergreen Enterprises or Mr. Nilesh Bharani or any of his related entities and requested stay on penalty proceedings since levy of penalty is dependent on addition of Income which itself is disputed and appealed against which is pending with Commissioner of Income Tax (Appeals).”
The Ld. Commissioner though considered the aforesaid submissions of the Assessee, however, not being satisfied with the same, ultimately, affirmed the penalty levied under Section 271D of the Act, by observing and holding as under:
Findings and Reasons The core of the appeal filed by the appellant revolves around challenging the penalty of Rs. 64,25,000/- levied under Section 2710 of the Income-tax Act, 1961, for alleged acceptance of cash loan in violation of Section 269SS. The appellant denies the very existence of such cash loans and contends that the penalty is premature, unjustified, and procedurally flawed. After carefully considering the facts of the case, the order of the AO, the grounds of appeal, and the submissions made by the appellant, the following findings are recorded: i. Applicability of Section 269SS and Section 271D:- Section 269SS mandates that no person shall accept any loan or deposit of Rs. 20,000 or more otherwise than by account payee cheque or bank draft. Violation of this Section attracts penalty under Section 271D equal to the amount so accepted. The AO has brought on record evidence in the form of statements of Mr Nilesh Bharani, Mr Ashwin Rathod, Mrs. Vibha Sachin Rawate, and other employees during the search in M/s Evergreen Enterprises, documents evidencing ledger entries and transaction details indicating acceptance of cash loans by the appellant. These form a prima facie and credible basis for concluding that the appellant had accepted cash loans in contravention of Section 269SS. ii. Retraction of Statement: The appellant has placed reliance on the retraction affidavit of Mr. Nilesh Bharani dated 14.10.2017. However, no cross- verification or evidence has been produced to prove that the affidavit was accepted by the department or that the original statement was invalidated. The retraction, being after a considerable lapse of time and not backed by substantial justification, cannot override the evidentiary value of contemporaneous statements recorded under oath. iii. Lack of Cross-Examination: of cross-examination, the assessment was was completed under Section 144 due to non-compliance by the appellant himself. Hence, the appellant cannot now claim denial of opportunity when he failed to respond within the time provided during the assessment proceedings. iv. Reasonable Cause under Section 2738: The appellant has not provided any cogent evidence or explanation showing reasonable cause for the acceptance of
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loan, even assuming such a loan was taken. Mere denial of transaction or pendency of quantum appeal does not constitute reasonable cause under Section 273B. v. Penalty Proceedings Independent of Assessment:- It is well settled in law that penalty u/s 271D is independent of the outcome of the quantum assessment. Even if an appeal is pending against the addition, the existence of a loan/deposit accepted in cash can separately attract penalty under 271D. In this case, the AO has clearly established the fact of cash loan being accepted in violation of Section 269SS, and the appellant has failed to discharge the onus of proving otherwise or to establish reasonable cause for such acceptance. In light of the above discussion and after considering the totality of facts, I am of the considered opinion that. a) The appellant has falled to rebut the findings of the AO with any credible evidence. b) No reasonable cause has been demonstrated for accepting cash loans. c) Procedural violations, if any, are not fatal to the validity of penalty in this case due to lack of compliance on the part of the appellant during assessment proceedings. Accordingly, the appeal filed by the appellant is dismissed, and the penalty of Rs. 64,25,000/- levied u/s 271D is confirmed.
Thus, the Assessee being aggrieved has preferred the instant appeal against the impugned order, which is under challenge. The ld. Counsel for the Assessee at the outset has claimed that the Hon’ble Coordinate Bench of the Tribunal in the quantum appeal filed against the assessment order/addition made by the A.O. has ultimately, deleted the aforesaid addition of Rs. 64,25,000/- in I.T.A. No. 440/Mum/2024 & ors, relevant for the assessment year 2016-17, decided on 12.06.2024, by observing and holding has under:
We heard the rival submission and considered the documents available on record. The assessment was initiated against notice U/s 148. The observation in 'recorded reason' is itself erroneous. The addition of un-explained cash loan is contradicting the violation of Section 269SS r.w.s. 271D related penalty. The entire assessment & addition is based on the statement of the partners of M/s Evergreen Enterprises. No other evidence is brought to record by the Id. AO. The issue is squarely covered by the order of assessee's own case for AY 2012-13 bearing ITA No.3081/Mum/2022(supra). We respectfully relied on the order of the Sanjiv Amritlal Cheda (supra)&the order of Coordinate Bench of ITAT Mumbai. The Id. DR unable to bring any contrary fact against the submission of the Id. AR. In our considered view we
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set aside the impugned appeal order. The addition U/s 68 of the Act amounts to Rs. 66 lakh is quashed. So, the appeal of the assessee is succeeded. 9. The bench has noticed that the issues raised by the assessee in the above appeals are equally similar on set of facts and grounds. Therefore, it is not imperative to repeat the facts and various grounds raised by the assessee. Hence, the bench feels that the decision taken by us in ITA 440/Mum/2024for the Assessment Year 2013-14 shall apply mutatis mutandis in the above listed appeals. In the result, the appeals of the assessee bearing ITA 440/Mum/2024, ITA 442/Mum/2024, and ITA 443/Mum/2024 are allowed.
Thus, the Assessing Officer, consequently drop the penalty proceedings initiated under Section 271 (1) (c) of the Act, vide order dated 26.02.2025.
The ld. Counsel further claimed that in the Assessee’s own case for the A.Y. 2012-13, the identical addition has been made and the Hon’ble Coordinate Bench of the Tribunal in I.T.A. No. 3081/Mum/2022 order dated 28.02.2024 has also quashed the reasons recorded for the reopening the case, as well as the addition made by the A.O. and thus the Assessing Office ultimately has not levied any penalty, which supports the case of the Assessee.
Ld. Counsel for the Assessee also relied on a judgment passed by the Hon’ble Apex Court in the case of ACIT Vs. Pramod Jain (2025) 176 taxmann.com 762 (SC) {date of decision 17.07.2025}.
On the contrary, the Ld. D.R. refuted the claim of the Assessee mainly on the reason that assessment order and the penalty order are altogether different and simply on the basis of assessment order being set aside, the penalty levied cannot be deleted.
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Heard, the parties and perused the material available on record. Admittedly, the addition on the basis of which the penalty of Rs.64,25,000/- has been levied under Section 271 (D) of the Act vide penalty order dated 26.09.2022, is not in existence as observed above. The Assessee throughout the income tax proceedings claimed that he has not made any transaction of Rs.64,25,000/-, as alleged, with M/s. Evergreen Enterprises and the Hon’ble Coordinate Bench of the Tribunal vide order dated 12.06.2024 in the quantum appeal, by observing that entire assessment addition is based on the statements of the partners of M/s. Evergreen Enterprises. No other evidence is brought on record by the AO and the observation in the “reason recorded” is itself erroneous and while relying on the decision of the Hon’ble Coordinate Bench of the Tribunal, in the Assessee’s own case for the AY 2012-13, ultimately quashed the addition made under Section 68 of the Act.
We further observe that in the assessment order dated 22.03.2022 under Section 147 read with Section 144 (B) of the Act, the AO has not recorded clear cut satisfaction with regard to the initiation of the penalty proceedings under Section 271 (D) of the Act and thus, attracts the judgment of the Hon’ble Apex Court in the case of CIT vs. M/s. Jaya Laxmi Rice Mills (2015) 379 ITR 521 (SC) wherein the Hon’ble Apex Court has held as under:
"In these appeals, we are concerned with the question as to whether penalty proceeding under Section 271D of the Income Tax Act (hereinafter referred to as "the Act") is independent of the assessment proceeding and this question arises for consideration in respect of Assessment Years 1991-1992 and 1992-1993 under the following circumstances: In respect of Assessment Year 1992-1993, assessment order was passed on 26.02.1996 on the basis of CIB information informing the Department that the assessee is engaged in large scale purchase and sale of wheat, but it is not filing income tax return. Ex-parte proceedings were initiated, which resulted in
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the aforesaid order, as per which net taxable income of the assessee was assessed at 18,34,584/-While framing the assessment, the Assessing Officer also observed that the assessee had contravened the provisions of Section 269SS of the Act and because of this the Assessing Officer was satisfied that penalty proceedings under Section 271E of the Act were to be initiated. The assessee carried out this order in appeal. The Commissioner of Income Tax (Appeals) allowed the appeal and set aside the assessment order with a direction to frame the assessment de novo after affording adequate opportunity to the assessee. After remand, the Assessing Officer passed fresh assessment order. In this assessment order, however, no satisfaction regarding initiation of penalty proceedings under Section 271E of the Act was recorded. It so happened that on the basis of the original assessment order dated 26.02.1996, show cause notice was given to the assessee and it resulted in passing the penalty order dated 23.09.1996. Thus, this penalty order was passed before the appeal of the assessee against the original assessment order was heard and allowed thereby setting aside the assessment order itself. It is in this backdrop, a question has arisen as to whether the penalty order, which was passed on the basis of original assessment order and when that assessment order had been set aside, could still survive. The Tribunal as well as the High Court has held that it could not be so for the simple reason that when the original assessment order itself was set aside, the satisfaction recorded therein for the purpose of initiation of the penalty proceeding under Section 271E would also not survive. This according to us is the correct proposition of law stated by the High Court in the impugned order. As pointed out above, insofar as, fresh assessment order is concerned, there was no satisfaction recorded regarding penalty proceeding under Section 271E of the Act, though in that order the Assessing Officer wanted penalty proceeding to be initiated under Section 271(1)(c) of the Act. Thus, insofar as penalty under Section 271E is concerned, it was without any satisfaction and, therefore, no such penalty could be levied.
We further observe that the identical issue has also been dealt with by the Hon’ble Coordinate Bench of the Tribunal in the case of Ravi Nirman Nigam Ltd. vs. ACIT, Circle 13 (3) (1) (ITA No. 4140, 4141 and 4121/M/2023 decided on 25.06.2024 and while following the judgment of the Hon’ble Apex Court in the case of CIT vs. M/s. Jaya Laxmi Rice Mills, ultimately deleted the identical penalty levied
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under Section 271 (D) and 271 (E) of the Act and by observing and holding as under:
We have heard the rival contentions and perused the material on record. Admittedly, it is a fact on record that the reassessment proceedings, u/s. 147 of the Act in the course of which penalty proceedings u/s. 271D and 271E were initiated have been quashed as void ab initio by the Co-ordinate Bench. This fact was put forth before the ld. CIT(A) by the assessee but has been negated to upheld the penalty imposed by the ld. Assessing Officer. Based on these facts, we have perused the order of the Hon'ble Apex Court in the case of Jaya-lakshmi Rice Mills (supra), and find that it clearly applies in the pre- sent case to hold that with the quashing/annulling of the reassessment order passed in the case of the assessee by the ITAT, the penalty initiated there in u/s. 271D did not survive. 10. We also take note of the distinguishing facts brought before us in respect of the judicial precedents relied upon by the Id. Sr. DR and we agree with the same. We also note that the contentions put forth by the Id. Sr. DR have been dealt with by the Co-ordinate Bench of ITAT in the case of Karan Empire Pvt. Ltd. (supra) in paragraph 9, wherein it is noted as under: “though undeniably, there is a difference in the facts of both the cases as in the case before the Hon'ble Apex Court, the assessment had been set aside with the direction to frame a fresh assessment. While in the present case before us, the assessment order passed has been held to be invalid, the proposition laid by the Hon'ble Apex Court Hon'ble Apex Court still applies since the ultimate effect of the facts in both the cases still results in the original assessment order, not surviving, as also the satisfaction recorded therein for the purpose of initiation of penalty proceedings under section 271E/271D of the Act." 10.1. Considering the facts on record and the judicial precedents dealt in above, more importantly, by placing reliance on the decision of the Hon'ble Supreme Court, in the case of Jayalakshmi Rice Mills (supra), and the decision of the Co-ordinate Bench of ITAT, Chandigarh in the case of Karan Empire Pvt. Ltd. (supra), which has dealt with the decision of Hon'ble Supreme Court as well as similar contentions put forth by ld. Sr. DR, we delete the levy of penalty u/s. 271E of the Act amounting to ₹11,40,000/-. Accordingly, ground No.1 taken by the assessee is allowed. All other grounds taken by the assessee are thus, rendered academic in nature.”
We further observe that the Hon’ble Coordinate Bench of the Tribunal in the case of M/s. Karia Builders vs. ITO Ward 14 (3), (ITA No. 2401/PUN/2024 decided on 23.07.2025), also dealt with the
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penalty levied under Section 271 (D) of the Act and by following the aforesaid judgment in the case of Ravi Nirman Nigam Ltd. (supra) deleted the identical penalty by observing and holding as under:
“28. We find an identical issue had come up before the Mumbai Bench of the Tribunal in the case of Ravi Nirman Nigam Ltd. vs. ACIT (supra) where the Tribunal has held that the penalty proceedings initiated u/s 271D of the Act do not survive once the assessment is held to be invalid. The relevant observations of the Tribunal from para 9 to 10.1 read as under: "9. We have heard the rival contentions and perused the material on record. Admittedly, it is a fact on record that the reassessment proceedings, ws. 147 of the Act in the course of which penalty proceedings u/s. 271D and 271E were initiated have been quashed as void ab initio by the Co-ordinate Bench. This fact was put forth before the ld. CIT(A) by the assessee but has been negated to upheld the penalty imposed by the ld. Assessing Officer. Based on these facts, we have perused the order of the Hon'ble Apex Court in the case of Jayalakshmi Rice Mills (supra), and find that it clearly applies in the present case to hold that with the quashing/annulling of the reassessment order passed in the case of the assessee by the ITAT, the penalty initiated there in ws. 271D did not survive. 10. We also take note of the distinguishing facts brought before us in respect of the judicial precedents relied upon by the Id. Sr. DR and we agree with the same. We also note that the contentions put forth by the Id. Sr. DR have been dealt with by the Co-ordinate Bench of ITAT in the case of Karan Empire Pvt. Ltd. (supra) in paragraph 9, wherein it is noted as under "though undeniably, there is a difference in the facts of both the cases as in the case before the Hon'ble Apex Court, the assessment had been set aside with the direction to frame a fresh assessment. While in the present case before us, the assessment order passed has been held to be invalid, the proposition laid by the Hon'ble Apex Court Hon'ble Apex Court still applies since the ultimate effect of the facts in both the cases still results in the original assessment order, not surviving as also the satisfaction recorded therein for the purpose of initiation of penalty proceedings under section 271E/271D of the Act." 10.1 Considering the facts on record and the judicial precedents dealt in above. more importantly, by placing reliance on the decision of the Hon'ble Supreme Court, in the case of Jayalakshmi Rice Mills (supra), and the decision of the Co-ordinate Bench of ITAT, Chandigarh in the case of Karan Empire Pvt. Ltd (supra), which has dealt with the decision of Hon'ble Supreme Court as well as similar contentions put forth by ld. Sr. DR, we delete the levy of penalty u/s. 271E of the Act amounting to 211,40,000/-, Accordingly, ground No. I taken by the assessee is allowed. All other grounds taken by the assessee are thus, rendered academic in nature." 29. Since the assessee can always challenge the validity of assessment proceedings during the penalty proceedings as per the
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decision of Hon'ble Bombay High Court in the case of B.R. Bamasi vs. CIT (supra) and the decision of the Hon'ble Gujarat High Court in the case of P.V. Doshi vs. CIT (supra) and the various other decisions relied on by the Ld. Counsel for the assessee in the paper book and since we have already held that the re- assessment proceedings are not in accordance with law on account of not obtaining the approval from the competent authority as per the provisions of section 151 of the Act, therefore, the penalty proceedings initiated u/s 271D of the Act do not survive. In view of the above discussion, the penalty proceedings initiated by the Assessing Officer and sustained by the Ld. CIT(A)/NFAC are not in accordance with law and are liable to be quashed. We, therefore, hold that the penalty levied by the Assessing Officer and sustained by the Ld. CIT(A)/NFAC being not in accordance with law is liable to be deleted. We accordingly direct the Assessing Officer to cancel the penalty levied u/s 271D of the Act. The original grounds and the additional grounds raised by the assessee are accordingly allowed. 23. Thus, on the aforesaid analysis, the penalty levied and affirmed by the Ld. Commissioner, is unsustainable, hence the same is deleted.
In the result, Assessee’s appeal is allowed.
Order pronounced in the open court on 28.01.2026.
Sd/- Sd/- (BIJAYANANDA PRUSETH) (NARENDER KUMAR CHOUDHRY) ACCOUNTANT MEMBER JUDICIAL MEMBER
Tarun Kushwaha Sr. Private Secretary Copy to: The Appellant The Respondent The CIT, Concerned, Mumbai The DR Concerned Bench
//True Copy// By Order
Dy/Asstt. Registrar, ITAT, Mumbai.
