ACIT-2(1)(1), MUMBAI, MUMBAI vs. KUNDAN JEWELLERS, MUMBAI

आदेश / O R D E R PER AMIT SHUKLA (J.M): The aforesaid appeal has been filed by the Revenue against order dated 26/10/2023 passed by NFAC, Delhi for the quantum of assessment passed u/s.147 r.w.s. 143(3) of the Act for A.Y.2014-15. 2. The assessee in the grounds of appeal has challenged the addition of Rs.6,63,13,654/- made u/s.68 on account of cash

2 ITA No. 4493/Mum/2023 M/s. Kundan Jewellers deposits in the bank account. Assessee has also filed additional grounds under Rule 27 of ITAT Rules before us challenging the validity of reopening u/s.147 on the following grounds:- “1.On the facts and in the circumstances of the case, the Commissioner of Income-tax (Appeals) NFAC has erred in not adjudicating the ground of the assessee challenging the validity of reassessment, which is time-barred considering the provisions of the Act. The assessee respectfully submits that the reassessment made is time barred and therefore the same deserves to be quashed. 2 On the facts and in the circumstances of the case, the CIT (A) has erred in not adjudicating the additional ground of appeal raised by the assessee during the course of the appeal proceedings. The assessee respectfully submits that the issue of statutory notices /s. 148 of the Act by the jurisdictional assessing officer is in violation of the provisions of section 151A of the Act and the notifications issued thereunder. Accordingly the reassessment in pursuance of such notices is invalid and deserves to be quashed.”

3 ITA No. 4493/Mum/2023 M/s. Kundan Jewellers by applying the gross profit rate on such purchases and completed the assessment u/s. 143(3)/147 vide order dated 29/12/2016. Now again notice u/s.148 has been issued on 30/06/2021 based on information from ITD / ITBA system that assessee had made huge cash deposits in its bank account with Saraswat Co-operative Bank Ltd. Mumbai and after such cash deposit there is a transfer made to SME Parle Branch. The ‘reasons’ on which approval u/s.151 has been sought reads as under:- “The assessee filed its income declaring total income at Rs.1,80,69,900/-, which was processed u/s 143(1) of the Act accepting the return. Thereafter, the case was reopened and order u/s. 143(3) r.w.s.147 of the Act was passed on 29-12-2016 determining the total income at Rs. 1,85,75,480/- Information was made available in ITD/ITBA System, which indicate the assessee company is having bank account No.284100100010098 with The Saraswat Co.Op. Bank Ltd., Mumbai, wherein huge cash deposits have been made. After deposit of cash transfer was made to Account No.284500100000101 with SME Parle Branch. This account was also been alerted for transactions with Riddhi Siddhi Bullion. For the year under consideration the assessee has total cash credit entries of Rs.6,63,13,654/- in the bank accounts which were subsequently transferred to its account in SME Parle Branch and thereafter to Riddhi Siddhi Bullion. Since the assessee has made huge cash deposits in the year under consideration, the source of such cash deposits and its business rational in immediately transferring the same to its other account and then making payment to Riddhi Siddhi Bullion gives rise to the logical suspicion that the assessee has undisclosed income which it deposited in the bank and thereafter transferring the other account in order to give the colour of sale proceeds. Therefore, the cash deposits made in the bank account in the aforesaid bank is nothing but the undisclosed cash and escapement of income to that extent.

4 ITA No. 4493/Mum/2023 M/s. Kundan Jewellers In view of the above and on the basis of material available on records and on perusal and careful consideration of the same, I have prima facie reason to believe that income chargeable to tax to the tune of Rs.6,63,13,654/- has escaped assessment within the meaning of section 147 of the income tax Act, 1961 In this case four years have lapsed from the end of assessment year under consideration. Hence, necessary sanction to issue notice u/s 148 is being obtained separately as per the provisions of section 151 of the Act.” 4. The ld. AO intimated the assessee that notice u/s. 148 dated 30/06/2021 should be construed and treated as show-cause notice in terms of Section 148A(b) of the Act, in view of the judgment of Hon’ble Supreme Court in the case of Ashish Agarwal in Civil Appeal No.3005 of 2022 judgment and order dated 04/05/2022. In response to said show-cause notice assessee filed its reply in ITBA portal on 07/06/2022 stating as under:- "During the above assessment year, the company has deposited cash of Rs 9,06,50,000/- in the said Bank account. From the said bank account, the total net amount of Rs. 13,90,53,871/- (Includes cash and Cheque/Other mode) is transferred to bank account(Cash credit A/c) having account no 284500100000101 which is operated by head Office located at 223, SM Patil Building SV Road, Andheri (West), Mumbai. It is the policy of the company to pay the amount to creditors (RGD Dealer) by head office through account no 284500100000101 & for the purpose of payments to the creditors against the purchase of goods and expenses the amount is transferred from account no 284100100010098 (of Branch) to account по. 284500100000101 (of Head Office). From the said account the amount of Rs. 2,87,19,597/- was paid to Ridhi Siddhi Bullion against the purchase of Gold Bar/Bullion of Rs. 2,86,78,688/- having the closing balance of Rs. 39,970/- as on 31/3/2014. The cash deposited in the account (of branch) is mostly out of cash sales effected during the above mentioned

5 ITA No. 4493/Mum/2023 M/s. Kundan Jewellers assessment year. Every cash sales is supported with tax invoice/cash memo. As the sources of the cash deposited in bank is already explained and therefore it cannot be said that the Assessee fins undisclosed income. Simply with reason that cash deposited in one bank account and thereafter transferred to another bank account of the company from wherein payment is made to Riddhi Siddhi Bullion does not give rise to logical suspicion that Assessee has undisclosed income. There is no reason to believe that income chargeable to tax in the tune of Rs. 6,63, 13,654/- has escaped assessment within the meaning of section 147 of the Income Tax Act & therefore request you to close the reopening proceedings. 5. However, ld. AO rejected assessee’s contention and held that amount of Rs.6,63,13,654/- has escaped assessment within the meaning of Section 147. 6. Before the ld. AO assessee had also raised objection for the reopening on the ground that firstly, the notice u/s.148 is without jurisdiction, because, firstly, by the Finance Act 2021, earlier Sections 147 to 153 have been substituted and Section 148A was inserted which are prospective in nature w.e.f. 01/04/2021. Thus, such notice could not have been issued u/s.148A for the A.Y.2014-15. Secondly, there is no further evidence / information available with the ld. AO which indicate that income has escaped assessment and detailed objections was made in relying upon the various judgments; and lastly, assessee objected that it has disclosed all the details fully and truly and since in this case already assessment u/s.147 / 148 was completed, therefore, reopening cannot be done beyond the period of four years at the end of the relevant assessment year.

6 ITA No. 4493/Mum/2023 M/s. Kundan Jewellers 7. On merits also assessee had submitted and stated as under:- I. The transactions with M/s Riddhi Siddhi Bullion are in the normal course of Business. Assessee had purchased gold bar and bullion from M/s Riddhi Siddhi II. All the transactions are duly recorded and accounted for in the books of account. III. All the transactions were duly considered for the computation of total income and tax is already paid on the same. IV. All the transactions are done through banking channel so there is no question of any misstatements. V. The company has entered the transactions of purchase of gold bar & bullion of Rs 2,86,78,688/ with M/s Riddhi Siddhi Bullion. We enclose confirmed copies of ledger accounts for the period 01.04.2013 to 31.03.2014.Bank statements duly highlighted transactions entered with M/s Riddhi Siddhi Bullion are enclosed Further to prove the above transaction with Riddhi Siddhi Bullion we are here by enclosing the following: a. Documentary evidence with respect to transactions entered with M/s Riddhi Siddhi Bullion during the period 01.04.2013 to 31.03.2014 b. Monthly total sales and bifurcation of the cash sales and credit sales of HO and its two branches and consolidated also, c. Copy of Stock Statement for the period 01.04.2013 to 31.03.2014 showing the quantity inward, outward & closing quantity. Please note that inward of Gold Bullion from M/s Riddhi Siddhi Bullion duly highlighted in the said stock register.

7 ITA No. 4493/Mum/2023 M/s. Kundan Jewellers d. Copy of Ledger account of M/s Riddhi Siddhi Bullion in books of assessee. e. Copies of invoices of M/s Riddhi Siddhi Bullion. f. Bank Statement duly highlighting the transactions. g. Cash book of Head Office & center square for the period 01.04.2013 to 31.03.2014 h. Bank statements of all the bank accounts for the period 01.04.2013 to 31.03.2014 alongwith narrations of al debit and credit entries. 8. However, ld. AO rejected all the contentions of the assessee and simply based on this information received on the ITBA portal added the entire amount of Rs.6,63,13,654/-. In so far as the assessee’s contention about the jurisdiction of the notice that after the provision of Section 148A inserted by Finance Act 2021 prospectively from 01/04/2021, he relied upon the judgment of the Hon’ble Supreme Court in the case of Union of India vs. Ashish Agarwal (supra) wherein it is held that notice was issued during the period 01/04/2021 to 30/06/2021 shall be considered as valid and also proper approval has been taken u/s.151. 9. The ld. CIT(A) after incorporating the entire assessment order, submissions made by the assessee has deleted the entire contention of the ld. AO. The additions made by the ld. AO after observing as under:- 5.3 After going through the Assessment Order and the submission of the appellant, the following points are noted: Basis of Addition - The entire addition is based on only one fact as reiterated by the AO (quoted in the preceding paragraph) that Account No. 284500100000101 was alerted for transactions with

8 ITA No. 4493/Mum/2023 M/s. Kundan Jewellers M/s Ridhi Siddhi Bullion and that M/s Riddhi Siddhi Bullion was not engaged in real business transactions and there was no movement of goods. Apart from this bland assertion that the account in question used for transfer of funds to M/s Ridhi Siddhi Bullion was "alerted for transactions", the AO has nowhere mentioned that what this so- called alert was. Nowhere in the entire order, there is any mention of any evidence from which such a conclusion is drawn by the AO The second conclusion for making the addition is that M/s Riddhi Siddhi Bullion was not engaged in real business activities and no real business transactions took place and there was no movement of goods. Again, there is no mention of any evidence or basis leading to such a conclusion. Even if it is hypothetically presumed that the AO was in possession of such evidence, mere possession is not enough The basis of drawing the conclusion should have been part of the Order and the appellant should have been confronted with the same and should have been allowed an opportunity to present its case in relation to such evidence, in the interest of natural justice. Also, the AO's decision appears to have been greatly influenced by the fact that "there was no movement of goods It is relevant to note that the "goods" in question here are gold bullion Gold bullion is a high value item which was being transported from one part of the city to the other. It is not a case where a bulky item is being transported to a great distance through public means of transport i e railways, trucks, ship etc. In such circumstances, it is difficult to imagine as to what other evidence the appellant could have provided apart from sale invoices, entry in the books and bank statements evidencing payments to show that it did purchase gold bullion from M/s Riddhi Siddhi Bullion. Another basis for making the addition as given by the AO is that the "business rationale" in "immediately transferring" the amount deposited in cash to another account of the appellant and then making payment to Ridhi Siddhi Bullion gives rise to the "logical suspicion" that "the assessee has undisclosed Income" is beyond comprehension. The business practice or business policy of the appellant is a matter of appellant's discretion and its rationale can neither be questioned by the AO nor an apparent lack of business rationale, in the eyes of the AO, can lead to a suspicion that the

9 ITA No. 4493/Mum/2023 M/s. Kundan Jewellers assessee has undisclosed income and definitely cannot result in an addition. ********************************************************************* ii. Whether the source of cash deposit is explained-The AO has treated the entire cash deposit in the bank account amounting to Rs. 6,63,13,654/- as unexplained cash credit u/s 68. The appellant claims that cash deposits in bank account are proceeds of cash sales and sometimes advance against sales orders, a common occurrence in the business of jewellers and was duly recorded in the books. The said cash is reflected in the cash book and out of that, amount was deposited in the bank account. The data of total sales, cash sales, cash received from debtors & advances against sales orders and cash deposits into bank account were submitted on record & were available on record for other years also. The books of account were duly audited. Following details/ evidences inter alia were submitted:- i. Month-wise details of cash sales and credit sales for the Financial Year 2013-14. ii. Sources of Cash Deposits in bank account with Saraswat Co Op Bank Ltd. iii. Copies of VAT returns for all the quarters of Financial Year 2013- 14 iv. Copies of Assessment Orders for the preceding years v Details of transactions with M/s Ridhi Sidhi Bullion along with copies of invoices. vi. Stock statement for the financial year 2013-14. vii. Copy of ledger account of M/s Ridhi Siddhi Bullion for the period 01.04.2013 to 31.03.2014. viii Bank statement indicating transactions with M/s Ridhi Siddhi Bullion during the period 01.04.2013 to 31.03.2014

10 ITA No. 4493/Mum/2023 M/s. Kundan Jewellers ix. Sample copies of the sale bills, vouchers in support of the cash received from the parties from whom cash exceeding Rs. 50,000/- was received along with sample copies of bills/ vouchers x Cash Book for the period 01.04.2013 to 31.03 2014 xi Bank statements of all the bank accounts for the period 01.04.2013 to 31.03.2014 along with narrations of debit and credit entries The fact of submission of above details is acknowledged by the AO in para 3.2.2 of the Assessment Order. It is also a fact that the AO has not pointed out any non-compliance regarding filing of details in the assessment order, which may have led to drawing of adverse inference. It is also a fact that the AO has neither rejected the books nor at any point claimed that the figures of cash sales are bogus or unacceptable. The books of account were duly audited &if no mistake / discrepancy / irregularity is discovered/pointed out by the AO, the result of the audited books has to be accepted. The appellant has quoted judicial authorities, on identical facts of cash deposit that when books of the account of the appellant are not rejected and same are accepted by the Assessee., then additions disturbing the results of books are not sustainable: ********************************************************************* iii. Double Addition Vide ground no. 10 of Appeal the appellant has argued that the addition of Rs. 6,63,13,654/-amounts to double addition. The appellant submits that cash sales was already included in the total sales credited to the P & L Account and offered for taxation and a further addition of cash deposited in bank account out of the same sale proceeds, results in double assessment / addition of the same amount once as sales and then as cash deposit, not permissible in law. The appellant submits that the judicial authorities have held that when cash deposited in bank account is out of cash balance in the books and was received from sales then no addition can be made separately for cash deposited in the bank account quoting the decision of Hon'ble Vishakhapatnam ITAT in the case of ACIT, CC-I vs. M/s Hirapanna Jewellers (128 Taxmann.com291).

11 ITA No. 4493/Mum/2023 M/s. Kundan Jewellers I agree with the contention of the Appellant that this not only amounts to double addition but also that when the AO has not disputed the validity and correctness of cash sales then the cash receipts and subsequent cash deposits in the bank account are nothing but a manifestation of the cash sales already accepted by the AO. As the sales figure, which is unchallenged and unquestionably accepted by the AO, has been duly offered for taxation, there is no scope for making any addition under section 68 of the Act in respect of deposits made into the bank account Apart from non-allowability of addition on merits, it is also not permissible on the ground of double addition as raised by the appellant, since the deposits have been made from the cash balance available in the books of account, whose integrity remains unassailed. Hon'ble ITAT Mumbai in appellant's own case for AY 17-18 has treated such addition as a double addition as quoted below "Since the cash sales proceeds/receipts received from the customers are reflected in the Audited Profit & Loss account as income and if the cash deposits are added under section 68 of the Act that will amount to double taxation once as sales and again as unexplained cash credit which is against the principles of taxation." iii. Analysis of Financial results & Books of Accounts -The appellant has filed copies of Audited P & L A/c from FY ending 31.03.13 to 31.03.17. showing the sales figure and stock position. The appellant has also filed a comparative chart of total sales and amount received in cash against cash sales, advance received against orders & received from debtors for FY 11-12 to 16-17 Sr. FY AY Total Sales Amount % of No. (Rs.) received in cash cash received receiv against cash ed to sales . amount Total received sales against orders during & from the debtors (Rs.) year

12 ITA No. 4493/Mum/2023 M/s. Kundan Jewellers I 2011-12 2012-13 50,11,60,494 31,29,90,515 62.45 2 2012- 13 2013-14 53,15,78,963 35,10,05,234 66.03 3 2013-14 2014-15 54,78,84,227 25, 22,02,861 46.03 4 2014-15 2015-16 61,94,12,289 21,51,31,476 34.73 5 2015-16 2016-17 58,95,65,001 18,54,82,584 31 .46 6 2016-17 2017-18 81,99,71,796 25,64,27,788 31.27

The above table reveals that cash sales and cash receipt are regular features in appellant's business. The ratio of cash receipts to total sales is much higher in the earlier years and has gradually declined in this FY and subsequent years. In the immediately preceding two years le. FY 2011-12, 2012-13, the cash receipt was 62.45% and 66.03% of total sales respectively as compared to 46.03% of total sales in the present FY which is much lower. The above chart shows that there is nothing irregular or unusual that was suspicious and hence does not call for drawing of an adverse view. In fact the chart, established the fact of existence of cash sales in appellant's business with a certain amount of consistency Also, the summary of the cash book does not show that any unusual cash deposit, nor any unusual cash entry is pointed out by the AO in the Assessment Order. Therefore, there is nothing to suggest of an unusual or suspicious cash deposit camouflaged as cash sales. Therefore, in the absence of any concrete information or a discrepancy in the books, there is no case for drawing such an adverse inference for cash deposited as has been done by the A.O v Decision by CIT(A) and Hon'ble ITAT in AY 2017-18-It is seen from the appellant's submission that identical issue of addition u/s 68 of cash deposit without disturbing the results of P&L A/c or rejection of books came up for adjudication in AY 2017-18 in

13 ITA No. 4493/Mum/2023 M/s. Kundan Jewellers appellant's own case. The Hon'ble CIT (A) at National Faceless Appeal Centre (NFAC) deleted the addition made. The Hon'ble ITAT, Mumbai confirmed the order of CIT(A) under identical facts for AY 2017-18 after accepting the receipt of cash against sales etc 5.4 In view of the above discussion I am inclined the accept the explanation of the appellant that AO has not brought out any inconsistencies with regard to cash sales and hence addition on account of cash deposits cannot be sustained. It seems that AO has made the addition without any factual or legal foundation. Hence, AO is directed to delete the addition of Rs. 6,63,13,654/- u/s 68, made on account of cash deposit. In view of the discussion these grounds of appeal of the appellant are allowed.

14 ITA No. 4493/Mum/2023 M/s. Kundan Jewellers transactions are through banking channels. The assessee has also filed the purchase invoices of gold bar / bullion alongwith confirmed copies of ledger account, bank statements highlighting the transaction entered with Ridhi Siddhi Bullion, monthly sales and bifurcation of cash sales and credit sales from its head office in its two branches. Copy of stock statement for the entire financial year showing the quantity inward and outward and closing quantity and the purchases made from Ridhi Siddhi Bullion was duly entered in the stock register. Nowhere the ld. AO has acknowledged these documents or the evidence that, not only these transactions are recorded in the books but the corresponding sales of jewellery made out of such purchases. The ld. AO’s conclusion is simply based on information which only mentioned the transfer of funds to M/s. Ridhi Siddhi Bullion from the cash deposits in the bank account. Nowhere there is any information or material that how the Ridhi Siddhi Bullion was not engaged in real business activities and there is no business transaction or actual movement of goods. The ld. CIT (A) has correctly appreciated in para 5.3 as incorporated supra that ld. AO had no basis at all to draw such a conclusion. 11. In so far as the source of cash deposits are concerned, the assessee had duly demonstrated that these are out of proceeds of cash sales and on some occasion advance received against the sale orders which are duly recorded and incorporated in the books of account alongwith quantity of sale in the name of the parties. These cash sales are also recorded in the cash book which have duly deposited in the bank account. The data of total

15 ITA No. 4493/Mum/2023 M/s. Kundan Jewellers sales, cash sales, cash receipts from debtors and advances against sale orders and the cash deposited with the bank account was duly submitted and was part of the record before the AO. As noted above, to substantiate the cash sales, cash deposits, assessee had submitted following documents:- i. Month-wise details of cash sales and credit sales for the Financial Year 2013-14. ii. Sources of Cash Deposits in bank account with Saraswat Co Op Bank Ltd. iii. Copies of VAT returns for all the quarters of Financial Year 2013- 14 iv. Copies of Assessment Orders for the preceding years v Details of transactions with M/s Ridhi Sidhi Bullion along with copies of invoices. vi. Stock statement for the financial year 2013-14. vii. Copy of ledger account of M/s Ridhi Siddhi Bullion for the period 01.04.2013 to 31.03.2014. viii Bank statement indicating transactions with M/s Ridhi Siddhi Bullion during the period 01.04.2013 to 31.03.2014 ix. Sample copies of the sale bills, vouchers in support of the cash received from the parties from whom cash exceeding Rs. 50,000/- was received along with sample copies of bills/ vouchers x Cash Book for the period 01.04.2013 to 31.03 2014

16 ITA No. 4493/Mum/2023 M/s. Kundan Jewellers xi Bank statements of all the bank accounts for the period 01.04.2013 to 31.03.2014 along with narrations of debit and credit entries 12. Thus, on these facts it cannot be held that the sources of cash deposits are unexplained and the purchases made by the assessee from Ridhi Siddhi Bullion are a mere paper entry. Further, once assessee had already offered cash sales as income on the credit side, then the same cash cannot be added again u/s.68, because, once the cash sales have been accepted and the trading account has not been doubted or disturbed, then the cash receipts and deposits out of such cash sales in the bank account cannot be added. The ld. CIT(A) has analysed the financial accounts in the books of accounts and also the comparative chart of detailed sales received against cash sales to show that the cash sales was a regular pattern in the case of the assessee. In fact in the earlier financial years, the cash receipts were ranging from 62.45% and 66.03% whereas the in this year it was 46.03% on total sales which is lower. Thus, the cash deposits which has been added by the ld. AO is deleted and order of the ld. CIT (A) to the extent is confirmed. 13. It has also been brought on record that in assessee’s own case, this Tribunal in A.Y.2017-18 wherein on identical issue of addition u/s 68 out of cash deposit without disturbing the trading results or P&L A/c or rejection of books have been upheld. Accordingly, on merits the addition is deleted and grounds raised by the Revenue are dismissed.

17 ITA No. 4493/Mum/2023 M/s. Kundan Jewellers 14. In so far as additional grounds raised by the assessee under Rule 27 of the ITAT Rules, first of all, it is an undisputed fact that notice u/s.148 has been issued on 30/06/2021 under the new provisions brought by the Finance Act 2021 w.e.f. 01/04/2021. Now, it is a well settled by the Jurisdictional High Court that the validity of notice must be judged on the basis of law existing as on the date of which notice has been issued u/s.148. This has been held in the case of Godrej Industries Ltd. vs. ACIT reported in 68 txmann.com 13 vide judgment and order dated 20/02/2024. Otherwise also, in view of the time limit of issuance of notice u/s 148A has been provided in Section 149(1)(b) as existed prior to 01/04/2022 was three years from the end of the relevant assessment year. The said provision reads as under:- “(b) if three years, but not more than ten years, have elapsed from the end of the relevant assessment year unless the Assessing Officer has in his possession books of account or other documents or evidence which reveal that the income chargeable to tax, represented in the form of asset, which has escaped assessment amounts to or is likely to amount to fifty lakh rupees or more for that year.” 14. Thus, the limit for reopening the assessment was for three years from the end of the relevant assessment year unless ld. AO has in his possession books of account or other documents or evidence which reveal that the income chargeable to tax, represented in the form of asset, which has escaped assessment amounts to or is likely to amount to fifty lakhs rupees. Here it is not a case of any asset is over and above Rs.50,00,000/-, albeit it is case of cash deposited in bank for

18 ITA No. 4493/Mum/2023 M/s. Kundan Jewellers purchase of stock. This issue had been considered by the Hon’ble Bombay High Court in the case of Godrej Industries Ltd. (supra) Further Hon’ble Bombay High Court in the case of Hexaware Technologies Ltd vs. ACIT reported in (2024) 464 ITR 430 had dealt with exactly with the same issue after considering the judgment of the Hon’ble Supreme Court in the case of Ashish Agarwal. In facts of the present case, the time limit to issue notice u/s. 148 for the A.Y. 2014-15 had already expired before 01/04/2021 in view of erstwhile time limit of six years which had expired on 31/03/2021; whereas the notice u/s.148 has been issued on 30/06/2021. Thus, following the principle laid down by the Hon’ble Bombay High Court in the case of Hexaware Technologies Ltd (supra), we hold that notice u/s.148 issued by the ld. AO is barred by limitation. 15. In the result, additional ground raised by the assessee is allowed and appeal filed by the Revenue is dismissed. Order pronounced on 25th July, 2024.

Sd/- Sd/- (GAGAN GOYAL) (AMIT SHUKLA) ACCOUNTANT MEMBER JUDICIAL MEMBER Mumbai; Dated 25/07/2024 KARUNA, sr.ps

19 ITA No. 4493/Mum/2023 M/s. Kundan Jewellers Copy of the Order forwarded to : 1. The Appellant 2. The Respondent. 3. CIT BY ORDER, 4. DR, ITAT, Mumbai 5. Guard file. //True Copy// (Asstt. Registrar) ITAT, Mumbai