Andhra Pradesh State Road Transport Corporation v. ITO

52 ITR 524Supreme Court of India1964#1636 most cited

What is Andhra Pradesh State Road Transport Corporation v. ITO authority for?

A state road transport corporation, though state-owned, is a separate legal entity from the State. Its income is distinct from the income of the State and is not exempt from income tax under Article 289 of the Constitution of India.

69

judgments rely on this decision, according to BharatTax’s citation analysis of 366,339 Indian tax judgments — from 2011 to 2025.

Also referred to as

Andhra Pradesh State Road Transport Corporation v. ITO · 52 ITR 524 · Supreme Court · state corporation income · separate legal entity · income of the State · Article 289 · tax exemption for State undertakings · Section 10(20) · Section 10(46) · statutory corporation income tax

Sections most often in play

Section 1961Section 10(46)Section 12Section 143(3)Section 289Section 40A(3)Section 10(20)Section 10(46A)
Read the full judgment

Issues it is cited on

section 10(20a)public servantsection 10(20)section 10(46)self occupied propertysection 24asection 80lsection 74section 39section 38section 73section 10(2)

Judgments citing Andhra Pradesh State Road Transport Corporation v. ITO

Deputy Commissioner of Income Tax (Exemption)-2(1), Mumbai vs. Mumbai Metropolitan Region Development Authority, Mumbai

In the result, appeal of the Revenue for Assessment Year 2016-17

ITA 3936/MUM/2023[2018-19]Status: DisposedITAT Mumbai28 May 2025AY 2018-19

Bench: Shri Saktijit Dey, Hon'Ble & Shri Girish Agrawal

Section 11Section 12ASection 143(3)Section 154Section 2(15)

…IN THE INCOME TAX APPELLATE TRIBUNAL “D” BENCH MUMBAI BEFORE SHRI SAKTIJIT DEY, HON'BLE VICE PRESIDENT AND SHRI GIRISH AGRAWAL, ACCOUNTANT MEMBER ITA Nos. 3791 and 3936/MUM/ 2023 Assessment Year: 2018-19 ITA Nos. 3794 and 3795/MUM/ 2023 Assessment Years: 2017-18 and 2016-17 Deputy Commissioner of Mumbai Metropolitan Region Income Tax (Exemption) -2(1), Development Authority Mumbai Plot C 14 and C 15, MMRDA, Vs Bandra Kurla Complex, ‘| Bandra (East), Mumbai — 400 051 (PAN : AAATM7106R) (Appellant) (Respondent) Present for: Assessee_ : Shri Saurabh Soparkar, Sr. Advocate Mr. Chaitanya Joshi, Ms. Vrushti Galan…

Deputy Commissioner of Income-Tax(Exemption)-2(1), Mumbai vs. Mumbai Metropolitan Region Development Authority, Mumbai

ITA 3791/MUM/2023[2018 19]Status: DisposedITAT Mumbai28 May 2025

Bench: Shri Saktijit Dey, Hon'Ble & Shri Girish Agrawal

Section 11Section 126Section 12ASection 143(3)Section 154Section 2(15)Section 3

…without appreciating the fact that the assessee is a separate entity and, therefore, the income of the Assessee cannot be regarded as income of the State, the same is held in the case of Andhra Pradesh State Road Transport Corporation vs. Income Tax Officer - 52 ITR 524, further Section 3 of the MMRDA Act and Section 126 of the MRTP Act also states that the land is vested in the authority and, therefore, the authority cannot be an agent of this State? 5. Whether on the facts and in the circumstances of the case and in law, the Ld. CIT(A) has erred in not appreciating that the assessee is not a valid Trust in ter…

The Kumar Family Trust, Delhi vs. ACIT, Central Circle-4, Delhi

In the result, appeal for AYs 2013-14 & 2014-15 are unabated and assessments are set aside due to no incriminating material found during the search and the appeals for the said assessment years are...

ITA 2776/DEL/2022[2019-20]Status: DisposedITAT Delhi20 Nov 2024AY 2019-20

Bench: Shri S. Rifaur Rahman & Shri Sudhir Kumar, Judicialmember

For Appellant: Shri Akkal Dudhwewala, CAFor Respondent: Ms. Sapna Bhatia, CIT DR
Section 132Section 139Section 143(2)Section 153ASection 22Section 23(2)

…held to be assessable as an individual. The said decision drew strength from a number of decisions of the Supreme Court including that in Sodra Devi's case [1957] 32 ITR 615. The other decision is Andhra Pradesh State Road Transport Corporation v. ITO [1964] 52 ITR 524 (SC). We may also refer to the decision in Jogendra Nath Naskar v. CIT [1969] 74 ITR 33, wherein the Supreme Court has observed that there could be no reason why the word "individual" in section 3 of the Indian Income- tax Act, 1922, should be restricted to human being alone and not to juristic entities. … view that the trustees of the assessee-tr…

The Kumar Family Trust, Delhi vs. ACIT, Central Circle-4, Delhi

In the result, appeal for AYs 2013-14 & 2014-15 are unabated and assessments are set aside due to no incriminating material found during the search and the appeals for the said assessment years are...

ITA 2775/DEL/2022[2018-19]Status: DisposedITAT Delhi20 Nov 2024AY 2018-19

Bench: Shri S. Rifaur Rahman & Shri Sudhir Kumar, Judicialmember

For Appellant: Shri Akkal Dudhwewala, CAFor Respondent: Ms. Sapna Bhatia, CIT DR
Section 132Section 139Section 143(2)Section 153ASection 22Section 23(2)

…held to be assessable as an individual. The said decision drew strength from a number of decisions of the Supreme Court including that in Sodra Devi's case [1957] 32 ITR 615. The other decision is Andhra Pradesh State Road Transport Corporation v. ITO [1964] 52 ITR 524 (SC). We may also refer to the decision in Jogendra Nath Naskar v. CIT [1969] 74 ITR 33, wherein the Supreme Court has observed that there could be no reason why the word "individual" in section 3 of the Indian Income- tax Act, 1922, should be restricted to human being alone and not to juristic entities. … view that the trustees of the assessee-tr…

The Kumar Family Trust, Delhi vs. ACIT, Central Circle-4, New Delhi

In the result, appeal for AYs 2013-14 & 2014-15 are unabated and assessments are set aside due to no incriminating material found during the search and the appeals for the said assessment years are...

ITA 2774/DEL/2022[2017-18]Status: DisposedITAT Delhi20 Nov 2024AY 2017-18

Bench: Shri S. Rifaur Rahman & Shri Sudhir Kumar, Judicialmember

For Appellant: Shri Akkal Dudhwewala, CAFor Respondent: Ms. Sapna Bhatia, CIT DR
Section 132Section 139Section 143(2)Section 153ASection 22Section 23(2)

…held to be assessable as an individual. The said decision drew strength from a number of decisions of the Supreme Court including that in Sodra Devi's case [1957] 32 ITR 615. The other decision is Andhra Pradesh State Road Transport Corporation v. ITO [1964] 52 ITR 524 (SC). We may also refer to the decision in Jogendra Nath Naskar v. CIT [1969] 74 ITR 33, wherein the Supreme Court has observed that there could be no reason why the word "individual" in section 3 of the Indian Income- tax Act, 1922, should be restricted to human being alone and not to juristic entities. … view that the trustees of the assessee-tr…

The Kumar Family Trust, Delhi vs. ACIT, Central Circle-4, Delhi

In the result, appeal for AYs 2013-14 & 2014-15 are unabated and assessments are set aside due to no incriminating material found during the search and the appeals for the said assessment years are...

ITA 2773/DEL/2022[2016-17]Status: DisposedITAT Delhi20 Nov 2024AY 2016-17

Bench: Shri S. Rifaur Rahman & Shri Sudhir Kumar, Judicialmember

For Appellant: Shri Akkal Dudhwewala, CAFor Respondent: Ms. Sapna Bhatia, CIT DR
Section 132Section 139Section 143(2)Section 153ASection 22Section 23(2)

…held to be assessable as an individual. The said decision drew strength from a number of decisions of the Supreme Court including that in Sodra Devi's case [1957] 32 ITR 615. The other decision is Andhra Pradesh State Road Transport Corporation v. ITO [1964] 52 ITR 524 (SC). We may also refer to the decision in Jogendra Nath Naskar v. CIT [1969] 74 ITR 33, wherein the Supreme Court has observed that there could be no reason why the word "individual" in section 3 of the Indian Income- tax Act, 1922, should be restricted to human being alone and not to juristic entities. … view that the trustees of the assessee-tr…

The Kumar Family Trust, Delhi vs. ACIT, Central Circle-4, New Delhi

In the result, appeal for AYs 2013-14 & 2014-15 are unabated and assessments are set aside due to no incriminating material found during the search and the appeals for the said assessment years are...

ITA 2772/DEL/2022[2015-16]Status: DisposedITAT Delhi20 Nov 2024AY 2015-16

Bench: Shri S. Rifaur Rahman & Shri Sudhir Kumar, Judicialmember

For Appellant: Shri Akkal Dudhwewala, CAFor Respondent: Ms. Sapna Bhatia, CIT DR
Section 132Section 139Section 143(2)Section 153ASection 22Section 23(2)

…held to be assessable as an individual. The said decision drew strength from a number of decisions of the Supreme Court including that in Sodra Devi's case [1957] 32 ITR 615. The other decision is Andhra Pradesh State Road Transport Corporation v. ITO [1964] 52 ITR 524 (SC). We may also refer to the decision in Jogendra Nath Naskar v. CIT [1969] 74 ITR 33, wherein the Supreme Court has observed that there could be no reason why the word "individual" in section 3 of the Indian Income- tax Act, 1922, should be restricted to human being alone and not to juristic entities. … view that the trustees of the assessee-tr…

The Kumar Family Trust, Delhi vs. ACIT, Center Circle-4, Delhi

In the result, appeal for AYs 2013-14 & 2014-15 are unabated and assessments are set aside due to no incriminating material found during the search and the appeals for the said assessment years are...

ITA 2771/DEL/2022[2014-15]Status: DisposedITAT Delhi20 Nov 2024AY 2014-15

Bench: Shri S. Rifaur Rahman & Shri Sudhir Kumar, Judicialmember

For Appellant: Shri Akkal Dudhwewala, CAFor Respondent: Ms. Sapna Bhatia, CIT DR
Section 132Section 139Section 143(2)Section 153ASection 22Section 23(2)

…held to be assessable as an individual. The said decision drew strength from a number of decisions of the Supreme Court including that in Sodra Devi's case [1957] 32 ITR 615. The other decision is Andhra Pradesh State Road Transport Corporation v. ITO [1964] 52 ITR 524 (SC). We may also refer to the decision in Jogendra Nath Naskar v. CIT [1969] 74 ITR 33, wherein the Supreme Court has observed that there could be no reason why the word "individual" in section 3 of the Indian Income- tax Act, 1922, should be restricted to human being alone and not to juristic entities. … view that the trustees of the assessee-tr…

The Kumar Family Trust, Delhi vs. ACIT, Central Circle-4, New Delhi

In the result, appeal for AYs 2013-14 & 2014-15 are unabated and assessments are set aside due to no incriminating material found during the search and the appeals for the said assessment years are...

ITA 2770/DEL/2022[2013-14]Status: DisposedITAT Delhi20 Nov 2024AY 2013-14

Bench: Shri S. Rifaur Rahman & Shri Sudhir Kumar, Judicialmember

For Appellant: Shri Akkal Dudhwewala, CAFor Respondent: Ms. Sapna Bhatia, CIT DR
Section 132Section 139Section 143(2)Section 153ASection 22Section 23(2)

…held to be assessable as an individual. The said decision drew strength from a number of decisions of the Supreme Court including that in Sodra Devi's case [1957] 32 ITR 615. The other decision is Andhra Pradesh State Road Transport Corporation v. ITO [1964] 52 ITR 524 (SC). We may also refer to the decision in Jogendra Nath Naskar v. CIT [1969] 74 ITR 33, wherein the Supreme Court has observed that there could be no reason why the word "individual" in section 3 of the Indian Income- tax Act, 1922, should be restricted to human being alone and not to juristic entities. … view that the trustees of the assessee-tr…

State Pollution Control Board Odisha, Bhubaneswar vs. ITO, Warad 5(2), Bhubaneswar

In the result, appeal of the assessee stands allowed and stay petition stands dismissed

ITA 301/CTK/2024[2017-18]Status: DisposedITAT Cuttack24 Oct 2024AY 2017-18

Bench: Before Shri George Mathanmember & Manish Agarwal Manish Agarwals.P.No.11/Ctk/2024 Assessment Year :2017-18 State Pollution Control Board State Pollution Control Board, Vs. Ito, Ward 5(2), Plot No.A-118, Paribesh Bhawan, 118, Paribesh Bhawan, Bhubaneswar Nilakantha Nagar, Agar, Nayapali, Nayapali, Unit-Vii, Bhubaneswar Neswar Pan/Gir No.Aaals 2490 J Aaals 2490 J (Appellant) (Appellant .. ( Respondent Respondent) Assessee By : Shri S.K.Agrawalla, Ca Walla, Ca Revenue By : Shri Sanjay Kumar, Cit Sanjay Kumar, Cit Dr Date Of Hearing : 24/10/20 2024 Date Of Pronouncement : 24/10/20 024 O R D E R Per Bench

For Appellant: Shri S.K.Agrawalla, CA walla, CAFor Respondent: Shri Sanjay Kumar, CIT
Section 4

…tion by the Government thereunder.” 16. The Hon’ble Supreme Court after analyzing the provisions contained under article 289 as a whole and taking note of the principles laid down by the Hon’ble Supreme Court in case of AP State Road Transport Corpn. Vs. ITO (52 ITR 524) observed as under: “Considerable reliance was placed on the principles laid down in the aforesaid decision by learned counsel appearing for the Union of India. He submitted that having regard to the provisions of the Act under which the appellant/Authority is established, the same conclusion may be reached. In particular, emphasizing the fact tha…

DCIT (Exemption)- 2(1), Mumbai vs. Maharashtra Energy Development Agency, Mumbai

ITA 1765/MUM/2023[2013-14]Status: DisposedITAT Mumbai27 Jun 2024AY 2013-14

Bench: SHRI OM PRAKASH KANT, ACCOUNTANT MEMBER SHRI RAHUL CHAUDHARY (Judicial Member)

For Appellant: Shri Kishore PhadkeFor Respondent: Smt. Sanyogita Nagpal
Section 10Section 11Section 143(3)

…The Assessing Officer rejected the contention of the Assessee that Assessee/MEDA is an agent of the Government of Maharashtra by placing reliance on the judgment of Hon’ble Supreme Court in the case of Andhra Pradesh State Road Transport Corporation Vs. ITO: 52 ITR 524 (SC). 5.2. Being aggrieved, the Assessee/MEDA preferred appeal before the CIT(A) against the Assessment Order, dated 28/03/2016. The CIT(A) vide order, dated 20/03/2023, partly allowed the appeal of the Assessee. The summary of findings/observation of the CIT(A) are as under: 5.2.1. The CIT(A) took note of the fact that approval granted to the A…

Dy Commissioner of Income Tax (E)-2(1), Mumbai vs. Maharashtra Labour Welfare Board, Mumbai

In the result, appeals of the Revenue are dismissed and Cross objections of the assessee are allowed

ITA 138/MUM/2023[2010-11]Status: DisposedITAT Mumbai25 Sept 2023AY 2010-11

Bench: Shri Kuldip Singh & Shri Gagan Goyal & Dy. Commissioner Of Income Tax (E)-2(1) Mumbai ...... Appellant Vs. Maharashtra Labour Welfare Board Girni Kamgar Kareeda Bhavan, Elphinston Senapati Bapat Marg Mumbai – 400 013 Pan: Aaaam3255A ..... Respondent

For Respondent: Shri Vipul Joshi & Shri Ashok Patil, Ld.AR
Section 10Section 11Section 12ASection 143(3)Section 20Section 250Section 4

…he arm of Government of Maharashtra and its income is not taxable, in this regards following legal positions may be noted and relied upon. a) The contention of the assessee is not acceptable in view of decision of Hon'ble Supreme Court in the case of APSRTC (52 ITR 524) wherein it has been clearly bifurcated that the income of the state is different and income of the corporation is different. The relevant portion is reproduced as under "Reading the three clauses together, one consideration emerges beyond all doubt and that is that the property as well as the income in respect of which exemption is claimed clause…

Dy Commissioner of Income Tax (E)-2(1), Mumbai vs. Maharashtra Labour Welfare Board Girni Kamgar, Mumbai

In the result, appeals of the Revenue are dismissed and Cross objections of the assessee are allowed

ITA 137/MUM/2023[2008-09]Status: DisposedITAT Mumbai25 Sept 2023AY 2008-09

Bench: Shri Kuldip Singh & Shri Gagan Goyal & Dy. Commissioner Of Income Tax (E)-2(1) Mumbai ...... Appellant Vs. Maharashtra Labour Welfare Board Girni Kamgar Kareeda Bhavan, Elphinston Senapati Bapat Marg Mumbai – 400 013 Pan: Aaaam3255A ..... Respondent

For Respondent: Shri Vipul Joshi & Shri Ashok Patil, Ld.AR
Section 10Section 11Section 12ASection 143(3)Section 20Section 250Section 4

…he arm of Government of Maharashtra and its income is not taxable, in this regards following legal positions may be noted and relied upon. a) The contention of the assessee is not acceptable in view of decision of Hon'ble Supreme Court in the case of APSRTC (52 ITR 524) wherein it has been clearly bifurcated that the income of the state is different and income of the corporation is different. The relevant portion is reproduced as under "Reading the three clauses together, one consideration emerges beyond all doubt and that is that the property as well as the income in respect of which exemption is claimed clause…

M/S. Bangalore Metro Rail Corporation Limited, Bangalore vs. Deputy Commissioner of Income Tax, Circle- 1(1)(2), Bangalore

In the result, all the appeals of the assessee as well as revenue’s appeal are partly allowed for statistical purposes

ITA 1116/BANG/2019[2015-16]Status: DisposedITAT Bangalore06 Apr 2023AY 2015-16

Bench: Shri N.V. Vasudevan & Shri Chandra Poojariassessment Year: 2011-12

For Appellant: Shri Srihari Kutsa, A.RFor Respondent: Shri Sankar Ganesh K., D.R
Section 2Section 3

…Government as well as by State Government. As such, assessee’s income is immune from Union Taxation. At this point it is appropriate to refer the observation made by Hon’ble Supreme Court in the caes of Andhra Pradesh State Road Transport Corporation Vs. ITO 52 ITR 524, wherein held as under: “It may be that the statute under which a notification has been issued constituting the appellant Corporation may provide expressly or by necessary implication that the income derived by the Corporation from its trading activity would be the income of the State. The doctrine of separate identity or personality of the corpo…

M/S. Bangalore Metro Rail Corporation Limited, Bangalore vs. Deputy Commissioner of Income Tax, Circle- 1(1)(2), Bangalore

In the result, all the appeals of the assessee as well as revenue’s appeal are partly allowed for statistical purposes

ITA 1115/BANG/2019[2014-15]Status: DisposedITAT Bangalore06 Apr 2023AY 2014-15

Bench: Shri N.V. Vasudevan & Shri Chandra Poojariassessment Year: 2011-12

For Appellant: Shri Srihari Kutsa, A.RFor Respondent: Shri Sankar Ganesh K., D.R
Section 2Section 3

…Government as well as by State Government. As such, assessee’s income is immune from Union Taxation. At this point it is appropriate to refer the observation made by Hon’ble Supreme Court in the caes of Andhra Pradesh State Road Transport Corporation Vs. ITO 52 ITR 524, wherein held as under: “It may be that the statute under which a notification has been issued constituting the appellant Corporation may provide expressly or by necessary implication that the income derived by the Corporation from its trading activity would be the income of the State. The doctrine of separate identity or personality of the corpo…

M/S. Bangalore Metro Rail Corporation Limited, Bangalore vs. Deputy Commissioner of Income Tax, Circle - 1(1)(2), Bangalore

In the result, all the appeals of the assessee as well as revenue’s appeal are partly allowed for statistical purposes

ITA 1114/BANG/2019[2013-14]Status: DisposedITAT Bangalore06 Apr 2023AY 2013-14

Bench: Shri N.V. Vasudevan & Shri Chandra Poojariassessment Year: 2011-12

For Appellant: Shri Srihari Kutsa, A.RFor Respondent: Shri Sankar Ganesh K., D.R
Section 2Section 3

…Government as well as by State Government. As such, assessee’s income is immune from Union Taxation. At this point it is appropriate to refer the observation made by Hon’ble Supreme Court in the caes of Andhra Pradesh State Road Transport Corporation Vs. ITO 52 ITR 524, wherein held as under: “It may be that the statute under which a notification has been issued constituting the appellant Corporation may provide expressly or by necessary implication that the income derived by the Corporation from its trading activity would be the income of the State. The doctrine of separate identity or personality of the corpo…

M/S. Bangalore Metro Rail Corporation Limited, Bangalore vs. Deputy Commissioner of Income Tax, Circle - 1(1)(2), Bangalore

In the result, all the appeals of the assessee as well as revenue’s appeal are partly allowed for statistical purposes

ITA 1113/BANG/2019[2012-13]Status: DisposedITAT Bangalore06 Apr 2023AY 2012-13

Bench: Shri N.V. Vasudevan & Shri Chandra Poojariassessment Year: 2011-12

For Appellant: Shri Srihari Kutsa, A.RFor Respondent: Shri Sankar Ganesh K., D.R
Section 2Section 3

…Government as well as by State Government. As such, assessee’s income is immune from Union Taxation. At this point it is appropriate to refer the observation made by Hon’ble Supreme Court in the caes of Andhra Pradesh State Road Transport Corporation Vs. ITO 52 ITR 524, wherein held as under: “It may be that the statute under which a notification has been issued constituting the appellant Corporation may provide expressly or by necessary implication that the income derived by the Corporation from its trading activity would be the income of the State. The doctrine of separate identity or personality of the corpo…

M/S. Bangalore Metro Rail Corporation Limited, Bangalore vs. Deputy Commissioner of Income Tax, Circle - 1(1)(2), Bangalore

In the result, all the appeals of the assessee as well as revenue’s appeal are partly allowed for statistical purposes

ITA 1112/BANG/2019[2011-12]Status: DisposedITAT Bangalore06 Apr 2023AY 2011-12

Bench: Shri N.V. Vasudevan & Shri Chandra Poojariassessment Year: 2011-12

For Appellant: Shri Srihari Kutsa, A.RFor Respondent: Shri Sankar Ganesh K., D.R
Section 2Section 3

…Government as well as by State Government. As such, assessee’s income is immune from Union Taxation. At this point it is appropriate to refer the observation made by Hon’ble Supreme Court in the caes of Andhra Pradesh State Road Transport Corporation Vs. ITO 52 ITR 524, wherein held as under: “It may be that the statute under which a notification has been issued constituting the appellant Corporation may provide expressly or by necessary implication that the income derived by the Corporation from its trading activity would be the income of the State. The doctrine of separate identity or personality of the corpo…

Additional Commissioner of Income Tax, Special Range - 1, Bangalore vs. M/S. Bangalore Metro Rail Corporation Limited, Bangalore

In the result, all the appeals of the assessee as well as revenue’s appeal are partly allowed for statistical purposes

ITA 1048/BANG/2019[2011-12]Status: DisposedITAT Bangalore06 Apr 2023AY 2011-12

Bench: Shri N.V. Vasudevan & Shri Chandra Poojariassessment Year: 2011-12

For Appellant: Shri Srihari Kutsa, A.RFor Respondent: Shri Sankar Ganesh K., D.R
Section 2Section 3

…Government as well as by State Government. As such, assessee’s income is immune from Union Taxation. At this point it is appropriate to refer the observation made by Hon’ble Supreme Court in the caes of Andhra Pradesh State Road Transport Corporation Vs. ITO 52 ITR 524, wherein held as under: “It may be that the statute under which a notification has been issued constituting the appellant Corporation may provide expressly or by necessary implication that the income derived by the Corporation from its trading activity would be the income of the State. The doctrine of separate identity or personality of the corpo…

City & Industrial Development Corporation of Maharashtra Ltd., Mumbai vs. ITO, Ward-15(1)(3), Mumbai

In the result, the grounds raised by the assessee are allowed

ITA 795/MUM/2021[2016-17]Status: DisposedITAT Mumbai15 Nov 2021AY 2016-17

Bench: Shri Saktijit Dey () & Shri S. Rifaur Rahman () Assessment Year: 2016-17 City & Industrial Development Income Tax Officer, Ward-15(1)(3), Corporation Of Maharashtra Limited, Vs. Ground Floor, Aayakar Bhavan, “Nirmal” 2Nd Floor, Nariman Point, Maharshi Karve Road, Mumbai-400 021. Mumbai-400 020. Pan No. Aaccc 3303 K Appellant Respondent Assessee By : Mr. Madhur Aggarwal, Ar Revenue By : Ms. Shreekala Pardeshi, Dr Date Of Hearing : 18/08/2021 Date Of Pronouncement : 15/11/2021

For Appellant: Mr. Madhur Aggarwal, ARFor Respondent: Ms. Shreekala Pardeshi, DR
Section 10Section 143(3)Section 2(31)Section 263Section 4Section 5

…IN THE INCOME TAX APPELLATE TRIBUNAL MUMBAI BENCH “C” MUMBAI BEFORE SHRI SAKTIJIT DEY (JUDICIAL MEMBER) AND SHRI S. RIFAUR RAHMAN (ACCOUNTANT MEMBER) Assessment Year: 2016-17 City and Industrial Development Income Tax Officer, Ward-15(1)(3), Corporation of Maharashtra Limited, Vs. Ground floor, Aayakar Bhavan, “Nirmal” 2nd floor, Nariman Point, Maharshi Karve Road, Mumbai-400 021. Mumbai-400 020. PAN No. AACCC 3303 K Appellant Respondent Assessee by : Mr. Madhur Aggarwal, AR Revenue by : Ms. Shreekala Pardeshi, DR Date of Hearing : 18/08/2021 Date of pronouncement : 15/11/2021 ORDER PER S. RIFAUR RAHMAN, A.M. Th…