CIT v. Brandix Mauritius

149 Taxmann.com 238High Court2023#1221 most cited
93

judgments rely on this decision, according to BharatTax’s citation analysis of 366,314 Indian tax judgments — from 2023 to 2026.

Also referred to as

CIT v. Brandix Mauritius · reassessment proceedings section 147 · section 148 notice · surrender of income validity · statement during search section 132(4) · survey operations section 133A · cash credits section 68 · unexplained expenditure section 69C · waiver of notice objection section 292BB · closely held company assessment

Also reported as

456 ITR 34

Sections most often in play

Section 143(3)Section 148Section 68Section 133ASection 69CSection 131Section 147Section 132(4)

Issues it is cited on

section 5(8)section 282a(1)closely held companyprincipal director general of income-taxsection 65aaccumulated profitssection 282asurrender of incomesection 282section 292bbsection 144(1)section 292b

Judgments citing CIT v. Brandix Mauritius

Superdeal Resources Pvt. Ltd., Kolkata vs. ITO, Ward 5(1), Kolkata

In the result, the appeal of the assessee is allowed

ITA 726/KOL/2025[2022-2023]Status: DisposedITAT Kolkata16 Sept 2025AY 2022-2023

Bench: Shri Rajesh Kumar, Am & Shripradip Kumar Choubey, Jm Superdeal Resources Pvt. Ltd. Ito, Wad 5(1), Kolkata C/O Subash Agarwal & Ito, Ward 5(1), Associates, Advocates Sidha Aaykar Bhavan, P-7, Gibson, 1, Gibson Lane, Suite Vs. Chowringhee Square, 213, 2Nd Floor, Kolkata-700069 Kolkata-70069 West Bengal (Appellant) (Respondent) Pan No. Aadcs7472E Assessee By : Shri Siddarth Agarwal, Ar Revenue By : Shri Sanat Kumar Raha, Dr Date Of Hearing: 30.07.2025 Date Of Pronouncement: 16.09.2025

For Appellant: Shri Siddarth Agarwal, ARFor Respondent: Shri Sanat Kumar Raha, DR
Section 115BSection 133(6)Section 143(1)Section 68

…IN THE INCOME TAX APPELLATE TRIBUNAL “D” BENCH, KOLKATA BEFORE SHRI RAJESH KUMAR, AM AND SHRIPRADIP KUMAR CHOUBEY, JM Superdeal Resources Pvt. Ltd. ITO, Wad 5(1), Kolkata C/o Subash Agarwal & ITO, Ward 5(1), Associates, Advocates Sidha Aaykar Bhavan, P-7, Gibson, 1, Gibson Lane, Suite Vs. Chowringhee Square, 213, 2nd Floor, Kolkata-700069 Kolkata-70069 West Bengal (Appellant) (Respondent) PAN No. AADCS7472E Assessee by : Shri Siddarth Agarwal, AR Revenue by : Shri Sanat Kumar Raha, DR Date of hearing: 30.07.2025 Date of pronouncement: 16.09.2025 O R D E R Per Rajesh Kumar, AM: This is an appeal preferred by th…

Kaliyaperumal Padmanaban, Cuddalore vs. ITO, Ward-2, Cuddalore

In the result, appeal filed by the assessee is allowed

ITA 1176/CHNY/2025[2012-13]Status: DisposedITAT Chennai25 Aug 2025AY 2012-13

Bench: Shri Aby T. Varkey & Shri Amitabh Shukla

For Appellant: Mr.N. Arjun Raj, AdvocateFor Respondent: Ms. Anitha, Addl. CIT
Section 144

…hall upload the notices in these cases on the Systems by 31th October, 2019. 5. At this juncture, the Ld.AR brought to our notice that the Hon’ble Delhi High Court order dated 20.03.2023 in the case of M/s Brandix Mauritius Holdings Ltd., reported in [2023] 456 ITR 34 (Delhi), wherein the Hon’ble Court had an occasion to explain the Circular at Para Nos.3 to 8.3 of order, which is noted as under: 3. Inter alia, the object and purpose of allocating DIN to the communications, such as notices, orders, summons, letters and/or any correspondence emanating from the revenue is to maintain a proper audit trail. 3.1…

DCIT, Mumbai vs. J Kumar Infraprojects Limited, Mumbai

The Appeal of the Assessee is partly allowed and that of the department is dismissed

ITA 4593/MUM/2024[2017-18]Status: DisposedITAT Mumbai03 Jul 2025AY 2017-18

Bench: Hon’Ble Shri Sandeep Gosain & Shri Prabhash Shankar

Section 250Section 69A

…n by the Assessee and the Ld. DR on this issue and there are contradictory decisions of High Courts on this issue. At the same time, we are aware of the decision of the Hon’ble Delhi High Court in the case of CIT (IT) v. Brandix Mauritius Holdings Ltd. (2023) 456 ITR 34 (Del) wherein it is held that assessment order 188 J Kumar Infraprojects Ltd. passed by the AO did not bear DIN and there was nothing on record to show any exceptional circumstances as mentioned in 2019, Circular No.19 of 2019 dated 14.08.2019 reported in (2019) 416 ITR 140 (St.) and this decision is stayed by the Hon’ble Supreme Court in CIT v.…

DCIT CC 5-1, Mumbai vs. J Kumar Infraprojects Limited, Mumbai

The Appeal of the Assessee is partly allowed and that of the department is dismissed

ITA 4591/MUM/2024[2018-19]Status: DisposedITAT Mumbai03 Jul 2025AY 2018-19

Bench: Hon’Ble Shri Sandeep Gosain & Shri Prabhash Shankar

Section 250Section 69A

…n by the Assessee and the Ld. DR on this issue and there are contradictory decisions of High Courts on this issue. At the same time, we are aware of the decision of the Hon’ble Delhi High Court in the case of CIT (IT) v. Brandix Mauritius Holdings Ltd. (2023) 456 ITR 34 (Del) wherein it is held that assessment order 188 J Kumar Infraprojects Ltd. passed by the AO did not bear DIN and there was nothing on record to show any exceptional circumstances as mentioned in 2019, Circular No.19 of 2019 dated 14.08.2019 reported in (2019) 416 ITR 140 (St.) and this decision is stayed by the Hon’ble Supreme Court in CIT v.…

DCIT CC 5 1 Mumbai, Mumbai vs. Jagdishkumar M Gupta, Mumbai

Appeal of the department is dismissed

ITA 4584/MUM/2024[2019-20]Status: DisposedITAT Mumbai03 Jul 2025AY 2019-20

Bench: Hon’Ble Shri Sandeep Gosain & Shri Prabhash Shankar

Section 250Section 69ASection 69C

…n by the Assessee and the Ld. DR on this issue and there are contradictory decisions of High Courts on this issue. At the same time, we are aware of the decision of the Hon’ble Delhi High Court in the case of CIT (IT) v. Brandix Mauritius Holdings Ltd. (2023) 456 ITR 34 (Del) wherein it is held that assessment order passed by the AO did not bear DIN and there was nothing on record to show any exceptional circumstances as mentioned in 2019, Circular No.19 of 2019 dated 14.08.2019 reported in (2019) 416 ITR 140 (St.) and this decision is stayed by the Hon’ble Supreme Court in CIT v. Brandix Mauritius Holding Ltd. (…

DCIT CC 5 1 Mumbai, Mumbai vs. Jagdishkumar M Gupta, Mumbai

Appeal of the department is dismissed

ITA 4583/MUM/2024[2020-21]Status: DisposedITAT Mumbai03 Jul 2025AY 2020-21

Bench: Hon'Ble Shri Sandeep Gosain & Shri Prabhash Shankar

Section 250Section 69ASection 69C

…n by the Assessee and the Ld. DR on this issue and there are contradictory decisions of High Courts on this issue. At the same time, we are aware of the decision of the Hon'ble Delhi High Court in the case of CIT (IT) v. Brandix Mauritius Holdings Ltd. (2023) 456 ITR 34 (Del) wherein it is held that assessment order passed by the AO did not bear DIN and there was nothing on record to show any exceptional circumstances as mentioned in 2019, Circular No.19 of 2019 dated 14.08.2019 reported in (2019) 416 ITR 140 (St.) and this decision is stayed by the Hon'ble Supreme Court in CIT v. Brandix Mauritius Holding Ltd. (…

DCIT CC 5 1 Mumbai, Mumbai vs. Jagdishkumar M Gupta, Mumbai

Appeal of the department is dismissed

ITA 4582/MUM/2024[2021-22]Status: DisposedITAT Mumbai03 Jul 2025AY 2021-22

Bench: Hon'Ble Shri Sandeep Gosain & Shri Prabhash Shankar

For Appellant: Shri K Shivram Sr. Advocate &For Respondent: Ms. Neena Jeph, CIT DR
Section 250Section 69ASection 69C

…n by the Assessee and the Ld. DR on this issue and there are contradictory decisions of High Courts on this issue. At the same time, we are aware of the decision of the Hon'ble Delhi High Court in the case of CIT (IT) v. Brandix Mauritius Holdings Ltd. (2023) 456 ITR 34 (Del) wherein it is held that assessment order passed by the AO did not bear DIN and there was nothing on record to show any exceptional circumstances as mentioned in 2019, Circular No.19 of 2019 dated 14.08.2019 reported in (2019) 416 ITR 140 (St.) and this decision is stayed by the Hon'ble Supreme Court in CIT v. Brandix Mauritius Holding Ltd. (…

DCIT CC 5 1 Mumbai, Mumbai vs. Jagdishkumar M Gupta, Mumbai

Appeal of the department is dismissed

ITA 4581/MUM/2024[2022-23]Status: DisposedITAT Mumbai03 Jul 2025AY 2022-23

Bench: Hon'Ble Shri Sandeep Gosain & Shri Prabhash Shankar

Section 250Section 69ASection 69C

…n by the Assessee and the Ld. DR on this issue and there are contradictory decisions of High Courts on this issue. At the same time, we are aware of the decision of the Hon'ble Delhi High Court in the case of CIT (IT) v. Brandix Mauritius Holdings Ltd. (2023) 456 ITR 34 (Del) wherein it is held that assessment order passed by the AO did not bear DIN and there was nothing on record to show any exceptional circumstances as mentioned in 2019, Circular No.19 of 2019 dated 14.08.2019 reported in (2019) 416 ITR 140 (St.) and this decision is stayed by the Hon'ble Supreme Court in CIT v. Brandix Mauritius Holding Ltd. (…

J Kumar Infraprojects Limited, Mumbai vs. The Dy Commissioner of Income Tax Central Circle -5(1), Mumbai

The Appeal of the Assessee is partly allowed and that of the department is dismissed

ITA 4153/MUM/2024[2020-21]Status: DisposedITAT Mumbai03 Jul 2025AY 2020-21

Bench: Hon’Ble Shri Sandeep Gosain & Shri Prabhash Shankar

Section 250Section 69A

…n by the Assessee and the Ld. DR on this issue and there are contradictory decisions of High Courts on this issue. At the same time, we are aware of the decision of the Hon’ble Delhi High Court in the case of CIT (IT) v. Brandix Mauritius Holdings Ltd. (2023) 456 ITR 34 (Del) wherein it is held that assessment order 188 J Kumar Infraprojects Ltd. passed by the AO did not bear DIN and there was nothing on record to show any exceptional circumstances as mentioned in 2019, Circular No.19 of 2019 dated 14.08.2019 reported in (2019) 416 ITR 140 (St.) and this decision is stayed by the Hon’ble Supreme Court in CIT v.…

J Kumar Infraprojects Limited, Mumbai vs. The Dy Commissioner of Income Tax Central Circle -5(1), Mumbai

The Appeal of the Assessee is partly allowed and that of the department is dismissed

ITA 4151/MUM/2024[2022-23]Status: DisposedITAT Mumbai03 Jul 2025AY 2022-23

Bench: Hon’Ble Shri Sandeep Gosain & Shri Prabhash Shankar

Section 250Section 69A

…n by the Assessee and the Ld. DR on this issue and there are contradictory decisions of High Courts on this issue. At the same time, we are aware of the decision of the Hon’ble Delhi High Court in the case of CIT (IT) v. Brandix Mauritius Holdings Ltd. (2023) 456 ITR 34 (Del) wherein it is held that assessment order 188 J Kumar Infraprojects Ltd. passed by the AO did not bear DIN and there was nothing on record to show any exceptional circumstances as mentioned in 2019, Circular No.19 of 2019 dated 14.08.2019 reported in (2019) 416 ITR 140 (St.) and this decision is stayed by the Hon’ble Supreme Court in CIT v.…

J Kumar Infraprojects Limited, Mumbai vs. The Dy Commissioner of Income Tax Central Circle -5(1), Mumbai

The Appeal of the Assessee is partly allowed and that of the department is dismissed

ITA 4150/MUM/2024[2019-20]Status: DisposedITAT Mumbai03 Jul 2025AY 2019-20

Bench: Hon’Ble Shri Sandeep Gosain & Shri Prabhash Shankar

Section 250Section 69A

…n by the Assessee and the Ld. DR on this issue and there are contradictory decisions of High Courts on this issue. At the same time, we are aware of the decision of the Hon’ble Delhi High Court in the case of CIT (IT) v. Brandix Mauritius Holdings Ltd. (2023) 456 ITR 34 (Del) wherein it is held that assessment order 188 J Kumar Infraprojects Ltd. passed by the AO did not bear DIN and there was nothing on record to show any exceptional circumstances as mentioned in 2019, Circular No.19 of 2019 dated 14.08.2019 reported in (2019) 416 ITR 140 (St.) and this decision is stayed by the Hon’ble Supreme Court in CIT v.…

Jagdishkumar Madanlal Gupta, Mumbai vs. Deputy Commissioner of Income Tax Central Circle -5(1), Mumbai

Appeal of the department is dismissed

ITA 4112/MUM/2024[2019-20]Status: DisposedITAT Mumbai03 Jul 2025AY 2019-20

Bench: Hon'Ble Shri Sandeep Gosain & Shri Prabhash Shankar

Section 250Section 69ASection 69C

…n by the Assessee and the Ld. DR on this issue and there are contradictory decisions of High Courts on this issue. At the same time, we are aware of the decision of the Hon'ble Delhi High Court in the case of CIT (IT) v. Brandix Mauritius Holdings Ltd. (2023) 456 ITR 34 (Del) wherein it is held that assessment order passed by the AO did not bear DIN and there was nothing on record to show any exceptional circumstances as mentioned in 2019, Circular No.19 of 2019 dated 14.08.2019 reported in (2019) 416 ITR 140 (St.) and this decision is stayed by the Hon'ble Supreme Court in CIT v. Brandix Mauritius Holding Ltd. (…

Jagdishkumar Madanlal Gupta, Mumbai vs. Deputy Commissioner of Income Tax Central Circle 5(1), Mumbai

Appeal of the department is dismissed

ITA 4111/MUM/2024[2021-22]Status: DisposedITAT Mumbai03 Jul 2025AY 2021-22

Bench: Hon'Ble Shri Sandeep Gosain & Shri Prabhash Shankar

Section 250Section 69ASection 69C

…n by the Assessee and the Ld. DR on this issue and there are contradictory decisions of High Courts on this issue. At the same time, we are aware of the decision of the Hon'ble Delhi High Court in the case of CIT (IT) v. Brandix Mauritius Holdings Ltd. (2023) 456 ITR 34 (Del) wherein it is held that assessment order passed by the AO did not bear DIN and there was nothing on record to show any exceptional circumstances as mentioned in 2019, Circular No.19 of 2019 dated 14.08.2019 reported in (2019) 416 ITR 140 (St.) and this decision is stayed by the Hon'ble Supreme Court in CIT v. Brandix Mauritius Holding Ltd. (…

Jagdishkumar Madanlal Gupta, Mumbai vs. Deputy Commissioner of Income Tax Central Circle -5(1), Mumbai

Appeal of the department is dismissed

ITA 4110/MUM/2024[2022-23]Status: DisposedITAT Mumbai03 Jul 2025AY 2022-23

Bench: Hon'Ble Shri Sandeep Gosain & Shri Prabhash Shankar

Section 250Section 69ASection 69C

…n by the Assessee and the Ld. DR on this issue and there are contradictory decisions of High Courts on this issue. At the same time, we are aware of the decision of the Hon'ble Delhi High Court in the case of CIT (IT) v. Brandix Mauritius Holdings Ltd. (2023) 456 ITR 34 (Del) wherein it is held that assessment order passed by the AO did not bear DIN and there was nothing on record to show any exceptional circumstances as mentioned in 2019, Circular No.19 of 2019 dated 14.08.2019 reported in (2019) 416 ITR 140 (St.) and this decision is stayed by the Hon'ble Supreme Court in CIT v. Brandix Mauritius Holding Ltd. (…

ACIT, CC-13, New Delhi vs. Minda Capital Pvt. Ltd., New Delhi

In the result, the appeal being ITA No

ITA 1856/DEL/2021[2017-18]Status: DisposedITAT Delhi13 Jun 2025AY 2017-18

Bench: Shris.Rifaur Rahman & Shri Anubhav Sharma

For Appellant: Shri Salil Aggarwal, Sr. AdvocateFor Respondent: Shri Sunil Kumar Yadav, CIT DR
Section 153ASection 153DSection 69C

…163 taxmann.com 118. Copy of order of Hon'ble ITAT Delhi in the case of Millenium 36-53 Vinimay Pvt. Ltd. vs ACIT in ITA No. 458/Del/2022. Copy of judgment of Hon'ble High Court of Delhi in the case of 54-59 CIT vs Brandix Maurities Holdings Ltd. reported in 456 ITR 34. Copy of order of Hon'ble ITAT Delhi in the case of Smt. Usha 60-72 Sharma vs DCIT in ITA No. 480/Del/2025. Copy of order of Hon'ble ITAT Delhi in the case of Parasram 73-80 Holdings Pvt. Ltd. vs DCIT in ITA No. 2824 to 2827/Del/2023. Copy of order of Hon'ble ITAT Delhi in the case of Veena Singh 81-97 vs ACIT in ITA No. 294/Del/2022. Copy of orde…

ACIT-CC-13, New Delhi vs. Minda Capital Pvt. Ltd., New Delhi

In the result, the appeal being ITA No

ITA 1855/DEL/2021[2016-17]Status: DisposedITAT Delhi13 Jun 2025AY 2016-17

Bench: Shris.Rifaur Rahman & Shri Anubhav Sharma

For Appellant: Shri Salil Aggarwal, Sr. AdvocateFor Respondent: Shri Sunil Kumar Yadav, CIT DR
Section 153ASection 153DSection 69C

…163 taxmann.com 118. Copy of order of Hon'ble ITAT Delhi in the case of Millenium 36-53 Vinimay Pvt. Ltd. vs ACIT in ITA No. 458/Del/2022. Copy of judgment of Hon'ble High Court of Delhi in the case of 54-59 CIT vs Brandix Maurities Holdings Ltd. reported in 456 ITR 34. Copy of order of Hon'ble ITAT Delhi in the case of Smt. Usha 60-72 Sharma vs DCIT in ITA No. 480/Del/2025. Copy of order of Hon'ble ITAT Delhi in the case of Parasram 73-80 Holdings Pvt. Ltd. vs DCIT in ITA No. 2824 to 2827/Del/2023. Copy of order of Hon'ble ITAT Delhi in the case of Veena Singh 81-97 vs ACIT in ITA No. 294/Del/2022. Copy of orde…

Minda Capital Pvt Ltd, New Delhi vs. ACIT Central Circle-13, New Delhi

In the result, the appeal being ITA No

ITA 1392/DEL/2020[2018-19]Status: DisposedITAT Delhi13 Jun 2025AY 2018-19

Bench: Shris.Rifaur Rahman & Shri Anubhav Sharma

For Appellant: Shri Salil Aggarwal, Sr. AdvocateFor Respondent: Shri Sunil Kumar Yadav, CIT DR
Section 153ASection 153DSection 69C

…163 taxmann.com 118. Copy of order of Hon'ble ITAT Delhi in the case of Millenium 36-53 Vinimay Pvt. Ltd. vs ACIT in ITA No. 458/Del/2022. Copy of judgment of Hon'ble High Court of Delhi in the case of 54-59 CIT vs Brandix Maurities Holdings Ltd. reported in 456 ITR 34. Copy of order of Hon'ble ITAT Delhi in the case of Smt. Usha 60-72 Sharma vs DCIT in ITA No. 480/Del/2025. Copy of order of Hon'ble ITAT Delhi in the case of Parasram 73-80 Holdings Pvt. Ltd. vs DCIT in ITA No. 2824 to 2827/Del/2023. Copy of order of Hon'ble ITAT Delhi in the case of Veena Singh 81-97 vs ACIT in ITA No. 294/Del/2022. Copy of orde…

Minda Capital Pvt Ltd, New Delhi vs. ACIT Central Circle-13, New Delhi

In the result, the appeal being ITA No

ITA 1391/DEL/2020[2017-18]Status: DisposedITAT Delhi13 Jun 2025AY 2017-18

Bench: Shris.Rifaur Rahman & Shri Anubhav Sharma

For Appellant: Shri Salil Aggarwal, Sr. AdvocateFor Respondent: Shri Sunil Kumar Yadav, CIT DR
Section 153ASection 153DSection 69C

…163 taxmann.com 118. Copy of order of Hon'ble ITAT Delhi in the case of Millenium 36-53 Vinimay Pvt. Ltd. vs ACIT in ITA No. 458/Del/2022. Copy of judgment of Hon'ble High Court of Delhi in the case of 54-59 CIT vs Brandix Maurities Holdings Ltd. reported in 456 ITR 34. Copy of order of Hon'ble ITAT Delhi in the case of Smt. Usha 60-72 Sharma vs DCIT in ITA No. 480/Del/2025. Copy of order of Hon'ble ITAT Delhi in the case of Parasram 73-80 Holdings Pvt. Ltd. vs DCIT in ITA No. 2824 to 2827/Del/2023. Copy of order of Hon'ble ITAT Delhi in the case of Veena Singh 81-97 vs ACIT in ITA No. 294/Del/2022. Copy of orde…

Minda Capital Pvt Ltd, New Delhi vs. ACIT Central Circle-13, New Delhi

In the result, the appeal being ITA No

ITA 1390/DEL/2020[2016-17]Status: DisposedITAT Delhi13 Jun 2025AY 2016-17

Bench: Shris.Rifaur Rahman & Shri Anubhav Sharma

For Appellant: Shri Salil Aggarwal, Sr. AdvocateFor Respondent: Shri Sunil Kumar Yadav, CIT DR
Section 153ASection 153DSection 69C

…163 taxmann.com 118. Copy of order of Hon'ble ITAT Delhi in the case of Millenium 36-53 Vinimay Pvt. Ltd. vs ACIT in ITA No. 458/Del/2022. Copy of judgment of Hon'ble High Court of Delhi in the case of 54-59 CIT vs Brandix Maurities Holdings Ltd. reported in 456 ITR 34. Copy of order of Hon'ble ITAT Delhi in the case of Smt. Usha 60-72 Sharma vs DCIT in ITA No. 480/Del/2025. Copy of order of Hon'ble ITAT Delhi in the case of Parasram 73-80 Holdings Pvt. Ltd. vs DCIT in ITA No. 2824 to 2827/Del/2023. Copy of order of Hon'ble ITAT Delhi in the case of Veena Singh 81-97 vs ACIT in ITA No. 294/Del/2022. Copy of orde…

The Commissioner of Income Tax - International Taxation -3 vs. Six Continents Hotels Inc

Appeal is allowed and the Assessee’s appeal [ITA No

ITA/263/2024HC Delhi15 May 2025

Bench: The Itat Impugning The Final Assessment Order Dated 04.02.2021 Passed By The Assessing Officer [Ao] Under Section 143(3) Read With Section 144C(13) Of The Act. 2. The Said Assessment Order Was Passed Pursuant To The Directions Issued By The Dispute Resolution Panel [Drp] On 31.12.2020. One Of The Grounds Urged By The Assessee Before The Itat – Which Was Accepted By This Is A Digitally Signed Order. The Authenticity Of The Order Can Be Re-Verified From Delhi High Court Order Portal By Scanning The Qr Code Shown Above. The Order Is Downloaded From The Dhc Server On 21/05/2025 At 13:45:32

Section 143(3)Section 144C(13)Section 260A

…$~3 * IN THE HIGH COURT OF DELHI AT NEW DELHI + ITA 263/2024 THE COMMISSIONER OF INCOME TAX - INTERNATIONAL TAXATION -3 .....Appellant Through: Mr. Ruchir Bhatia, SSC with Mr. Anant Mann, JSC; Mr. P. Gupta, JSC and Mr. Abhishek Anand, Advocate. versus SIX CONTINENTS HOTELS INC. .....Respondent Through: Mr. Manuj Sabharwal, Mr. Devvrat Tiwari and Mr. Drona Negi, Advocates. CORAM: HON'BLE MR. JUSTICE VIBHU BAKHRU HON'BLE MR. JUSTICE TEJAS KARIA O R D E R % 15.05.2025 1. The Revenue has filed the present appeal u…