“Section 56(2)(vii)(b)”

Section References (mined)Section 56Section 56(2)(vii)(b)543 judgments

The decision most relied on for Section 56(2)(vii)(b) is CIT v. Puneet Sabharwal (338 ITR 485), cited in 69 judgments on BharatTax.

Leading authorities on Section 56(2)(vii)(b)

CIT v. Puneet Sabharwal

338 ITR 485 · 2011 · High Court

citing judgments

The revenue must prove that an assessee received extra consideration beyond the declared value; a Departmental Valuation Officer's (DVO) report alone is insufficient to establish such receipt.

Calcutta in Reliance Jute Industries Ltd. v. Income Tax Officer

150 ITR 643 · 1984 · High Court

citing judgments

The Assessing Officer (AO) is not required to refer the valuation to the District Valuation Officer (DVO) if the AO has conducted a detailed inquiry and is satisfied with the cost of construction. Strict adherence to procedural requirements is essential; failure to comply with mandatory conditions renders the assessment based on such non-compliance invalid.

Gateway Leasing (P.) Ltd. v. ACIT

117 Taxmann.com 442 · 2020 · High Court

citing judgments

A notice under section 148 of the Income Tax Act, 1961, issued after the expiry of four years from the end of the relevant assessment year, is barred by limitation if the original assessment was completed under section 143(3).

Joseph Mudaliar v. DCIT

130 Taxmann.com 250 · 2021 · Reported

citing judgments

The amendment to section 50C(1) of the Income Tax Act, 1961, by inserting the third proviso through the Finance Act, 2018, is curative and applies retrospectively. This means the tolerance band for the difference between sale consideration and stamp duty value, introduced by this amendment, is applicable to earlier assessment years.

CIT v. MEGHMANI ORGANICS LTD.

221 Taxmann 25 · 2014 · High Court

citing judgments

Assessments initiated without proper jurisdiction, such as under section 153C without the necessary foundation, are null and void and must be annulled.

Mubarak Gafur Korabu v. ITO

117 Taxmann.com 828 · 2020 · ITAT

citing judgments

Section 56(2)(vii)(b) of the Income-tax Act, 1961, which deals with income from acquisition of property for inadequate consideration, does not apply to agricultural land purchased by an assessee, as it is not considered a capital asset under Section 2(14) of the Act.

Radha Kishan Kungwani v. ITO Ward

185 ITD 433 · ITAT

citing judgments

For the purpose of determining income under Section 56(2)(vii)(b) or 56(2)(x)(b), the stamp duty value or fair market value of immovable property is to be considered as on the date of payment made by the assessee towards booking of the property, where an agreement for purchase and payment of consideration has been made prior to the date of registration.

CIT v. Kay Arr Enterprises

299 ITR 348 · 2008 · High Court

citing judgments

A family arrangement or settlement does not give rise to any income. This is because it represents the working out of existing rights among family members rather than a transfer of property.

Judgments citing Section 56(2)(vii)(b)

S Murugesh, Tirunelveli vs. DCIT, Central Circle-1(3), Chennai

In the result, appeals filed by the assessees are allowed

ITA 3171/CHNY/2024[2017-18]Status: DisposedITAT Chennai06 Mar 2025AY 2017-18

Bench: Shri George George K & Shri S.R. Raghunathaआयकर अपील सं./Ita No.: 3169/Chny/2024 "नधा"रण वष"/Assessment Years: 2017-18 Shri S.Pothiraj, Deputy Commissioner # 3, North Car Street, Vs. Of Income Tax, Tirunelveli Town-627 006. Central Circle-1(3) Pan: Acxpp-8538-R Chennai. (अपीलाथ"/Appellant) (""यथ"/Respondent) & आयकर अपील सं./Ita No.: 3170/Chny/2024 "नधा"रण वष"/Assessment Years: 2017-18 Shri S.Mahesh, Deputy Commissioner # 3, North Car Street, Vs. Of Income Tax, Tirunelveli Town-627 006. Central Circle-1(3) Pan: Acvpm-6890-K Chennai. (अपीलाथ"/Appellant) (""यथ"/Respondent) & आयकर अपील सं./Ita No.: 3171/Chny/2024 "नधा"रण वष"/Assessment Years: 2017-18 Shri S.Murugesh Deputy Commissioner # 3, North Car Street, Vs. Of Income Tax, Tirunelveli Town-627 006. Central Circle-1(3) Pan: Acvpm-6963-D Chennai. (अपीलाथ"/Appellant) (""यथ"/Respondent) & आयकर अपील सं./Ita No.: 3172/Chny/2024 "नधा"रण वष"/Assessment Years: 2017-18 Shri S.Ashok Deputy Commissioner # 3, North Car Street, Vs. Of Income Tax

For Appellant: Mr. Y.Sridhar, FCAFor Respondent: Ms.Gouthami Manivasagam, JCIT

Section 132Section 153CSection 250Section 270ASection 56(2)(vii)

addition made was based on deeming provisions, not due to underreporting by the assessee. The penalty should be deleted. The AO used Section 56(2)(vii)(b) to add the difference between the sale price and a valuation estimate by the DVO (District Valuation Officer). This estimate is not concrete ... pending adjudication before the Hon’ble High Court. In the instance case, the addition is made invoking deeming provision as per section 56(2)(vii)(b) of the Act. The only basis of addition is estimate made by the DVO. There is nothing on record to suggest that assessee

S Magesh, Tirunelveli vs. DCIT, Central Circle-1(3), Chennai

In the result, appeals filed by the assessees are allowed

ITA 3170/CHNY/2024[2017-18]Status: DisposedITAT Chennai06 Mar 2025AY 2017-18

For Appellant: Mr. Y.Sridhar, FCAFor Respondent: Ms.Gouthami Manivasagam, JCIT

Section 132Section 153CSection 250Section 270ASection 56(2)(vii)

S. Pothyraj, Tiunelveli vs. DCIT, Central Circle01(3), Chennai

In the result, appeals filed by the assessees are allowed

ITA 3169/CHNY/2024[2017-18]Status: DisposedITAT Chennai06 Mar 2025AY 2017-18

For Appellant: Mr. Y.Sridhar, FCAFor Respondent: Ms.Gouthami Manivasagam, JCIT

Section 132Section 153CSection 250Section 270ASection 56(2)(vii)

Nitin Narayan Kadamdhad, Nagpur vs. ITO Ward 4(5) Nagpur, Nagpur

In the result, assessee’s appeal stands allowed

ITA 564/NAG/2024[2014-15]Status: DisposedITAT Nagpur05 Mar 2025AY 2014-15

Bench: Shri V. Durgarao

For Appellant: Shri Ritesh MehtaFor Respondent: Shri Abhay Y. Marathe

Section 143(3)Section 56(2)(vii)

aggrega– ting to ` 9,76,000 was proposed to be treated as “Income From Other Sources” by invoking provisions of section 56(2)(vii)(b)(ii) of the Act. Consequent upon issuance of assessment order passed by the Assessing Officer, the assessee being aggrieved filed appeal before the first appellate ... stamp duty valuation of the property vide sale deed dated: 27.06.2013. Therefore, given this difference, the AO considered applying the provisions of section 56(2)(vii)(b)(ii) of the IT Act and made the addition of Rs. 9,76,000/- as an income from other sources and assessed total

Kavita Agarwal, Kanpur vs. ITO Ward-2(2)(1), Kanpur

In the result, the appeal of the assessee is partly allowed for statistical purposes

ITA 567/LKW/2024[2012-13]Status: DisposedITAT Lucknow03 Mar 2025AY 2012-13

Bench: Shri Anadee Nath Misshrakavita Agarwal V. Income Tax Officer Ward-2(2)(1) Flat No.204-2A/209 Raman Dham Apartment Azad Nagar- 15/295, Vaibhav Bhawan, Kanpur-208002. Civil Lines-Kanpur- 208001. Pan:Asfpa7273C (Appellant) (Respondent) Appellant By: None Respondent By: Shri Sunil Kumar Rajwanshi, Addl. Cit(Dr) O R D E R

For Appellant: NoneFor Respondent: Shri Sunil Kumar Rajwanshi, Addl

Section 144Section 250Section 250(6)Section 56(2)(vii)Section 69B

addition of Rs.3,36,000.00 being the difference in between the Stamp Duty Value and purchase price of the appellant under section 56(2)(vii)(b) of the Act. 2. That the Ld. CIT(Appeals) erred in law in making the above addition since the provisions of section 56(2 ... Stamp Duty Value over the Purchase Price of the Immovable property. Page 2 of 4 3. That the Provisions of section 56(2)(vii)(b) as they stood during the A.Y. 2012-13 taxed the stamp duty value of the immovable property only if the immovable property was purchased without

Suresh Gulabchand Oswal, Pune vs. ITO Ward 6(3), Pune

In the result, the appeal of assessee is treated as allowed for statistical purposes

ITA 2493/PUN/2024[2015-16]Status: DisposedITAT Pune28 Feb 2025AY 2015-16

Bench: Shri R.K. Panda & Ms. Astha Chandra

For Appellant: Shri Sarvesh KandelwalFor Respondent: Shri Arvind Desai

Section 143(1)Section 143(2)Section 143(3)Section 56(2)(vii)Section 68

difference of Rs. 49,33,000/- i.e. Rs. 24,66,500/- should not added to his total income under the provisions of section 56(2)(vii)(b)(ii) of the Act. The assessee was also asked to explain the source of investment of Rs.1,69,75,750/- in the purchase ... total income of Rs.61,31,800/- including therein –(i) addition of Rs.24,66,500/- under the provisions of section 56(2)(vii)(b)(ii) of the Act and addition of Rs.10,00,000/- u/s 68 of the Act. 4. The assessee carried the matter in appeal before

Ambika Trading Corporation, Mumbai vs. DCIT 24(1), Mumbai

In the result the appeals filed by the assessee for both assessment years stands partly allowed

ITA 6058/MUM/2024[2015-16]Status: DisposedITAT Mumbai28 Feb 2025AY 2015-16

Bench: Smt. Beena Pillai () & Shri Omkareshwar Chidara ()

Section 139(1)Section 147Section 148

appeal no. 3 taken up by the appellant is therefore allowed. 8.5 It is pertinent to mention here that the provisions of section 56(2)(vii)(b) as applicable to AY 2014-15 under consideration providing for taxation of the difference between the stamp duty value of the immovable property

Ambika Trading Corporation, Mumbai vs. DCIT 24(1), Mumbai

In the result the appeals filed by the assessee for both assessment years stands partly allowed

ITA 6057/MUM/2024[2014-15]Status: DisposedITAT Mumbai28 Feb 2025AY 2014-15

Bench: Smt. Beena Pillai () & Shri Omkareshwar Chidara ()

Section 139(1)Section 147Section 148

Rumina Shamsuddin Wallani, India vs. ITO 19(1)(5), Pirmal Chambers

In the result the appeal filed by the assessee stands allowed

ITA 5057/MUM/2024[2017-18]Status: DisposedITAT Mumbai28 Feb 2025AY 2017-18

Bench: Smt. Beena Pillai ()

Section 148Section 148ASection 56(2)(vii)Section 69

deed was executed and registered in 2016 and therefore the reckoner value of 2014 needs to be adopted for the purpose of section 56(2)(vii)(b). 4. On the facts and circumstances of the case and in law, the Ld. CIT(A) erred in upholding the additions ... relevant to the A.Y. 2017-18 for which the value of stamp duty is Rs.1,17,37,000/-. As per section 56(2)(vii)(b) of the Act, the difference between cost of acquisition and the value of stamp duty is taxable under the head income from Other Source

Ali Hasnain Rafique Cassum, Mumbai vs. Income Tax Officer - 17(1)(1), Mumbai

In the result, the appeal filed by the assessee is treated as allowed for statistical purposes

ITA 6/MUM/2025[2018-19]Status: DisposedITAT Mumbai27 Feb 2025AY 2018-19

Bench: Shri B.R. Baskaran & Shri Narender Kumar Choudhryassessment Year : 2018-19 Ali Hasnain Rafique Cassum, Income Tax Officer-17(1)(1), 74-B, Peddar Road, Kautilya Bhavan, Dr. Gopalrao Deshmukh Marg, Vs. Mumbai Cumballa Hills, S.O. Mumbai Pan : Adbpc5032E (Appellant) (Respondent)

For Appellant: Shri Dharan GandhiFor Respondent: Shri Umesh Chandra Sinha

Section 14Section 56(2)(x)

hyper technical interpretation at the end of the A.O. Pinki Chetan Shah assessee's case clearly falls in the proviso to Section 56(2)(vii)(b). In the above said case, the co-ordinate bench has held that the allotment letter can be taken as agreement for sale. We also

Anmol Land Developers, Mumbai vs. NFAC, Delhi (I.T.O. Ward 20(1)(1), Mumbai)

In the result, appeal of the assessee is allowed for statistical purposes

ITA 173/MUM/2025[2017-18]Status: DisposedITAT Mumbai24 Feb 2025AY 2017-18

Bench: Shri Narender Kumar Choudhry, Judical Member & Shri Prabhash Shankarआयकर अपील सं./Ita No.173/Mum/2025 (निर्धारण वर्ा / Assessment Year :2017-2018)

For Appellant: Shri Tejas Chandarana, AR byFor Respondent: Shri Ram Krishn Kedia, Sr

Section 142(1)Section 147Section 250Section 56(2)(vii)

Rs.4,37,50,540/- on account of difference in value of purchase consideration and market value, as per the provisions of Section 56(2)(vii)(b)/50C of the Act and added the same in the income of the assessee. 3. The Assessee being aggrieved though challenged the said addition

Prasad Jaykar Shetty, Thane vs. Income Tax Officer, Thane

ITA 3651/MUM/2023[2014-15]Status: DisposedITAT Mumbai24 Feb 2025AY 2014-15

Bench: Smt. Kavitha Rajagopal (Jm) & Shri Omkareshwar Chidara (Am) Prasad Jaykar Shetty Ito, Ward-3(2) A-43, Building No. 2 Ashar I.T. Park Vishram Tower Vs. 6Th Floor, Room No. Wagle Estate 04, Ambika Nagar, Thane West-400 604. Wagle Estate Thane-400 604. Pan : Aozps2736L Appellant Respondent

For Appellant: Shri P.D. ChouguleFor Respondent: Shri Jagdish Shetty

Section 143(3)Section 56(2)(vii)

withdraw any or all the above grounds of Appeal 2. The Ld. AO made an addition of Rs. 31,70,500/- under section 56(2)(vii)(b)(ii) of the I.T. Act by stating as follows while completing the assessment under section 143(3) of the Act :- 2 Prasad Jaykar ... Shetty “Therefore by virtue of provision of section 56(2)(vii)(b)(ii) of the I.T.Act,1961, the amount of Rs. 31,70,500/- is liable to be treated as income of the assessee. The provision of section 56(2)(vii)(b)(ii) of the I.T.Act,1961 says that, "Where

Sri. D. K Shivakumar, Bangalore vs. The Deputy Commissioner of Income Tax, Central Circle-1(4), Bengaluru

ITA 1064/BANG/2024[2018-19]Status: DisposedITAT Bangalore21 Feb 2025AY 2018-19

Bench: Shri Laxmi Prasad Sahu & Shri Soundarajan Kassessment Year : 2018-19

For Appellant: S/ShriFor Respondent: Shri.Y. V. Raviraj, Sr. Standing Counsel

Section 132(4)Section 143(2)Section 250Section 292CSection 69ASection 69B

IN THE INCOME TAX APPELLATE TRIBUNAL “B” BENCH : BANGALORE BEFORE SHRI LAXMI PRASAD SAHU, ACCOUNTANT MEMBER AND SHRI SOUNDARAJAN K

Bharat Mithalal Jain, Bhayandar vs. NFAC, Delhi

In the result, the appeal filed by the Assessee is allowed in the aforesaid terms

ITA 5217/MUM/2024[2015-16]Status: DisposedITAT Mumbai19 Feb 2025AY 2015-16

Bench: Shri Narender Kumar Choudhry

For Appellant: Shri Vimal Punmiya, Ld. CAFor Respondent: Shri Srinivas P., Ld. Sr.DR

Section 115BSection 147Section 148Section 250Section 56(2)(vii)Section 69

Rs.22,06,000/- and therefore the AO construed that the Assessee has not offered the difference of consideration as envisaged in section 56(2)(vii)(b) of the Act and consequently issued the notice dated 31.03.2021 u/s 148 of the Act to the Assessee who in response filed his return ... Rs.13,96,400/- being difference between the stamp duty value and the agreement value, for the taxation as per the provision of section 56(2)(vii)(b) of the Act, by filing his return of income on dated 10.08.2021 in response to the notice

Sunny Tarunkumar Doshi, Jetpur vs. The ITO, Ward-1(1)(1), Ahmedabad

In the result, appeal filed by the assessee is dismissed

ITA 288/AHD/2021[2014-15]Status: DisposedITAT Ahmedabad14 Feb 2025AY 2014-15

Bench: Smt. Annapurna Gupta & Ms. Suchitra Kambleassessment Year: 2014-15

Section 142(1)Section 143(3)Section 147Section 148Section 234ASection 271(1)(c)Section 56(1)(vii)Section 56(2)(vii)Section 69A

well as S.69 of the Act related to the purchase of immovable property. - The final assessment order made an addition under Section 56(2)(vii)(b) on the grounds of "without consideration", deviating from the original reasons for reopening. Moreover, when the Assessing Officer has himself found that the Appellant ... accordingly the share of the appellant amounting to Rs.69,49,250/- (50%) was added to the total income of the appellant under section 56(2)(vii)(b)(i) of the Act. - In this connection, the assessee most respectfully submits that the provisions of S.56(2)(vii)(b

Fiero Fernandes, Mumbai vs. Jurisdiction Ward 42(2)(2), Mumbai

In the result, the appeal by the assessee is allowed for statistical purposes

ITA 23/MUM/2025[2015-16]Status: DisposedITAT Mumbai14 Feb 2025AY 2015-16

Bench: Shri Sandeep Singh Karhail, Jm & Shri Girish Agrawal, Am आयकर अपील सं./Ita No.23/Mum/2025 (िनधा"रण वष" / Assessment Year :2015-2016) Fiero Fernandes Vs. Ito, Ward-42(2)(2), 1202 Lourdes Heritage, Mumbai Opposite Our Lady Of Lourdes Church, Orlem Malad West Mumbai "थायी लेखा सं./Pan No. : Aaspf 3097 Q (अपीलाथ" /Appellant) (""यथ" / Respondent) .. िनधा"रती की ओर से /Assessee By : Ms. Chaitee Londhe, Ar राज"व क" ओर से /Revenue By : Shri Pravin Salunkhe, Sr.Dr सुनवाई क" तारीख / Date Of Hearing : 12/02/2025 घोषणा क" तारीख/Date Of Pronouncement : 14/02/2025 आदेश / O R D E R Per Sandeep Singh Karhail, Jm : The Present Appeal Has Been Filed By The Assessee Challenging The Impugned Order Dated 05/11/2024 Passed Under Section 250 Of The Income Tax Act, 1961 (“The Act”) By The Learned Commissioner Of Income Tax (Appeals), National Faceless Appeal Centre, Delhi [“Learned Cit(A)”], For The Assessment Year 2015-16. 2. In This Appeal, The Assessee Has Raised The Following Grounds: -

For Appellant: Ms. Chaitee Londhe, ARFor Respondent: Shri Pravin Salunkhe, Sr.DR

Section 148Section 149Section 151ASection 250Section 250(6)Section 56Section 56(2)(vii)Section 56(2)(x)Section 69

w.e.f. 01.04.2019 prescribing a price band of 10% being curative and beneficial in nature, would apply retrospectively to section 56(2)(vii)(b) of the Act as well. 8. The appellant previously to add alter or amend any of the grounds of appeal prior to or at the time

Sundarakrishnan, Chennai vs. PCIT, Coimbatore

ITA 1935/CHNY/2024[2014-15]Status: DisposedITAT Chennai11 Feb 2025AY 2014-15

Bench: Shri Manu Kumar Giri, Hon’Ble & Shri S. R. Raghunatha, Hon’Bleआयकर अपील सं./Ita No.: 1935/Chny/2024 िनधा"रण वष" / Assessment Year: 2014-15 Sundarakrishnan, Principal Commissioner Of No. 15, 5Th Main Road, V. Income Tax, Kasturba Nagar, Coimbatore -1. Adyar – 600 020. [Pan: Arbps-4782-R] (अपीलाथ"/Appellant) (""यथ"/Respondent) अपीलाथ" क" ओर से/Appellant By : Shri. Y. Sridhar, Fca ""यथ" क" ओर से/Respondent By : Shri. R. Clement Ramesh Kumar, Cit सुनवाई क" तारीख/Date Of Hearing : 04.02.2025 घोषणा क" तारीख/Date Of Pronouncement : 11.02.2025 आदेश /O R D E R Per S. R. Raghunatha:

For Appellant: Shri. Y. Sridhar, FCAFor Respondent: Shri. R. Clement Ramesh Kumar, CIT

Section 143(3)Section 263Section 50CSection 54FSection 5O

this computation of LTCG u/s.50C of the Act, but was :-8-: ITA. No: 1935/Chny/2024 confined to invoking of the provisions of section 56(2)(vii)(b), that too, in respect of the asset newly acquired and does not pertain to the assets transferred resulting in LTCG. This process of applying ... provisions of Section 56(2)(vii)(b) did not comprise any error. Therefore, the solitary intrigue in this appeal is whether the alleged error while invoking the provisions of Sec.50C of the Act, subsists in the original assessment order u/s.143(3) or in the subsequent reassessment order u/s.147

Kamal Kishor Pandey, Gwalior vs. CIT (A) NFAC, Income Tax

Appeal is allowed for statistical purposes

ITA 235/AGR/2024[2014-15]Status: DisposedITAT Agra10 Feb 2025AY 2014-15

Bench: Shri Satbeer Singh Godara & Shri Manoj Kumar Aggarwalkamal Kishore Pandey Vs. Cit(A)/Nfac, Shivaji Nagar, Amkho Delhi Lashkar,Gwalior Madhya Pradesh-474001 "ायीलेखासं./जीआइआरसं./Pan/Gir No: Asjpp5665K Appellant .. Respondent

For Appellant: NoneFor Respondent: Sh. Shalendra Shrivastava, Sr. DR

Section 143(3)Section 50C(2)Section 56(2)(vii)

emerges during the course of hearing that the able assistance coming from the Revenue side that both the lower authorities has made Section 56(2)(vii)(b) addition of Rs.72 lacs representing the assessee’s actual purchase price of Rs.3 lacs viz-a-viz that assessed to the tune ... Revenue’s case accordingly before us is that we ought to uphold the impugned addition since representing the said difference attracting section 56(2)(vii)(b) of the Act. 4. We are of the considered view that in this factual backdrop that the learned lower authorities have recorded any categorical

Shamoon Ahmed Mulla, Thane vs. ITO Ward 2(4), Mumbai

In the result, appeal of the assessee is allowed

ITA 6070/MUM/2024[2015-16]Status: DisposedITAT Mumbai10 Feb 2025AY 2015-16

Bench: Shri Sandeep Gosain & Shri Girish Agrawalassessment Year: 2015-16

For Appellant: Shri Akash Singh, AdvocateFor Respondent: Ms. Monika H. Pande, Sr.DR

Section 143(3)Section 271(1)(c)Section 56(2)(vii)

levied u/s.271(1)(c) 2 Shamoon Ahmed Mulla., AY 2015-16 of the Act on the addition made under deemed provisions of section 56(2)(vii) (b) of the Act. 2. "On the facts and circumstances of the case, the Id. CIT(A) of National Faceless Appeal Centre has erred ... initiated on the deemed income computed by adopting the stamp value of the property as on the date of agreement during which section 56(2)(vii)(b) was not in existence 3. "On the facts and circumstances of the case, the ld. CIT(A) of National Faceless Appeal Centre

Dilip Kumar Agrawal, Kolkata vs. I.T.O., Ward - 34(3), Kolkata

In the result, the appeal filed by the assessee is allowed

ITA 1547/KOL/2024[2017-2018]Status: DisposedITAT Kolkata03 Feb 2025AY 2017-2018

Bench: Dr.Manish Boradआयकर अपील सं. / Ita No.1547/Kol/2024 Assessment Year : 2017-18 Shri Dilip Kumar Agrawal, Ito, Ward-34(3), 1D, 14Th Floor, 78, V/S Kolkata Bentinck Street, Dalhousie, Kolkata-700 001 West Bengal Pan : Acwpa9714D Appellant Respondent

For Appellant: Shri Abheshek Bansal, ARFor Respondent: Smt. Madhumita Das, Addl. CIT

Section 143(2)Section 143(3)Section 250Section 56(2)(vii)

IN THE INCOME TAX APPELLATE TRIBUNAL KOLKATA BENCHES “SMC”, KOLKATA BEFORE DR.MANISH BORAD, ACCOUNTANT MEMBER आयकर अपील सं. / ITA No.1547/KOL/2024