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“DDT”

Special Rate ProvisionsSection 115-OSection 115-O499 judgments

The decision most relied on for DDT is Sesa Goa Ltd. v. JCIT (117 Taxmann.com 96), cited in 291 judgments on BharatTax.

Leading authorities on DDT

Sesa Goa Ltd. v. JCIT
117 Taxmann.com 96 · 2020 · High Court
291
citing judgments

Education cess paid on total income and dividend distribution tax are allowable deductions for income tax purposes.

Trib.) Giesecke & Devrient 16.994%). India Pvt Ltd. v. ACIT
120 Taxmann.com 338 · 2020 · High Court
52
citing judgments

The provisions of a Double Taxation Avoidance Agreement (DTAA) would prevail over the domestic law rate of Dividend Distribution Tax (DDT) under Section 115-O.

Union of India v. Tata Tea Co Ltd.
398 ITR 260 · 2017 · Supreme Court
38
citing judgments

Dividend Distribution Tax (DDT) is a tax on the profits of the domestic company, not on the shareholder. The Supreme Court's decision in Tata Tea Co. Ltd. did not address the precise nature of DDT as a tax on the company versus the shareholder.

Torrent India Pvt. Ltd. v. CIT
35 Taxmann.com 300 · 2013 · High Court
36
citing judgments

Excess Dividend Distribution Tax (DDT) paid by a company is refundable to the assessee, even though Section 115-O(4) states DDT is a final payment.

SIDBI v. CBDT
133 Taxmann.com 158 · 2021 · High Court
23
citing judgments

Dividend Distribution Tax (DDT) under section 115-O is a charge on the company's profits and not on the income in the hands of the shareholder, meaning it does not constitute double taxation and is not subject to Double Taxation Avoidance Agreements (DTAA).

Genpact India (P). Ltd. v. Dy. CIT
111 Taxmann.com 402 · 2019 · Supreme Court
11
citing judgments

An assessee can challenge tax liability arising from special charging provisions, such as Section 115QA, by filing a separate appeal under Section 246A. Dividend Distribution Tax (DDT), as an additional tax not linked to the computation of total income, must be appealed independently.

AMD Metplast (P.) Ltd. v. Dy. CIT
20 Taxmann.com 647 · 2012 · High Court
10
citing judgments

Commission paid to a Managing Director for services rendered is eligible for deduction under section 36(1)(ii) of the Income-tax Act, 1961, provided it is paid as per the terms of employment and not merely to avoid Dividend Distribution Tax (DDT).

Judgments citing DDT

Philips India Limited, Kolkata vs. A.C.I.T., Circle - 11(1), Kolkata

ITA 1783/KOL/2024[2015-2016]Status: DisposedITAT Kolkata20 Mar 2026AY 2015-2016

Bench: Shri Sonjoy Sarma & Shri Rakesh Mishra

Section 115Section 244ASection 250

case, the National Faceless Appeal Centre, Delhi [the Ld. CIT(A)] erred in rejecting the claim of refund of excess Dividend Distribution Tax (DDT) paid by the Appellant amounting to Rs.94,81,687. 2. That on the facts and circumstances of the case, the Ld. CIT(A) erred in following ... Special Bench decision of Mumbai Tribunal in the case of DCIT vs Tata Oil India Pvt Ltd (ITA No 6997/Mum/2019) upholding that DDT is a tax on profits of the domestic company and not on the shareholder. 2. 1. That on the facts and circumstances of the case

Philips India Limited, Kolkata vs. A.C.I.T., Circle - 11(1), Kolkata

In the result, the appeals filed by the assessee for all the assessment years i

ITA 1782/KOL/2024[2014-2015]Status: DisposedITAT Kolkata20 Mar 2026AY 2014-2015

Bench: Shri Sonjoy Sarma & Shri Rakesh Mishra

Section 115Section 237Section 244ASection 250

case, the National Faceless Appeal Centre, Delhi [the Ld. CIT(A)] erred in rejecting the claim of refund of excess Dividend Distribution Tax (DDT) paid by the Appellant amounting to Rs. 94,81,687. 2. That on the facts and circumstances of the case, the Ld. CIT(A) erred ... following the Special Bench decision of Mumbai Tribunal in the case of DCIT vs Tata Oil India Pvt Ltd (ITA No 6997/Mum/2019) upholding that DDT is a tax on profits of the domestic company and not on the shareholder. 2.1. That on the facts and circumstances of the case

Philips India Limited, Kolkata vs. A.C.I.T., Circle - 11(1), Kolkata

In the result, the appeals filed by the assessee for all the assessment years i

ITA 1781/KOL/2024[2013-2014]Status: DisposedITAT Kolkata20 Mar 2026AY 2013-2014

Bench: Shri Sonjoy Sarma & Shri Rakesh Mishra

Section 115Section 237Section 244ASection 250

case, the National Faceless Appeal Centre, Delhi [the Ld. CIT(A)] erred in rejecting the claim of refund of excess Dividend Distribution Tax (DDT) paid by the Appellant amounting to Rs. 94,81,687. 2. That on the facts and circumstances of the case, the Ld. CIT(A) erred ... following the Special Bench decision of Mumbai Tribunal in the case of DCIT vs Tata Oil India Pvt Ltd (ITA No 6997/Mum/2019) upholding that DDT is a tax on profits of the domestic company and not on the shareholder. 2.1. That on the facts and circumstances of the case

Philips India Limited, Kolkata vs. A.C.I.T., Circle - 11(1), Kolkata

In the result, the appeals filed by the assessee for all the assessment years i

ITA 1780/KOL/2024[2012-2013]Status: DisposedITAT Kolkata20 Mar 2026AY 2012-2013

Bench: Shri Sonjoy Sarma & Shri Rakesh Mishra

Section 115Section 237Section 244ASection 250

case, the National Faceless Appeal Centre, Delhi [the Ld. CIT(A)] erred in rejecting the claim of refund of excess Dividend Distribution Tax (DDT) paid by the Appellant amounting to Rs. 94,81,687. 2. That on the facts and circumstances of the case, the Ld. CIT(A) erred ... following the Special Bench decision of Mumbai Tribunal in the case of DCIT vs Tata Oil India Pvt Ltd (ITA No 6997/Mum/2019) upholding that DDT is a tax on profits of the domestic company and not on the shareholder. 2.1. That on the facts and circumstances of the case

Philips India Limited, Kolkata vs. A.C.I.T., Circle - 11(1), Kolkata

In the result, the appeals filed by the assessee for all the

ITA 1779/KOL/2024[2011-2012]Status: DisposedITAT Kolkata20 Mar 2026AY 2011-2012

Bench: Shri Sonjoy Sarma & Shri Rakesh Mishra

Section 115Section 237Section 244ASection 250

case, the National Faceless Appeal Centre, Delhi [the Ld. CIT(A)] erred in rejecting the claim of refund of excess Dividend Distribution Tax (DDT) paid by the Appellant amounting to Rs.94,81,687. 2. That on the facts and circumstances of the case, the Ld. CIT(A) erred in following ... Special Bench decision of Mumbai Tribunal in the case of DCIT vs Tata Oil India Pvt Ltd (ITA No 6997/Mum/2019) upholding that DDT is a tax on profits of the domestic company and not on the shareholder. 2. 1. That on the facts and circumstances of the case

Philips India Ltd., Kolkata vs. A.C.I.T., Circle - 11(1), Kolkata

ITA 1778/KOL/2024[2010-2011]Status: DisposedITAT Kolkata20 Mar 2026AY 2010-2011

Bench: Shri Sonjoy Sarma & Shri Rakesh Mishra

Section 115Section 244ASection 250

case, the National Faceless Appeal Centre, Delhi [the Ld. CIT(A)] erred in rejecting the claim of refund of excess Dividend Distribution Tax (DDT) paid by the Appellant amounting to Rs.94,81,687. 2. That on the facts and circumstances of the case, the Ld. CIT(A) erred in following ... Special Bench decision of Mumbai Tribunal in the case of DCIT vs Tata Oil India Pvt Ltd (ITA No 6997/Mum/2019) upholding that DDT is a tax on profits of the domestic company and not on the shareholder. 2. 1. That on the facts and circumstances of the case

Philips India Limited, Kolkata vs. A.C.I.T., Circle - 11(1), Kolkata

In the result, the appeals filed by the assessee for all the assessment years i

ITA 1777/KOL/2024[2009-2010]Status: DisposedITAT Kolkata20 Mar 2026AY 2009-2010

Bench: Shri Sonjoy Sarma & Shri Rakesh Mishra

Section 115Section 237Section 244ASection 250

case, the National Faceless Appeal Centre, Delhi [the Ld. CIT(A)] erred in rejecting the claim of refund of excess Dividend Distribution Tax (DDT) paid by the Appellant amounting to Rs. 94,81,687. 2. That on the facts and circumstances of the case, the Ld. CIT(A) erred ... following the Special Bench decision of Mumbai Tribunal in the case of DCIT vs Tata Oil India Pvt Ltd (ITA No 6997/Mum/2019) upholding that DDT is a tax on profits of the domestic company and not on the shareholder. 2.1. That on the facts and circumstances of the case

Philips India Limited, Kolkata vs. A.C.I.T., Circle - 11(1), Kolkata

In the result, the appeals filed by the assessee for all the

ITA 1776/KOL/2024[2008-2009]Status: DisposedITAT Kolkata20 Mar 2026AY 2008-2009

Bench: Shri Sonjoy Sarma & Shri Rakesh Mishra

Section 115Section 237Section 244ASection 250

case, the National Faceless Appeal Centre, Delhi [the Ld. CIT(A)] erred in rejecting the claim of refund of excess Dividend Distribution Tax (DDT) paid by the Appellant amounting to Rs.94,81,687. 2. That on the facts and circumstances of the case, the Ld. CIT(A) erred in following ... Special Bench decision of Mumbai Tribunal in the case of DCIT vs Tata Oil India Pvt Ltd (ITA No 6997/Mum/2019) upholding that DDT is a tax on profits of the domestic company and not on the shareholder. 2. 1. That on the facts and circumstances of the case

Dcm Shriram Industris Ltd, New Delhi vs. DCIT Circle-7(1), New Delhi

In the result, the appeal filed by the assessee is allowed in above terms

ITA 2166/DEL/2022[2018-19]Status: DisposedITAT Delhi18 Mar 2026AY 2018-19

Bench: Shri Challa Nagemdra Prasad & Shri S. Rifaur Rahman

Section 115JSection 143(3)Section 144C(10)Section 14ASection 80Section 92C

account of normal tax and interest payable thereon and remaining 2,09,68,122/- on account of non-payment of Dividend distribution tax (DDT) and interest thereon] which is laced with the following mistakes apparent from records and which are wholly illegal, untenable and erroneous: 1.1 The Ld. DRP/TPO ... return of income is ₹68,20,48,545/-. 1.3 That the Id. AO has erred in raising an incorrect demand on account of DDT payable [1,41,67,650/-] and interest u/s 115P [268,00,472/-] completely ignoring that DDT amounting to ₹1,41,67,650/- has been duly paid

Denso International India Private Limited, Delhi vs. Dy. Commissioner of Income Tax, Delhi

In the result, this appeal is partly allowed

ITA 6688/DEL/2025[2019-20]Status: DisposedITAT Delhi13 Mar 2026AY 2019-20

Bench: Shri Challa Nagendra Prasad & Shri Sanjay Awasthiआ.अ.सं/.I.T.A No.6688/Del/2025 िनधा"रणवष"/Assessment Year: 2019-20 बनाम Denso International India Private Ld. Dcit, Limited, Vs. Circle 7(1), B-1/D-4, Ground Floor,Mohan C.R. Building, Delhi. Cooperative Estate,Delhi. Pan No.Aabcd1103D अपीलाथ" Appellant ""यथ"/Respondent

Section 115Section 143(1)Section 143(1)(a)Section 250Section 36(1)(va)Section 43B

uphold the action of Ld. AO. The second point of dispute was concerning the refund 1 of excess Dividend Distribution Tax (DDT) paid by the assessee, which was claimed as a refund on the basis that the beneficial treaty provisions (India-Japan DTAA) permitted such refund. 1.1 The aggrieved assessee ... erred both in law and on facts in failing to adjudicate the additional ground relating to the claim of excess Dividend Distribution Tax (DDT) paid amounting to Rs.77,24,055/-. 3. The order passed by Ld. CIT(A) and Ld. AO is bad in law and against the facts

Metlife Global Operations Support Center Private Limited, New Delhi vs. Deputy Commissioner of Income-Tax Circle 16(1), New Delhi

ITA 8750/DEL/2025[2018-19]Status: DisposedITAT Delhi09 Mar 2026AY 2018-19

Bench: Ms. Madhumita Roy & Shri Amitabh Shukla, Accountnat Member [Assessment Year: 2018-19] Metlife Global Operations Deputy Commissioner Of Income Support Centre Private Limited. Tax, Circle-16(1), Paharpur Business Centre, Vs C.R. Building, I.P. Estate, 21 Nehru Place, New Delhi-110002 New Delhi-1100019 Pan-Aafcm5000N Appellant Respondent Appellant/Assessee By Shri Rajan Vohra, Adv. & Shri Lekh Mehta, Ca Respondent/Revenue By Shri Shrikant Namdeo, Cit-Dr Date Of Hearing 03.03.2026 Date Of Pronouncement 09.03.2026

Section 115Section 115OSection 143Section 143(3)

actions of the learned Assessing Officer in not considering and allowing the Appellant's additional claim for refund of excess Dividend Distribution Tax (DDT) paid by it without providing any cogent reasons; Ground of Appeal Nos. 2 and 3: Maintainability of the Appellant's additional claim: 2. was not justified ... therefore, should have been adjudicated upon; Ground of Appeal Nos. 5 and 6: Allowability of the Appellant's additional claim for refund of excess DDT - Rs. 25,85,47,626: 5. ought to have appreciated that dividend paid by the Appellant to its foreign shareholders (viz. MetLife Solutions

Tml Benefit Trust, Mumbai vs. ITO Ward 30(1)(1), Mumbai

In the result: (i) The appeal against the adjustment under section 143(1)

ITA 7826/MUM/2025[2018-19]Status: DisposedITAT Mumbai20 Feb 2026AY 2018-19

Bench: SHRI AMIT SHUKLA (Judicial Member), SHRI ARUN KHODPIA (Accountant Member)

Section 10(34)Section 115Section 143(1)Section 143(1)(a)Section 143(3)

from Tech Mahindra Limited, a domestic company. At the relevant time, dividend distributed by a domestic company was subject to Dividend Distribution Tax (DDT) in the hands of the company under section 115-O, and correspondingly the dividend income in the hands of the recipient was claimed exempt under section ... Trust, its status, and the exclusive beneficiary being TML. It clarified that the dividend was received from a domestic company which had paid DDT and that, as per the provisions applicable for the year under consideration, dividend referred to in section 115-O was exempt under section

Tml Benefit Trust, Mumbai vs. ITO 30(1)(1), Mumbai

In the result: (i) The appeal against the adjustment under section 143(1)

ITA 7756/MUM/2025[2018-19]Status: DisposedITAT Mumbai20 Feb 2026AY 2018-19

Bench: SHRI AMIT SHUKLA (Judicial Member), SHRI ARUN KHODPIA (Accountant Member)

Section 10(34)Section 115Section 143(1)Section 143(1)(a)Section 143(3)

from Tech Mahindra Limited, a domestic company. At the relevant time, dividend distributed by a domestic company was subject to Dividend Distribution Tax (DDT) in the hands of the company under section 115-O, and correspondingly the dividend income in the hands of the recipient was claimed exempt under section ... Trust, its status, and the exclusive beneficiary being TML. It clarified that the dividend was received from a domestic company which had paid DDT and that, as per the provisions applicable for the year under consideration, dividend referred to in section 115-O was exempt under section

Indian Clearing Corporation Ltd, Mumbai vs. The Addissional/Joint/Deputy/Assistant Commissioner of Income Tax, Mumbai

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

ITA 6381/MUM/2025[2018-19]Status: DisposedITAT Mumbai18 Feb 2026AY 2018-19

Bench: Shri Vikram Singh Yadav & Shri Sandeep Singh Karhailassessment Year : 2018-19 Indian Clearing Corporation Deputy Commissioner Of Ltd., Income Tax, 25Th Floor, P.J. Tower, Vs. Circle-1(2)(1), Dalal Street, Fort, Aayakar Bhavan, Mumbai-400001. Mumbai-400020. Pan : Aabci7140K (Appellant) (Respondent) For Assessee : Shri Niraj Sheth A/W. Ms. Niyati Parikh For Revenue : Shri R.A. Dhyani, Cit-Dr Date Of Hearing : 09-02-2026 Date Of Pronouncement : 18-02-2026 O R D E R Per Vikram Singh Yadav, A.M :

For Appellant: Shri Niraj Sheth a/wFor Respondent: Shri R.A. Dhyani, CIT-DR
Section 115Section 143(3)Section 72

learned Commissioner of Income tax (Appeals), NFAC erred in confirming the order of Assessment Officer of not granting credit of Dividend Distribution tax (DDT) paid of Rs.7,37,50,973/- shown in Schedule DDT of ITR 6 and charging of interest of Rs. 1,66,40,041/- u/s.115 ... spite of the fact that DDT was paid in time. 7. The appellant craves leave to add, delete, withdraw and/or modify any one/more or all the above grounds of appeal on or before the date of final hearing.” 2. Briefly, the facts of the case are that the assessment

Aditya Birla Sun Life Amc Limited, Maharashtra vs. The Deputy Commissioner of Income Tax- Circle 6(1)(1), Maharashtra

ITA 6703/MUM/2025[2023-24]Status: DisposedITAT Mumbai06 Feb 2026AY 2023-24

Bench: Shri Amit Shukla & Shri Makarand Vasant Mahadeokar1. Ita No. 6663/Mum/2025 (Assessment Year: 2017-18) 2. Ita No. 6701/Mum/2025 (Assessment Year: 2018-19) 3. Ita No. 6702/Mum/2025 (Assessment Year: 2022-23) & 4. Ita No. 6703/Mum/2025 (Assessment Year: 2023-24) Aditya Birla Sun Life Dcitcircle-6(1)(1), Amc Limited, Room No. 502, 5Th 17Th Floor, One World Vs. Floor, Aayakar Centre Tower-1, Jupiter Bhavan, M. K. Mill Compount, 841, Road, Churchgate, Senapati Bapat Marg, Mumbai-400 020 Delisle Road, S.O. Mumbai-400 013 Pan/Gir No. Aaacb6134D (Applicant) (Respondent) Assessee By Shri Ronak Doshi, Shri Shrey Agrawal & Shri Aadish Jain, Ld. Ars Revenue By Shri Surendra Mohan, Ld. Dr Date Of Hearing 27.01.2026 Date Of Pronouncement 06.02.2026

Section 142(1)Section 143(1)Section 143(2)Section 143(3)Section 144BSection 250Section 270ASection 36(1)(va)Section 40Section 43B

that the claim of deduction u/s 80G amounting to Rs. 92,31,072/- be allowed. GROUND NO. V: NON-GRANTING OF DIVIDEND DISTRIBUTION TAX (“DDT”) AMOUNTING TO RS. 10,17,96,378/- 1. On the facts and circumstances of case and in law, CIT(A) erred in upholding the action ... distribution tax paid by the Appellant amounting to Rs. 10,17,96,378/- in the computation sheet and in not granting refund of excess DDT paid amounting to Rs. 81,10,486/-. 2. The Appellant prays that the AO be directed to grant the full credit of DDT amounting

Aditya Birla Sun Life Amc Limited, Maharashtra vs. The Deputy Commissioner of Income Tax-Circle 6(1)(1), Maharashtra

ITA 6702/MUM/2025[2022-23]Status: DisposedITAT Mumbai06 Feb 2026AY 2022-23
Section 142(1)Section 143(1)Section 143(2)Section 143(3)Section 144BSection 250Section 270ASection 36(1)(va)Section 40Section 43B

that the claim of deduction u/s 80G amounting to Rs. 92,31,072/- be allowed. GROUND NO. V: NON-GRANTING OF DIVIDEND DISTRIBUTION TAX (“DDT”) AMOUNTING TO RS. 10,17,96,378/- 1. On the facts and circumstances of case and in law, CIT(A) erred in upholding the action ... distribution tax paid by the Appellant amounting to Rs. 10,17,96,378/- in the computation sheet and in not granting refund of excess DDT paid amounting to Rs. 81,10,486/-. 2. The Appellant prays that the AO be directed to grant the full credit of DDT amounting

Aditya Birla Sun Life Amc Limited, Maharashtra vs. The Deputy Commissioner of Income Tax- Circle 6 (1)(1), Maharashtra

Accordingly, this ground is allowed

ITA 6701/MUM/2025[2018-19]Status: DisposedITAT Mumbai06 Feb 2026AY 2018-19
Section 142(1)Section 143(1)Section 143(2)Section 143(3)Section 144BSection 250Section 270ASection 36(1)(va)Section 40Section 43B

that the claim of deduction u/s 80G amounting to Rs. 92,31,072/- be allowed. GROUND NO. V: NON-GRANTING OF DIVIDEND DISTRIBUTION TAX (“DDT”) AMOUNTING TO RS. 10,17,96,378/- 1. On the facts and circumstances of case and in law, CIT(A) erred in upholding the action ... distribution tax paid by the Appellant amounting to Rs. 10,17,96,378/- in the computation sheet and in not granting refund of excess DDT paid amounting to Rs. 81,10,486/-. 2. The Appellant prays that the AO be directed to grant the full credit of DDT amounting

Aditya Birla Sun Life Amc Limited, Maharashtra vs. The Deputy Commissioner of Income Tax Circle 6(1)(1), Maharashtra

Accordingly, this ground is allowed

ITA 6663/MUM/2025[2017-18]Status: DisposedITAT Mumbai06 Feb 2026AY 2017-18
Section 142(1)Section 143(1)Section 143(2)Section 143(3)Section 144BSection 250Section 270ASection 36(1)(va)Section 40Section 43B

that the claim of deduction u/s 80G amounting to Rs. 92,31,072/- be allowed. GROUND NO. V: NON-GRANTING OF DIVIDEND DISTRIBUTION TAX (“DDT”) AMOUNTING TO RS. 10,17,96,378/- 1. On the facts and circumstances of case and in law, CIT(A) erred in upholding the action ... distribution tax paid by the Appellant amounting to Rs. 10,17,96,378/- in the computation sheet and in not granting refund of excess DDT paid amounting to Rs. 81,10,486/-. 2. The Appellant prays that the AO be directed to grant the full credit of DDT amounting

Mystical Constructions Private Limited, Mumbai vs. DCIT Circle 5(2)(1), Mumbai

In the result, the appeal is Allowed

ITA 5222/MUM/2024[2011-12]Status: DisposedITAT Mumbai02 Feb 2026AY 2011-12

Bench: Shri Sandeep Gosain & Shri Girish Agrawalι.Τ.Α. No.5222/Mum/2024 A.Y: 2011-12 Mystical Pvt Ltd Constructions A 603, A1 Akbar Bldg, Pe Road, Momin Nagar, Jogeswari (W), Mumbai - 400102 Pan - Aaccn5191N (Appellant) Vs Dcit, Circle 5(2)(1) Aayakar Bhawan, Mumbai. (Respondent) Assessee By Ms. Simran Dhawan A/W Mr. Ravi Gantara Revenue By Shri Umashankar Prasad, Cit Dr Date Of Hearing 04.11.2025 Date Of Pronouncement 02.02.2026 Order Per: Shri. Sandeep Gosain, J.M.: The Present Appeal Has Been Filed By The Assessee Challenging The Impugned Order Dt. 06.08.2025 Passed Under Section 250 Of The Income Tax Act, 1961 ('The Act'), By The National Faceless Appeal Centre (Nfac) / Cit(A) For The

Section 132Section 143(3)Section 147Section 148Section 153CSection 250Section 271(1)Section 274

1 IN THE INCOME TAX APPELLATE TRIBUNAL "D" BENCH, MUMBAI BEFORE SHRI SANDEEP GOSAIN, JUDICIAL MEMBER & SHRI GIRISH AGRAWAL, ACCOUNTANT

Hari Singh, Raisen vs. ITO Raisen, Raisen

In the result “Impugned order” is set aside as and by way

ITA 536/IND/2025[2012-13]Status: DisposedITAT Indore30 Jan 2026AY 2012-13

Bench: Shri B.M. Biyani & Shri Paresh M Joshihari Singh, Ito, Raisen बनाम/ S/O Sh. Dhara Singh, 86,Vill- Vs. Semri Khurd, Tehsil- Sultanpur, Raisen,Bhopal, Mp (Pan: Aiaps1986M) (Appellant) (Respondent) Assessee By None Revenue By Shri Ashish Porwal, Sr.Dr Date Of Hearing 15.01.2026 Date Of Pronouncement 30.01.2026 आदेश/ O R D E R

Section 133(6)Section 144Section 148Section 148(2)Section 246ASection 250Section 253

आयकरअपीलीयअिधकरण, इंदौर"ायपीठ, इंदौर IN THE INCOME TAX APPELLATE TRIBUNAL INDORE BENCH, INDORE BEFORE SHRI B.M. BIYANI, ACCOUNTANT MEMBER AND