← All Phrases

“Section 143(1)”

Section References (mined)Section 143Section 143(1)13,466 judgments

The decision most relied on for Section 143(1) is Collector, Land Acquisition v. Mst. Katiji (167 ITR 471), cited in 3,926 judgments on BharatTax.

Leading authorities on Section 143(1)

Collector, Land Acquisition v. Mst. Katiji
167 ITR 471 · 1987 · Supreme Court
3,926
citing judgments

Delay in filing appeals, when supported by sufficient or justifiable cause, should be condoned with a liberal approach to ensure substantial justice. This principle prioritizes the cause of justice over mere technicalities.

CIT v. Kabul Chawla
380 ITR 573 · 2016 · High Court
3,235
citing judgments

In a search assessment under Section 153A, additions can only be made for completed or non-abated assessment years if incriminating material relevant to those years is found during the search, although notice under Section 153A(1) is mandatorily issued for six assessment years preceding the search.

Malabar Industrial Co. Ltd. v. CIT
243 ITR 83 · 2000 · Supreme Court
2,943
citing judgments

For revision under Section 263, the Assessing Officer's order must be both erroneous and prejudicial to the interests of the revenue; if either condition is not met, the revisionary jurisdiction cannot be invoked. An order is not erroneous merely because the Assessing Officer did not record the details of enquiries conducted, provided due enquiries were made.

CIT v. Manjunatha Cotton & Ginning Factory
359 ITR 565 · 2013 · High Court
2,590
citing judgments

A penalty notice issued under section 274 read with section 271(1)(c) is invalid if it fails to specify whether the penalty proceedings are initiated for concealment of income or for furnishing inaccurate particulars of income. This non-specification vitiates the penalty proceedings.

CIT v. Multiplan India Ltd.
38 ITD 320 · 1991 · ITAT
2,267
citing judgments

An appeal before the Income Tax Appellate Tribunal can be dismissed for non-prosecution or treated as unadmitted when the appellant fails to appear, cooperate, or show diligence, in accordance with Rule 19(2) of the Income-tax (Appellate Tribunal) Rules. The law aids the vigilant, not those who sleep on their rights.

CIT v. Reliance Petroproducts Pvt. Ltd.
322 ITR 158 · 2010 · Supreme Court
2,228
citing judgments

Penalty under Section 271(1)(c) for furnishing inaccurate particulars or concealment of income is not automatically leviable if the assessee has made a full disclosure of all particulars and the addition or disallowance arises from a difference of opinion.

CIT v. Reliance Utilities & Power Ltd.
313 ITR 340 · 2009 · High Court
2,118
citing judgments

Where an assessee claims that investments were made out of own funds, interest disallowance under Section 14A read with Rule 8D may not apply if the assessee demonstrates the availability of sufficient interest-free funds to cover such investments.

Estate of Late Tukojirao Holkar v. CWT
223 ITR 480 · 1997 · High Court
2,040
citing judgments

A court or tribunal is not bound to answer a reference or adjudicate an appeal on its merits if the party at whose instance the proceeding is made fails to appear at the hearing or take necessary steps for its proper conduct.

Judgments citing Section 143(1)

Infinity Towers Co Operative Housing Society Limited, Mumbai vs. ITO 22(1)(1), Mumbai

In the result, the appeal of the assessee bearing ITA No

ITA 3556/MUM/2025[2021-22]Status: DisposedITAT Mumbai25 Nov 2025AY 2021-22

Bench: Shri Vikram Singh Yadav & Shri Anikesh Banerjee

For Appellant: Ms. Neelam Jadhav a/wFor Respondent: Shri Bhagirath Ramawat, (SR.DR.)
Section 139(1)Section 143(1)Section 250Section 80PSection 80P(2)(d)Section 80P(4)

considered view the assessee filed the return of income under section 139(1) of the Act, which was subsequently processed under section 143(1). The Ld. AO disallowed the deduction claimed under section 80P of the Act Infinity Towers Co-operative Housing Society Limited in respect of interest earned from ... investments made in co-operative banks, resulting in a demand of Rs.8,19,400/–. The assessee did not notice the intimation issued under section 143(1). It was only upon receipt of a recovery notice dated 06.02.2025 that the assessee became aware of the demand. Consequently, the assessee filed appeals

Infinity Towers Co Operative Housing Society Limited, Mumbai vs. ITO -22(1)(1), Mumbai

In the result, the appeal of the assessee bearing ITA No

ITA 3555/MUM/2025[2020-21]Status: DisposedITAT Mumbai25 Nov 2025AY 2020-21

Bench: Shri Vikram Singh Yadav & Shri Anikesh Banerjee

For Appellant: Ms. Neelam Jadhav a/wFor Respondent: Shri Bhagirath Ramawat, (SR.DR.)
Section 139(1)Section 143(1)Section 250Section 80PSection 80P(2)(d)Section 80P(4)

considered view the assessee filed the return of income under section 139(1) of the Act, which was subsequently processed under section 143(1). The Ld. AO disallowed the deduction claimed under section 80P of the Act Infinity Towers Co-operative Housing Society Limited in respect of interest earned from ... investments made in co-operative banks, resulting in a demand of Rs.8,19,400/–. The assessee did not notice the intimation issued under section 143(1). It was only upon receipt of a recovery notice dated 06.02.2025 that the assessee became aware of the demand. Consequently, the assessee filed appeals

The Panchratna Co Operative Housing Society Ltd, Mumbai vs. Income Tax Officer -19(3)(1), Mumbai

In the result, the appeal of the assessee bearing ITA No

ITA 1433/MUM/2025[2013-14]Status: DisposedITAT Mumbai25 Nov 2025AY 2013-14

Bench: Shri Vikram Singh Yadav & Shri Anikesh Banerjee

For Appellant: Shri Poojan Mehta, CAFor Respondent: Shri Virabhadra Mahajan, (SR.DR.)
Section 139Section 143(1)Section 143(3)Section 147Section 148Section 194CSection 250Section 80PSection 80P(2)(d)

IN THE INCOME TAX APPELLATE TRIBUNAL MUMBAI BENCH “C”, MUMBAI BEFORE SHRI VIKRAM SINGH YADAV, ACCOUNTANT MEMBER AND SHRI ANIKESH

Baosteel India Company Private Limited, Mumbai vs. Deputy Commissioner of Income-Tax, Mumbai

Appeal is allowed for statistical purposes

ITA 6139/MUM/2024[2021-22]Status: DisposedITAT Mumbai25 Nov 2025AY 2021-22

Bench: Smt. Beena Pillai (Jm) & Shri Omkareshwar Chidara (Am) Baosteel India Company Pvt. Ltd. Dcit, Circle 1(2)(1) Unit 603, 6Th Floor, C&B Square Aayakar Bhavan Sangam Complex, Adheri Kurla Vs. M.K. Road Road, Chakala, Andheri East Churchgate Mumbai-400 059. Mumbai-400 020. Pan : Aafcb1748J Appellant Respondent

For Appellant: Shri Bhagirath RamawatFor Respondent: Shri Vishal Kalra
Section 115JSection 143(1)

appellant says that the Ld. AO/CPC has added again stating that they were not added. The appellant challenges the addition made under section 143(1) of the Act by CPC and filed all documents including Tax Audit Report and Income Tax Return, computation of Income, Financials of company

Charanjeet Singh, Panipat vs. Income Tax Officer, Ward 1, Panipat

In the result, appeal of the assessee is allowed

ITA 6387/DEL/2025[2018-19]Status: DisposedITAT Delhi25 Nov 2025AY 2018-19

Bench: Shri Satbeer Singh Godaraassessment Year: 2018-19 Sh. Charanjeet Singh, Vs. Income Tax Officer, H. No. 115, Baholi, Ward-1, Panipat Refinery, Panipat Panipat, Haryana Pan: Ddaps7473H (Appellant) (Respondent) Assessee By Sh. Suresh Gupta, Ca Department By Sh. Manoj Kumar, Sr. Dr

Section 10(37)Section 142(1)Section 143Section 143(1)(a)Section 143(2)Section 143(3)Section 263Section 28Section 56(2)(viii)Section 57

individual. He filed his return for AY 2018-19 on 29.08.2018 declaring income of Rs. 6,35,470/-. His return was processed under section 143(1)(a) on 28.06.2019. His case was selected for complete scrutiny assessment under the e- assessment Scheme, 2019 on two issues, namely refund claim ... income from other sources and claimed deduction for 50% as per section 57(iv) of the 1961 Act. The return was processed under section 143(1) of the Act. An application under section 9 | P a g e 264 was made claiming that by mistake the assessee treated the interest

Kamla Educational Trust, Deoghar vs. ITO Ward 3(3), Dumka

In the result, appeal of the assessee is allowed

ITA 265/RAN/2025[2023-2024]Status: DisposedITAT Ranchi24 Nov 2025AY 2023-2024

Bench: Shri George Mathan(Through Hybrid Mode) आयकर अपील सं./Ita No.265/Ran/2025 (निर्धारण वर्ा / Assessment Year :2023-2024) Kamla Educational Trust, Vs. Ito Ward-3(3), Dumka, C/O Prem Kumar Jharkhand Bidhu Bhushan Sarkar Road, Willams Town, Deoghar-814112 स्थायी लेखा सं./Pan No. : Aactk 9414 E (अपीलार्थी /Appellant) (प्रत्यर्थी / Respondent) ..

For Appellant: Shri P.P.Singh, ARFor Respondent: Shri Khubchand T Pandya, Sr
Section 10Section 143(1)

arithmetical mistake. As the intimation issued u/s.143(1) of the Act is not in line with the provisions of section 143(1) of the Act, the intimation issued u/s.143(1) stands quashed. 6. In the result, appeal of the assessee is allowed. Order dictated and pronounced in the open court

Chairman Florida Estate B Co Op Housing Society Limited, Pune vs. DCIT, Cir-7, Pune

In the result, appeal of the Assessee in ITA No

ITA 1986/PUN/2025[2015-16]Status: DisposedITAT Pune24 Nov 2025AY 2015-16

Bench: Shri Manish Borad & Shri Vinay Bhamore

For Appellant: Shri Subas P. Bora, CAFor Respondent: Shri Milind Debaje, JCIT –DR
Section 143(1)Section 143(1)(a)Section 154Section 250Section 80P

IN THE INCOME TAX APPELLATE TRIBUNAL PUNE “SMC” BENCH : PUNE BEFORE SHRI MANISH BORAD, ACCOUNTANT MEMBER & SHRI VINAY BHAMORE, JUDICIAL

Chairman Florida Estate B Co Op Housing Society Limited, Pune vs. Deputy Commissioner of Income Tax-Circle 7, Pune

In the result, appeal of the Assessee in ITA No

ITA 1704/PUN/2025[2015-16]Status: DisposedITAT Pune24 Nov 2025AY 2015-16

Bench: Shri Manish Borad & Shri Vinay Bhamore

For Appellant: Shri Subas P. Bora, CAFor Respondent: Shri Milind Debaje, JCIT –DR
Section 143(1)Section 143(1)(a)Section 154Section 250Section 80P

IN THE INCOME TAX APPELLATE TRIBUNAL PUNE “SMC” BENCH : PUNE BEFORE SHRI MANISH BORAD, ACCOUNTANT MEMBER & SHRI VINAY BHAMORE, JUDICIAL

Bvg Developrs, Pune vs. Income Tax Authority, Pune

In the result, both the appeals filed by the assessee are allowed for statistical purposes

ITA 1057/PUN/2025[2022-23]Status: DisposedITAT Pune24 Nov 2025AY 2022-23

Bench: Justice (Retd.) C V Bhadang & Shri R. K. Panda

For Appellant: Ms. Gauri S ManjrekarFor Respondent: Shri A D Kulkarni
Section 143(1)

IN THE INCOME TAX APPELLATE TRIBUNAL PUNE BENCH “A”, PUNE BEFORE JUSTICE (RETD.) C V BHADANG, PRESIDENT AND SHRI R

Bvg Developrs, Pune vs. Income Tax Authority, Pune

In the result, both the appeals filed by the assessee are allowed for statistical purposes

ITA 1053/PUN/2025[2023-24]Status: DisposedITAT Pune24 Nov 2025AY 2023-24

Bench: Justice (Retd.) C V Bhadang & Shri R. K. Panda

For Appellant: Ms. Gauri S ManjrekarFor Respondent: Shri A D Kulkarni
Section 143(1)

IN THE INCOME TAX APPELLATE TRIBUNAL PUNE BENCH “A”, PUNE BEFORE JUSTICE (RETD.) C V BHADANG, PRESIDENT AND SHRI R

Birlasoft Limited, Pune vs. DCIT, Circle 8, Pune

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

ITA 1116/PUN/2023[2018-19]Status: DisposedITAT Pune24 Nov 2025AY 2018-19

Bench: Shri R. K. Panda & Ms. Astha Chandraassessment Year : 2018-19 Birlasoft Limited Dcit, Circle – 8, Pune 35 & 36, Rajiv Gandhi Infotech Vs. Park, Phase-1, Midc, Hinjawadi, Pune – 411057 Pan: Aaack7308N (Appellant) (Respondent) Assessee By : Shri Kishor B Phadke Department By : Shri Amol Khairnar, Cit-Dr Date Of Hearing : 30-09-2025 Date Of Pronouncement : 24-11-2025 O R D E R Per R.K. Panda, V.P: This Appeal Filed By The Assessee Is Directed Against The Order Dated 23.08.2023 Of The Ld. Cit(A) / Nfac, Delhi Relating To Assessment Year 2018-19. 2. Facts Of The Case, In Brief, Are That The Assesse Is A Public Limited Company & Is Engaged In The Business Of Computer & Software Services. It Filed Its Return Of Income On 29.11.2018 Declaring Total Income Of Rs.95,13,15,400/-. The Return Was Processed By The Cpc & An Intimation U/S 143(1) Of The Income Tax Act, 1961 (Hereinafter Referred To As ‘The Act’) Was Passed On 25.01.2021 Determining The Total Income At Rs.1,00,23,03,750/-. The Case Was Selected For Complete Scrutiny Assessment Under The E-Assessment Scheme, 2019 On The Following Issues:

For Appellant: Shri Kishor B PhadkeFor Respondent: Shri Amol Khairnar, CIT-DR
Section 10ASection 10A(3)Section 143(1)Section 143(2)Section 27Section 36(1)(va)Section 51Section 80ISection 90

IN THE INCOME TAX APPELLATE TRIBUNAL PUNE BENCH “A”, PUNE BEFORE SHRI R. K. PANDA, VICE PRESIDENT AND MS. ASTHA

Jai Kankaria Foundation, Kolkata vs. ITO, Ward 1(1), Exempt, Kolkata

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

ITA 2146/KOL/2025[2019-2020]Status: DisposedITAT Kolkata24 Nov 2025AY 2019-2020

Bench: Shri George Mathan & Shri Rakesh Mishraआयकर अपील सं/Ita No.2146/Kol/2025 (निर्धारण वर्ा / Assessment Year : 2019-2020) Jai Kankaria Foundation Vs Cpc, Bangalore/ 5, Middleton Street, Kolkata Ito Ward-1(1), Exempt, Kolkata Pan No. :Aaatj 2147 F (अपीलधर्थी /Appellant) .. (प्रत्यर्थी / Respondent) निर्धाररती की ओर से /Assessee By Shri Soumitra Choudhury & Shri Pranobesh Sarkar, Advocates रधजस्व की ओर से /Revenue By : Shri Sandeep Kumar Mehta, Sr. Dr सुनवाई की तारीख / Date Of Hearing : 24/11/2025 घोषणा की तारीख/Date Of Pronouncement : 24/11/2025 आदेश / O R D E R Per George Mathan, Jm : This Is An Appeal Filed By The Revenue Against The Order Of The Ld. Addl/Cit(A)-7, Delhi, Dated 14.07.2025 For The Assessment Year 2019-2020 2. It Was Submitted By The Ld. Ar That The Appeal Of The Assessee Has Been Dismissed By The Ld.Cit(A) On Account Of Delay Of 28 Days. In This Regard, Ld. Ar Drew Our Attention To The Judgment Of The Hon’Ble Supreme Court In Miscellaneous Application No.21 Of 2022 In Suo Motu Writ Petition (C) No.3 Of 2020, Dated 10.01.2022, Wherein The Hon’Ble Supreme Court Has Directed To Exclude The Period Of Limitation For The Period As Mentioned In The Said Judgment On Account Of Covid-19. The Relevant Observations Of The Hon’Ble Supreme Court Are As Under :- 4. The Present Miscellaneous Application Has Been Filed By The Supreme Court Advocates-On-Record Association In The Context Of The Spread Of The New Variant Of The Covid-19 & The Drastic Surge In The Number Of Covid Cases Across The Country. Considering The Prevailing Conditions, The Applicants Are Seeking The Following:

For Respondent: Shri Sandeep Kumar Mehta, Sr. DR
Section 12ASection 138Section 143(1)

IN THE INCOME TAX APPELLATE TRIBUNAL “B” BENCH, KOLKATA BEFORE SHRI GEORGE MATHAN, JUDICIAL MEMBER AND SHRI RAKESH MISHRA, ACCOUNTANT

Lakshmisha Bhandary, Mangaluru vs. Deputy Commissioner of Income Tax, Central Circle - 1, Mangaluru

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

ITA 907/BANG/2025[2022-23]Status: DisposedITAT Bangalore24 Nov 2025AY 2022-23

Bench: Shri Waseem Ahmed & Shri Soundararajan K.Assessment Year : 2022-23

For Appellant: Dr. B S N Prasad, AdvocateFor Respondent: Shri Balusamy N, JCIT-DR
Section 133ASection 142(1)Section 143(1)Section 143(2)Section 144

IN THE INCOME TAX APPELLATE TRIBUNAL ‘A’ BENCH : BANGALORE BEFORE SHRI WASEEM AHMED, ACCOUNTANT MEMBER AND SHRI SOUNDARARAJAN K., JUDICIAL

Intact Developers Private Limited, Bangalore vs. DCIT, Central Circle-1(2), Bangalore

ITA 825/BANG/2025[2017-18]Status: DisposedITAT Bangalore24 Nov 2025AY 2017-18

Bench: Shri Waseem Ahmed & Shri Keshav Dubey

Section 143(2)Section 144Section 148Section 234ASection 250

Clause (b) of Section 158 BC by referring to Section 143(2) and (3) would appear to imply that the provisions of Section 143(1) are excluded. But Section 143(2) itself becomes necessary only where it becomes necessary to check the return, so that where block return conforms

Intact Developers Private Limited, Bangalore vs. DCIT, Central Circle-1(2), Bangalore

ITA 824/BANG/2025[2016-17]Status: DisposedITAT Bangalore24 Nov 2025AY 2016-17

Bench: Shri Waseem Ahmed & Shri Keshav Dubey

For Appellant: Sri Zain Ahmed Khan, A.RFor Respondent: Sri Balusamy N, D.R
Section 143(2)Section 144Section 148Section 234ASection 250

Clause (b) of Section 158 BC by referring to Section 143(2) and (3) would appear to imply that the provisions of Section 143(1) are excluded. But Section 143(2) itself becomes necessary only where it becomes necessary to check the return, so that where block return conforms

Intact Developers Private Limited, Bangalore vs. DCIT, Central Circle-1(2), Bangalore

ITA 823/BANG/2025[2015-16]Status: DisposedITAT Bangalore24 Nov 2025AY 2015-16

Bench: Shri Waseem Ahmed & Shri Keshav Dubey

For Appellant: Sri Zain Ahmed Khan, A.RFor Respondent: Sri Balusamy N, D.R
Section 143(2)Section 144Section 148Section 234ASection 250

Clause (b) of Section 158 BC by referring to Section 143(2) and (3) would appear to imply that the provisions of Section 143(1) are excluded. But Section 143(2) itself becomes necessary only where it becomes necessary to check the return, so that where block return conforms

Mandhatasinhji Manoharsinhji Jadeja, Mumbai vs. The Circle 19(1), Mumbai

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

ITA 5579/MUM/2025[2021-22]Status: DisposedITAT Mumbai24 Nov 2025AY 2021-22

Bench: Ms. Kavitha Rajagopal, Jm & Smt. Renu Jauhri, Am Mandhatasinhji M. Jadeja Circle 19(1), Mumbai 12, Floor-5, 51 – Narendra Bhuvan, Vs. Cumballa Hill, Mumbai.

For Appellant: Shri Viraj Mehta, CA (Virtually appear)For Respondent: Shri Ritesh Misra, CIT DR
Section 115BSection 143(1)Section 143(2)Section 143(3)Section 250Section 68

IN THE INCOME TAX APPELLATE TRIBUNAL “E” BENCH, MUMBAI BEFORE MS. KAVITHA RAJAGOPAL, JM AND SMT. RENU JAUHRI, AM Mandhatasinhji

Bahri Auto Service, Mumbai vs. CIT (Appeals), Delhi

In the result, the addition so sustained by the Ld

ITA 3479/MUM/2025[2015-16]Status: DisposedITAT Mumbai24 Nov 2025AY 2015-16

Bench: Shri Vikram Singh Yadav & Shri Sandeep Singh Karhailassessment Year : 2015-16 Bahri Auto Service, Cit(Appeals) Plot No. 2, National Faceless Appeal Centre Sion Trombay Road, Vs. (Nfac), Chembur, Delhi-110001. Mumbai-400071. Pan : Aaofb2961P (Appellant) (Respondent) Assessee By : Shri Anil Bhasin Revenue By : Shri Pravin Salunkhe, Sr.Dr Date Of Hearing : 20-11-2025 Date Of Pronouncement : 24-11-2025 O R D E R Per Vikram Singh Yadav, A.M : This Is An Appeal Filed By The Assessee Against The Order Of The Learned Commissioner Of Income Tax (Appeals)-National Faceless Appeal Centre (Nfac), Delhi [„Ld.Cit(A)‟], Dated 19-03-2025, Pertaining To Assessment Year (Ay) 2015-16. 2. Briefly The Facts Of The Case Are That Case Of The Assessee Firm Was Reopened Basis Information That The Assessee-Firm Has Made Certain Cash Deposit In Its Bank Account Maintained With Bank Of Baroda & Fail To File Its Return Of Income For The Impugned Assessment Year. Thereafter, After Issuance Of Notice & Calling For The Necessary Information & Documentation, The Assessment Proceedings Were Completed U/S. 147 R.W.S. 144 R.W.S. 144B Of The Income Tax Act, 1961 („The Act‟), Vide Order Dt.

For Appellant: Shri Anil BhasinFor Respondent: Shri Pravin Salunkhe, Sr.DR
Section 147

IN THE INCOME TAX APPELLATE TRIBUNAL MUMBAI “H(SMC)” BENCH : MUMBAI BEFORE SHRI VIKRAM SINGH YADAV, ACCOUNTANT MEMBER AND SHRI

Smt. Indubala Jayant Jain, Mumbai vs. I.T.O Ward, 17(2)(1), Mumbai

In the result, the appeal of the assessee bearing ITA No

ITA 4953/MUM/2024[2010-11]Status: DisposedITAT Mumbai24 Nov 2025AY 2010-11

Bench: Shri. Vikram Singh Yadav & Shri. Anikesh Banerjee

For Appellant: Shri G. P. Mehta, CAFor Respondent: Shri Virabhadra Mahajan, (SR.DR.)
Section 124Section 143(1)Section 143(3)Section 148Section 250Section 255(5)

IN THE INCOME TAX APPELLATE TRIBUNAL MUMBAI BENCH “C”, MUMBAI BEFORE SHRI. VIKRAM SINGH YADAV, ACCOUNTANT MEMBER AND SHRI. ANIKESH

Abdul Hamid Abdul Majid Nathani, Mumbai vs. ACIT 22(1), Mumbai, Maharashtra

In the result, the appeal by the assessee is allowed

ITA 2528/MUM/2024[2012-13]Status: DisposedITAT Mumbai24 Nov 2025AY 2012-13

Bench: Shri Sandeep Singh Karhailshri Girish Agrawalabdul Hamid Abdul Majid Nathani Flat No.3102, 31St Floor Kalapataru Heights, Dr. A.L. Nair Road Agripada, Mumbai - 400011 ............... Appellant Pan: Aabpn1625K V/S Assistant Commissioner Of Income Tax, – 22(1), Mumbai ……………… Respondent Mumbai.

For Appellant: Shri Dharan GandhiFor Respondent: Shri Surendra Mohan, Sr.DR
Section 142(1)Section 143(1)Section 143(2)Section 147Section 148Section 250Section 3Section 68

declaring a total income of INR 26,50,900. The return filed by the assessee was processed vide intimation dated 16/01/2013 issued under section 143(1) of the Act. Subsequently, on the basis of the information received from the DDIT (Investigation), Unit-8(3), Mumbai that the assessee has received