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“Section 139(1)”

Section References (mined)Section 139Section 139(1)7,818 judgments

The decision most relied on for Section 139(1) is CIT v. Manjunatha Cotton & Ginning Factory (359 ITR 565), cited in 2,590 judgments on BharatTax.

Leading authorities on Section 139(1)

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.

Goetze (India) Ltd. v. CIT
284 ITR 323 · 2006 · Supreme Court
1,842
citing judgments

An assessee cannot raise a new claim or a claim not made in the original or revised return of income for the first time directly before the Assessing Officer during assessment proceedings.

CIT v. Kelvinator of India Ltd.
320 ITR 561 · 2010 · Supreme Court
1,673
citing judgments

An Assessing Officer cannot initiate reassessment proceedings under Section 147 of the Income Tax Act based on a mere change of opinion. Reassessment is permissible only when there is fresh tangible material leading to the belief of income escapement, not merely a review of existing facts.

CIT v. AIMIL Ltd.
321 ITR 508 · 2010 · High Court
1,629
citing judgments

Employee contributions to PF and ESIC, deposited beyond the due date under the respective Acts but within the due date for filing the income tax return under Section 139(1), are allowable deductions under Section 36(1)(va). Such disallowance cannot be made during processing under Section 143(1).

Checkmate Services Pvt. Ltd. v. CIT
143 Taxmann.com 178 · 2022 · Supreme Court
1,392
citing judgments

Employee contributions to provident fund and ESI deposited by an employer beyond the due dates prescribed under the respective special Acts are not allowable as a deduction under section 36(1)(va) of the Income-tax Act, 1961. Such disallowance can be made during processing under section 143(1).

CIT v. Gujarat State Road Transport Corporation
366 ITR 170 · 2014 · High Court
1,158
citing judgments

Employees' contributions to welfare funds, such as provident fund, are not allowable as a deduction under section 36(1)(va) if deposited beyond the due date prescribed under the respective welfare statutes, even by a single day. Such delayed deposits are not cured even if made before the income-tax return filing due date.

CIT v. Pruthvi Brokers & Shareholders
349 ITR 336 · 2012 · High Court
956
citing judgments

Appellate authorities can entertain fresh claims or revised computations of income made by an assessee, even if these were not submitted through a revised return of income.

CIT v. SSA’s Emerald Meadows
73 Taxmann.com 241 · 2016 · High Court
791
citing judgments

A penalty notice under section 271(1)(c) read with section 274 of the Income Tax Act is invalid if it fails to specify whether the penalty is for concealment of income or for furnishing incorrect particulars of income.

Judgments citing Section 139(1)

Asst. Commissioner of Income Tax, Vikash Bhwan Delhi vs. Sumit Chhabra, Delhi

The appeal of the assessee is allowed and appeal of the Revenue is dismissed as infructuous

ITA 3879/DEL/2024[2018-19]Status: DisposedITAT Delhi29 Aug 2025AY 2018-19

Bench: Ms. Madhumita Roy & Shri Naveen Chandrasumit Chhabra Vs. Assessment Unit, Nafac, Hno. 3, Kiran Vihar, Vikas Bhawan Karkardooma,, Anand Delhi Vihar, S.O. Anand Vihar East Delhi – 110092 "थायीलेखासं./जीआइआरसं./Pan/Gir No: Aecpc8652G Appellant .. Respondent Acit, Vikash Bhawan Vs. Sumit Chhabra Room No. 216, 2Nd Floor, H. No. 3, Kiran Vihar, D Block, Vikash Bhawan, Karkardooma, I.P. Estate, Delhi Delhi – 110092 110002 "थायीलेखासं./जीआइआरसं./Pan/Gir No: Aecpc8652G Appellant .. Respondent

For Appellant: Sh. Gaurav Jain, AdvFor Respondent: Sh. Manish Gupta, Sr. DR
Section 139(1)Section 147Section 148ASection 69C

r.w.s 144B of the Income Tax Act for Assessment Years 2018-19. 2. The assessee, an individual filed its return of income under Section 139(1) of the Act dated 02.11.2018 for Assessment Year 2018-19 declaring total income at Rs.18,15,750/-. Subsequently, on the basis of information received

Sumit Chhabra, Kiran Vihar, East Delhi vs. Assessment Unit, Nafac, Vikas Bhawan Delhi

The appeal of the assessee is allowed and appeal of the Revenue is dismissed as infructuous

ITA 3556/DEL/2024[2018-19]Status: DisposedITAT Delhi29 Aug 2025AY 2018-19

Bench: Ms. Madhumita Roy & Shri Naveen Chandrasumit Chhabra Vs. Assessment Unit, Nafac, Hno. 3, Kiran Vihar, Vikas Bhawan Karkardooma,, Anand Delhi Vihar, S.O. Anand Vihar East Delhi – 110092 "थायीलेखासं./जीआइआरसं./Pan/Gir No: Aecpc8652G Appellant .. Respondent Acit, Vikash Bhawan Vs. Sumit Chhabra Room No. 216, 2Nd Floor, H. No. 3, Kiran Vihar, D Block, Vikash Bhawan, Karkardooma, I.P. Estate, Delhi Delhi – 110092 110002 "थायीलेखासं./जीआइआरसं./Pan/Gir No: Aecpc8652G Appellant .. Respondent

For Appellant: Sh. Gaurav Jain, AdvFor Respondent: Sh. Manish Gupta, Sr. DR
Section 139(1)Section 147Section 148ASection 69C

r.w.s 144B of the Income Tax Act for Assessment Years 2018-19. 2. The assessee, an individual filed its return of income under Section 139(1) of the Act dated 02.11.2018 for Assessment Year 2018-19 declaring total income at Rs.18,15,750/-. Subsequently, on the basis of information received

Srg Custodians and Securities (India) Ltd., Guwahati vs. DCIT Central Circle 31, New Delhi

ITA 1460/DEL/2024[2021-22]Status: DisposedITAT Delhi29 Aug 2025AY 2021-22

Bench: Ms. Madhumita Roy & Shri Naveen Chandra

For Appellant: Sh. Sanjay Garg, CAFor Respondent: Sh. Mahesh Kumar, CIT, DR
Section 132(4)Section 139(1)Section 142(1)Section 143(2)Section 143(3)Section 153CSection 69C

assessee is an individual having income from house property and other sources during the year under consideration filed return of income under Section 139(1) of the Act on 16.03.2022 declaring income at Rs.68,49,230/-. Subsequently, the case of the assessee was selected for scrutiny and notice under Section

Sita Gupta, Jalaun vs. DCIT Central Circle-31, New Delhi

ITA 1454/DEL/2024[2021-22]Status: DisposedITAT Delhi29 Aug 2025AY 2021-22

Bench: Ms. Madhumita Roy & Shri Naveen Chandra

For Appellant: Sh. Sanjay Garg, CAFor Respondent: Sh. Mahesh Kumar, CIT, DR
Section 132(4)Section 139(1)Section 142(1)Section 143(2)Section 143(3)Section 153CSection 69C

assessee is an individual having income from house property and other sources during the year under consideration filed return of income under Section 139(1) of the Act on 16.03.2022 declaring income at Rs.68,49,230/-. Subsequently, the case of the assessee was selected for scrutiny and notice under Section

DCIT, CC-06, New Delhi vs. Jatin Madani, Delhi

The appeal of the Revenue is dismissed

ITA 2033/DEL/2021[2015-16]Status: DisposedITAT Delhi29 Aug 2025AY 2015-16

Bench: SHRI ANUBHAV SHARMA (Judicial Member), SHRI AMITABH SHUKLA (Accountant Member)

For Appellant: Shri Mayank Patawari, Advocate &For Respondent: Ms Monika Singh, CIT-DR
Section 147Section 148Section 149Section 150Section 153ASection 68Section 69

IN THE INCOME TAX APPELLATE TRIBUNAL DELHI BENCHES: F : NEW DELHI BEFORE SHRI ANUBHAV SHARMA, JUDICIAL MEMBER AND SHRI AMITABH

Brahtakar Krishi Sakh Sahakari Samiti Maryadit, Sahajpur vs. Income Tax Officer Ward 1(2), Jabalpur

In the result, all the three appeals in ITA Nos

ITA 151/JAB/2025[2015-16]Status: DisposedITAT Jabalpur28 Aug 2025AY 2015-16

Bench: SH. KUL BHARAT, VICE PRESIDENT AND SH. NIKHIL CHOUDHARY (Accountant Member)

For Appellant: Sh. Sapan Usrethe, Advocate & ShFor Respondent: Sh. Alok Bhura, Sr. DR
Section 143(2)Section 147Section 148Section 250Section 80P

respective assessment years. In the assessment year 2014-15, as the assessee filed its return beyond the due date laid down under section 139(1), the ld. AO disallowed the net loss of Rs.27,488/- claimed by the assessee. A.Ys. 2013-14 to 2015-16 Brahtakar Krishi Sakh Sahkari Samiti ... There is no conditionality in the same that the return had to be filed before the due date as laid down in section 139(1). Infact such provisions are now reflected in 80AC, as it was amended w.e.f. 1.04.2018. Prior to its substitution, section 80AC, as inserted by the Finance

Brahtakar Krishi Sakh Sahakari Samiti Maryadit, Sahajpur vs. Income Tax Officer Ward 1(2), Jabalpur

In the result, all the three appeals in ITA Nos

ITA 149/JAB/2025[2013-14]Status: DisposedITAT Jabalpur28 Aug 2025AY 2013-14

Bench: SH. KUL BHARAT, VICE PRESIDENT AND SH. NIKHIL CHOUDHARY (Accountant Member)

For Appellant: Sh. Sapan Usrethe, Advocate & ShFor Respondent: Sh. Alok Bhura, Sr. DR
Section 143(2)Section 147Section 148Section 250Section 80P

respective assessment years. In the assessment year 2014-15, as the assessee filed its return beyond the due date laid down under section 139(1), the ld. AO disallowed the net loss of Rs.27,488/- claimed by the assessee. A.Ys. 2013-14 to 2015-16 Brahtakar Krishi Sakh Sahkari Samiti ... There is no conditionality in the same that the return had to be filed before the due date as laid down in section 139(1). Infact such provisions are now reflected in 80AC, as it was amended w.e.f. 1.04.2018. Prior to its substitution, section 80AC, as inserted by the Finance

Jabalpur Entertainment Complexes Private Limited, Jabalpur vs. DCIT, CPC, Bengaluru & DCIT, Circle 2(1), Jabalpur

In the result, the appeal is allowed for statistical purposes

ITA 184/JAB/2024[2023-24]Status: DisposedITAT Jabalpur28 Aug 2025AY 2023-24

Bench: SH. KUL BHARAT, VICE PRESIDENT AND SH. NIKHIL CHOUDHARY (Accountant Member)

For Appellant: Sh. Apoorva Rajesh Mehta, C.AFor Respondent: Sh. Alok Bhura, Sr. DR
Section 115BSection 143(1)Section 250

twin condition of furnishing a declaration before the ld. AO and before the due date of filing the original return of income under section 139(1) are to be satisfied and both are 4 A.Y. 2023-24 Jabalpur Entertainment Complexes P. Ltd. mandatorily to be complied with. Relying upon ... conditions were satisfied. i. The return of income for the relevant year had been filed on or before the due date specified under section 139(1) of the Act. ii. The assessee company had opted for taxation under section 115BAA of the Act in Item (E) ‘filing status’ in PART

Ishar Infrastructure Develpopers Private Limited, Bathinda vs. Deputy Commissioner of Income Tax Circle-1, Bathinda

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

ITA 686/ASR/2024[2022-23]Status: DisposedITAT Amritsar28 Aug 2025AY 2022-23

Bench: Sh. Manoj Kumar Aggarwal & Sh. Udayan Dasgupta(Hybrid Hearing) I.T.A. No. 686/Asr/2024 Assessment Year: 2022-23

Section 139(1)Section 143(1)Section 250Section 32(2)Section 72Section 72(3)

IN THE INCOME TAX APPELLATE TRIBUNAL AMRITSAR BENCH, AMRITSAR. BEFORE SH. MANOJ KUMAR AGGARWAL, ACCOUNTANT MEMBER AND SH. UDAYAN DASGUPTA

Ajay Aggarwal, Amritsar vs. Ward 2(1), Amritsar, New C R Building

In the result, the appeal filed by the assessee is allowed as indicated above

ITA 627/ASR/2024[2023-24]Status: DisposedITAT Amritsar28 Aug 2025AY 2023-24

Bench: Sh. Manoj Kumar Aggarwal & Sh. Udayan Dasgupta

For Appellant: Sh. J. P. Bhatia, Adv
Section 115BSection 139(1)Section 143(1)Section 250

Without prejudice to the above, the Form 101E, filed by the appellant for AY 2021-22 was beyond the due date specified by Section 139(1). Thus, there was violation of the provisions of Section 115BAC(5) (i) of the Act. It may be mentioned that the appellant had offered

Tanuja Chhatoi, Cuttack vs. Income Tax Officer, Ward-1(1), Cuttack

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

ITA 223/CTK/2025[2016-17]Status: DisposedITAT Cuttack28 Aug 2025AY 2016-17

Bench: Shri Duvvuru Rl Reddy & Shri Rajesh Kumar(Through Virtual Hearing At Kolkata ) आयकर अपील सं/Ita No.223/Ctk/2025 (नििाारण वर्ा / Assessment Year : 2016-2017) Tanuja Chhatoi, Vs Ito, Ward-1(1), Cuttack Balabhadrapur, Chhatra Bazar, Arunodaya Market, Cuttack Pan No. :Afjpc 8959 E (अपीलार्थी /Appellant) (प्रत्यर्थी / Respondent) .. नििााररती की ओर से /Assessee By : Shri Ambika Prasad Mohanty, Ca राजस्व की ओर से /Revenue By : Shri Vijay Singh, Sr. Dr सुनवाई की तारीख / Date Of Hearing : 21/08/2025 घोषणा की तारीख/Date Of Pronouncement : 28/08/2025 आदेश / O R D E R

For Appellant: Shri Ambika Prasad Mohanty, CAFor Respondent: Shri Vijay Singh, Sr. DR
Section 139(1)Section 147Section 44ASection 69A

आयकर अपीलीय अधिकरण, कटक न्यायपीठ,कटक IN THE INCOME TAX APPELLATE TRIBUNAL CUTTACK BENCH CUTTACK BEFORE SHRI DUVVURU RL REDDY

Inder Kumar Nigotiya, Jaipur vs. ITO Ward, 1 (1), Jaipur

The appeal of the assessee is allowed

ITA 1011/JPR/2025[2017-2018]Status: DisposedITAT Jaipur28 Aug 2025AY 2017-2018

Bench: SHRI RATHOD KAMLESH JAYANTBHAI (Accountant Member), SHRI NARINDER KUMAR (Judicial Member)

For Appellant: Sh. Rajeev Sogani, CAFor Respondent: Sh. Gautam Singh Choudhary, JCIT
Section 115BSection 139(1)Section 143(2)Section 143(3)Section 69A

आयकर अपीलीय अधिकरण] जयपुर न्यायपीठ] जयपुर IN THE INCOME TAX APPELLATE TRIBUNAL, JAIPUR BENCHES,”SMC” JAIPUR Jh jkBkSM+ deys'k

G.S.Express Pvt.Ltd, Lucknow vs. DCIT-CC-2, Lucknow

In the result, the appeal is held to be partly allowed

ITA 633/LKW/2024[2018-19]Status: DisposedITAT Lucknow28 Aug 2025AY 2018-19

Bench: Sh. Sudhanshu Srivastava & Sh. Nikhil Choudharya.Y. 2018-19 G.S. Express Private Ltd., C-877 Vs. The D. Commissioner Of Income Mahanagar, Lucknow Tax, P.K. Complex, Ram Mohan Rai Marg, Lucknow Pan: Aaccg5655J (Appellant) (Respondent) Assessee By: Sh. Shubham Rastogi, C.A. Revenue By: Sh. Amit Kumar, Dr Date Of Hearing: 29.07.2025 Date Of Pronouncement: 28.08.2025 O R D E R Per Nikhil Choudhary, A.M.: This Is An Appeal Filed By The Assessee Against The Order Of The Ld. Cit(A)-3, Lucknow Under Section 250 Of The Income Tax Act, 1961, Dismissing The Appeal Of The Assessee Against The Orders Of The Ld. Ao, Imposing A Penalty Under Section 271B On 29.03.2022. The Grounds Of Appeal Are As Under: - “1-That The Ld. C.I.T. (A)-3, Lucknow Erred On Facts & In Law In Not Considering That The Show Cause Notice U/S 271B Of 1. T. Act Dated 31.12.2019, Did Not Specify That Whether The Penalty Is For Failure To Get Accounts Audited Or Failure To Furnish The Report & Thus Non Striking Of Irrelevant Clause Renders The Penalty Notice Invalid As Also The Consequential Penalty Order As Illegal & Liable To Be Quashed. Without Prejudice To Above 2-That The Ld. C.I.T. (A) Erred On Facts & In Law In Confirming Penalty Of Rs. 1,50,000/- U/S 2718 Of 1. T. Act, Without Appreciating That There Was A Reasonable Cause For Delay In Audit & Obtaining Report U/S 44Ab Of It Act As Due To Search & Seizure On 01.02.2018 The Entire Records Were Seized By Investigation Wing. 3-That The Ld. C.I.T. (A) Did Not Appreciate That Books Of Accounts & Related Records Were Seized By Investigation Wing & Only After Obtaining Copy Of Seized Documents

For Appellant: Sh. Shubham Rastogi, C.AFor Respondent: Sh. Amit Kumar, DR
Section 132Section 139Section 250Section 271Section 271BSection 44A

taxman.com 118 (Pune-Trib) where the assessee was unable to get his accounts audited on or before the due date prescribed under section 139(1), due to the fact that his documents had been impounded during a survey and there was a lapse on the part of the Chartered Accountant

Attak Machinery Private Limited, Kanpur vs. Deputy Commissioner of Incometax, Circle-1, Kanpur

In the result, the appeal of the assessee is partly allowed

ITA 134/LKW/2024[2022-23]Status: DisposedITAT Lucknow28 Aug 2025AY 2022-23

Bench: SH. KUL BHARAT, VICE PRESIDENT AND SH. NIKHIL CHOUDHARY (Accountant Member)

For Appellant: Sh. B.P. Yadav, AdvocateFor Respondent: Sh. Deepak Yadav, DR
Section 115Section 115BSection 143(1)Section 154Section 250

were satisfied. i. The return of income for the relevant assessment year had been filed on or before the due date specified under section 139(1) of the Act. ii. The assessee company had opted for taxation under section 115 BAA of the Act in item (e) of ‘filing status

ACIT Anand Circle, Anand vs. Elecon Engineering Company Ltd, Vallabh Vidyanagar

In the result, appeal filed by the Revenue is dismissed

ITA 2084/AHD/2024[2020-21]Status: DisposedITAT Ahmedabad28 Aug 2025AY 2020-21

Bench: Us.

For Appellant: Smt. Kakoli Uttam Ghosh, Sr. DRFor Respondent: Shri M. K. Patel, Advocate
Section 139(1)Section 139(4)Section 143(1)Section 154Section 250Section 32(2)

that section 80 requires that return be filed as per section 139(3) to carry forward losses within due date as envisaged under section 139(1). However, section 32(2) is not included within ambit of section 80. 12. Further, reliance also placed on decision of Delhi High Court

Arusuvai Food Processors Pvt. Ltd., Salem vs. DCIT, Circle-1(1), Salem

In the result, appeal filed by the assessee is allowed

ITA 416/CHNY/2025[2017-18]Status: DisposedITAT Chennai28 Aug 2025AY 2017-18

Bench: Shri Aby T. Varkey & Shri Jagadish

For Appellant: Mr.D. Anand, Advocate
Section 133(6)Section 142(1)Section 143(3)Section 264Section 270ASection 270A(1)Section 270A(9)(a)Section 270A(9)(c)Section 271Section 41(1)

आयकर अपीलीय अिधकरण, ‘ए’ "यायपीठ, चे"ई। IN THE INCOME TAX APPELLATE TRIBUNAL ‘A’ BENCH: CHENNAI "ी एबी टी. वक", "ाियक

Krishnamurthy L/R by Smt. Nagarathnamma, Bangalore vs. DCIT, Circle-2(1), Bangalore

In the result, appeal filed by the assessee is allowed

ITA 570/BANG/2025[2012-13]Status: DisposedITAT Bangalore28 Aug 2025AY 2012-13

Bench: Shri Laxmi Prasad Sahu & Shri Soundararajan Kassessment Year : 2012-13 Shri. Krishnamurthy, Vs. Dcit, Represented By His Lr Smt. Nagarathnamma, Circle –2(1), No.152, 2Nd Floor, Hanuman Chambers, Bangalore. 7Th Cross, 2Nd Main, Chamarajpet, Bangalore – 560 018. Pan : Admpk 2463 J Appellant Respondent Assessee By : Shri. Ravishankar S. V, Advocate Revenue By : Shri. Balusamy N, Jcit(Dr)(Itat), Bangalore. Date Of Hearing : 22.07.2025 Date Of Pronouncement : 28.08.2025

For Appellant: Shri. Ravishankar S. V, AdvocateFor Respondent: Shri. Balusamy N, JCIT(DR)(ITAT), Bangalore
Section 139(1)Section 139(9)Section 140ASection 143(1)Section 143(2)Section 148Section 292B

appellant and the respondent. 7. The assessment which is subject matter of this appeal is for the assessment year 1986-87. Section 139 (1) of the Act provides for filing of a return by an assessee if his total income during the previous year exceeds the maximum amount which ... assessee had failed to file the return. The C.B.D.T. has rightly directed that in case where the return is furnished voluntarily under Section 139 (1), the I.T.O. cannot proceed to make ex parte assessment under Section 144 without serving notice under Section 139(2) or as the case

Nagamma, Raichur vs. Income Tax Office-Ward 1, Raichur

ITA 549/BANG/2025[2018-19]Status: DisposedITAT Bangalore28 Aug 2025AY 2018-19

Bench: Shri Laxmi Prasad Sahu & Shri Soundararajan K

Section 142(1)Section 143(2)Section 148Section 54BSection 54FSection 54F(2)

ground that he did not deposit the said amount in capital gains account scheme before the due date prescribed under Section 139(1) of the IT Act?" 4. Re.Point No. 1 Section 54(F) deals with capital gains on transfer of certain capital assets not to be charged in case

Yellapragada Srinivasa Sankara Narayana, Bangalore vs. ACIT, International Circle 1(2), Bangalore

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

ITA 3/BANG/2025[2021-22]Status: DisposedITAT Bangalore28 Aug 2025AY 2021-22

Bench: Shri Laxmi Prasad Sahu & Shri Soundararajan Kassessment Year : 2021-22 Shri. Yellapragada Srinivasa Sankara Narayana, Vs. Acit, 666, 2Nd Phase, 7Th Block, Bsk 3Rd Stage, International Taxation, Bangalore – 560 085. Circle – 1(2), Pan : Accpn 8746 L Bangalore. Appellant Respondent Assessee By : Shri. Prathik P,Advocate Revenue By : Shri.Sankar Ganesh D, Addl. Cit(Dr)(Itat), Bangalore. Date Of Hearing : 12.08.2025 Date Of Pronouncement : 28.08.2025

For Appellant: Shri. Prathik P,AdvocateFor Respondent: Shri.Sankar Ganesh D, Addl. CIT(DR)(ITAT), Bangalore
Section 139(1)Section 139(5)Section 154Section 45

declaring income of Rs.2,18,34,470/- claiming refund of Rs.9,210/-. On 02.11.2021, the CPC processed return filed under section 139(1) of the Act and raised a demand of Rs.1,430/-. On 23.02.2022 Page 2 of 4 assessee filed second revised return declaring the taxable income of Rs.45

Pavan Vitthal Gaikwad, Mumbai vs. Principal Commissioner of Income Tax, Mumbai

ITA 3527/MUM/2025[2020-21]Status: DisposedITAT Mumbai28 Aug 2025AY 2020-21

Bench: SHRI VIKRAM SINGH YADAV, ACCOUNTANT MEMBER SHRI RAHUL CHAUDHARY (Judicial Member)

For Appellant: Shri. R. A. Dhyani, CIT DRFor Respondent: None
Section 143(3)Section 144BSection 263Section 263(1)Section 56(2)Section 56(2)(X)Section 56(2)(x)

IN THE INCOME TAX APPELLATE TRIBUNAL “C” BENCH, MUMBAI SHRI VIKRAM SINGH YADAV, ACCOUNTANT MEMBER SHRI RAHUL CHAUDHARY, JUDICIAL MEMBER