AMERICAN CHEMICAL SOCIETY,USA V. DCIT (INTERNATIONAL TAX), CIRCLE 1(1)(1), MUMBAI

ITA 1603/MUM/2025

AI Insights

The case involves the American Chemical Society appealing against the final assessment order by the Deputy Commissioner of Income-tax (International Tax), which assessed the total income of the appellant at INR 1,47,44,58,663 as opposed to the returned income of nil. The primary contention was whether the subscription charges received from Indian customers for the CAS and PUBS divisions were chargeable to tax as royalty under Article 12(3) of the India-US DTAA and Section 9(1)(vi) of the Income-tax Act. The tribunal referenced previous rulings in favor of the appellant for similar assessment years, highlighting that the business model and revenue streams had not changed, and thus, the principle of consistency applied.

• Counselvise Citation: [2025] 140 COUNSELVISE.COM (IT) 784237 (ITAT-MUMBAI)
• Duration Of Justice: 8 month(s) 7 day(s)
• Appeal Type: Income Tax Appeal
• Pronouncement Date: 13-11-2025
• Appeal Filed By: Assessee
• Order Result: Allowed
• Bench Allotted: I
• Assessment Year: 2022-2023
• Appeal Filed On: 06-03-2025
• Other Referred Cases: ITA No. 6811/Mum/2017, ITA No. 1160/Mum/2024
• Laws Referred To: Income Tax Act, India-US Double Tax Avoidance Agreement
• Result in Favour of: Assessee
• Court: TRIBUNAL
• Department Lawyers: SATYAPAL KUMAR
• Assessee Lawyers: VISHAL KARLA
• Keywords: Rule of consistency; Double taxation relief
• Section: 147; 143(3); 234B; 244A

Judgement Text

"IN THE INCOME TAX APPELLATE TRIBUNAL MUMBAI BENCH “I” MUMBAI BEFORE SHRI OM PRAKASH KANT (ACCOUNTANT MEMBER) AND SHRI RAHUL CHAUDHARY (JUDICIAL MEMBER) ITA No. 1603/MUM/2025 Assessment Year: 2022-23 American Chemical Society, C/o Deloitte Haskins and Sells LLP, 7th floor, Building 10, Tower B, DFL Cyber City Complex, DLF City Phase-II, Gurgaon-122002. Vs. DCIT (International Tax), Circle 1(1)(1), Room No. 534, 5th floor, Kautilya Bhavan, C-41 to C-43, G Block, Bandra Kurla Complex, Bandra (East), Mumbai-400051. PAN NO. AALCA4959L Appellant Respondent Assessee by : Mr. Vishal Karla Revenue by : Mr. Satya Pal Kumar, CIT-DR Date of Hearing : 12/09/2025 Date of pronouncement : 13/11/2025 ORDER PER OM PRAKASH KANT, AM This appeal by the assessee is directed against final assessment order dated 27.01.2025, passed by the Ld. Assistant/ Deputy Commissioner of Income-tax (International Taxation) – 1(1)(1), Mumbai (in short the Assessing Officer), pursuant to the direction of Ld. Dispute Resolution Panel (in short ld. DRP) for assessment year 2022-23, raising following grounds: Printed from counselvise.com 1. That on the fact Ld. AO has erred in assessing the total income of the Appellant under Section 143(3) read with Section 144C(13) of the Act at INR 1,47,44,58,663 as against the returned income of Nil. 2. That on the facts and Ld. AO/ Dispute Resolution Panel (\"DRP\") have erred in holding that the receipts from Indian customers are chargeable to tax as royalty in terms of Article 12(3) of India Agreement (\"DTAA\") 2.1 That on the facts and in the circumstances of the case and in law, the Ld. AO/ DRP have erred in holding that the subscription charges received under Chemical Abstract Service (CAS) division and Publications (PUB under India- concerning industrial, commercial or scientific experience and / or for use of industrial, commercial or scientific equipment. 2.2 That on the facts Ld. AO/ DRP have erred in not following the principle of consistency, while holding that subscription charges received by the appellant are chargeable to tax under the India received for use of appreciating that the same has never been held in the past by the Ld. AO/ DRP. 2.3 That on the facts and circumstances of the case and in law, the Ld. AO/ DRP have erred in holding that the subscription received under CAS and PUBS divisions would be chargeable to tax in India under India databases / software. 2.4 That on the facts and circumstances of the case and in law, the Ld. AO/DRP have erred in not follo Hon'ble Mumbai Bench of the Income in Appellant's own case for immediately preceding assessment years i.e. AY 2014 circumstances, the Hon'ble ITAT h and PUBS division cannot be taxed as royalty under Section 9(1)(vi) of the Act as well as Article 12(3) of India 3. That on the facts and circumstances of the case and in law, the Ld. AO has erred in levying interest Section 234B of the Act. American Chemical Society ITA No. 1603/MUM/2025 1. That on the facts and circumstances of the case and in law, the Ld. AO has erred in assessing the total income of the Appellant under Section 143(3) read with Section 144C(13) of the Act at INR 1,47,44,58,663 as against the returned income of Nil. 2. That on the facts and circumstances of the case and in law, the Ld. AO/ Dispute Resolution Panel (\"DRP\") have erred in holding that the receipts from Indian customers are chargeable to tax as royalty in terms of Article 12(3) of India-US Double Tax Avoidance Agreement (\"DTAA\") and under Section 9(1)(vi) of the Act. 2.1 That on the facts and in the circumstances of the case and in law, the Ld. AO/ DRP have erred in holding that the subscription charges received under Chemical Abstract Service (CAS) division and Publications (PUBS) division would be chargeable to tax in India -US DTAA being received for use of information concerning industrial, commercial or scientific experience and / or for use of industrial, commercial or scientific equipment. 2.2 That on the facts and circumstances of the case and in law, the Ld. AO/ DRP have erred in not following the principle of consistency, while holding that subscription charges received by the appellant are chargeable to tax under the India-US DTAA as being received for use of industrial, commercial or scientific equipment, not appreciating that the same has never been held in the past by the Ld. AO/ DRP. 2.3 That on the facts and circumstances of the case and in law, the Ld. AO/ DRP have erred in holding that the subscription received under CAS and PUBS divisions would be chargeable to tax in India under India-US DTAA being received for use of ACS databases / software. 2.4 That on the facts and circumstances of the case and in law, the Ld. AO/DRP have erred in not following the decision passed by the Hon'ble Mumbai Bench of the Income-tax Appellate Tribunal (\"ITAT\") in Appellant's own case for immediately preceding assessment years i.e. AY 2014-15 to 2021-22, wherein on similar circumstances, the Hon'ble ITAT held that the revenue from CAS and PUBS division cannot be taxed as royalty under Section 9(1)(vi) of the Act as well as Article 12(3) of India-US DTAA. 3. That on the facts and circumstances of the case and in law, the Ld. AO has erred in levying interest of INR 4,32,67,210 under Section 234B of the Act. American Chemical Society 2 ITA No. 1603/MUM/2025 s and circumstances of the case and in law, the Ld. AO has erred in assessing the total income of the Appellant under Section 143(3) read with Section 144C(13) of the Act at INR circumstances of the case and in law, the Ld. AO/ Dispute Resolution Panel (\"DRP\") have erred in holding that the receipts from Indian customers are chargeable to tax as royalty US Double Tax Avoidance and under Section 9(1)(vi) of the Act. 2.1 That on the facts and in the circumstances of the case and in law, the Ld. AO/ DRP have erred in holding that the subscription charges received under Chemical Abstract Service (CAS) division S) division would be chargeable to tax in India US DTAA being received for use of information concerning industrial, commercial or scientific experience and / or for use of industrial, commercial or scientific equipment. and circumstances of the case and in law, the Ld. AO/ DRP have erred in not following the principle of consistency, while holding that subscription charges received by the US DTAA as being industrial, commercial or scientific equipment, not appreciating that the same has never been held in the past by the 2.3 That on the facts and circumstances of the case and in law, the Ld. AO/ DRP have erred in holding that the subscription charges received under CAS and PUBS divisions would be chargeable to tax US DTAA being received for use of ACS 2.4 That on the facts and circumstances of the case and in law, the wing the decision passed by the tax Appellate Tribunal (\"ITAT\") in Appellant's own case for immediately preceding assessment similar facts and eld that the revenue from CAS and PUBS division cannot be taxed as royalty under Section 9(1)(vi) 3. That on the facts and circumstances of the case and in law, the of INR 4,32,67,210 under Printed from counselvise.com 4. That on the facts and circumstances of the case and in law, the Ld. AO has grossly erred in computing the aggregate income tax liability (including interest) of the Appellant at INR 19,20,49,126. 5. That on the facts and circumstances of the case and in law, the Ld. AO has erred in computing the correct amount of interest on refund under Section 244A of the Act. 6. That on the facts and circumstances of the case and in law, the Ld. AO has erred in initia 270A of the 2. We have heard rival submissions of the parties and perused the relevant materials on record assessee is aggrieved with the finding of the holding that the subscription charges received under chemical abstract service division ‘royalty’ under domestic law received for use of information concern scientific experience and/or for use of industrial, commercial or scientific equipment. Before us, the Ld. counsel for the assessee submitted that identical issue has been decided by the Co Bench of the Tribunal in ITA No. 6811/Mum/2017 for asses year 2014-15 and ITA No. 1160/Mum/2024 for assessment year 2013-14 in favour of the assessee and therefore, in view of principle of consistency without any change of Ld. Assessing Officer/DRP is not justified in upholding addition for treating the subscription charges under chemical abstract division and publication division as royalty. We find that the Tribunal in assessment year 2014 American Chemical Society ITA No. 1603/MUM/2025 4. That on the facts and circumstances of the case and in law, the Ld. AO has grossly erred in computing the aggregate income tax liability (including interest) of the Appellant at INR 19,20,49,126. t on the facts and circumstances of the case and in law, the Ld. AO has erred in computing the correct amount of interest on refund under Section 244A of the Act. 6. That on the facts and circumstances of the case and in law, the Ld. AO has erred in initiating penalty proceedings under Section Act. We have heard rival submissions of the parties and perused the relevant materials on record. In the grounds raised, the assessee is aggrieved with the finding of the ld Assessing Officer in the subscription charges received under chemical abstract service division and publication division under domestic law as well as under India US DTAA use of information concerning industrial, commercial or scientific experience and/or for use of industrial, commercial or scientific equipment. Before us, the Ld. counsel for the assessee submitted that identical issue has been decided by the Co Bench of the Tribunal in ITA No. 6811/Mum/2017 for asses 15 and ITA No. 1160/Mum/2024 for assessment year 14 in favour of the assessee and therefore, in view of principle consistency without any change of facts and circumstances, the Ld. Assessing Officer/DRP is not justified in upholding addition for treating the subscription charges under chemical abstract division and publication division as royalty. We find that the Tribunal in assessment year 2014-15 has specifically noted that consideration American Chemical Society 3 ITA No. 1603/MUM/2025 4. That on the facts and circumstances of the case and in law, the Ld. AO has grossly erred in computing the aggregate income tax liability (including interest) of the Appellant at INR 19,20,49,126. t on the facts and circumstances of the case and in law, the Ld. AO has erred in computing the correct amount of interest on 6. That on the facts and circumstances of the case and in law, the ting penalty proceedings under Section We have heard rival submissions of the parties and perused . In the grounds raised, the Assessing Officer in the subscription charges received under chemical publication division was taxable as as well as under India US DTAA, being industrial, commercial or scientific experience and/or for use of industrial, commercial or scientific equipment. Before us, the Ld. counsel for the assessee submitted that identical issue has been decided by the Co-ordinate Bench of the Tribunal in ITA No. 6811/Mum/2017 for assessment 15 and ITA No. 1160/Mum/2024 for assessment year 14 in favour of the assessee and therefore, in view of principle facts and circumstances, the Ld. Assessing Officer/DRP is not justified in upholding addition for treating the subscription charges under chemical abstract division and publication division as royalty. We find that the Tribunal in that consideration Printed from counselvise.com received from ‘copyright therefore, same does not quality as the Tribunal (supra) is reproduced as under: “17. We have heard the rival relevant material on record including the order of the lower authorities on the issue in dispute. We find that issue with respect to the PUBS division coincides with the issues on the CAS fee. The journal provided by the PUBS d not provide any information arising from assessee's previous experience. The assessee's experience lies in the creation of/maintaining such information online. By granting access to the journals, the assessee neither shares its experiences, tech evolving databases with the users, nor imparts any information relating to them. As is clearly evident from the sample agreements, all that the customers get is the right to search, view and display the articles (whether o taking a print) and reproducing or exploiting the same in any manner other than for personal use is strictly prohibited. Further, the customers do not get any rights to the journal or articles therein. They can only view the article in the journal that they have subscribed to and cannot amend or replicate or reproduce the journal. Thus, the customers are only able to access journal/articles for personal use of the information. No 'use or right to use' in any copyright or any other intellectual p is provided by the assessee to its customers. Furthermore, the information resides on servers outside India, to which the customers have no right or access, nor do they possess control or dominion over the servers in any way. Therefore, the question of such payments qualifying as consideration for use or right to use any equipment, whether industrial, commercial or scientific, does not arise. 18. To put a comparison, if someone purchases a book, then the consideration paid is not for the the book/ article. The purchaser of a book does not acquire the right to make multiple copies for re derivative works of the book, i.e., the purchaser of a book does not obtain the copyright in the book. Similarly, American Chemical Society ITA No. 1603/MUM/2025 copyrighted article’ is different from therefore, same does not quality as ‘royalty’. The relevant finding of is reproduced as under: We have heard the rival submissions and perused the relevant material on record including the order of the lower authorities on the issue in dispute. We find that issue with respect to the PUBS division coincides with the issues on the CAS fee. The journal provided by the PUBS d not provide any information arising from assessee's previous experience. The assessee's experience lies in the creation of/maintaining such information online. By granting access to the journals, the assessee neither shares its experiences, techniques or methodology employed in evolving databases with the users, nor imparts any information relating to them. As is clearly evident from the sample agreements, all that the customers get is the right to search, view and display the articles (whether online or by taking a print) and reproducing or exploiting the same in any manner other than for personal use is strictly prohibited. Further, the customers do not get any rights to the journal or articles therein. They can only view the article nal that they have subscribed to and cannot amend or replicate or reproduce the journal. Thus, the customers are only able to access journal/articles for personal use of the information. No 'use or right to use' in any copyright or any other intellectual property of any kind is provided by the assessee to its customers. Furthermore, the information resides on servers outside India, to which the customers have no right or access, nor do they possess control or dominion over the servers in any way. Therefore, the question of such payments qualifying as consideration for use or right to use any equipment, whether industrial, commercial or scientific, does not arise. 18. To put a comparison, if someone purchases a book, then the consideration paid is not for the use of the copyright in the book/ article. The purchaser of a book does not acquire the right to make multiple copies for re-sale or to make derivative works of the book, i.e., the purchaser of a book does not obtain the copyright in the book. Similarly, American Chemical Society 4 ITA No. 1603/MUM/2025 is different from ‘copyright’ and . The relevant finding of submissions and perused the relevant material on record including the order of the lower authorities on the issue in dispute. We find that issue with respect to the PUBS division coincides with the issues on the CAS fee. The journal provided by the PUBS division do not provide any information arising from assessee's previous experience. The assessee's experience lies in the creation of/maintaining such information online. By granting access to the journals, the assessee neither shares niques or methodology employed in evolving databases with the users, nor imparts any information relating to them. As is clearly evident from the sample agreements, all that the customers get is the right to nline or by taking a print) and reproducing or exploiting the same in any manner other than for personal use is strictly prohibited. Further, the customers do not get any rights to the journal or articles therein. They can only view the article nal that they have subscribed to and cannot amend or replicate or reproduce the journal. Thus, the customers are only able to access journal/articles for personal use of the information. No 'use or right to use' in roperty of any kind is provided by the assessee to its customers. Furthermore, the information resides on servers outside India, to which the customers have no right or access, nor do they possess control or dominion over the servers in any way. Therefore, the question of such payments qualifying as consideration for use or right to use any equipment, whether industrial, 18. To put a comparison, if someone purchases a book, then use of the copyright in the book/ article. The purchaser of a book does not acquire sale or to make derivative works of the book, i.e., the purchaser of a book does not obtain the copyright in the book. Similarly, the Printed from counselvise.com purchaser of the assessee's journals, articles or database access does not have the right to make copies for re and does not have the right to make derivative works. In short, the purchaser has not acquired the copyright of the article or of the d copyrighted product, and accordingly the consideration paid is not royalty, but for purchase of a product. In the instant case too, what is acquired by the customer is a copyrighted article, copyrights of which continue to all purposes. lt is a well settled law that copyrighted article is different from a copyright, and that consideration for the former, i.e. a copyrighted article does not qualify as royalties. 19. Thus, the principles noted by us in t this order in the context of the income earned by way of CAS fee are squarely applicable to the subscription revenue received from customers of PUBS division for sale of journal also, and accordingly PUBS fee also does not qualify as 'Royalty' in terms of section 9(1)(vi) of the Act as well as Article 12(3) of the India 2.1 Further, in assessment year 2013 the finding of the Co The relevant finding in assessme under: “10. The aforesaid order so passed by the Coordinate Bench has since been consistently followed by the Coordinate Benches while adjudicating the matter for subsequent assessment years right up to A.Y 2021 we have noted in the beginning, the AO has al the assessment order that assessee's business model has remained the same in comparison to A.Y. 2014 2020-21 and stream of revenue was also the same and no other income has been earned by the assessee company from India. Thus, admit changes in the facts and circumstances of the case in the impugned assessment year except that the matter was reopened u/s 147 of the Act. Though the Revenue has challenged the orders so passed by the Coordinate Benches American Chemical Society ITA No. 1603/MUM/2025 purchaser of the assessee's journals, articles or database access does not have the right to make copies for re and does not have the right to make derivative works. In short, the purchaser has not acquired the copyright of the article or of the database. What the buyer gets is a copyrighted product, and accordingly the consideration paid is not royalty, but for purchase of a product. In the instant case too, what is acquired by the customer is a copyrighted article, copyrights of which continue to lie with assessee for all purposes. lt is a well settled law that copyrighted article is different from a copyright, and that consideration for the former, i.e. a copyrighted article does not qualify as 19. Thus, the principles noted by us in the earlier part of this order in the context of the income earned by way of CAS fee are squarely applicable to the subscription revenue received from customers of PUBS division for sale of journal also, and accordingly PUBS fee also does not qualify as yalty' in terms of section 9(1)(vi) of the Act as well as Article 12(3) of the India-USA DTAA.” Further, in assessment year 2013-14, the Tribunal followed the finding of the Co-ordinate Bench in assessment year 2014 The relevant finding in assessment year 2013-14 is reproduced as 10. The aforesaid order so passed by the Coordinate Bench has since been consistently followed by the Coordinate Benches while adjudicating the matter for subsequent assessment years right up to A.Y 2021 we have noted in the beginning, the AO has also stated in the assessment order that assessee's business model has remained the same in comparison to A.Y. 2014- 21 and stream of revenue was also the same and no other income has been earned by the assessee company from India. Thus, admittedly and undisputedly, there are no changes in the facts and circumstances of the case in the impugned assessment year except that the matter was reopened u/s 147 of the Act. Though the Revenue has challenged the orders so passed by the Coordinate Benches American Chemical Society 5 ITA No. 1603/MUM/2025 purchaser of the assessee's journals, articles or database access does not have the right to make copies for re-sale and does not have the right to make derivative works. In short, the purchaser has not acquired the copyright of the atabase. What the buyer gets is a copyrighted product, and accordingly the consideration paid is not royalty, but for purchase of a product. In the instant case too, what is acquired by the customer is a copyrighted lie with assessee for all purposes. lt is a well settled law that copyrighted article is different from a copyright, and that consideration for the former, i.e. a copyrighted article does not qualify as he earlier part of this order in the context of the income earned by way of CAS fee are squarely applicable to the subscription revenue received from customers of PUBS division for sale of journal also, and accordingly PUBS fee also does not qualify as yalty' in terms of section 9(1)(vi) of the Act as well as 14, the Tribunal followed ordinate Bench in assessment year 2014-15. 14 is reproduced as 10. The aforesaid order so passed by the Coordinate Bench has since been consistently followed by the Coordinate Benches while adjudicating the matter for subsequent assessment years right up to A.Y 2021-22. As so stated in the assessment order that assessee's business model has -15 to A.Y. 21 and stream of revenue was also the same and no other income has been earned by the assessee company tedly and undisputedly, there are no changes in the facts and circumstances of the case in the impugned assessment year except that the matter was reopened u/s 147 of the Act. Though the Revenue has challenged the orders so passed by the Coordinate Benches Printed from counselvise.com before the Hon'ble Bombay High Court and the matter is currently pending adjudication, however, there is no stay which has either been sought or granted against the orders so passed by the Coordinate Benches. Given that there are no changes in the facts a see no reason to deviate from the view so taken by the Coordinate Bench which has consistently been followed in subsequent years. In light of the same, we uphold the plea so taken by the ld AR on behalf of the assessee and that subscription revenues for CAS as well as PUBS divisions cannot be brought to tax as royalty in terms of section 9(1)(vi) as well as Article 12(3) of India the hands of the assessee and the addition so made is hereby directed to be del 11. In light of the aforesaid, where we have deleted the addition, other grounds raised by the assessee including the ground challenging the jurisdiction of the AO have become academic in nature and we donot deem it necessary to adjudicate the same a same are left 2.2 As facts and circumstances in the year under consideration being identical, without the principle of consistency and respectfully following the Co ordinate Bench of the Tribunal, we received under chemical abstract service division and publication division are not in the nature of royalty under the Income-tax Act or under the provisions of the India US DTAA. Accordingly, the issue in d the assessee is allowed. American Chemical Society ITA No. 1603/MUM/2025 before the Hon'ble Bombay High Court and the matter is currently pending adjudication, however, there is no stay which has either been sought or granted against the orders so passed by the Coordinate Benches. Given that there are no changes in the facts and circumstances of the case, we see no reason to deviate from the view so taken by the Coordinate Bench which has consistently been followed in subsequent years. In light of the same, we uphold the plea so taken by the ld AR on behalf of the assessee and that subscription revenues for CAS as well as PUBS divisions cannot be brought to tax as royalty in terms of section 9(1)(vi) as well as Article 12(3) of India-USA DTAA in the hands of the assessee and the addition so made is hereby directed to be deleted. 11. In light of the aforesaid, where we have deleted the addition, other grounds raised by the assessee including the ground challenging the jurisdiction of the AO have become academic in nature and we donot deem it necessary to adjudicate the same a left open.” As facts and circumstances in the year under consideration being identical, without there being any material change the principle of consistency and respectfully following the Co ordinate Bench of the Tribunal, we hold that subscription charges received under chemical abstract service division and publication division are not in the nature of royalty under the provisions of the tax Act or under the provisions of the India US DTAA. Accordingly, the issue in dispute raised in the grounds of appeal of the assessee is allowed. American Chemical Society 6 ITA No. 1603/MUM/2025 before the Hon'ble Bombay High Court and the matter is currently pending adjudication, however, there is no stay which has either been sought or granted against the orders so passed by the Coordinate Benches. Given that there are nd circumstances of the case, we see no reason to deviate from the view so taken by the Coordinate Bench which has consistently been followed in subsequent years. In light of the same, we uphold the plea so taken by the ld AR on behalf of the assessee and hold that subscription revenues for CAS as well as PUBS divisions cannot be brought to tax as royalty in terms of USA DTAA in the hands of the assessee and the addition so made is 11. In light of the aforesaid, where we have deleted the addition, other grounds raised by the assessee including the ground challenging the jurisdiction of the AO have become academic in nature and we donot deem it necessary to adjudicate the same and the As facts and circumstances in the year under consideration change, following the principle of consistency and respectfully following the Co- hold that subscription charges received under chemical abstract service division and publication provisions of the tax Act or under the provisions of the India US DTAA. ispute raised in the grounds of appeal of Printed from counselvise.com 3. In the result, the appeal of the assessee is allowed. Order pronounced in the open Court on Sd/- (RAHUL CHAUDHARY JUDICIAL MEMBER Mumbai; Dated: 13/11/2025 Rahul Sharma, Sr. P.S. Copy of the Order forwarded to 1. The Appellant 2. The Respondent. 3. CIT 4. DR, ITAT, Mumbai 5. Guard file. //True Copy// American Chemical Society ITA No. 1603/MUM/2025 In the result, the appeal of the assessee is allowed. ounced in the open Court on 13/11/2025. Sd/ (RAHUL CHAUDHARY) (OM PRAKASH KANT JUDICIAL MEMBER ACCOUNTANT MEMBER Copy of the Order forwarded to : BY ORDER, (Assistant Registrar) ITAT, Mumbai American Chemical Society 7 ITA No. 1603/MUM/2025 In the result, the appeal of the assessee is allowed. /11/2025. Sd/- OM PRAKASH KANT) ACCOUNTANT MEMBER BY ORDER, (Assistant Registrar) ITAT, Mumbai Printed from counselvise.com "