GS STRATEGIC INVESTMENTS LIMITED,MUMBAI V. ACIT, INTERNATIONAL TAX CIRCLE-2(3)(2), MUMBAI

ITA 4401/MUM/2023

AI Insights

The case involves GS Strategic Investments Limited appealing against the Final Assessment Order passed by the Assistant Commissioner of Income Tax, which set off long-term capital losses from previous years against long-term capital gains of the current year, claimed to be exempt under the India-Mauritius DTAA. The Tribunal examined whether the gains, which were not taxed in India due to the DTAA, should be set off against the losses. The Tribunal found that similar issues had been decided in favor of the assessee in previous cases and directed the Assessing Officer to verify the exemption claim and not to set off the gains against the losses if they are found to be exempt.

• Counselvise Citation: [2024] 140 COUNSELVISE.COM (IT) 32753 (ITAT-MUMBAI)
• Duration Of Justice: 10 month(s) 17 day(s)
• Appeal Type: Income Tax Appeal
• Pronouncement Date: 22-10-2024
• Appeal Filed By: Assessee
• Order Result: Partly Allowed
• Bench Allotted: I
• Next Hearing Date: 30-07-2024
• Assessment Year: 2021-2022
• Appeal Filed On: 05-12-2023
• Other Referred Cases: Goldman Sachs Investments (Mauritius) Ltd. Vs. DCIT (International Taxation) \\u2013 2(3)(2), Flagship Indian Investment Co. (Mauritius) Ltd. Vs. ACIT, DCIT vs. Patni Computers Systems Ltd.
• Laws Referred To: Income Tax Act, 1961
• Result in Favour of: Partly Allowed
• Court: TRIBUNAL
• Department Lawyers: GOLDMAN SACHS INVESTMENTS MAURITIUS LTD. VS. DCIT
• Assessee Lawyers: ASSESSEE
• Keywords: Set aside; Opportunity of being heard; Capital Gains; Search and seizure; Double taxation relief; Benefit of exemption
• Section: 143(3); 143(1); 13; 92CA

Judgement Text

"IN THE INCOME TAX APPELLATE TRIBUNAL \"I” BENCH, MUMBAI SHRI NARENDRA KUMAR BILLAIYA, ACCOUNTANT MEMBER SHRI RAHUL CHAUDHARY, JUDICIAL MEMBER ITA No. 4401/MUM/2023 (Assessment Year: 2021-22) GS Strategic Investments Limited C/o, Sehajpreet Kaur BBSR & Associates 14 Floor, Central Wing, Tower 4, Nesco Center, Western Express Highway, Goregaon (East) Mumbai – 400 063 Maharashtra [PAN:AAFFC0912J] …………. Appellant Assistant Commissioner of Income Tax, International Tax Circle – 2(3)(2) Air India Building, 3rd Floor, Earnest House, Nariman Point, Mumbai – 400 021. Vs …………. Respondent Appearance For the Appellant/Assessee For the Respondent/Department : : Shri Ajit Jain Shri Siddesh Chaugule Smt. Shaileja Rai Date Conclusion of hearing Pronouncement of order : : 30.07.2024 22.10.2024 O R D E R [ Per Rahul Chaudhary, Judicial Member: 1. This present appeal preferred by the Assessee against the Final Assessment Order, dated 18/10/2023, passed by the Assessing Officer under Section 143(3) r.w.s. 92CA r.w.s. 144C(13) of the Income Tax Act, 1961 [hereinafter referred to as ‘the Act’], as per the direction issued by Dispute Resolution Panel (1), Mumbai [for short ‘DRP’] on 26/09/2023 under Section 144C(5) of the Act for the Assessment Year 2021-22. 2. The Appellant has raised following grounds of appeal : ITA No.4401/Mum/2023 Assessment Year 2021-22 2 “Based on the facts and circumstances of the case, OS Strategic Investments Limited (hereinafter referred to as \"GSSIL\" or \"The Appellant\" or \"the Company\"), respectfully submits in respect of the Final Assessment Order (\"FAO\" or \"Order\") dated 18 November 2023 passed by the learned Assistant Commissioner of Income-tax, International tax, Circle 2(3)(2), Mumbai (\"Assessing Officer\" or \"learned AD\") under section 143(3) read with section 144C(13) of the Income tax Act, 1961 (\"the Act\") for the Assessment Year (\"AY\") 2021-22 that- 1. The FAO passed by the learned AD, in so far as it is prejudicial to the interests of the Appellant, it bad in law. 2 The FAO passed by the learned AD is barred by limitation as the same is not passed within the statutory tune limit for completion of assessment prescribed under section 153(1) of the Act and hence the same is liable to be quashed. Without prejudice to the above, 3. The learned AO/DRP have erred in law and on facts in setting- off the long-term capital losses (\"LTCL\") amounting to INR 4,57,99,14,322/- brought forward from earlier AYs against the current years long term capital gains (\"LTCG\") amounting to INR 3,01,51,81,694 that were claimed as exempt under Article 13 of the India-Mauritius Double Taxation Avoidance Agreement (\"DTAA\") 4. The learned AO/DRP have therefore erred in law and on facts in allowing the carry forward of only the balance brought forward LTCL, amounting to INR 1,56,47,32,628 remaining after the said set off (i.e. INR 4,57,99,14,322 less INR 3,01,51,81,694) to future years as against the entire amount of INR 4,57,99,14,322 as claimed in the ROI. 5. The learned AO/ DRP have failed to appreciate and acknowledge the settled principle that for the purposes of carrying out a set-off of LTCL under section 74 of the Act, existence of taxable income (i.e. existence of taxable LTCG) in that year is compulsory. 6. The learned AO/DRP have therefore failed to appreciate that since in subject AY, the LTCG was not chargeable to tax in India under Article 13(4) of the India-Mauritius DTAA, the ITA No.4401/Mum/2023 Assessment Year 2021-22 3 question of adjustment of the same brought forward loss of the preceding years does not arise. 7. The learned AO/DRP have erred in law in holding that the operation of the DTAA will exclude the application of the domestic Act and its provisions including the application of section 74 the Act. 8. The learned AO has erred in law in holding that the Appellant on one side was coming from tax in India as per the DTAA and on other side, the case of losses the same nature, was carrying the same forward to subsequent A.Y.s for set-off, without appreciating the fact that in the previous AY, the Appellant had elected to be the provisions of the Act as against the DTAA. 9. The learned AO / DRP have erred in law in falling to appreciate that an assessee is allowed to apply the provisions of the Act or the DTAA, whichever is beneficial to it, in every year and that there is no compulsion that if taxability under the Act is chosen for a year, the same needs to be followed every year. 10. The learned AO/DRP failed to follow decisions of the jurisdictional Tribunal which are directly on the issue under consideration on the grounds that appeal has been filed by the Revenue against the same. 11. The learned AD/DRP have erred in relying on judicial precedents which are clearly distinguishable on facts vis-à-vis the case of the Appellant. The Appellant craves leave to add, alter, rescind and modify the grounds herein above or produce further documents, facts and evidence before or at the time of hearing of this appeal For the above and any other grounds which may be raised at the time of hearing, it is prayed that necessary relief may be provided.” 3. Ground No. 1 and 2 raised by the Appellant are dismissed as being not pressed in view of letter, dated 29/07/2024, filed by the Appellant. 4. Ground Nos. 3 to 10 are connected and are, therefore, being taken ITA No.4401/Mum/2023 Assessment Year 2021-22 4 up together hereinafter. The solitary issue raise in the aforesaid grounds is that the Assessing Officer has set off long-term capital losses brought forward from the earlier assessment years against the current year long-term capital gains. The contention of the Appellant is that long-term capital gains earned by the Appellant during the relevant previous year are exempt from tax in India in view of Article 13 of the Double Taxation Avoidance Agreement between India and Mauritius [for short ‘DTAA’]. Since there is no taxable income during the current year, the provisions of Section 74 of the act are not triggered. 5. When the appeal was taken up for hearing the Learned Authorised Representative for the Appellant, at the outset, submitted that identical issue stands decided in favour of the assessee and against the Revenue by following decisions of the Tribunal: Goldman Sachs Investments (Mauritius) Ltd. Vs. DCIT (International Taxation) – 2(3)(2): [2021] 187 ITD 184 (Mumbai - Trib.)[24-09-2020] Flagship Indian Investment Co. (Mauritius) Ltd. Vs. ACIT [2010] 133 TTJ 792 (Mum) and DCIT vs. Patni Computers Systems Ltd.: (2008) 114 ITD 159 (Pune – Trib.) DCIT vs. Patni Computers Systems Ltd.: (2008) 114 ITD 159 (Pune – Trib.). 6. Per contra when the Departmental Representative relied upon the Final Assessment Order, dated 18/10/2023 as well as order dated 26/09/2023 passed by the DRP. Further, the Learned Departmental Representative submitted that the contention of the Appellant that the long-term capital gain earned by the Appellant during the relevant previous year is exempt from tax in terms of Article 13 of the DTAA has not been tested either by Assessing Officer or by the DRP since the same was set off with brought forward long-term capital losses and to this extent, the issue should be reminded back ITA No.4401/Mum/2023 Assessment Year 2021-22 5 to the file of the Assessing Officer in case the Appellants contention is accepted in the present appeal. 7. We have considered the rival submissions and perused the material on record, including the decisions of the Tribunal on which reliance was placed by the Learned Authorised Representative for the Appellant. We find that identical issue had come up for consideration before the Tribunal in the case of Goldman Sachs Investments (Mauritius) Ltd. Vs. DCIT (International Taxation) – 2(3)(2): [2021] 187 ITD 184 (Mumbai - Trib.)[24-09-2020] on which reliance was placed by the Learned Authorised Representative for the Appellant. In that case, after making reference to the decision of the Co- ordinate Bench of the Tribunal in the case of Flagship Indian Investment Co. (Mauritius) Ltd. Vs. ACIT [2010] 133 TTJ 792 (Mum) and DCIT vs. Patni Computers Systems Ltd.: (2008) 114 ITD 159 (Pune – Trib.), the Tribunal decided the issue in favour of the assessee holding as under: “11. On a perusal of the grounds of appeal, we find, that there are two facets on the basis of which the observations of the A.O/DRP as regards carry forward of the earlier years capital losses has been assailed by the assessee before us, viz. (i). that the A.O/DRP had erred in concluding that the Short term capital losses brought forward by the assessee from the preceding years were to be first \"set off\" against the short term and long term capital gains for the year under consideration i.e A.Y 2013-14, and only the balance amount of short term capital losses were to be carried forward to the subsequent years; AND (ii). that the A.O/DRP had erred in denying the assessee's right to carry forward the Long term capital losses brought forward from the preceding years, despite the fact, that the same were determined and permitted to be carried forward by the A.O vide his assessment order passed u/s 143(3), dated 19-3-2015 for A.Y 2012-13. 12. We shall first deal with the grievance of the assessee that as to whether the A.O/DRP were right in law and the facts of the case, in concluding, that the short term and long term capital gains earned by the assessee from transfer of securities in India during the year under consideration i.e A.Y. 2013-14, were to be adjusted against the STCL ITA No.4401/Mum/2023 Assessment Year 2021-22 6 brought forward by the assessee from the earlier years, and thus, only the balance amount of STCL was to be carried forward to the subsequent years. At this stage, we may herein observe that the assessee had claimed the short term and long term capital gains arising in its hands from transfer of securities during the year under consideration i.e A.Y. 2013-14, as exempt, under Article 13 of the India-Mauritius Tax Treaty. As regards the claim of the assessee that the capital gains on transfer of securities in India was not exigible to tax in India as per Article 13 of the India-Mauritius tax treaty, we find, that the same is not in dispute. On a careful perusal of the observations of the DRP, we find that a direction has been given by the panel for adjustment of the brought forward STCL against the short term and long term capital gains earned by the assessee during the year under consideration. We are thus confronted with a direction of the DRP, wherein despite accepting that the short term and long term capital gains earned by the assessee from transfer of securities during the year under consideration were exempt from tax in India under Article 13 of the India-Mauritius tax treaty, the panel had directed that the brought forward STCL be first adjusted against such exempt short term and long term capital gains, and only the balance amount of brought forward STCL be carried forward to the subsequent years. In our considered view the aforesaid direction of the DRP is bereft of any reasoning and does not merit acceptance. We are unable to comprehend that now when admittedly the short term and long term capital gains earned by the assessee from transfer of securities during the year in question are exempt under Article 13 of the India-Mauritius Tax Treaty, where would there be any occasion for seeking adjustment of the brought forward STCL against such exempt income. Our aforesaid view is squarely covered by the order of the ITAT, Mumbai in the case of Flagship Indian Investment Company (Mauritius) Ltd. (supra). In the case of the assessee before the Tribunal that pertained to A.Y. 2005-06 the assessee had brought forward capital loss of Rs. 87,06,49,335/- from transfer of securities in A.Y. 2002-03. The aforesaid loss was determined in the hands of the assessee vide an intimation under Sec. 143(1) for A.Y 2002-03. Observing, that since the capital gains were not taxable in India as per Article 13 of the Indian-Mauritius Tax Treaty, the A.O being of the view that capital loss would also be exempted, and therefore, the assessee would not be entitled to claim the benefit of carry forward of such capital losses of the earlier years, thus, declined the set-off of the same against the capital gains for the relevant assessment years. On appeal, the CIT(A) upheld the order of the A.O. On further appeal, the Tribunal concluded that the assessee was fully justified in claiming the carry forward of the capital losses of the earlier years to the subsequent years, and both the A.O and the CIT(A) were in error in ITA No.4401/Mum/2023 Assessment Year 2021-22 7 not allowing the same. Accordingly, the A.O was directed to allow the carry forward of the capital losses of the earlier years to the subsequent years, according to law. As in the aforesaid case, in the case of the present assessee before us, as the short term and long term capital gains earned by the assessee from transfer of securities during the year in question are admittedly exempt from tax under Article 13 of the India-Mauritius tax treaty, therefore, the brought forward STCL of the previous years was rightly carried forward by the assessee to the subsequent years. As regards the reliance placed by the ld. D.R on the observations of the lower authorities that as the words \"income\" or \"profits and gains\" were to include losses also, therefore, now when Sec. 45 of the Act, by virtue of the India- Mauritius tax treaty was rendered unworkable in respect of \"capital gains\" derived by the assessee from transfer transactions carried out in India, the \"capital losses\" would also not form part of its \"total income\", and thus, were not required to be computed under the Act, we are afraid the same does not find favour with us. Before adverting any further, we may herein reiterate that the DRP vide its order passed u/s 144C(5), dated 21-11-2016, had concluded, that now when the \"capital loss\" was allowed to be carried forward by the A.O, vide his order passed under sec. 143(3), dated 19-3-2015 for A.Y 2012-13, the same could not have thereafter been reviewed in the assessment proceedings of any subsequent year. As the said observation of the DRP has not been assailed any further by the revenue in appeal before us, the same thus had attained finality. Now coming to the claim of the revenue that as Sec. 45 of the Act, by virtue of India-Mauritius tax treaty was rendered unworkable in respect of \"capital gains\" derived by the assessee from transfer of securities in India, therefore, the \"capital losses\" would also not form part of the assessee's \"total income\", and thus, could not be computed under the Act, we are afraid does not find favour with us. Apropos the aforesaid observation of the A.O, we are of the considered view that the same had been arrived at by loosing sight of the fact that the \"capital losses\" in question had been brought forward from the earlier years and had been determined and allowed to be carried forward by the A.O while framing the assessment for A.Y 2012-13, vide his order passed u/s 143(3), date 19-3-2015, and had not arisen during the year under consideration i.e A.Y 2013-14. Accordingly, the claim of the A.O that the \"capital losses\" b/forward from the earlier years, pertaining to a source of income that was exempt from tax was thus not to be carried forward to the subsequent years, being devoid of any merit, is thus rejected. At this stage, we may herein observe that it is for the assessee to examine whether or not in the light of the applicable legal provisions and the precise factual position the provisions of the IT Act are beneficial to ITA No.4401/Mum/2023 Assessment Year 2021-22 8 him or that of the applicable DTAA. In any case, the tax treaty cannot be thrust upon an assessee. In case the assessee during one year does not opt for the tax treaty, it would not be precluded from availing the benefits of the said treaty in the subsequent years. Our aforesaid view is fortified by the order of the ITAT, Pune in Patni Computer Systems Ltd. (supra). We thus in terms of our aforesaid observations, not being able to persuade ourselves to subscribe to the view taken by the A.O/DRP, who as noticed by us hereinabove had sought adjustment of the b/forward STCL against the exempt short term and long term capital gains earned by the assessee during the year in question, thus 'set aside' the order of the A.O in context of the issue under consideration. Accordingly, we direct the A.O to allow carry forward of the b/forward STCL of Rs. 3926,36,70,910/- to the subsequent years. The Grounds of appeal Nos. 1 and 2 are allowed in terms of our aforesaid observations. 13. We shall now advert to the second limb of the grievance of the assessee. As is discernible from the records, the assessee had brought forward from the preceding years Long term capital losses aggregating to Rs. 7,63,95,386/- [B/forward LTCL from A.Y 2009-10: Rs. 1,09,800/- (+) B/forward LTCL from A.Y 2012-13 : Rs. 7,62,85,586/-]. Admittedly, the aforesaid Long term capital loss of Rs. 7,63,95,386/- was determined and allowed to be carried forward by the A.O while framing the assessment in the case of the assessee for A.Y 2012-13, vide his order passed u/s 143(3), dated 19-3-2015. In fact, the aforesaid factual position had duly been taken cognizance of by the DRP at Para 2.3 of its order passed u/s 144C(5), dated 21- 11-2016. As observed by us hereinabove, the DRP had observed that once the STCL was allowed to be carried forward by the A.O in a scrutiny assessment order passed u/s 143(3) for a particular assessment year, the same cannot be reviewed in the assessment proceedings of any subsequent assessment year. In our considered view, now when the DRP had directed the A.O to allow carry forward of the STCL brought forward from the preceding years, there can be no justification for denial of carry forward of similarly placed Long term capital losses brought forward by the assessee from the preceding years. We thus are of the considered view that as Long term capital losses of Rs. 7,63,95,386/- were determined and permitted to be carried forward by the A.O while framing the assessment in the case of the assessee for A.Y 2012-13, vide his order passed u/s 143(3), dated 19-3-2015, the assessee therefore would be duly entitled to carry forward the same to the subsequent years. As observed by us hereinabove, the assessee had also moved with the DRP a rectification application u/rule 13 of the Income-tax (Dispute Resolution Panel) Rules, 2009 r.w sec. 144C(5) of the Act, dated 11-1-2017, seeking a direction for carry forward of the ITA No.4401/Mum/2023 Assessment Year 2021-22 9 b/forward Long term capital losses. After considering the issue, the DRP vide its order passed u/rule 13 of the Income-tax (Dispute Resolution Panel) Rules, 2009, dated 01-12-2017, had concluded, that following the rationale adopted for allowing the carry forward of brought forward STCL, the Long term capital losses amounting to Rs. 7,63,95,386/- that were brought forward from the preceding years were also to be allowed to be carried forward to the subsequent years. At the same time, the DRP observed that as the assessee during the year in question i.e A.Y 2013-14 had shown short term and long term capital gains, therefore, the b/forward losses would be first 'set off' against such income, and the remaining losses would be allowed to be carried forward to the subsequent years. Accordingly, it was observed by the DRP that as the assessee had during the year in question i.e A.Y 2013-14 shown Long term capital gains of Rs. 5,63,11,782/-, therefore, the same would be first set off against the b/forward Long term capital losses of Rs. 7,63,95,386/-, and the balance amount would be allowed to be carried forward to the subsequent years. However, as the DRP in its order u/s 144C(5), dated 21-11-2016 at Page 8 - Para 2.10 had directed adjustment of the Long term capital gains of Rs. 5,63,11,782/- as against the b/forward STCL of Rs. 3926,36,70,910/-, as per sec. 74(1)(a) of the Act, therefore, pursuant to its aforesaid directions, it had therein directed that its observations recorded in Para 2.9 to Para 2.12 would also stand modified. We have given a thoughtful consideration to the aforesaid issue before us, and on the basis of our observations recorded hereinabove, we herein conclude that the assessee is duly entitled for carry forward of its brought forward Long term capital losses of Rs. 7,63,95,386/- to the subsequent years. Further, in terms of our observations and reasoning adopted for concluding that the brought forward STCL of the earlier years are not to be adjusted against the Short term capital gain earned by the assessee during the year in question, we herein direct that on the same basis the brought forward Long term capital losses of the earlier years shall not be set off against the Long term capital gain earned by the assessee from transfer of securities during the year in question i.e A.Y 2013-14. The Ground of appeal No. 3 is allowed in terms of our aforesaid observations.” (Emphasis Supplied) 8. The above decision of the Tribunal in the case of Goldman Sachs Investments (Mauritius) Ltd. (supra) was also followed by the Mumbai Bench of the Tribunal in the case of Deputy Commissioner of Income Tax (International Taxation)-4(2)(2), Mumbai, Vs. Swiss Finance Corporation (Mauritius) [ITA No. 1338/MUM/2021 (Assessment ITA No.4401/Mum/2023 Assessment Year 2021-22 10 Year: 2015-16) & ITA No. 2449/MUM/2021 (Assessment Year: 2017-18), Common Order dated 07/10/2022]. “10. In the present case, there was no dispute that the Assessee was entitled to claim the benefit of exemption from tax in India granted by Article 13(4) of the DTAA in respect of Short/Long Term Capital Gains arising during the relevant previous year. The contention of the Revenue was that the aforesaid benefit of Article 13(4) of DTAA could only be claimed in respect of net/balance Short/Long Term Capital Gains in terms of Section 74 of the Act. The Tribunal had, in the case of Goldman Sachs Investments (Mauritius) Ltd. (supra), rejected the aforesaid contention of the Revenue holding that the Assessee was entitled to claim benefit of Article 13(4) of DTAA in respect of entire current year Short/Long Term Capital Gains (without setting of the Brought Forward Short/Long Term Capital Gains). The Tribunal also permitted carry forward of the Brought Forward Short/Long Term Capital Gains to the subsequent assessment years holding that the Short/Long Term Capital Loss permitted to be carried forward in a previous assessment could not be reviewed in the assessment proceedings of a subsequent assessment year. In view of the aforesaid, we find merit in the contention of the Ld. Authorised Representative for the Assessee that all the issues raised by the Revenue in the present appeal stand decided in favour of the Assessee by the decision of the Tribunal in the case of Goldman Sachs Investments (Mauritius) Ltd. (supra). Accordingly, we do not find any infirmity in the order passed by the CIT(A). Ground No.1, 2 and 3 raised by the Revenue are dismissed.” 9. Accordingly, respectfully following the above decisions of the Co-ordinate Bench of the Tribunal, we accept the contention of the Appellant that in case long-term capital gains arising during the relevant previous year are exempt from tax in terms of Article 13 of the DTAA, the provisions contained in Section 74 of the Act would not get triggered and therefore, the occasion to set off the long-term ITA No.4401/Mum/2023 Assessment Year 2021-22 11 capital gains against the brought forward long-term capital gains would not arise. 10. However, we find merit in the contention advanced by the Learned Departmental Representative that the contention of the Appellant that the long-term capital gains earned by the Appellant during the relevant previous years are exempt from tax has not been tested during the assessment proceedings and for that reason the necessary facts are not on record. Therefore, for the limited purpose of examining this aspect, we remand this issue back to the file of Assessing Officer. All the rights and contention of the Appellant in relation to the same are left open. The Assessing Officer is directed to decide the issue as per law after granting the Appellant a reasonable opportunity of being heard. In case the Assessing Officer comes to a conclusion that the long-term capital gain earned by the Appellant during the relevant previous year are exempt from tax in terms of the provisions of the Act read with the provision of the DTAA, the same would not be set off against the brought forward long-term capital gains and the same would be carried forward as per the provisions of the Act. In terms of the aforesaid, Ground No. 3 to 9 raised by the Appellant are party allowed. 11. In result, the present appeal preferred by the Assessee is partly allowed. Order pronounced on 22.10.2024. Sd/- Sd/- (Shri Narendra Kumar Billaiya) Accountant Member (Rahul Chaudhary) Judicial Member मुंबई Mumbai; िदनांक Dated : 22.10.2024 Milan, LDC ITA No.4401/Mum/2023 Assessment Year 2021-22 12 आदेश की Ůितिलिप अŤेिषत/Copy of the Order forwarded to : 1. अपीलाथŎ / The Appellant 2. ŮȑथŎ / The Respondent. 3. आयकर आयुƅ/ The CIT 4. Ůधान आयकर आयुƅ / Pr.CIT 5. िवभागीय Ůितिनिध ,आयकर अपीलीय अिधकरण ,मुंबई / DR, ITAT, Mumbai 6. गाडŊ फाईल / Guard file. आदेशानुसार/ BY ORDER, सȑािपत Ůित //True Copy// उप/सहायक पंजीकार /(Dy./Asstt. Registrar) आयकर अपीलीय अिधकरण, मुंबई / ITAT, Mumbai "