INCOME TAX OFFICER-41(2)(4), MUMBAI, BKC, MUMBAI V. RBI EMPLOYEES BHAGVATI COOP HOUSING SOCIETY LTD , MULUND EAST, MUMBAI

ITA 4073/MUM/2025

AI Insights

The case involves the Income Tax Officer appealing against the decision of the CIT(A) which had deleted the addition of INR 4,97,63,657 as Short Term Capital Gains in the hands of the RBI Employees Bhagvati Co-op. Housing Society Ltd. for the Assessment Year 2011-2012. The CIT(A) had ruled that the income from the redevelopment agreement was taxable in the hands of the individual members of the society, not the society itself. The Revenue challenged this decision, arguing that the society was the legal entity that entered into the development agreement and thus should be liable for the tax. The Tribunal, after reviewing the submissions and the development agreement, agreed with the CIT(A) and dismissed the Revenue's appeal.

• Counselvise Citation: [2025] 140 COUNSELVISE.COM (IT) 782497 (ITAT-MUMBAI)
• Duration Of Justice: 4 month(s) 18 day(s)
• Appeal Type: Income Tax Appeal
• Pronouncement Date: 27-10-2025
• Appeal Filed By: Department
• Order Result: Dismissed
• Bench Allotted: D
• Assessment Year: misc
• Appeal Filed On: 09-06-2025
• Other Referred Cases: Raj Ratan Palace Co. Op. Hsg. Society Ltd. Vs. Deputy Commissioner of Income Tax, Circle 25(3)
• Laws Referred To: Income Tax Act, 1961
• Result in Favour of: Assessee
• Court: TRIBUNAL
• Assessee Lawyers: ASSESSEE
• Keywords: Set aside; Capital asset; Reassessment proceedings; Sale consideration of property below Jantri Value; Fair market value; Cost of acquisition; Capital Gains
• Section: 147; 148; 143(3); 271(1)(c); 139; 50C

Judgement Text

"IN THE INCOME TAX APPELLATE TRIBUNAL “D” BENCH, MUMBAI SHRI VIKRAM SINGH YADAV, ACCOUNTANT MEMBER SHRI RAHUL CHAUDHARY, JUDICIAL MEMBER ITA No.3595/MUM/2025 (AY:2011-2012) ITA No.4073/MUM/2025 (AY:2011-2012) Income Tax Officer 41(2)(4), Mumbai Room No.836. 8th Floor, Kautilya Bhavan, G- Block, BKC, Bandra (East) Mumbai – 400051. Maharashtra. …………. Appellant RBI Employees Bhagvati Co-op. Housing Society Ltd. A/15, RBI Employees Bhagvat CHS Ltd., Hutatama Chaphekar Bandhu Marg, Mulund East S.O. Mumbai – 400081 Maharashtra [PAN:AAAAR8956] Vs …………. Respondent Cross Objection No.243/Mum/2025 (In ITA No.3595/Mum/2025) (Assessment Year:2011-2012) RBI Employees Bhagvati Co-op. Housing Society Ltd. A/15, RBI Employees Bhagvat CHS Ltd., Hutatama Chaphekar Bandhu Marg, Mulund East S.O. Mumbai – 400081. Maharashtra [PAN:AAAAR8956] …………. Appellant Income Tax Officer 41(2)(4), Mumbai Room No.836. 8th Floor, Kautilya Bhavan, G- Block, BKC, Bandra (East) Mumbai – 400051. Maharashtra. Vs …………. Respondent Appearance For the Appellant/Department For the Respondent/Assessee : : Shri Annavaran Kosuri Shri Fenil Bhatt Date Conclusion of hearing Pronouncement of order : : 01.10.2025 27.10.2025 O R D E R [ Per Rahul Chaudhary, Judicial Member: 1. This batch of matters consists of (a) appeal preferred by the Revenue pertaining to Assessment Years 2011-2012 Printed from counselvise.com ITA No.3595&4073/Mum/2025 C.O. No.243/Mum/2025 Assessment Year 2011-2012 2 (b) Cross Objections filed by the Assessee in the aforesaid appeal preferred by the Revenue and (c) appeal preferred by the Revenue against penalty levied under Section 271(1)(c) of the Income Tax Act, 1961 (hereinafter referred to as ‘the Act’) for the Assessment Year 2011-2012. ITA No.3595/Mum/2025 [Assessment Year 2011-2012] 2. First we would take up appeal preferred by the Revenue for the Assessment Year 2011-2012 against the Order, dated 15/04/2025, passed by the National Faceless Appeal Centre (NFAC), Delhi [hereinafter referred to as the ‘CIT(A)’], whereby the Ld. CIT(A) had partly allowed the appeal of the Assessee against the Assessment Order, dated 10/12/2018, passed under Section 143(3) read with Section 147 of the Act. 2.1. The Revenue has raised following grounds of appeal in ITA No.3595/Mum/2025 [Assessment Year 2011-2012] : “1. On the facts and in the circumstances of the case, AMD in law, the Ld. CIT(A) erred in deleting the addition of Rs.4,97,63,657/- made by the Assessing Officer as Short Term Capital Gain on account of transfer of development rights under a registered development agreement, despite clear applicability of Section 2(47)(v) read with Section 50C of the Income-tax Act, 1961. 2. On the facts and in the circumstances of the case, and in law, the Ld. CIT(A) erred in holding that the income from redevelopment transactions is not taxable in the hands of the society but in the hands of individual members, without appreciating that the registered agreement was executed by the society and all rights, including the receipt of consideration, were exercised by the society as a legal entity. Printed from counselvise.com ITA No.3595&4073/Mum/2025 C.O. No.243/Mum/2025 Assessment Year 2011-2012 3 3. On the facts and in the circumstances of the case, AMD in law, the Ld. CIT(A) erred in accepting the assessee‟s argument that development rights have “no cost of acquisition” AMD hence not taxable, ignoring the legal position that Section 50C specifically applies to transfer of land or building or rights therein. AMD the valuation for stamp duty purposes is a valid mechanism for computing capital gain under section 48. 4. On the facts and in the circumstances of the case, the Ld. CIT(A) erred in treating the receipt of Rs.10,00,000/- as mere security deposit and not a part of the consideration, despite evidence that the agreement had commercial substance and irrevocable rights were transferred to the developer during the year under consideration. 5. On the facts and in the circumstances of the case, the Ld. CIT(A) failed to appreciate that all conditions of Section 2(47)(v) read with Section 53A of the Transfer of Property Act 1882 were satisfied, as the development agreement was registered, irrevocable and possession was constructively parted with, thereby constituting a transfer in the year under consideration. 6. The Ld. CIT(A) erred in allowing the appeal despite the fact that the assessee had not filed any return of income voluntarily under section 139 and only filed a return in response to notice under section 148, which indicated prima facie Concealment of taxable income and warranted addition based on available the materials with the Assessing Officer.” 3. The relevant facts in brief are that the Assessee, a Co-operative Housing Society registered under Maharashtra Co-operative Housing Society Act 1960, did not filed return of income for the Assessment Year 2011-2012. The Assessing Officer received information that the Assessee had entered into an agreement with M/s Chetan Enterprises on 09/11/2010 [hereinafter referred to as ‘the Development Agreement’] for a consideration of INR.37,67,500/- and had paid stamp duty of INR.27,76,850/- whereas the applicable Stamp Duty Value was INR.5,55,37,000/-. Further the Assessee had Printed from counselvise.com ITA No.3595&4073/Mum/2025 C.O. No.243/Mum/2025 Assessment Year 2011-2012 4 received interest-free refundable deposit of INR.1,00,000/- in terms of the aforesaid Development Agreement. Therefore reassessment proceedings were initiated in case of the Assessee under Section 147 of the Act. In response to notice issued under Section 148 of the Act, the Assessee filed return of income for the Assessment Year 2011-2012 on 28/04/2018 declaring ‘Nil’ income. The aforesaid reassessment proceedings culminated into passing of Assessment Order, dated 10/12/2018, under Section 143(3) read with Section 147 of the Act whereby an addition of INR.4,97,60,657/- was made in the hands of the Assessee as Short Term Capital Gains taxable at the rate of 30%. 4. Aggrieved by the above addition made by the Assessing Officer, the Assessee filed appeal before the Ld. CIT(A). Since the Assessee was non-responsive to the notices issued during the appeal proceedings and the Ld. CIT(A) passed ex-parte order under Section 250 of the Act on 27/12/2021 dismissing the appeal of the Assessee. However, in appeal preferred by the Assessee, vide Order dated 27/06/2022, the Tribunal set aside the order passed by the Ld. CIT(A) and restored appeal back to the file of the Ld. CIT(A) to pass fresh order as per law. 5. As per the directions of the Tribunal, after taking into consideration the written submissions on 15/04/2024, 30/04/2024 & 11/03/2025 filed by the Assessee, the Ld. CIT(A) disposed off the appeal preferred by the Assessee vide order dated 15/04/2025 impugned by way of present appeal. The Ld. CIT(A) accepted the contention of the Assessee that the consideration received in terms of the Development Agreement was not liable to tax in the hands of the Assessee and the same was taxable in the hands of the members of the cooperative society. Therefore, the addition of INR.4,97,60,657/- made by the Assessing Officer in the hands of the Assessee was deleted. Printed from counselvise.com ITA No.3595&4073/Mum/2025 C.O. No.243/Mum/2025 Assessment Year 2011-2012 5 6. Being aggrieved the Revenue has preferred the present appeal before the Tribunal on the ground to produce in paragraph 2 above. 7. We have heard both the sides and perused the material on record. 8. During the course of hearing the learned Departmental Representative placed reliance upon the Assessment Order and submitted that the Ld. CIT(A) had failed to appreciate that the Assessee had entered into a Development Agreement with the builder and therefore, the consideration was liable to be taxed in the hands of the Assessee only. Referring to the financial statements of the Assessee-Society, the learned Departmental Representative submitted that the society had shown the land and building under the head fixed assets and therefore, the Assessee should be regarded as its owner. 9. Per contra the Learned Authorised Representative for the Assessee placed reliance upon Paragraph 7.1 and 8 of the order impugned passed by Ld. CIT(A) and submitted that there was no infirmity in the order passed by the Ld. CIT(A), since the Ld. CIT(A) had followed the binding Circular No.9 [F.No.8/2/69-IT(A-I)], dated 25/02/1969 issued by Central Board of Direct Taxes which provided that the ownership of flats vested in the individual members themselves and not in the hands of cooperative society. Though the Assessee had entered into a re-development agreement with the builders the real owners of the flats were the individual members occupying the flats in the society. Reliance will also placed upon the decision of the Tribunal in the case of Raj Ratan Palace Co. Op. Hsg. Society Ltd, Vs. Deputy Commissioner of Income Tax, Circle 25(3), dated 25/02/2011 reported in [2011] 12 taxmann.com 172 (Mumbai) in this regard. 10. We have considered the rival submissions and have perused the Printed from counselvise.com ITA No.3595&4073/Mum/2025 C.O. No.243/Mum/2025 Assessment Year 2011-2012 6 material on record. 11. We find that Ld. CIT(A), while deleting the addition made by Assessing Officer, concluded as under: “7.1. The written submissions of the appellant are carefully perused. The appellant has raised 3 propositions on the issue of taxability of Short Term capital Gains as under without prejudice to each other: Proposition I - Income accruing to the members of the Appellant society in cash/kind is not taxable in the hands of Appellant: Proposition II – in the absence of „cost of acquisition‟, computation mechanism u/s. 48 of the Act fails and therefore no capital gains attracted to transfer of development right: Proposition III - Taxable event not in the current year. 7.2 Vide proposition 1, the appellant has stated that in the present case, the individual members are the owners of their respective flats and that the society is merely entering the re- development agreement on behalf its members, the consideration so received is taxable in the hands of members and not the Appellant society. Further, the appellant placing reliance on the Board Circular No. 9 in F.No. 8/2/69-IT(A-I)], dated 25-03-1969 has stated that circular clearly states that the legal ownership in the flats can be said to vest in the individual members themselves and not in the co-operative society. The appellant also placed reliance on the judgements of the Hon‟ble Supreme Court in the case of CIT v. Poddar Cement Pvt. Ltd. (SC) AIR 1997, Mysore Minerals Ltd. v. CIT 239 ITR 775 (SC) and Hon‟ble Jurisdictional Tribunal in Raj Ratan Co. Op. Hsg. Society Ltd. v. DCIT (12 taxmann.com 172)(Trib. Mumbai). 7.3. In the present case the individual members of the society purchased the respective flats from builder and thereafter they constituted a cooperative housing society. All the flats in the building and land appurtenant thereto belong to the members of the appellant and do not belong to the Appellant itself. The Members are the real owners of old flats which were transferred to developer for exchange of new flats with more space. Though the appellant society made a redevelopment Printed from counselvise.com ITA No.3595&4073/Mum/2025 C.O. No.243/Mum/2025 Assessment Year 2011-2012 7 agreement with the builder, the real owners of the property are the individual members who enjoy the full rights of the property. As held by the AO, the appellant had received Rs.10,00,000/- from the builder. However, this amount is a security provided by the developer to complete the project and would be refunded on receiving occupation certificate. The decision of Hon‟ble ITAT, Mumbai in Raj Ratan Co. Op. Hsg. Society Ltd. v. DCIT (12 taxmann.com 172)(Trib. Mumbai), relied by the appellant squarely covers the present case. In the said case, the Hon‟ble ITAT has held that incidence of taxation will be in the hands of the individual members and not in the hands of the society and mere grant of consent would not amount to transfer of land/or any rights therein. In view of the facts & circumstances of the case, the claim of the appellant in proposition I that the consideration so received is taxable in the hands of members and not the Appellant society is found to be acceptable. Therefore, the AO is directed to delete the addition of Rs.4,97,63,657/- in the hands of the appellant. Further, as the Proposition I is decided positively, remaining propositions II & III become academic in nature. Accordingly, ground no 1 & 3 raised by the appellant are treated as allowed. 8. Ground no 4 is related to the issue of AO not allowing the appellant the option of substituting the F.M.V as on 1.4.1981 duly indexed in term of section 55 r.w.s 48 of the Act. The appellant made arguments that if it is held that Capital Gain is charged to tax then the AO be directed to allow deduction in respect of F.M.V as on 1 .4.1981 duly indexed as per law. However, since the total addition made as Short term capital Gain is deleted vide discussion in preceding paras with regard to ground no 1 & 3, the present ground no 4 becomes academic in nature. Accordingly, no separate adjudication is required on this ground. 12. On perusal above, we the find that the Ld. CIT(A) as returned a finding that the Assessee had only received a refundable deposit of INR.10,00,000/-. We have perused a copy of the Development Agreement placed on record by the Assessee. On perusal of the same, we find that as per the agreed terms, the consideration was to flow to the individual members of the Assessee and the Assessee had only received refundable deposit of INR.10,00,000/-. Thus, we concur with the finding returned by the Ld. CIT(A) that the Printed from counselvise.com ITA No.3595&4073/Mum/2025 C.O. No.243/Mum/2025 Assessment Year 2011-2012 8 individual members were the owners of respective flats and that Assessee had entered into Development Agreement in the capacity of the representative of the flat owners/members. Schedule to the development agreement clearly provided down the list of members who were to receive consideration in terms of the Development Agreement. Following Clauses of the Development Agreement support the conclusion drawn by Ld. CIT(A) is as under : “7. The Builders/Developers shall provide to each of the present members of the said Society occupying the flats in the said Old Building as per the details setout in the Second Schedule hereunder written, the Member Premise free of any cost and on ownership basis. Such Members premises shall have an additional carpet are of 20% over and above the carpet areas of the old premises in the present occupation of the said Existing Members of the Society hereunder written. The Members Premises as aforesaid to be allotted to the said Existing Members shall be between 2nd to 13th floors of the said Building. The Builders/Developers shall provide in the said Members Premises the amenities and specifications as stated in the Third Schedule hereunder written and quality of the amenities to be provided shall be strictly as per the Offer Letter dated 07-10-2008 issued by the Developers to the Society. 8 to 11. xx xx 12. The Developers have ascertained the availability of T.D.R./FAR for use of this plot and due to that have found the viability of the said Development project before execution of these presents. The Developers shall obtain I.O.D. and also Commencement Certificate within a period of 6 (six) months from execution of this Development Agreement and General Power of Attorney, subject to fulfillment and compliances of the requirements that may be made by MCGM as per its D. C. Regulations and the Society and the said Existing Members extending co-operation and assistance for the same from time to time. (T.D.R. in the name of society shall be bought by the Development before I.O.D.). 13. Within a period of 30 (Thirty) days from the intimation by the Developers to the Society regarding sanction of the plan, the Printed from counselvise.com ITA No.3595&4073/Mum/2025 C.O. No.243/Mum/2025 Assessment Year 2011-2012 9 Society shall confirm exact identity of the New Flats to be allotted to the Existing Members of the Society vis-à-vis that is provided herein and the details in respect thereof shall be submitted to the Developers. At such time, if required under the law individual Agreement/s between the Developers and the said Existing Members of the Society for allotment of New Flats under the provisions of the Ownership Act shall be executed and registered. However, each said Existing Members shall bear and pay stamp duty, registration charges and other incidental charges related thereto. 14. If any said Existing Members of the Society intends to buy additional area from salcable components over and above agreed area by the Developers then such flat Purchasers shall pay to the Developers for additional area as follows:- (i) for additional area upto 50 sq.ft. Carpet Rs.7,000/- per sq. ft. (ii) for additional area from 51 sq. ft. to 100 sq. ft. Carpet Rs.8,400/- per sq. ft. (iii) for additional area above 100 sq. ft. Carpet Rs.9,100/- per sq. ft. It is specifically agreed that the Stamp Duty in respect of the aforesaid additional premises shall be borne and paid by the respective members of the Society. 15. The Transit Compensation payable to each of the said Existing Members occupying the flats in the said Old Building shall be calculated at the rate of Rs.30/- (Rupees Thirty only) per square feet (carpet area) per month of the old flats in the Old Building in the respective occupation of the said Existing Members of the Society (hereinafter referred to as the „Transit Compensation‟). The Builders/Developers shall pay to the Existing Members of the Society occupying the said Old Building the Transit compensation for the period of 26 (twenty six) month from the date of the last Existing Members of the Society vacating his/her respective premises until the date of the said Members Premises are constructed and offered to the Existing Members of the Society. Upon payment of the said Transit Compensation the Builders/Developers shall not be liable to provide transit accommodation to the Existing Members of the Society. The said Transit Compensation shall be paid by the Builders/Developers to each of the said Existing Members of the Society in the manner as follows: Printed from counselvise.com ITA No.3595&4073/Mum/2025 C.O. No.243/Mum/2025 Assessment Year 2011-2012 10 (i). The aggregate Transit Compensation for the initial period of 3 (three) months shall be paid to each of the said Existing Members at the time of vacating their respective Premises in the said Old Building; (ii) The post-dated cheque for the subsequent period of 23 (twenty three) months at the time of vacating the flat by respective members. The Developers shall hand over the aforesaid post dated cheque to each of the said Existing Members with a express undertaking that Developers shall make all necessary arrangements for encashment of the said cheque as and when presented by each and or by any of the Existing Members. It is specifically agreed that in the event any of the aforesaid cheque that may be handed over by the Developers to the Existing Members if returned dishonored for any reason whatsoever the Developers shall pay Rs.5000/- per month as and by way of penal interest to Such Existing Member till the default continues over and above the amount of such cheque. (iii) The Developers shall pay refundable security deposit to Existing Members of the society of Rs.50,000/- for 1 Room kitchen Rs.1,00,000/- for 1 BHK & Rs.1,20,000/- for 2 BHK. It is specifically agreed by the society that before accepting the possession of new flats from the Developers, each of the said Existing Members shall refund the security deposit to the Developers.” 13. In view of the above, we do not find any infirmity in the conclusion drawn by Ld. CIT(A). Accordingly, Ground No. 1 to 6 raised by the revenue are dismissed. 14. In result appeal preferred by the revenue is dismissed. Cross Objection No.243/Mum/2025 [Assessment Year 2011- 2012] 15. Now we would take up Cross Objection preferred by the Assessee for the Assessment Year 2011-2012 16. The Assessee has raised following grounds of appeal in Cross Printed from counselvise.com ITA No.3595&4073/Mum/2025 C.O. No.243/Mum/2025 Assessment Year 2011-2012 11 Objection No.243/Mum/2025 [Assessment Year 2011-2012] : “1. On the facts and in the circumstances of the case and in law, the Commissioner of Income tax (Appeals) (“Ld. CIT(A)) erred in confirming the action of the Ld. Assessing Officer (“Ld. A.O”) in issuing notice u/s.148 of the Act and consequently passing an order u/s.143(3) r.w.s. 147 of the Act without appreciating that the jurisdictional requirements under sections 147 to 151 of the Act are not satisfied. 2. The Cross Objector therefore prays that the reassessment proceedings initiated by the Ld. AO be held as null and viod ab initio, and the order passed u/s.143(36) r.w.s. 147 of the Act be annulled. Without prejudice to the above, challenge on the merits of the addition: 3. On the facts and in the circumstances of the case and in law, the Ld. CIT(A) erred in not holding that even otherwise, no addition could be sustained under section 50C of the Act amounting to Rs.4,97,63,657. 4. The Cross Objector prays that the addition under section 50C of the Act amounting to Rs.4,97,63,657 of the Act be deleted. 5. On the facts and in the circumstances of the case and in law, the Ld. CIT(A) erred in not treating the transfer of immovable property as a long term capital asset and substituting the cost of acquisition of the immovable property with Fair Market Value as on April 1, 1981 as provided under section 48 read with section 55 of the Act granting indexed cost of acquisition thereon. 6. The Cross Objector prays that the Ld. AO be directed to treat the transfer of immovable property as long term capital asset and the Fair Market Value of the immovable property as on April 1, 1981 as the Cost of acquisition of immovable property and allow indexed cost of acquisition on the same.” 17. Since we have dismissed the appeal preferred by the Revenue, the Cross objection filed by the Assessee are dismissed as having been Printed from counselvise.com ITA No.3595&4073/Mum/2025 C.O. No.243/Mum/2025 Assessment Year 2011-2012 12 rendered infructuous. ITA No.4073/Mum/2025 [Assessment Year 2011-2012] 18. Now we would take up appeal preferred by the Revenue for the Assessment Year 2011-2012 against the Order, dated 22/04/2025, passed by the Ld. CIT(A), whereby the Ld. CIT(A) had allowed the appeal of the Assessee against the Penalty Order, dated 01/03/2022, passed under Section 271(1)(c) of the Act. 2.2. The Revenue has raised following grounds of appeal in ITA No.4073/Mum/2025 [Assessment Year 2011-2012] : “1. On the facts and circumstances of the case and in law, the Ld. CIT(A) erred in deleting the penalty of Rs.1,53,76,971/- levied u/s.271(1)(c) without appreciating that the assessee failed to offer any satisfactory explanation during penalty proceedings and that the quantum addition of Rs.4,97,63,657/- was still under challenge before the Hon‟ble ITAT and had not attained finality? 2. On the facts and circumstances of the case and in law, the Ld. CIT(A) erred in annulling the penalty merely on the basis of deletion of quantum addition, ignoring the well-settled principle that penalty proceedings are independent and must be adjudicated on merits irrespective of quantum appeal pendency? 19. In the quantum proceedings the appeal preferred by the Revenue has been dismissed. As a result, order of the Ld. CIT(A) deleting the addition forming the basis of penalty proceedings stands has been confirmed. Accordingly, we do not find any reason to interfere with the order passed by the Learned CIT(A) deleting penalty of INR.1,53,76,971/- levied by the Assessing Officer. Therefore, all the Printed from counselvise.com ITA No.3595&4073/Mum/2025 C.O. No.243/Mum/2025 Assessment Year 2011-2012 13 grounds raised by the Revenue are dismissed. 20. In result, the appeal preferred by the Revenue is dismissed. 21. In result, the both the appeals preferred by the Revenue and the cross-objections raised by the Assessee are dismissed, Order pronounced on 27.10.2025. Sd/- Sd/- (Vikram Singh Yadav) Accountant Member (Rahul Chaudhary) Judicial Member म ुंबई Mumbai; दिन ुंक Dated : 27.10.2025 Milan,LDC Printed from counselvise.com ITA No.3595&4073/Mum/2025 C.O. No.243/Mum/2025 Assessment Year 2011-2012 14 आदेश की प्रतितिति अग्रेतिि/Copy of the Order forwarded to : 1. अपील र्थी / The Appellant 2. प्रत्यर्थी / The Respondent. 3. आयकर आय क्त/ The CIT 4. प्रध न आयकर आय क्त / Pr.CIT 5. दिभ गीय प्रदिदनदध ,आयकर अपीलीय अदधकरण ,म ुंबई / DR, ITAT, Mumbai 6. ग र्ड फ ईल / Guard file. आिेश न स र/ BY ORDER, सत्य दपि प्रदि //True Copy// उप/सह यक पुंजीक र /(Dy./Asstt. Registrar) आयकर अपीलीय अदधकरण, म ुंबई / ITAT, Mumbai Printed from counselvise.com "