PRITI POTPHODE, MUMBAI V. INCOME TAX OFFICER WARD-3, PALGHAR

ITA 4129/MUM/2018

• Counselvise Citation: [2020] 110 COUNSELVISE.COM (IT) 9577 (ITAT-MUMBAI)
• Duration Of Justice: 2 year(s) 27 day(s)
• Appeal Type: Income Tax Appeal
• Pronouncement Date: 08-07-2020
• Appeal Filed By: Assessee
• Order Result: Allowed
• Bench Allotted: C
• Assessment Year: 2014-2015
• Appeal Filed On: 11-06-2018
• Result in Favour of: Assessee
• Court: TRIBUNAL
• Department Lawyers: KUMAR PADMA
• Keywords: Principle of natural justice; FORM 26AS
• Section: 201

Judgement Text

IN THE INCOME TAX APPELLATE TRIBUNAL C , BENCH MUMBAI BEFORE SHRI C.N. PRASAD, JM & SHRI M.BALAGANESH, AM I TA NO. 4 1 29 /MUM/ 2018 ( ASSESSMENT YEAR : 2014 - 15 ) SMT . PRITI POTPHODE UMBER PADA, WADARE SAPHALE PALGHAR 401 102 VS. INCOME TAX OFFICER - WARD - 3 AAYAKAR BHAVAN BIDCO ROAD PALGHAR 401 404 PAN/GIR NO. AJHPM9841M (APPELLANT ) .. (RESPONDENT ) ASSESSEE BY MS. CHAITEE LONDHE REVENUE BY SHRI KUMAR PADMAPANI BORA DATE OF HEARING 03 / 02 /2020 DATE OF PRONO U NCEMENT 08 / 07 /2020 / O R D E R PER M. BALAGANESH (A.M) : THIS APPEAL IN ITA NO. 429/MUM/2018 FOR A.Y. 201 4 - 15 ARISES OUT OF THE ORDER BY THE LD. COMMISSIONER OF INCOME TAX (APPEALS) - 3 , MUMBAI IN APPEAL NO. CIT(A) - 10581 - THN/16 - 17 DATED 15/03/2 018 (LD. CI T(A) IN SHORT) AGAINST THE ORDER OF ASSESSMENT PASSED U/S.143(3) OF THE INCOME TAX ACT, 1961 (HEREINAFTER REFERRED TO AS ACT) DATED 27/12/201 6 BY THE LD. INCOME TAX OFFICER - WARD - 3, PALGHAR (HEREINAFTER REFERRED T O AS LD. AO). ITA NO . 4 1 29 /MUM/ 2018 SMT . PRITI P OTP HODE . 2 2. THE ONLY ISSUE TO BE DEC I DED IN THIS APPEAL IS AS TO WHETHER THE LD. CIT(A) WAS JUSTIFIED IN CO NFIRMING THE ADDITION OF RS.57 , 31 , 862/ - IN THE FACTS AND CIRCU MSTANCES OF THE CASE. 3. WE HAVE HEARD RIVAL SUBMISSIONS AND PERUSED THE MATERIALS AVAILABLE ON RECORD. WE FIND THAT THE A S SESSEE IS AN INDIV IDUAL ENGAGED IN THE BUSINESS OF SEALING SYSTEM THAT CAN PREVENT THEFT, TAMPER ING, AD ULTERATIO N AND PILFERAGE OF MATERIALS . THE GROSS RECEIPTS OF THE ASSESSEE AS P ER FORM 26AS OF RS.3 , 03 , 62 , 555/ - WHEREAS THE GROSS RECEIPTS AS PER PROFIT A ND LOSS ACCOUNT SHOWN BY THE ASSESSEE WAS AT RS.2 , 12 , 65 , 589/ - . DURING THE COURSE OF ASSESSMENT PROCEEDING S, ASSESSEE WAS ASKED TO RECONCILE THE SAID DIFFERENCE . DURING THE COURSE OF ASSESSMENT PROCEEDINGS, ASSESSEE FILED RECON CILIATION STATEMENT AND ALSO S UBMITTED THAT THE SAME BUSINESS WA S CARRIED OUT I N THE NAME OF PRIVATE LIMITED COMPANY FLO ATED BY THE ASSESSEE W.E.F. 01/10/2013 AND THAT THE PERMANENT ACC OUNT NUMBER (PAN) FOR THE PRI VATE LIMITED COMPANY WAS NOT INTIMATE D PRO PERLY TO ALL THE CLIENTS OF TH E ASSESSEE . HENCE, CERTAIN INCOME HAD BEEN REFLECTED IN THE FORM 26AS IN THE INDIVIDUAL PAN O F THE ASSESSEE, WHEREAS THE CORRESPONDING INCOME HAS BEEN SHOWN IN THE HANDS OF THE PRIVATE LIMITED COMPANY. THE ASSESSEE EVEN GAVE THE LIST OF NAMES AND ADDRESSES OF THE PARTIES FROM WHOM MONIES WERE RECEIVED BOTH BY HIM AS WELL AS BY THE PRIVATE LIMITED COMPANY BEFORE THE LD. AO. THE LD. AO SOUGHT TO MAKE VERIFICATION OF THO SE PARTIES BY ISSUING NOTICES U/S.13 3( 6 ) OF THE ACT. SOME PART IES RE SPONDED DIRECTLY TO THE LD. AO T O THE SAID NOTICE WHICH W ERE DULY ACCEPTED BY THE LD. AO IN THE ASSESSMENT PRO CEEDINGS. IN R ESPECT OF PARTIES WHO DID NOT RESPOND, THE LD. AO DISBELIE VED THE EXP LANATION OF THE ASSESSEE AND PROCEEDED TO MAKE ADDITION OF R S.57,31,862/ - FOR THE DI FF ERENCE IN GROSS RECEIPTS BETW EEN THE AMOUNT SHOWN BY THE ASSESSEE AND FORM 26 AS. ITA NO . 4 1 29 /MUM/ 2018 SMT . PRITI P OTP HODE . 3 3.1. BEFORE THE LD. CIT(A), THE ASSESSEE FILED CONFIRMATION FROM TWO PARTIES EXPLAINING THE DIFFERENCE TO SOME EXTENT . THE LD. CIT(A) CALLED FOR A REMAND REP ORT FRO M THE LD . A O. THE LD. AO HELD THAT THE FRESH CONFIRMATION FILED BEFORE THE LD. CIT(A) SHOULD NOT BE ENTERTAINED BY THE LD. CIT(A). THE ASSESSEE HAD ALSO FI LED A DET AILED RECONCILIATION STATEMENT BEFORE THE LD. AO IN THE REMAND PROCEEDI NGS GIV ING THE COMPLE TE BREAK - UP OF INCOME OFFERED IN INDIVIDUAL HANDS AS WELL AS IN THE HANDS OF THE COMPANY. THE LD. CIT(A) ACCE PTED THE VERSION OF THE LD. AO IN THE REMAND REPORT AND CONFIRMED THE ADDITION OF RS.57 , 31 , 862/ - FOR THE DIFFEREN CE IN THE RECEIPT SHOWN BY T HE ASSESSEE AND T HAT REFLECTED ON 26AS. 4. FROM THE AFORESAID NARRATION OF FACTS AND ON HEARING BOTH THE PARTIES, WE FIND THAT IN COME WAS RECEIVED BY THE ASSESSEE BOTH IN HER INDIVIDUAL HANDS (PROPRIET ARY CONCER N) AND ALSO IN THE HANDS OF THE N EWLY FORMED PRIVATE LIMITED COMPANY . CONSIDERING THE FACTS THAT THERE SHOULD NOT BE ANY DOUBLE ADDITION MADE IN RESPECT OF THE SAME RECEIPT AND ALSO CONSIDERING THE DECISION OF THE HON BLE JURISDICTIONAL HIGH COUR T IN THE CASE OF S.GANESH IN THE INCOME TAX APPEAL NO. 1930/2011 DATED 1 8/03/2014, WE DEEM IT FI T AND APPROPRIATE IN THE INTEREST OF NATURAL JUSTICE AND FAIR PLAY, TO REMAND THIS ISSUE TO THE FILE OF THE LD. AO WITH A DIRECTION TO VERIFY THE DETAILED RECONCILIAT ION STATEMENT FILED BY THE ASSESSEE AND ALSO ENSURE THAT IF A PART I CU LAR RECEIPT HAS BEEN OFFERED IN THE HANDS OF THE PRIVATE LIMITED COMPANY, THE SAME SHOULD NOT BE CONSIDERED IN THE HANDS OF THE ASSESSEE INDIVIDUAL. THIS WOULD PREVENT DOUBLE ADDITION B EING MADE BY THE REVENUE. ACCORDINGLY, THE GROUND S RAISED BY THE ASS ESS EE ARE ALLOWED FOR STATISTICAL PURPOSES. 5 . IT IS PERTIN ENT TO MENTION HERE THAT THIS ORDER IS PRONOUNCED AFTER A PERI OD OF 90 DA YS FROM THE DATE OF CONCLUSION OF THE HEAR ING. IN THIS ITA NO . 4 1 29 /MUM/ 2018 SMT . PRITI P OTP HODE . 4 REGARD, WE PLACE RELIANCE ON THE DECISION OF CO - ORDINATE BENCH OF T HIS TRIBUNAL IN THE CASE OF JSW LTD IN ITA NOS. 6264 & 6103/M UM/2018 DATED 14.5.2020, WHEREIN THIS ISSUE HAS BEEN ADD RESSED IN DETAIL ALLOWING TIME TO PRONOUNCE THE ORDER BEYON D 90 DAYS FROM THE DATE OF CONCLUSION OF HEARING BY EXCLUDING THE DAYS FOR WHICH TH E LOCKDOWN ANNOUNCED BY THE GOVERNMENT WAS IN FORCE. THE RELEVANT OBSERVATIONS OF THIS TRIBUNAL IN THE SAID BINDI NG PRE CEDENT ARE AS UNDER: - 7. HOWEVER, BEFORE WE PART WITH THE MATTER, WE MUST DEAL WITH ONE PROCEDURAL ISSUE AS WELL. WHILE HEARING OF THE SE APPEALS WAS CONCLUDED ON 7TH JANUARY 2020, THIS ORDER THER EON IS BEING PRONOUNCED TODAY ON 14 TH DAY OF MAY, 2020, MUCH AFTER THE E XPIRY OF 90 DAYS FROM THE DATE OF CONCLUSI ON OF HEARING. WE ARE ALSO ALIVE TO THE FACT THAT RULE 34(5) OF THE INCOME TAX A PPE LLATE TRIBUNAL RULES 1963, WHICH DEALS WITH PRONOUNCEMENT OF ORDERS, PROVIDES AS FOLLOWS: (5) THE PRONOUNCEMENT MAY B E IN A NY OF THE FOLLOWING MANNERS : (A) THE BENCH MAY PRONOUN CE THE ORDER IMMEDIATELY UPON THE CONCLUSION OF THE HEARING. (B) IN CASE WHERE THE ORDER IS NOT PRONOUNCED IMMEDIATELY ON THE CONCLUSION OF THE HEARING, THE BENCH SHALL GIVE A D ATE FOR PRONOUNCEMENT. (C ) IN A CASE WHERE NO DATE OF PRONOUNCEMENT IS GIV EN BY THE BENCH, EVERY ENDEAVOUR SHALL BE MADE BY THE BENCH TO PRONOUNCE THE ORDER WI THIN 60 DAYS FROM THE DATE ON WHICH THE HEARING OF THE C ASE WAS CONCLUDED BUT, WHERE IT IS NOT PRACTICABLE SO TO DO O N THE GROUND OF EXCEPTIONAL AND EXTRAORDINARY CIRCUMST ANCES OF THE CASE, THE BENCH SHALL FIX A FUTURE DAY FOR PRONOUNCEMENT OF THE ORDER, A ND SUCH DATE SHALL NOT ORDINARILY (EMPHASIS SUPPLIED BY US NOW) BE A DAY BEYOND A FURTHER PERI OD OF 30 DAYS AND DUE N O TICE OF THE DAY SO FIXED SHALL BE GIVEN ON THE NOTICE BOARD. 8 . QUITE CLEARLY, ORDINARILY THE ORDER ON AN APPEAL SHOULD BE PRONOUNCED B Y THE BENCH WITHIN NO MORE THAN 90 DAYS FROM THE DATE ITA NO . 4 1 29 /MUM/ 2018 SMT . PRITI P OTP HODE . 5 OF CONCLUDING THE HEARING. IT IS, HOWEVE R, IMPORTANT TO NOTE TH A T THE EXPRESSION ORDINARILY HAS BEEN USED IN THE SA ID RULE ITSELF. THIS RULE WAS INSERTED AS A RESULT OF DIRECTIONS OF HONBLE JURISDI CT IONAL HIGH COURT IN THE CASE OF SHIVSAGAR VEG RESTAURANT VS ACIT [(2009) 317 ITR 433 (BOM)] WH EREIN THEIR LORDSHIPS H AD, INTER ALIA, DIRECTED THAT WE, THEREFORE, DIRECT THE PRESIDENT OF THE APPELLATE TRIBUNAL TO FRAME AND LAY DOWN THE GUIDELINES IN THE S IMILAR LINES AS ARE LAID DOWN BY THE APEX COURT IN THE C ASE OF ANIL RAI (SUPRA) AND TO ISSUE A PPROPRIATE ADMINISTRATI V E DIRECTIONS TO ALL THE BENCHES OF THE TRIBUNAL IN TH AT BEHALF . WE HOPE AND TRUST THAT SUITABLE GUIDELINES SHALL BE FRAMED AND ISSUED BY T HE PRESIDENT OF THE APPELLATE TRIBUNAL WITHIN SHORTEST R EASONABLE TIME AND FOLLOWED STRICTLY B Y ALL THE BENCHES OF TH E TRIBUNAL. IN THE MEANWHILE ( EMPHASIS, BY UNDERLINING , SUPPLIED BY US NOW ), ALL THE REVISIONAL AND APPELLATE AUTHORITIES UNDER THE INCOM E - TAX ACT ARE DIRECTED TO DECIDE MATTERS HEARD BY THEM WIT HIN A PERIOD OF THREE MONTHS FROM THE DATE CASE IS CLOSED FOR JUDGMENT . IN THE RULED SO FRAMED, AS A RESULT OF THE SE DIRECTIONS, THE EXPRESSION ORDINARILY HAS BEEN INSERTED IN THE REQUIREMENT TO PR ONOUNCE THE ORDER WITHIN A PERIOD OF 90 DAYS. THE QUESTI ON THEN ARISES WHETHER THE PASSING OF THIS ORDER, BEYOND NINE T Y DAYS, WAS NECESSITATED BY ANY EXTRAORDINARY CIRCU MSTANCES. 9 . LET US IN THIS LIGHT REVERT TO THE PREVAILING SITUATION IN THE COUNT RY . ON 24TH MARCH, 2020, HONBLE PRIME MINISTER OF INDIA T OOK THE BOLD STEP OF IMPOSING A NATION WIDE LOCKDOWN, FOR 21 D A YS, TO PREVENT THE SPREAD OF COVID 19 EPIDEMIC, AND T HIS LOCKDOWN WAS EXTENDED FROM TIME TO TIME. AS A MATTER OF FACT, EVEN BEFORE THIS FO RMAL NATIONWIDE LOCKDOWN, THE FUNCTIONING OF THE INCOME TAX APPELLATE TRIBUNAL AT MUMBAI WAS S EVERELY RESTRICTED ON A C COUNT OF LOCKDOWN BY THE MAHARASHTRA GOVERNMENT, AND ON ACCOUNT OF STRICT ENFORCEMENT OF HEALTH ADVISORIES WITH A VIEW OF CHECKING SPREA D OF COVID 19. THE EPIDEMIC SITUATION IN MUMBAI BEING GRAV E, THERE WAS NOT MUCH OF A RELAXATION IN SUBSEQUENT LOCKDOWNS ALSO. IN ANY CASE, THERE WAS UNPRECEDENTED DISRUPTION OF JUDICIAL WOK ALL OVER THE COUNTRY. AS A MATTER OF FACT, IT HAS BEEN SUCH AN UN PRECEDENTED SITUATION, CAUSING DISRUPTION IN THE FUNCTIO NING OF JUDICIAL MACHINERY, THAT HONB LE SUPREME COURT OF IND I A, IN AN UNPRECEDENTED ORDER IN THE HISTORY OF INDIA AND VIDE ORDER DATED 6.5.2020 READ WITH ORDER DATED 23.3.2020, EXTENDED THE LIMITAT IO N TO EXCLUDE NOT ONLY THIS LOCKDOWN PERIOD BUT ITA NO . 4 1 29 /MUM/ 2018 SMT . PRITI P OTP HODE . 6 ALSO A FE W MORE DAYS PRIOR TO, AND AFTER, THE L OCKDOWN BY OBSERVING TH A T IN CASE THE LIMITATION HAS EXPIRED AFTER 15.03.202 0 THEN THE PERIOD FROM 15.03.2020 TILL THE DATE ON WHICH THE LOCKDOWN IS LIFTED IN TH E JURISDICTIONAL AREA WHERE THE DISPUTE LIES OR WHERE TH E CAUSE OF ACTION ARISES SHALL BE EXTE NDED FOR A PERIOD OF 15 DAYS AFTER THE LIFTING OF LOCKDOWN . HONBLE BOMBAY H IGH COURT, IN AN ORDER DATED 15TH APRIL 2020, HAS, BESIDES EXTENDING THE VALIDITY O F ALL INTERIM ORDERS, HAS ALSO OBSERVED THAT, IT IS ALSO CLARIFIED THAT WHILE CALCULATING TIME FOR DISPOSAL OF MATTERS MADE TIME - BOUND BY THIS COURT, THE PERIOD FOR WHICH T HE ORDER DATED 26TH MARCH 2020 CONTINUES TO OPERATE SHALL BE ADDED AND TIME SHALL S TA ND EXTENDED ACCORDINGLY , AND ALSO OBSERVED THAT ARRANG EMENT CONTINUED BY AN ORDER DATED 26TH MARCH 2020 TILL 30TH A P RIL 2020 SHALL CONTINUE FURTHER TILL 15TH JUNE 2020 . IT HAS BEEN AN UNPRECEDENTED SITUATION NOT ONLY IN INDIA BUT ALL OVER T HE WORLD. GOVERNMENT OF INDIA HAS, VIDE NOTIFICATION DA TED 19 TH FEBRUARY 2020, TAKEN THE STAN D THAT, THE CORONAVIRUS SHOULD BE CONSIDERED A CASE OF NATURAL CALAMITY AND FMC (I.E. FORCE MAJEURE CLAUSE) MAYBE INVOKED, WHEREVER CONSIDERED APPROPRIATE, FOL LO WING THE DUE PROCEDURE. THE TERM FORCE MAJEURE HAS B EEN DEFINED IN BLACKS LAW DICTIONARY, AS AN EVENT OR EFFECT THAT CAN BE NEITHER ANTICIPATED NOR CONTROLLED WHEN SUCH IS THE POSITION, AND IT IS OFFICIALLY SO NOTIFIED BY THE GOVERNMENT OF INDIA A ND THE COVID - 19 EPIDEMIC HAS BEEN NOTIFIED AS A DISASTER U NDER THE NATIONAL DISASTER MANAGEMENT ACT, 2005, AND ALSO IN T HE LIGHT OF THE DISCUSSIONS ABOVE, THE PERIOD DURING WHICH LOCKDOWN WAS IN FORCE CAN BE ANYTHING BUT AN ORDINARY PERIOD. 10 .IN THE LIG HT OF THE ABOVE DISCUSSIONS, WE ARE OF THE CONSIDERED V IEW THAT RATHER THAN TAKING A PEDANTIC VIEW OF THE RULE REQUI R ING PRONOUNCEMENT OF ORDERS WITHIN 90 DAYS, DISREGARD ING THE IMPORTANT FACT THAT THE ENTIRE COUNTRY WAS IN LOCKDOWN, WE SHOULD COMPUTE T HE PERIOD OF 90 DAYS BY EXCLUDING AT LEAST THE PERIOD DURI NG WHICH THE LOCKDOWN WAS IN FORCE. WE MUST FACTOR GROUND REA L ITIES IN MIND WHILE INTERPRETING THE TIME LIMIT FOR T HE PRONOUNCEMENT OF THE ORDER. LAW IS NOT BROODING OMNIPOTENCE IN THE SKY. IT IS A PRA GMATIC TOOL OF THE SOCIAL ORDER. THE TENETS OF LAW BEIN G ENACTED ON THE BASIS OF PRAGMATISM, AND THAT IS HOW THE LAW IS REQUIRED TO INTERPRETED. THE INTERPRETATION SO ASS IGNED BY US IS NOT ONLY IN CONSONANCE WITH THE LETTER AND SPIRIT OF RULE 34(5) BUT IS ALSO A PRAGMATIC APPROACH AT A ITA NO . 4 1 29 /MUM/ 2018 SMT . PRITI P OTP HODE . 7 TIME WHEN A DISASTER, NO TIFIED UNDER THE DISASTER MANAGEMENT A CT 2005, IS CAUSING UNP R ECEDENTED DISRUPTION IN THE FUNCTIONING OF OUR JUSTIC E DELIVERY SYSTEM. UNDOUBTEDLY, IN THE CASE OF OTTERS CLUB VS DIT [(2017) 392 ITR 2 44 (BOM)] , HONBLE BOMBAY HIGH COURT DID NOT APPROVE AN OR DER BEING PASSED BY THE TRIBUNAL BEYON D A PERIOD OF 90 DAYS, B UT THEN IN THE PRESENT SITUATION HONBLE BOMBAY HIGH COURT ITSELF HAS, VIDE JUDGMENT DATED 15 TH APRIL 2020, HELD THAT DIRECTED WHILE C ALC ULATING THE TIME FOR DISPOSAL OF MATTERS MADE TIME - BOU ND BY THIS COURT, THE PERIOD FOR WHICH THE ORDER DATED 26TH M A RCH 2020 CONTINUES TO OPERATE SHALL BE ADDED AND TIM E SHALL STAND EXTENDED ACCORDINGLY . THE EXTRAORDINARY STEPS TAKEN SUO MOTU BY HON BLE JURISDICTIONAL HIGH COURT AND HONBLE SUPREME COURT AL SO INDICATE THAT THIS PERIOD OF LOCKDO WN CANNOT BE TREATED AS AN ORDINARY PERIOD DURING WHICH THE NORMAL TIME LIMIT S ARE TO REMAIN IN FORCE. IN OUR CONSIDERED VIEW, EVEN WITHOUT THE WORDS ORDINARIL Y, IN THE LIGHT OF THE ABOVE ANALYSIS OF THE LEGAL POSITI ON, THE PERIOD DURING WHICH LOCKOUT WA S IN FORCE IS TO EXCLUD E D FOR THE PURPOSE OF TIME LIMITS SET OUT IN RULE 34(5 ) OF THE APPELLATE TRIBUNAL RULES, 1963. VIEWED THUS, THE EXCEPTION, TO 90 - DAY TIME - LI MIT FOR PRONOUNCEMENT OF ORDERS, INHERENT IN RULE 34(5) (C), WITH RESPECT TO THE PRONOUNCEMENT OF ORDERS WITHIN NINET Y DAYS, CLEARLY COMES INTO PLAY IN THE PRESENT CASE. O F COURSE, THERE IS NO, AND THERE CANNOT BE ANY, BAR ON THE DISCRETION OF THE BENCHE S T O REFIX THE MATTERS FOR CLARIFICATIONS BECAUSE OF CONSI DERABLE TIME LAG BETWEEN THE POINT OF TIME WHEN THE HEARING I S CONCLUDED AND THE POINT OF TIME WHEN THE ORDER THERE ON IS BEING FINALIZED, BUT THEN, IN OUR CONSIDERED VIEW, NO SUCH EXERCISE WAS REQUI RED TO BE CARRIED OUT ON THE FACTS OF THIS CASE. 11. TO SUM UP, THE APPEAL OF THE ASSESSEE IS ALLOWED, AND APPEAL OF THE ASSESSING OFFICER IS DISMISSED. ORDER PRONOUNCED UNDER RULE 34(4) OF THE INCOME TAX (APPELLATE TRIBUNAL) RULES, 1962, BY PLACING THE DE TAILS ON THE NOTICE BOARD. 5 . 1. RESPECTFULLY FOLLOWIN G THE AFORESAID JUDICIAL PRECEDENT, W E PROCEED TO PRONOUNCE TH IS ORDER BEYOND A PERIOD OF 90 DAYS FROM THE DATE OF CONCLUSION OF HEARING. ITA NO . 4 1 29 /MUM/ 2018 SMT . PRITI P OTP HODE . 8 6 . IN THE RESULT, THE APPEAL OF THE ASSESSEE IS ALLOWED FO R STATISTICAL PURPOSES . ORDER PRONOUNCED AS PER RULE 34(5) OF ITAT RULES AND BY PLACIN G THE PRONOUNCEMENT LIST IN THE NOTICE BOARD ON 08 / 07 / 2020 . SD/ - ( C.N. PRASAD ) SD/ - (M.BALAGANESH) JUDICIAL MEMB ER ACCOUNTANT MEMBER MUMBAI ; DATED 08 / 07 / 2020 KARUNA , SR.PS COPY OF THE O RDER FORWARDED TO : BY ORDER, ( ASSTT. REGIST RAR) ITAT, MUMBAI 1. THE APPELLANT 2. THE RESPONDENT. 3. THE CIT(A), MUMBAI. 4. CIT 5. DR, ITA T, MUMBAI 6. GUARD FILE. //TRUE COPY//