ITO-22(1)(6), MUMBAI, MUMBAI V. ARCIL RETAIL LOAN PORTFOLIO- 001- A- TRUST, MUMBAI

ITA 4252/MUM/2025

AI Insights

The case involves the ARCIL Retail Loan Portfolio 001-A Trust, which was assessed by the Income Tax Officer (ITO) as an Association of Persons (AOP) and taxed accordingly. The trust, constituted under the SARFAESI Act, 2002, and RBI Guidelines, issued Security Receipts (SRs) to Qualified Institutional Buyers (QIBs) for the purpose of acquiring and resolving Non-Performing Assets (NPAs). The ITO's assessment was contested, leading to an appeal before the CIT(A), which ruled in favor of the trust, a decision later upheld by the Tribunal. The Tribunal's decision was based on the trust's revocable nature and the specific provisions of the Income-tax Act, particularly sections 61 to 63, which govern the taxation of income from revocable trusts.

• Counselvise Citation: [2026] 140 COUNSELVISE.COM (IT) 831927 (ITAT-MUMBAI)
• Duration Of Justice: 6 month(s) 27 day(s)
• Appeal Type: Income Tax Appeal
• Pronouncement Date: 22-01-2026
• Appeal Filed By: Department
• Order Result: Dismissed
• Bench Allotted: A
• Assessment Year: misc
• Appeal Filed On: 26-06-2025
• Other Referred Cases: Scheme A1 of ARCIL CPS 002 XI Trust for A.Y. 2013-14, ARCIL AARF-I-1 Trust for A.Y. 2013-14, Scheme A1 of ARCIL CPS 002 XIII Trust for A.Y. 2009-10, ARCIL Retail Loan Portfolio 004 B Trust for A.Y. 2016-17, ARCIL Retail Loan Portfolio 001 J Trust for A.Y. 2016-17, ARCIL Shalimar Wires Industries Ltd II Trust for A.Y. 2016-17
• Laws Referred To: Income-tax Act, 1961, SARFAESI Act, 2002, RBI Guidelines
• Result in Favour of: Assessee
• Court: TRIBUNAL
• Department Lawyers: SHRIRAJESH KUMAR YADAV
• Assessee Lawyers: JEET KAMDAR; DECISIONS OF
• Keywords: Set aside; Business income; Diversion of income; TDS; Search and seizure; Earning of tax free income; Revocable transfer
• Section: 143(3); 271(1)(c); 234B; 63

Judgement Text

" IN THE INCOME TAX APPELLATE TRIBUNAL “A” BENCH MUMBAI BEFORE SHRI AMIT SHUKLA, JUDICIAL MEMBER& SHRI MAKARAND VASANT MAHADEOKAR, ACCOUNTANT MEMBER ITA No. 4252/Mum/2025 (Assessment Year: 2016-17) ITO-22(1)(6), MUMBAI Room No. 206, 2nd Floor , Income Tax Office, Piramal Chamber Lalbaug, Parel, Mumbai -400012 Vs. ARCIL RETAIL LOAN PORTFOLIO – 001- A- TRUST 10th Floor, The Ruby, 29 Senapati Bapat Road, Dadar West, Mumbai Maharashtra - 400028 PAN/GIR No. AACTA0944P (Applicant) (Respondent) Assessee by ShriJeet Kamdar Revenue by ShriRajesh Kumar Yadav (CIT-DR) Date of Hearing 13.01.2026 Date of Pronouncement 22.01.2026 आदेश / ORDER PER MAKARAND VASANT MAHADEOKAR, AM: Printed from counselvise.com 2 ITA No. 4252/Mum/2025 ARCIL RETAIL LOAN PORTFOLIO- 001- A TRUST This appeal by the Revenue is directed against the order dated 03.04.2025 passed by the Commissioner of Income-tax (Appeals), National Faceless Appeal Centre, Delhi [hereinafter referred to as “CIT(A)”], under section 250 of the Income-tax Act, 1961 [hereinafter referred to as “the Act”], for Assessment Year 2016–17, arising out of the assessment order dated 27.12.2018 passed by the Income Tax Officer, Ward 21(1)(2), Mumbai [hereinafter referred to as “Assessing Officer or AO”], under section 143(3) of the Act. 2. Facts of the Case 2.1 The assessee filed its return of income for A.Y. 2016–17 on 29.09.2016 declaring total income at Rs. NIL. The assessee claimed exempt income of Rs. 27,63,75,223/- under section 61 read with section 63 of the Act and also claimed credit of TDS of Rs. 1,39,587/-. The return was processed under section 143(1) and the case was selected for complete scrutiny under CASS. 2.2 During the course of assessment proceedings the Assessing Officer noted that the assessee was constituted as a trust by Asset Reconstruction Company (India) Ltd. (ARCIL) pursuant to the provisions of the SARFAESI Act, 2002 and RBI Guidelines, for the purpose of acquisition and resolution of Non-Performing Assets. Funds were raised by issuance of Security Receipts (SRs) to Qualified Institutional Buyers. ARCIL functioned as settlor, trustee and asset manager of the trust. From the financial Printed from counselvise.com 3 ITA No. 4252/Mum/2025 ARCIL RETAIL LOAN PORTFOLIO- 001- A TRUST statements, the AO recorded that during the year the assessee had earned interest income of Rs. 14,11,256/- and surplus on realization of NPAs amounting to Rs. 30,19,34,691/-, against which protection, preservation and insurance expenses of Rs. 2,69,70,724/- were claimed. The net surplus of Rs. 27,63,75,223/- was claimed as exempt by the assessee. 2.3 The assessee submitted before the AO that it was a revocable determinate trust, that the income was taxable only in the hands of the SR holders in terms of sections 61 to 63 of the Act, and that the trust was merely a pass-through entity. It was further contended that the trust could not be assessed as an Association of Persons and that the principle of diversion of income by overriding title was applicable. 2.4 The Assessing Officer rejected the contentions of the assessee. He held that the assessee could not be regarded as a trust for the purposes of sections 61 to 63 of the Act and that, on the facts, the contributors and beneficiaries had joined in a common purpose of earning income. According to the AO, the assessee constituted an Association of Persons within the meaning of section 2(31) of the Act. The AO further held that the trust was neither revocable nor determinate, that the provisions of section 164 were attracted, and that even otherwise the assessee was liable to be assessed as an AOP. The claim of exemption under sections 61 to 63 was denied. The AO also disallowed the claim of protection, preservation and insurance Printed from counselvise.com 4 ITA No. 4252/Mum/2025 ARCIL RETAIL LOAN PORTFOLIO- 001- A TRUST expenses of Rs. 2,69,70,724/- and treated interest income as income from other sources. Accordingly, the AO assessed the total income of the assessee at Rs. 30,33,45,950/- and initiated penalty proceedings under sections 271(1)(b) and 271(1)(c) of the Act. 2.5 Aggrieved, the assessee carried the matter in appeal before the CIT(A). Before the CIT(A), the assessee reiterated that it was a trust constituted strictly in accordance with the SARFAESI Act and RBI Guidelines, that securitisation activity could be undertaken only through a trust structure, and that there was no common action or common management among the contributors. It was further submitted that the contributions of SR holders were revocable in terms of the trust deed and that the income was taxable only in the hands of the beneficiaries under sections 61 to 63 of the Act. 2.6 The assessee also contended that the trust was determinate, as the contributors and their respective shares were identifiable with reference to the trust deed and contribution agreements. Reliance was placed on various judicial precedents and on earlier decisions of coordinate benches of the Tribunal in the cases of other ARCIL securitisation trusts, wherein similar additions had been deleted. 3. The CIT(A) examined the facts and noted that the issue involved stood covered in favour of the assessee by decisions of Printed from counselvise.com 5 ITA No. 4252/Mum/2025 ARCIL RETAIL LOAN PORTFOLIO- 001- A TRUST the coordinate benches of the Tribunal on identical facts. Relying on such binding precedents, the CIT(A) held that the assessee could not be treated as an AOP and that the income was not taxable in its hands. Accordingly, the entire addition of Rs. 30,33,45,950/- made by the AO was directed to be deleted. The grounds relating to levy of interest under sections 234B and 234D were held to be consequential. Thus, the appeal of the assessee was allowed in full. 4. Aggrieved by the order of the CIT(A), the Revenue is in appeal before us and has raised following revised grounds: 1. The CIT(A) is not justified in deleting the entire addition of Rs.30,33,45,947/- made on account of business income, income from other sources, disallowances of Protection preservation, Insurance Expenses and Management Charge and interest income. 2. The CIT(A) has not appreciated the fact that the assessee is not arevocable trust since contributors have practically no over the income arisingout of the activities of the fund and the contribution can be revoked only withthe consent of the contributors holding 75% of the units and thus the assesseewill not be eligible for the benefit of section 61 to 63 of the I.T.Act not beingrevocabletrust. 3. The CIT(A) has ignored the fact that the assessee trust and the beneficiaries have joined in a common purpose or common action, the object of which was to produce income, profit and gains and therefore, the assessee is liable to be categorised as an AOP and has to be taxed accordingly. 4. The Ld. CIT(A) has not justified the action of the AO in treating the assessee as AOP based on nature of activity carried out by the Printed from counselvise.com 6 ITA No. 4252/Mum/2025 ARCIL RETAIL LOAN PORTFOLIO- 001- A TRUST assessee. The Ld.CIT(A) has ignored the fact that the assessee is engaged in business activity with a profit motive. 5. The appellant craves leave to amend or alter or add a new ground which may be necessary. 5. During the course of hearing, the learned Authorised Representative (AR) for the assessee reiterated the facts and submissions as placed on record before the lower authorities. The AR submitted that Asset Reconstruction Company (India) Ltd. (ARCIL) is registered with the Reserve Bank of India under section 3 of the Securitisation and Reconstruction of Financial Assets and Enforcement of Security Interest Act, 2002 (SARFAESI Act) as an Asset Reconstruction Company (ARC). It was submitted that ARCs are strictly regulated by the Reserve Bank of India and, in terms of the SARFAESI Act, no ARC can commence or carry on business without obtaining a certificate of registration from RBI. RBI has also issued detailed guidelines regulating the functioning of ARCs. 6. The AR submitted that the assessee trust was duly constituted by ARCIL by a declaration of trust dated 28.09.2007 in accordance with the Indian Trusts Act, 1882. The Assessing Officer erred in treating the assessee trust as an Association of Persons on the premise that there was a common purpose or common action. It was pointed out that, for the year under consideration, there was only one QIB, namely United Bank of India, and therefore the very foundation for invoking the concept of AOP was absent. The QIB merely applied for subscription to Printed from counselvise.com 7 ITA No. 4252/Mum/2025 ARCIL RETAIL LOAN PORTFOLIO- 001- A TRUST SRs and the trustee, in its discretion, allotted SRs in accordance with the trust deed. The AR invited attention to the relevant clause of the trust deed which provides that the trustee may accept contributions from investors pursuant to an offer document and, upon acceptance, issue Security Receipts on such terms and conditions as stipulated therein, entirely at the discretion of the trustee. 7. The AR placed reliance on the Budget Speech of the Hon‟ble Finance Minister while presenting the Finance Bill, 2016, wherein securitisation trusts, including those set up by ARCs, were expressly recognised as trusts and granted pass-through status. The relevant extract relied upon reads as under: “I propose to provide complete pass through of income-tax to securitization trusts including trusts of ARCs. The income will be taxed in the hands of the investors instead of the trust.” 8. It was submitted that the amendment introduced by the Finance Bill, 2016 was clarificatory in nature with respect to taxability and did not alter the classification of such entities. Reliance was also placed on the Memorandum to the Finance Bill, 2016, which states that the income of securitisation trusts shall continue to be exempt. 9. The learned Authorised Representative further submitted that the issue involved in the present appeal is no longer res Printed from counselvise.com 8 ITA No. 4252/Mum/2025 ARCIL RETAIL LOAN PORTFOLIO- 001- A TRUST integra and stands squarely covered in favour of the assessee by a series of decisions rendered by the co-ordinate Benches, on identical facts in the case of ARCIL securitisation trusts. It was submitted that in all such cases, the Co-ordinate Bench has consistently held that ARCIL-managed securitisation trusts cannot be assessed as an Association of Persons and that the income is not taxable in the hands of the trust. In this regard, the learned AR placed reliance on the following decisions, copies of which were placed in the paper book: 1. Order of the Income-tax Appellate Tribunal, „G‟ Bench, Mumbai, in the case ofScheme A1 of ARCIL CPS 002 XI Trust for A.Y. 2013–14(ITA No. 2293/Mum/2018). 2. Order of the Income-tax Appellate Tribunal, „A‟ Bench, Mumbai, in the case ofARCIL AARF-I-1 Trust for A.Y. 2013–14(ITA No. 7353/Mum/2019). 3. Order of the Income-tax Appellate Tribunal, „A‟ Bench, Mumbai, in the case ofScheme A1 of ARCIL CPS 002 XIII Trust for A.Y. 2009–10(ITA No. 434/Mum/2017). 4. Order of the Income-tax Appellate Tribunal, „A‟ Bench,Mumbai, in the case ofARCIL Retail Loan Portfolio 004 BTrust for A.Y. 2016–17(ITA No. 256/Mum/2024). 5. Order of the Income-tax Appellate Tribunal, „A‟ Bench,Mumbai, in the case ofARCIL Retail Loan Portfolio 001 J Trust (ITA No. 4199/Mum/2023) andARCIL Shalimar Wires Industries Ltd II Trust (ITA No. 2909/Mum/2023)for A.Y. 2016–17. Printed from counselvise.com 9 ITA No. 4252/Mum/2025 ARCIL RETAIL LOAN PORTFOLIO- 001- A TRUST 10. The learned AR submitted that the facts of the present case are pari materia with the facts considered in the aforesaid decisions, the statutory framework governing the assessee trust is identical, and there is no distinguishing feature brought on record by the Revenue. It was therefore contended that, following the principle of judicial consistency and discipline, the order passed by the learned CIT(A) deserves to be upheld and the appeal filed by the Revenue be dismissed. 11. Per contra, the learned Departmental Representative (DR) relied heavily on the order passed by the Assessing Officer and submitted that the learned CIT(A) has erred in granting relief to the assessee without properly appreciating the statutory scheme of sections 61 to 63 of the Act. It was submitted that the assessee has wrongly claimed the benefit of revocable transfer, whereas, on a correct reading of the trust deed and surrounding facts, the trust does not satisfy the conditions prescribed under section 63 of the Act. 11.1 In support of the above contention, the learned DR specifically drew attention to section 63 of the Act, and submitted that, in the present case, the trust deed does not provide for any re-transfer of income or assets to the transferor, nor does it confer a right upon the transferor to re-assume power over the income or assets in the manner contemplated by section 63(a). It was further contended that, in the absence of a valid revocable transfer within the meaning of section 63, the assessee cannot Printed from counselvise.com 10 ITA No. 4252/Mum/2025 ARCIL RETAIL LOAN PORTFOLIO- 001- A TRUST seek to escape assessment in its own hands by invoking sections 61 to 63. 12. The learnedDR, further, submitted that the Assessing Officer has rightly held that the assessee trust is not entitled to pass-through treatment and that the income has been correctly assessed in the hands of the assessee by treating it as an Association of Persons, having regard to the nature of activities carried on and the manner in which income is generated. The learned DR, therefore, submitted that the order of the Assessing Officer deserves to be restored and the order passed by the learned CIT(A) deleting the addition be set aside. 13. In rejoinder, the learned AR invited our attention to the specific provisions of the Trust Deed governing revocation of contributions, and submitted that the contention of the learned DR that the trust is not revocable within the meaning of section 63 of the Act is contrary to the express contractual terms. The learned AR submitted that Clause 5.2 of the Trust Deed expressly provides for revocation of contributions by the Security Receipt Holders, and therefore the transfer squarely falls within the ambit of a “revocable transfer” as defined in section 63(a) of the Act. 14. We have carefully considered the rival submissions, perused the orders of the Assessing Officer and the learned CIT(A), examined the Trust Deed placed on record, and analysed the statutory provisions and judicial precedents relied upon by both Printed from counselvise.com 11 ITA No. 4252/Mum/2025 ARCIL RETAIL LOAN PORTFOLIO- 001- A TRUST sides. The core issues that arise for adjudication are whether the assessee trust is liable to be assessed as an Association of Persons, whether the trust is revocable or irrevocable for the purposes of sections 61 to 63 of the Income-tax Act, 1961, and consequently whether the income can be brought to tax in the hands of the trust by invoking section 164 of the Act. 15. Sections 61 to 63 form a self-contained code dealing with taxation of income arising from revocable transfers. The legislative scheme is explicit that where the transferor retains, directly or indirectly, the right to re-assume control over income or assets, such income cannot be assessed in the hands of an intermediary entity but must be taxed in the hands of the transferor. Section 63 deliberately adopts a wide and inclusive definition of both “transfer” and “revocable transfer”. The statute does not prescribe that revocation must be unilateral, unconditional, or exercisable by an individual contributor. What is required is the existence of a contractual or legal mechanism for re-transfer of assets or re-assumption of power. This statutory scheme must be read harmoniously with the regulatory framework governing securitisation trusts, which are mandated under the SARFAESI Act and RBI Guidelines to operate as pass- through vehicles with beneficial ownership resting with Security Receipt Holders. 16. In this context, it is relevant to reproduce paragraph 9.4 of the order of the co-ordinate Bench in ITO v. Scheme A1 of ARCIL Printed from counselvise.com 12 ITA No. 4252/Mum/2025 ARCIL RETAIL LOAN PORTFOLIO- 001- A TRUST CPS 002 XI Trust (ITA No. 2293/Mum/2018), wherein the learned CIT(A)‟s reasoning, subsequently approved by the Tribunal, has been set out as under: “9.4 Thus it is seen that under section 61 of the Act all income arising to any person by virtue of a revocable transfer of assets shall be chargeable to income-tax as the income of the transferor and shall be included in his total income. Section 62 of the Act provides that if a transfer is irrevocable for a specified period then section 61 will not apply. Section 63 defines as to what is „transfer‟ and „revocable transfer‟ for the purpose of sections 61 & 62 of the Act. It provides that:- (a) a transfer shall be deemed to be revocable if: (i) it contains any provision for the re- transfer directly or indirectly of the whole or any part of the income or assets to the transferor, or (ii) it, in any way, gives the transferor a right to re-assume power directly or indirectly over the whole or any part of the income or assets; (b) „transfer‟ includes any settlement, trust, covenant, agreement or arrangement. In this regard, I agree with the Ld. AR that the provisions of the I.T. Act nowhere state that if the transfer is „explicitly revocable‟, the provisions of section 61 and section 63 would not apply. I have also carefully gone through the relevant clauses of the trust deed, as highlighted by the Ld. AR.” 16.1 On a plain reading of Clause 5.2 of the Trust Deed, we find that the Security Receipt Holders are expressly conferred a right Printed from counselvise.com 13 ITA No. 4252/Mum/2025 ARCIL RETAIL LOAN PORTFOLIO- 001- A TRUST to revoke their contributions during the subsistence of the trust. Upon such revocation, the entire Trust Fund stands re- transferred to the Security Receipt Holders or their designees in proportion to their holdings, the scheme itself stands dissolved, the trustee ceases to act as trustee, and the Security Receipts stand extinguished. These provisions clearly satisfy both limbs of section 63(a), namely - i. a provision for re-transfer of assets, and ii. a right to re-assume power over the assets, albeit through a structured and collective mechanism. 17. The contention of the Revenue that revocation requiring consent of a specified percentage of holders negates revocability has been expressly rejected by the Co-ordinate Bench. In this regard, paragraph 18 of the order in ITO v. Scheme A1 of ARCIL CPS 002 XI Trust (supra) is directly applicable and is reproduced as under: “The Co-ordinate Bench further categorically rejected the precise objection raised by the Revenue in the present case, namely that revocation being conditional would render the transfer irrevocable, by observing as under in the same paragraph: Insofar, the view taken by the A.O, that as the revocation of the contributions is conditional upon the consent of the contributors holding 75% of the units, we are afraid that the same would not render the contributions as irrevocable.” Printed from counselvise.com 14 ITA No. 4252/Mum/2025 ARCIL RETAIL LOAN PORTFOLIO- 001- A TRUST 18. The statutory position was further clarified by the Co- ordinate Bench in paragraph 7.6.4(iii) of the said order, (as reproduced from the Indian Corporate Loan and Securitisation Trust - 2008 Series 14 in lTA no. ITA Nos.3986 & 4343/Mum/2013 dated 17.02.2017) which reads as under: The section does not say the deed of transfer must confer or vest an unconditional or an exclusive power of revocation in the transferor. What emerges from out of the above discussion is that the beneficiaries need to be identifiable and the Trust Deed must contain provisions that vest the power of revocation. There is nothing in the section to read that such a power should be unconditional. 19. In view of the above binding exposition of law, it is evident that section 63 does not mandate unilateral or unconditional revocation, and that a revocation mechanism embedded in the governing instrument is sufficient. Collective revocation does not dilute the revocable character of the transfer. 20. The learned CIT(A), in our view, has rightly relied upon the aforesaid co-ordinate Bench decisions, including paras 9.4, 18– 19 and 7.6.4–7.6.5 of the decision in ITO v. Scheme A1 of ARCIL CPS 002 XI Trust (ITA No. 2293/Mum/2018). 21. The Assessing Officer has further sought to assess the assessee as an Association of Persons, invoking section 164 on Printed from counselvise.com 15 ITA No. 4252/Mum/2025 ARCIL RETAIL LOAN PORTFOLIO- 001- A TRUST the premise that beneficiaries are indeterminate and that the trust carries on business with a profit motive. We are unable to agree with this approach. 22. Firstly, the formation of the assessee trust is statutorily mandated under the SARFAESI Act and RBI Guidelines. The trust is not a voluntary association of persons coming together for a common purpose, but a regulatory vehicle created for securitisation. The trustee functions independently and exclusively in accordance with the Trust Deed. There is no joint management, no sharing of responsibilities, and no common volition among Security Receipt Holders so as to constitute an AOP. 23. Secondly, the beneficiaries are clearly identifiable with reference to the Trust Deed, Offer Documents and contribution records, and their respective shares are determinable in proportion to Security Receipts held. Merely because the names of beneficiaries are not set out in the Trust Deed itself does not render the trust indeterminate. This position is well settled by judicial precedents relied upon by the assessee and accepted by the learned CIT(A). 24. Thirdly, once it is held that the trust is revocable, section 164 has no independent application. Sections 61 to 63 override section 164 in cases of revocable transfers. The Assessing Printed from counselvise.com 16 ITA No. 4252/Mum/2025 ARCIL RETAIL LOAN PORTFOLIO- 001- A TRUST Officer‟s attempt to apply section 164, therefore, proceeds on an incorrect legal premise. 25. The issue before us is no longer res integra. The Mumbai Benches of the Tribunal, in a series of decisions involving ARCIL securitisation trusts with identical trust deeds, have consistently held that such trusts are revocable within the meaning of section 63, income is not taxable in the hands of the trust, and the trust cannot be assessed as an AOP. 26. In Scheme A1 of ARCIL CPS 002 XI Trust (A.Y. 2013–14) and ARCIL CPS 002 XIII Trust (A.Y. 2009–10), the Co-ordinate Bench examined Clause 5.2 in detail and categorically rejected the Revenue‟s argument that conditional revocation negates section 63. Similar conclusions have been reached in ARCIL Retail Loan Portfolio trusts for A.Y. 2016–17, which are directly comparable to the present case.Judicial discipline requires that, in the absence of any distinguishing facts or contrary higher judicial authority, we follow the consistent view taken by co- ordinate Benches. The Revenue has not demonstrated any departure either in facts or in law. 27. The legislative intent to treat securitisation trusts as pass- through entities is further reinforced by later amendments and CBDT clarifications. The Finance Bill, 2016 expressly recognised securitisation trusts, including those set up by ARCs, as vehicles through which income is to be taxed in the hands of investors Printed from counselvise.com 17 ITA No. 4252/Mum/2025 ARCIL RETAIL LOAN PORTFOLIO- 001- A TRUST and not the trust. These amendments are clarificatory in nature, explaining the manner of taxation rather than altering the character of such trusts. They fortify the conclusion that, even prior to the amendments, the law recognised the trust as a conduit and not as a separate taxable entity in respect of such income. In view of the foregoing discussion, we hold as under: 1. The assessee trust is a revocable trust within the meaning of sections 61 to 63 of the Act. 2. The income arising from the trust is not chargeable to tax in the hands of the trust, but in the hands of the Security Receipt Holders. 3. The assessee cannot be assessed as an Association of Persons, and section 164 has no application to the facts of the case. 4. The learned CIT(A) has correctly appreciated the statutory scheme, the Trust Deed, and the binding judicial precedents, and has rightly deleted the addition made by the Assessing Officer. 28. Accordingly, the order of the learned CIT(A) is affirmed, and the appeal filed by the Revenue is dismissed. Order pronounced in the open court on 22.01.2026. Sd/- Sd/- (AMIT SHUKLA) (MAKARAND VASANT MAHADEOKAR) JUDICIAL MEMBER ACCOUNTANT MEMBER Mumbai, Dated 22/01/2026 RY, Sr. P.S. Printed from counselvise.com 18 ITA No. 4252/Mum/2025 ARCIL RETAIL LOAN PORTFOLIO- 001- A TRUST आदेश की प्रतितिति अग्रेतिि/Copy of the Order forwarded to : 1. अपीलाथी / The Appellant 2. प्रत्यथी / The Respondent. 3. संबंधधत आयकर आयुक्त / The CIT(A) 4. आयकर आयुक्त(अपील) / Concerned CIT 5. धिभागीय प्रधतधनधध, आयकर अपीलीय अधधकरण, मुम्बई/ DR, ITAT, Mumbai 6. गार्ड फाईल / Guard file. आदेशानुसार/BY ORDER, सत्याधपत प्रधत //True Copy// 1. उि/सहायक िंजीकार ( Asst. Registrar) आयकर अिीिीय अतिकरण, मुम्बई / ITAT, Mumbai Printed from counselvise.com "