NOVARTIS INDIA LIMITED,MUMBAI V. DCIT (TDS)-2 3, MUMBAI, MUMBAI

CO 302/MUM/2025

AI Insights

The case involves an appeal by the Revenue and a cross-objection by the assessee, Novartis India Limited, against the order of the Learned Commissioner of Income-tax (Appeals) - 7, Kolkata, dated 16.07.2025. The original dispute arose from a survey conducted under section 133(2A) of the Income-tax Act at the premises of the assessee, leading to an order under sections 201(1) and 201(1A) of the Act, treating the assessee as a defaulter in tax deduction at source. The CIT(A) partly allowed the appeal, but both parties contested the correctness of the order, citing errors in facts and figures, including the misidentification of the assessee and incorrect application of legal provisions regarding tax deductions on discounts to stockists and ESOP benefits.

• Counselvise Citation: [2026] 140 COUNSELVISE.COM (IT) 835775 (ITAT-MUMBAI)
• Duration Of Justice: 3 month(s) 2 day(s)
• Appeal Type: Cross Objection
• Pronouncement Date: 09-02-2026
• Appeal Filed By: Assessee
• Order Result: Partly Allowed
• Bench Allotted: B
• Assessment Year: 2016-2017
• Appeal Filed On: 06-11-2025
• Laws Referred To: Income-tax Act, 1961
• Result in Favour of: Partly Allowed
• Court: TRIBUNAL
• Department Lawyers: S. SRINIVASE
• Assessee Lawyers: ANISH THACKER; PRANAY GANDHI
• Keywords: Set aside; TDS; Assessment record
• Section: 201(1)

Judgement Text

"IN THE INCOME TAX APPELLATE TRIBUNAL MUMBAI BENCH “B” MUMBAI BEFORE SHRI OM PRAKASH KANT (ACCOUNTANT MEMBER) AND MS. KAVITHA RAJAGOPAL (JUDICIAL MEMBER) ITA No. 5681/MUM/2025 Assessment Year: 2016-17 DCIT (TDS)-2(3), Room No. 320, 3rd floor, MTNL T.E. Building, Cumballa Hill, Peddar Road, Mumbai-400026. Vs. Novartis India Ltd., 7th floor, Inspire BKC, G Block BKC Main Road, Bandra Kurla Complex, Bandra East, Mumbai-400051. PAN NO. AAACH 2914 F Appellant Respondent C.O. No. 302/MUM/2025 (Arising out of ITA No. 5681/MUM/2025) Assessment Year: 2016-17 Novartis India Ltd., 7th floor, Inspire BKC, G Block BKC Main Road, Bandra Kurla Complex, Bandra East, Mumbai-400051. Vs. DCIT (TDS)-2 (3), Room No. 320, 3rd floor, MTNL T.E. Building, Cumballa Hill, Peddar Road, Gopalrao Deshmukh Marg, Mumbai-400026. PAN NO. AAACH 2914 F Appellant Respondent Assessee by : Mr. Anish Thacker & Mr. Pranay Gandhi Revenue by : Dr. S. Srinivase, CIT-DR Date of Hearing : 22/12/2025 Date of pronouncement : 09/02/2026 Printed from counselvise.com PER OM PRAKASH KANT, AM This appeal filed by the Revenue and the cross by the assessee arise out of the order dated 16.07.2025 passed by the Learned Additional/Joint (Appeals)–7, Kolkata [hereinafter referred to as “the Ld. CIT(A)”] for the assessment year 2016 sections 201(1) and 201(1A) of the Income Act”).The grounds raised by 1. Whether the Learned Addl./JCIT(A) has erred in facts and figures by incorrectly stating the amount of additions made by the Assessing Officer in the order passed under Section 201 of the Income \"Statement of Facts\" on Page No. 2 of his appellate order, which are inconsistent with the figures mentioned in the original order? 2. Whether the Learned Addl./JCIT(A) has erred in facts by incorrectly referring to the name of the assessee co \"Novartis Healthcare Private Limited\" instead of the correct name \"Novartis India Limited\", as reflected in Page No. 2 of his appellate order? 3. Whether the Learned Addl./JCIT(A) has erred in facts and figures by quoting, under the heading \"Obse Assessing Officer\", the text extracted from the order passed under Section 201 in the case of Novartis Healthcare Private Limited for A.Y. 2016 observations pertaining to the present assessee's case, reflected in Page Nos 10,15,17& 18 of his appellate order? 4. Whether the Learned Addl./JCIT(A) has erred in facts and figures by incorrectly stating the figures of additions made by the Assessing Officer and the relief granted to the ORDER PER OM PRAKASH KANT, AM This appeal filed by the Revenue and the cross by the assessee arise out of the order dated 16.07.2025 passed by the Learned Additional/Joint Commissioner of Income 7, Kolkata [hereinafter referred to as “the Ld. CIT(A)”] for the assessment year 2016-17, relating to liability determined under sections 201(1) and 201(1A) of the Income-tax Act, 1961 (“the The grounds raised by the Revenue are reproduced as under: 1. Whether the Learned Addl./JCIT(A) has erred in facts and figures by incorrectly stating the amount of additions made by the Assessing Officer in the order passed under Section 201 of the Income-tax Act, 1961, as reflected in the \"Statement of Facts\" on Page No. 2 of his appellate order, which are inconsistent with the figures mentioned in the original order? 2. Whether the Learned Addl./JCIT(A) has erred in facts by incorrectly referring to the name of the assessee co \"Novartis Healthcare Private Limited\" instead of the correct name \"Novartis India Limited\", as reflected in Page No. 2 of his appellate order? 3. Whether the Learned Addl./JCIT(A) has erred in facts and figures by quoting, under the heading \"Observations of the Assessing Officer\", the text extracted from the order passed under Section 201 in the case of Novartis Healthcare Private Limited for A.Y. 2016-17, instead of referring to the relevant observations pertaining to the present assessee's case, reflected in Page Nos 10,15,17& 18 of his appellate order? 4. Whether the Learned Addl./JCIT(A) has erred in facts and figures by incorrectly stating the figures of additions made by the Assessing Officer and the relief granted to the Novartis India Ltd. 2 ITA No. 5681 & CO No. 302/MUM/2025 This appeal filed by the Revenue and the cross-objection filed by the assessee arise out of the order dated 16.07.2025 passed by Commissioner of Income-tax 7, Kolkata [hereinafter referred to as “the Ld. CIT(A)”] for 17, relating to liability determined under tax Act, 1961 (“the the Revenue are reproduced as under: 1. Whether the Learned Addl./JCIT(A) has erred in facts and figures by incorrectly stating the amount of additions made by the Assessing Officer in the order passed under Section ected in the \"Statement of Facts\" on Page No. 2 of his appellate order, which are inconsistent with the figures mentioned in the 2. Whether the Learned Addl./JCIT(A) has erred in facts by incorrectly referring to the name of the assessee company as \"Novartis Healthcare Private Limited\" instead of the correct name \"Novartis India Limited\", as reflected in Page No. 2 of 3. Whether the Learned Addl./JCIT(A) has erred in facts and rvations of the Assessing Officer\", the text extracted from the order passed under Section 201 in the case of Novartis Healthcare Private 17, instead of referring to the relevant observations pertaining to the present assessee's case, as reflected in Page Nos 10,15,17& 18 of his appellate order? 4. Whether the Learned Addl./JCIT(A) has erred in facts and figures by incorrectly stating the figures of additions made by the Assessing Officer and the relief granted to the Printed from counselvise.com assessee company \"Grounds of Appeal\" (Page Nos. 19 Nos. 96-101) in his appellate order? 5. Whether the Learned Addl./JCIT(A) has erred in law and on facts in holding that the transaction between the assessee company and its stockists was on a principal basis, and thereby concluding that the discount offered to the stockists would not fall within the ambit of section 194H of the Act. 6. Whether the Learned Addl./JCIT(A) has failed to appreciate that Stockists entered into between the assessee and its stockists, all essential aspects of the business relationship, including pricing, invoicing, margins, payment terms, and even the mode of transport tare determined Novartis India Ltd. 7. Whether the Learned Addl./JCIT(A) has failed to appreciate the that the assessee imposes various restrictions on stockists/distributors/wholesalers, such as restrictions on the sale of products, allocation of terri of stockists, and monitoring and controlling of product stocks. These restrictions clearly establish that the stockists were functioning as agents of the assessee company for promoting and effecting sales on its behalf, and hence, the a contention of a principal 8. Whether the Learned Addl./JCIT(A)has erred in holding that tax on Employee Stock Ownership Plan (ESOP) benefits is deductible only at the time of exercise of options by the employees, without appreciating that the assessee had already quantified the value of ESOP benefits during AY 2016-17 itself, thereby leading to accrual of income in the hands of employees in that year.\" The Ld. Addl.CIT(A)'s order was passed in the above mentioned case on 16.07.2025. Last date for filing Appeal is 14.09.2025. However, appeal should be filed immediately. assessee company in his order, both under the sections \"Grounds of Appeal\" (Page Nos. 19-23) and \"Decision\" (Page. 101) in his appellate order? 5. Whether the Learned Addl./JCIT(A) has erred in law and on facts in holding that the transaction between the assessee ompany and its stockists was on a principal- basis, and thereby concluding that the discount offered to the stockists would not fall within the ambit of section 194H of 6. Whether the Learned Addl./JCIT(A) has failed to appreciate that, under the Agreement for Appointment of Stockists entered into between the assessee and its stockists, all essential aspects of the business relationship, including pricing, invoicing, margins, payment terms, and even the mode of transport tare determined and controlled by Novartis India Ltd. 7. Whether the Learned Addl./JCIT(A) has failed to appreciate the that the assessee imposes various restrictions on stockists/distributors/wholesalers, such as restrictions on the sale of products, allocation of territories, appointment of stockists, and monitoring and controlling of product stocks. These restrictions clearly establish that the stockists were functioning as agents of the assessee company for promoting and effecting sales on its behalf, and hence, the a contention of a principal- to-principal relationship is not valid. 8. Whether the Learned Addl./JCIT(A)has erred in holding that tax on Employee Stock Ownership Plan (ESOP) benefits is deductible only at the time of exercise of options by the loyees, without appreciating that the assessee had already quantified the value of ESOP benefits during AY 17 itself, thereby leading to accrual of income in the hands of employees in that year.\" The Ld. Addl.CIT(A)'s order was passed in the above tioned case on 16.07.2025. Last date for filing Appeal is 14.09.2025. However, appeal should be filed immediately. Novartis India Ltd. 3 ITA No. 5681 & CO No. 302/MUM/2025 in his order, both under the sections 23) and \"Decision\" (Page. 5. Whether the Learned Addl./JCIT(A) has erred in law and on facts in holding that the transaction between the assessee -to-principal basis, and thereby concluding that the discount offered to the stockists would not fall within the ambit of section 194H of 6. Whether the Learned Addl./JCIT(A) has failed to , under the Agreement for Appointment of Stockists entered into between the assessee and its stockists, all essential aspects of the business relationship, including pricing, invoicing, margins, payment terms, and and controlled by 7. Whether the Learned Addl./JCIT(A) has failed to appreciate the that the assessee imposes various restrictions on stockists/distributors/wholesalers, such as restrictions tories, appointment of stockists, and monitoring and controlling of product stocks. These restrictions clearly establish that the stockists were functioning as agents of the assessee company for promoting and effecting sales on its behalf, and hence, the assessee's principal relationship is not valid. 8. Whether the Learned Addl./JCIT(A)has erred in holding that tax on Employee Stock Ownership Plan (ESOP) benefits is deductible only at the time of exercise of options by the loyees, without appreciating that the assessee had already quantified the value of ESOP benefits during AY 17 itself, thereby leading to accrual of income in the The Ld. Addl.CIT(A)'s order was passed in the above tioned case on 16.07.2025. Last date for filing Appeal is 14.09.2025. However, appeal should be filed immediately. Printed from counselvise.com 2. The Revenue has raised multiple grounds, broadly alleging serious factual and legal infirmities in the impugned appellate order, including incorrect narration of facts, misstatement of figures, wrong identification of the assessee, reliance on assessment records of a different group entity, erroneous conclusions on applicability of section 194H in respect of trade discounts to stockists, and incorrect appreciation of the timing of tax deduction on ESOP benefits. 2.1 The cross objection raised under: On the facts and in the circumstances of the case, the learned CIT(A) has erred in: Applicability of provisions on interest on delayed payments to MSMEs: 1. confirming the learned assessing officer's observation that the Respondent ought to have deducted tax under section 194A of the Act on the provision created by it in respect of interest on delayed payments to MSME which has suo been disallowed by it; 2. failed to appreciate that since the amount so accrued by the Appellant in respect of delayed payments to MSME is not arising from any debt Company, the same is not governed by the provisions of section 194A read with section 2(28A) of the Act; 3. erred in confirming levy of interest amounting to Rs. 20,479 under section 201(1A) of the Act on the alleged amount of default; The Revenue has raised multiple grounds, broadly alleging serious factual and legal infirmities in the impugned appellate incorrect narration of facts, misstatement of figures, wrong identification of the assessee, reliance on assessment records of a different group entity, erroneous conclusions on applicability of section 194H in respect of trade discounts to incorrect appreciation of the timing of tax deduction The cross objection raised by the assessee are reproduced as On the facts and in the circumstances of the case, the learned CIT(A) has erred in: Applicability of provisions of section 194A of the Act on interest on delayed payments to MSMEs: 1. confirming the learned assessing officer's observation that the Respondent ought to have deducted tax under section 194A of the Act on the provision created by it in respect of st on delayed payments to MSME which has suo been disallowed by it; 2. failed to appreciate that since the amount so accrued by the Appellant in respect of delayed payments to MSME is not arising from any debt-claim or moneys borrowed by the the same is not governed by the provisions of section 194A read with section 2(28A) of the Act; 3. erred in confirming levy of interest amounting to Rs. 20,479 under section 201(1A) of the Act on the alleged amount of default; Novartis India Ltd. 4 ITA No. 5681 & CO No. 302/MUM/2025 The Revenue has raised multiple grounds, broadly alleging serious factual and legal infirmities in the impugned appellate incorrect narration of facts, misstatement of figures, wrong identification of the assessee, reliance on assessment records of a different group entity, erroneous conclusions on applicability of section 194H in respect of trade discounts to incorrect appreciation of the timing of tax deduction by the assessee are reproduced as On the facts and in the circumstances of the case, the of section 194A of the Act 1. confirming the learned assessing officer's observation that the Respondent ought to have deducted tax under section 194A of the Act on the provision created by it in respect of st on delayed payments to MSME which has suo-moto 2. failed to appreciate that since the amount so accrued by the Appellant in respect of delayed payments to MSME is not claim or moneys borrowed by the the same is not governed by the provisions of 3. erred in confirming levy of interest amounting to Rs. 20,479 under section 201(1A) of the Act on the alleged Printed from counselvise.com 3. Brief facts of the case of the Act was conducted at the premises of the assessee on 22.10.2019. During the course of survey proceedings, certain defaults relating to non source on various payments were Assessing Officer passed an order under sections 201(1) and 201(1A) of the Act dated 20.01.2020, treating the assessee as an assessee in default and raising a consolidated demand of ₹2,38,30,140/-. 3.1 Aggrieved, the asses CIT(A), who partly allowed the appeal by the impugned order dated 16.07.2025. 4. Before us, the Learned Departmental Representative (Ld. DR) assailed the impugned order on the ground of complete non application of mind. It was submitted that the Ld. CIT(A), while disposing of the appeal, has reproduced the statement of facts, observations of the Assessing Officer, and figures of additions pertaining not to the present assessee, but to another group concern, namely Nova pointed out that the Ld. CIT(A) has even incorrectly mentioned the name of the assessee as of the correct name, Novartis India Limited the impugned order is entirely vitiated as the conclusions have been Brief facts of the case are that a survey under section 133(2A) of the Act was conducted at the premises of the assessee on 22.10.2019. During the course of survey proceedings, certain defaults relating to non-deduction or short deduction of tax at source on various payments were noticed. Consequent thereto, the Assessing Officer passed an order under sections 201(1) and 201(1A) of the Act dated 20.01.2020, treating the assessee as an assessee in default and raising a consolidated demand of Aggrieved, the assessee preferred an appeal before the Ld. CIT(A), who partly allowed the appeal by the impugned order dated Before us, the Learned Departmental Representative (Ld. DR) assailed the impugned order on the ground of complete non d. It was submitted that the Ld. CIT(A), while disposing of the appeal, has reproduced the statement of facts, observations of the Assessing Officer, and figures of additions pertaining not to the present assessee, but to another group Novartis Healthcare Private Limited pointed out that the Ld. CIT(A) has even incorrectly mentioned the name of the assessee as Novartis Healthcare Private Limited Novartis India Limited. According to the Ld. DR, impugned order is entirely vitiated as the conclusions have been Novartis India Ltd. 5 ITA No. 5681 & CO No. 302/MUM/2025 a survey under section 133(2A) of the Act was conducted at the premises of the assessee on 22.10.2019. During the course of survey proceedings, certain deduction or short deduction of tax at noticed. Consequent thereto, the Assessing Officer passed an order under sections 201(1) and 201(1A) of the Act dated 20.01.2020, treating the assessee as an assessee in default and raising a consolidated demand of see preferred an appeal before the Ld. CIT(A), who partly allowed the appeal by the impugned order dated Before us, the Learned Departmental Representative (Ld. DR) assailed the impugned order on the ground of complete non- d. It was submitted that the Ld. CIT(A), while disposing of the appeal, has reproduced the statement of facts, observations of the Assessing Officer, and figures of additions pertaining not to the present assessee, but to another group rtis Healthcare Private Limited. It was further pointed out that the Ld. CIT(A) has even incorrectly mentioned the Novartis Healthcare Private Limited instead . According to the Ld. DR, impugned order is entirely vitiated as the conclusions have been Printed from counselvise.com drawn on the basis of facts and figures of a different assessee altogether, warranting its setting aside in toto. 4.1 The Learned Counsel for the assessee, on the other hand, fairly conceded that the statement of facts of the group concern had inadvertently been reproduced in support of the appeal. He also accepted that extracts from the assessment order for assessment year 2016-17 in the case of along with the corresponding figures of additions, had been relied upon by the Ld. CIT(A). 4.2 It was further submitted that immediately upon receipt of the impugned order, the assessee had moved an application seeking corrigendum under section 250 of the Act. Howe rejected the said request, observing that the order was passed on the basis of documents filed along with Form No. 35 and that no mistake had occurred. Thereafter, the assessee again filed an application for rectification on 05.08.2025, of the group concern were uploaded inadvertently. The said rectification application, as submitted, is stated to be pending before the Ld. CIT(A). 5. We have carefully considered the rival submissions and perused the material available on record. On an overall consideration of the facts, we find considerable force in the submissions advanced by the Revenue. The impugned order drawn on the basis of facts and figures of a different assessee altogether, warranting its setting aside in toto. The Learned Counsel for the assessee, on the other hand, that the statement of facts of the group concern had inadvertently been reproduced in support of the appeal. He also accepted that extracts from the assessment order for assessment 17 in the case of Novartis Healthcare Private Limited h the corresponding figures of additions, had been relied upon by the Ld. CIT(A). It was further submitted that immediately upon receipt of the impugned order, the assessee had moved an application seeking corrigendum under section 250 of the Act. However, the Ld. CIT(A) rejected the said request, observing that the order was passed on the basis of documents filed along with Form No. 35 and that no mistake had occurred. Thereafter, the assessee again filed an application for rectification on 05.08.2025, explaining that the facts of the group concern were uploaded inadvertently. The said rectification application, as submitted, is stated to be pending before the Ld. CIT(A). We have carefully considered the rival submissions and perused the material available on record. On an overall consideration of the facts, we find considerable force in the submissions advanced by the Revenue. The impugned order Novartis India Ltd. 6 ITA No. 5681 & CO No. 302/MUM/2025 drawn on the basis of facts and figures of a different assessee The Learned Counsel for the assessee, on the other hand, that the statement of facts of the group concern had inadvertently been reproduced in support of the appeal. He also accepted that extracts from the assessment order for assessment Novartis Healthcare Private Limited, h the corresponding figures of additions, had been relied It was further submitted that immediately upon receipt of the impugned order, the assessee had moved an application seeking ver, the Ld. CIT(A) rejected the said request, observing that the order was passed on the basis of documents filed along with Form No. 35 and that no mistake had occurred. Thereafter, the assessee again filed an explaining that the facts of the group concern were uploaded inadvertently. The said rectification application, as submitted, is stated to be pending We have carefully considered the rival submissions and perused the material available on record. On an overall consideration of the facts, we find considerable force in the submissions advanced by the Revenue. The impugned order Printed from counselvise.com unmistakably demonstrates c appeal before the Ld. CIT(A) pertained to whereas the statement of facts, extracts of the assessment order, and even the figures of additions and relief have been lifted from the case of Novartis Healthcare Private Limited 5.1 An appellate authority is required to adjudicate the appeal on the basis of the correct facts and material pertaining to the assessee before it. An order founded on facts of an entirely different assessee cannot be sustained in the eyes of law. Such an exe undermines the adjudicatory process but also vitiates the conclusions drawn there from. An order passed mechanically, or on the basis of facts relating to a different assessee, is vitiated by application of mind and is a nullity in the e 5.2 Once the foundational facts themselves are erroneous, the superstructure of conclusions built thereon must necessarily collapse. An appellate order so passed cannot be cured by assumptions, concessions, or post set aside in limine. 5.3 In these circumstances, the impugned order having been passed on an erroneous factual foundation, is rendered unsustainable and is liable to be set aside. The raised both in appeal and cross objection deserve the file of the Ld. CIT(A) for fresh adjudication, strictly in unmistakably demonstrates complete non-application of mind. The appeal before the Ld. CIT(A) pertained to Novartis India Limited whereas the statement of facts, extracts of the assessment order, and even the figures of additions and relief have been lifted from the Healthcare Private Limited, a distinct legal entity. An appellate authority is required to adjudicate the appeal on the basis of the correct facts and material pertaining to the assessee before it. An order founded on facts of an entirely different assessee cannot be sustained in the eyes of law. Such an exe undermines the adjudicatory process but also vitiates the conclusions drawn there from. An order passed mechanically, or on the basis of facts relating to a different assessee, is vitiated by and is a nullity in the eyes of law. Once the foundational facts themselves are erroneous, the superstructure of conclusions built thereon must necessarily collapse. An appellate order so passed cannot be cured by assumptions, concessions, or post-facto explanations, and must In these circumstances, the impugned order having been passed on an erroneous factual foundation, is rendered unsustainable and is liable to be set aside. The the ground on merit raised both in appeal and cross objection deserve to be restored to the file of the Ld. CIT(A) for fresh adjudication, strictly in Novartis India Ltd. 7 ITA No. 5681 & CO No. 302/MUM/2025 application of mind. The Novartis India Limited, whereas the statement of facts, extracts of the assessment order, and even the figures of additions and relief have been lifted from the , a distinct legal entity. An appellate authority is required to adjudicate the appeal on the basis of the correct facts and material pertaining to the assessee before it. An order founded on facts of an entirely different assessee cannot be sustained in the eyes of law. Such an exercise not only undermines the adjudicatory process but also vitiates the conclusions drawn there from. An order passed mechanically, or on the basis of facts relating to a different assessee, is vitiated by non- yes of law. Once the foundational facts themselves are erroneous, the superstructure of conclusions built thereon must necessarily collapse. An appellate order so passed cannot be cured by facto explanations, and must be In these circumstances, the impugned order having been passed on an erroneous factual foundation, is rendered the ground on merit to be restored to the file of the Ld. CIT(A) for fresh adjudication, strictly in Printed from counselvise.com accordance with law and after considering the correct facts and material relating to the present assessee, subject to the status of the pending rectification application, if 6. In the result, objection of the assessee are Order pronounced in the open Court on Sd/- (KAVITHA RAJAGOPAL JUDICIAL MEMBER Mumbai; Dated: 09/02/2026 Rahul Sharma, Sr. P.S. Copy of the Order forwarded to 1. The Appellant 2. The Respondent. 3. CIT 4. DR, ITAT, Mumbai 5. Guard file. //True Copy// accordance with law and after considering the correct facts and material relating to the present assessee, subject to the status of the pending rectification application, if any. In the result, both the appeal of the Revenue and cross objection of the assessee are allowed for statistical purpose ounced in the open Court on 09/02/2026. Sd/ (KAVITHA RAJAGOPAL) (OM PRAKASH KANT JUDICIAL MEMBER ACCOUNTANT MEMBER Copy of the Order forwarded to : BY ORDER, (Assistant Registrar) ITAT, Mumbai Novartis India Ltd. 8 ITA No. 5681 & CO No. 302/MUM/2025 accordance with law and after considering the correct facts and material relating to the present assessee, subject to the status of the appeal of the Revenue and cross- allowed for statistical purpose. /02/2026. Sd/- OM PRAKASH KANT) ACCOUNTANT MEMBER BY ORDER, (Assistant Registrar) ITAT, Mumbai Printed from counselvise.com "