PACKT PUBLISHING PVT LTD, MUMBAI V. DCIT CIRCLE 2(3)(1), MUMBAI

ITA 8922/MUM/2025

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Packt Publishing Private Limited appealed against the final order of the Assessment Unit of the Income Tax Department, which had assessed a higher taxable income for the Assessment Year 2022-23. The primary issues revolved around the transfer pricing adjustments made by the TPO concerning the publishing support services provided to its associated enterprise in the UK. The TPO had reclassified certain income and expenses, leading to a lower operating margin for the appellant, and had also made a notional interest adjustment on inter-company receivables. The Dispute Resolution Panel (DRP) provided partial relief but upheld significant adjustments. The Tribunal's decision focused on the correct classification of SEIS write-offs and foreign exchange gains, and the acceptance of working capital adjustments, leading to the allowance of the appeal.

• Counselvise Citation: [2026] 140 COUNSELVISE.COM (IT) 848678 (ITAT-MUMBAI)
• Duration Of Justice: 3 month(s) 4 day(s)
• Appeal Type: Income Tax Appeal
• Pronouncement Date: 26-03-2026
• Appeal Filed By: Assessee
• Order Result: Allowed
• Bench Allotted: Mumbai
• Assessment Year: 2022-2023
• Appeal Filed On: 22-12-2025
• Other Referred Cases: KGK Creations Pvt Ltd vs JAO, Sumit Diamond (India) Pvt Ltd vs Ad.CIT
• Laws Referred To: Income Tax Act
• Result in Favour of: Assessee
• Court: TRIBUNAL
• Department Lawyers: ASSESSEES COMPARABLES; ADITYA RAI
• Assessee Lawyers: NIKHIL TIWARI
• Keywords: Transfer pricing; International transaction; Notional interest; Initiation of penalty proceedings
• Section: 143(3); 234B

Judgement Text

"IN THE INCOME TAX APPELLATE TRIBUNAL “J” BENCH MUMBAI SHRI. ANIKESH BANERJEE, JUDICIAL MEMBER AND BEFORE SHRI. BIJAYANANDA PRUSETH, ACCOUNTANT MEMBER ITA No. 8922/MUM/2025 (Assessment Year: 2022-23) Packt Publishing Private Limited B-106, 1st Floor, Navkar Chambers, Andheri Kurla Road, Marol, Andheri East, J.B. Nagar S.O, Mumbai 400059 Vs. Deputy Commissioner of Income Tax, Circle 2(3)(1), Mumbai Office of the Deputy Commissioner of Income Tax, Circle 2(3)(1), Aaykar Bhawan, Mumbai 400020 ̾थायीलेखासं./जीआइआरसं./PAN/GIR No: AADCP5965H (Appellant) (Respondent) िनधाŊįरतीकीओरसे / Assessee by: Shri. Nikhil Tiwari /Revenue by: Shri. Aditya Rai SR. DR Date of Hearing 10.02.2026 Date of Pronouncement 26.03.2026 आदेश/O R D E R PER ANIKESH BANERJEE [J.M]: Instant appeal of the assessee preferred against the final order of the Assessment Unit Income Tax Department [hereinafter referred to as \"Ld. AO\"] order passed u/s. 143(3) r.w.s 144C(13) r.w.s 144B of the Act, [hereinafter referred to as \"Act\"], date of order 30.10.2025 by pursuing the order of Ld. CIT (DRP-2), Mumbai-2, [hereinafter referred to as \"Ld. DRP\"], order passed u/s. 144C(5) date of order 29.09.2025. 2. The assessee has taken the following grounds: Printed from counselvise.com 2 ITA No. 8922/Mum/2025 AY 2022-23 Packt Publishing Private Limited General Ground 1. erred in determining the total taxable income of the Appellant for the subject AY at Rs 5,78,93,145/- instead of Rs 3,76,36,370/- as reported in the return of income filed by the Appellant. Time barred proceedings 2. erred in not passing the final assessment order within the time limit as provided under Section 153 of the Act i.e., the outer limit for passing of the final assessment order which for AY 2022-23 was 31 March 2025 whereas the final assessment order was passed on 30 October 2025, thus making the assessment proceedings time barred and bad in law and thereby ought to be quashed. Reference to the TPO 3. erred in making a reference of the Appellant's case to the learned TPO, without complying with the provisions of Section 92CA of the act. Determination of ALP for the publishing support services transaction 4. erred in determining the arm's length operating margin for the publishing support services transaction to be 8.05% on operating costs. Incorrect computation of Appellant's operating margin (OP/OC) 5. as computed in TP study report by: erred in recomputing the Appellant's operating margin as 5.38%, compared to 10.14% I. incorrectly treating write-off of Service Exports from India Scheme ('SEIS') as an operating expense, disregarding Appellant's consistent position of treating any margin. income/ expense arising from SEIS as non-operating, for computing its operating II. incorrectly treating gain arising from foreign exchange fluctuations as non- operating income, disregarding Appellant's consistent treatment of the same as operating while computing its margin as well as the comparable's margins. This treatment is inconsistent with the Appellant's business realities, where foreign exchange gains and losses are integral to its international transactions and affect the operating results. Additional comparables introduced by the TPO for benchmarking the publishing support services transaction 6. erred in introducing two companies - Bharat Prakashan (Delhi) Ltd and ChhayaPrakashani Ltd in the final set of comparables on an ad-hoc basis, without Printed from counselvise.com 3 ITA No. 8922/Mum/2025 AY 2022-23 Packt Publishing Private Limited sharing the search process analysis undertaken, thereby resorting to cherry picking of comparables. 7. erred in adding two additional companies - Bharat Prakashan (Delhi) Ltd and ChhayaPrakashani Ltd which are functionally different as comparable to the Appellant for benchmarking the international transaction of provision of publishing support services. Adjustments required to be made to arm's length margin 8. erred in computing the operating margins of two comparable companies and erred in not sharing the detailed margin computation with the Appellant. 9. erred in not allowing the Appellant the benefit of working capital adjustment which is required to be undertaken in its case to account for the difference in working capital levels between the comparable companies and the Appellant Notional Interest on inter-company receivables 10. erred in imputing notional interest income of Rs 1,10,10,775 in the hands of the Appellant, by re-characterizing the receivables as unsecured loan to AE. 11. erred in treating outstanding receivables from its AE in relation to provision of publishing support services as a separate international transaction under Section 928 (1) of the Act, without appreciating that it is closely and inextricably linked to the international transaction of provision of publishing support services and that interest cost (if any) has already been factored in the price charged to the AE. 12. erred in not appreciating the fact that the AE is responsible for the group's funding requirements, and that the Appellant does not incur any finance charges for working capital (such as interest on loan) to internal or external sources and thus any adjustment of notional interest on outstanding receivables of the Appellant is not warranted. 13. Without prejudice to grounds 10-12 above, the learned TPO erred in adopting State Bank of India's ('SBI') Prime Lending Rate ('PLR') instead of London Inter Bank Offer Rate ('LIBOR') to compute interest disregarding the fact that the AE (borrower) is based in foreign jurisdiction and the receivables (deemed loan) are denominated in foreign currency. 14. Without prejudice to grounds 10-13 above, the learned TPO has erred in imputing notional interest on outstanding receivables for a period beyond 31 March 2022. 15. erred in initiating penalty proceedings under Section 270A of the Act. Printed from counselvise.com 4 ITA No. 8922/Mum/2025 AY 2022-23 Packt Publishing Private Limited 16. erred in law and facts in levy of interest under section 234A, 234B and 234C of the Act of Rs 24,10,914/-“ 3. Brief facts of the case is that the assessee is a private limited company and incorporated under Companies Act, 1956. The assessee is service company providing publishing supports services to Packt Publishing Limited UK and declaring a total taxable income of Rs. 3,76,36,370/- under the normal provisions of the Act. During the FY 2021-22, Mr. David Maclean holds 69.99% share in Packt India and 47.5% share in Packt UK. Accordingly, Packt India and Packt UK are associated person under section 92A(2)(j) of the Act. On verification it is found that the assessee incurred the international transaction as reported in the Form No. 3CEB by rendering of publishing support service to AE amount to Rs. 36,47,35,778/- and the method used TNMM. As per the information provided in Transaction Pricing Study Report (TPSR) the tested party i.e. Packt India has profit margin 10.14%. Finally,the search was going on of identical companies and considered as comparable to Packt India for analyzing the international transaction relating to rendering publishing support service. The assessee referred to financial data base Capitaline compiled by Capital Market Publishers India Private Limited (CLINE) to identity independent companies that perform similar functions and undertake corresponding risk to those of the tested parties. After the search processing data base, the Ld. TPO calculated weighted average of Rs. 8.66%. In TP study the Ld. TPO considered the write-off Service Export from India Scheme (SEIS) as an operating expenses by rejecting the assessee’s consistent position by income /expenses arising from SEIS as non-operating expenses for computing operating margin and considered gain arising from foreign exchange fluctuations as non-operating income by rejecting assessee’s consistent treatment as operating income. Printed from counselvise.com 5 ITA No. 8922/Mum/2025 AY 2022-23 Packt Publishing Private Limited Finally, the proposed adjustment aggregate amount to Rs. 2,23,67,775/-. The Ld. AO issued the Draft Assessment order after due order of the Ld. TPO. The assessee challenged the order before the Ld. DRP. The Ld. DRP granted partial relief in respect of the transfer pricing adjustment relating to publishing support services, thereby reducing the addition to Rs. 92,46,000/-. However, no relief was granted in respect of the adjustment on account of interest on outstanding receivables, and the addition of Rs. 1,10,10,775/- was upheld. Summary of the adjustments proposed/ sustained by the learned TPO/ DRP are as follows: Particulars As per TPO As per DRP Directions Publishing support services Rs. 1,13,57,000/- Rs. 92,46,000/- Interest on receivables Rs. 1,10,10,775/- Rs. 1,10,10,775/- Consequently, the Ld AO passed the impugned final order by assessing the assessee's income at Rs. 5,78,93,145/-. Being aggrieved the assessee filed an appeal before us. 4. The Ld. AR argued and filed a paper book comprising pages 1 to 732 which has been placed on record. The Ld. AR advanced his argument ground wise which is as below: Ground No. 5 : The Ld. Authorised Representative (Ld. AR) argued that Ld. AO had made incorrect re-computation of Operating Margin. The Ld. AR contended that the Ld. TPO erred in recomputing the operating margin of the assessee at 5.38% on operating cost, as against 10.14% computed in the Transfer Pricing Study Report, by incorrectly altering the treatment of certain income and expense items. The said recomputation, according to the Ld. AR, has resulted in an artificial distortion of the operating profitability of the assessee and Printed from counselvise.com 6 ITA No. 8922/Mum/2025 AY 2022-23 Packt Publishing Private Limited consequently led to an unwarranted transfer pricing adjustment. The Ld. AR submitted that the incorrect recomputation of the operating margin primarily arose on account of the following two adjustments made by the learned TPO: i. Treating the write-off/reversal relating to Service Exports from India Scheme (SEIS) as an operating expense, whereas the assessee has consistently treated SEIS related income/expense as non-operating; and ii. Treating foreign exchange fluctuation gain as non-operating income, despite the fact that such foreign exchange fluctuation arises directly from the operating activity of providing publishing support services. The Ld. DRP, while issuing directions under section 144C(5) of the Act, upheld the action of the Ld. TPO on the above aspects. 5. The Ld. AR has contended as follows:- Ground No-5(i): Treatment of SEIS Write-off The Ld. AR submitted that during the year under consideration the assessee had reversed SEIS income amounting to Rs.79,31,000/-, which had originally been accrued in earlier years based on the expected realization of SEIS incentives. The reversal occurred due to two principal reasons: • Downward revision in the SEIS incentive rate by the Government; and • Lower realisation value of SEIS scrips in the market due to adverse market conditions, including the impact of the COVID-19 pandemic. The Ld. AR explained the sequence of events as under: Under the SEIS framework, export incentive was earlier notified at 3% of foreign exchange earnings, which was subsequently revised upward to 5% in December 2017. During FY 2019-20, the assessee accrued SEIS income based on the prevailing rate and estimated realisation value. However, during FY Printed from counselvise.com 7 ITA No. 8922/Mum/2025 AY 2022-23 Packt Publishing Private Limited 2021-22, the Government revised the SEIS rate downward to 3%, and the actual sale of SEIS scrips also yielded lower realisation due to prevailing market conditions. The respective Notifications of Government of India Ministry of Commerce & Industry Department of Commerce are enclosed in APB pages 523 to 524. The calculation of the SEIS income accrued and realization in enclosed in APB page 557 which is reproduced as below:- Consequently, the assessee reversed the excess income earlier accrued, resulting in a write-off of Rs.79,31,000/- during the year under consideration. The Ld. AR submitted that the assessee has consistently treated SEIS income as non-operating for transfer pricing purposes, since such income does not arise from the core activity of providing publishing support services but rather from a government incentive scheme. It was therefore argued that once SEIS income itself has been treated as non- operating, the reversal or write-off of such income must necessarily receive the same treatment. Treating SEIS income as non-operating while treating the reversal is thereof as operating would violate the principles of consistency and matching and would artificially distort the operating margin. Printed from counselvise.com 8 ITA No. 8922/Mum/2025 AY 2022-23 Packt Publishing Private Limited The Ld. AR submitted that if the SEIS reversal is excluded from operating expenses, the revised operating margin of the assessee works out to 7.85%, which falls within the arm’s length range of 6.10% to 11.57% determined pursuant to the directions of the Hon’ble DRP. Accordingly, no transfer pricing adjustment would survive. Ground No. 5(ii): Treatment of Foreign Exchange Fluctuation The Ld. AR further submitted that the Ld. TPO erred in treating foreign exchange fluctuation gain of Rs.77,52,964/- as non-operating income. It was contended that the assessee is a captive service provider rendering publishing support services exclusively to its associated enterprise, and the foreign exchange fluctuation arises solely from realisation of export receivables relating to such services. The Ld. AR pointed out that the financial statements of the assessee demonstrate that the foreign exchange fluctuation pertains entirely to operating receivables arising from provision of services, and the assessee does not incur foreign currency expenditure unrelated to its operations. Further, the Ld. AR drew our attention to the inter-company agreement, which specifically provides that any foreign exchange fluctuation loss forms part of operating cost, which is compensated by the AE along with the agreed mark-up. Therefore, both foreign exchange gains and losses form part of the operating results of the assessee’s business activity. The Ld. AR submitted that various judicial precedents have consistently held that foreign exchange fluctuation arising from operating transactions must be treated as operating in nature while computing operating margins under the TNMM method. Respectful Reliance was placed on the following decisions: Printed from counselvise.com 9 ITA No. 8922/Mum/2025 AY 2022-23 Packt Publishing Private Limited • KGK Creations Pvt Ltd vs JAO, [ITA No. 6854/Mum/2024 date of order 28/03/2025.] • Sumit Diamond (India) Pvt Ltd vs Ad.CIT reported in [2013] 32 taxmann.com 394 date of order 23/01/2023. 6. It was further submitted that the Ld. TPO’s reliance on Rule 10TA of the Safe Harbour Rules for treating foreign exchange fluctuation as non-operating is misplaced, since the Safe Harbour provisions apply only where the assessee has opted for such regime, which is not the case here. The Ld. AR therefore submitted that foreign exchange fluctuation must be treated as operating in nature both for the assessee and the comparable companies. It was submitted that if foreign exchange fluctuation is treated as operating in nature, the revised operating margin of the assessee works out to 7.62%, which again falls within the arm’s length range determined by the DRP. Accordingly, the Ld. AR contended that the transfer pricing adjustment relating to publishing support services deserves to be deleted. 7. The Ld. DR argued stated that During the TP assessment proceedings, Ld. TPO treated foreign exchange gain/loss as non-operating in nature while recomputing the operating margin of the assessee on the basis of following • In the TP study report, the Appellant considered forex fluctuation as operating while computing its margins and treated forex fluctuation as non- operating while computing operating margins of comparable companies, • Relied upon Rule 10TA, contending that foreign exchange fluctuation is required to be treated as non-operating in nature. The Ld. DR stands in favour of the orders of revenue authorities. Printed from counselvise.com 10 ITA No. 8922/Mum/2025 AY 2022-23 Packt Publishing Private Limited 8. After considering the submissions of the Ld. AR and the material placed on record, it is observed that the recomputation of the operating margin by the Ld. TPO is primarily based on the reclassification of SEIS reversal and foreign exchange fluctuation. The assessee has demonstrated that SEIS related income has consistently been treated as non-operating, and therefore the reversal of such income must also receive identical treatment in order to maintain comparability and consistency. Further, foreign exchange fluctuation arising from the realisation of export receivables is intrinsically linked to the operating activity of the assessee and has been consistently held by various judicial precedents to be operating in nature for transfer pricing purposes. When the above adjustments are considered appropriately, the operating margin of the assessee falls within the arm’s length range determined by the DRP, and therefore no adjustment is required in respect of the international transaction of provision of publishing support services. Accordingly, the transfer pricing adjustment made on this issue is directed to be deleted. Ground No. 5 of assessee’s appeal is allowed. 9. Ground No. 9 – Working Capital Adjustment The Ld. AR submitted that the assessee had sought working capital adjustment under Rule 10B(1)(e)(iii) to neutralize differences in receivables and payables between the assessee and comparable companies. It was submitted that:  Working capital adjustment is a recognized comparability adjustment under TNMM.  The OECD guidelines support use of average working capital balances where daily data is unavailable. Printed from counselvise.com 11 ITA No. 8922/Mum/2025 AY 2022-23 Packt Publishing Private Limited  Denial of such adjustment merely due to absence of daily data is not justified. It was further submitted that after granting working capital adjustment, the comparable margin becomes 5.88%, which is lower than the assessee’s margin of 10.14%. 10. The Ld. AR also submitted that WCA \"normalises\" the comparable companies financial data by adjusting for differences in accounts receivable, accounts payable and inventory. Ld. AR arguments for grant of working capital adjustment before the DRP are provided on page 954 to 963 of the APB. The computation of working capital adjusted margins for assessee's comparables as well as TPO's comparables is provided on page 964 to 987 of the APB. Operating margin of Appellant Working capital adjusted margins of comparables OP/OC-10.14% OP/OC-5.88% From the above table, it is evident that the assessee's margins are higher than the working capital adjusted margins of comparable companies. 11. The Ld. DR argued and stands in favour of the orders of the revenue authorities. He contended that the DRP rejected the argument for grant of working capital adjustment on the following premise: Printed from counselvise.com 12 ITA No. 8922/Mum/2025 AY 2022-23 Packt Publishing Private Limited  Working capital adjustment based on opening and closing balance-sheet figures does not reflect intra-year movements in receivables, payables and inventory.  Cost of capital differs across companies, and working capital adjustment based on broad assumptions may not yield reliable results.  Working capital adjustment is highly data-intensive and daily working capital levels would be the most reliable basis for such computation. 12. In this regard, the Ld. AR contended that WCA based on opening and closing balance-sheet figures does not reflect intra-year movements in receivables, payables and inventory. He stated that WCA is a recognised comparability adjustment under TNMM, intended to account for differences in working capital levels which particularly accounts receivable and accounts payable between the tested party and the comparables, as such differences affect sales, cost of sales and profitability. However, the DRP's concern that opening/closing figures may not capture intra-year movements pertains to the computation of WCA, rather than rejection of WCA in principle. In this regard, it is the OECD guidance expressly recognises that comparison of receivables, inventory and payables as on the last day of the financial year may not be appropriate if such timing does not provide a representative level of working capital over the year and clarifies that averages may be used where they better reflect working capital levels. Accordingly, even where year-end balances may be influenced by timing of sales, the accepted approach is to adopt representative averages/periodic measures, and the premise cannot justify a Printed from counselvise.com 13 ITA No. 8922/Mum/2025 AY 2022-23 Packt Publishing Private Limited denial of WCA altogether. Cost of capital differs across companies, and working capital adjustment based on broad assumptions may not yield reliable results. The Ld. AR stated that WCA is an economic adjustment intended to improve comparability by reducing differences in trade credit and working capital levels. The fact that cost of capital may differ across companies does not, by itself, render WCA unreliable, rather, it is an issue addressed within the WCA framework through the selection of an appropriate interest rate. 13. The OECD guidance acknowledges that interest rate selection is a key aspect of WCA and states that the rate should generally be determined by reference to the rate(s) applicable to a commercial enterprise operating in the same market as the tested party, further, it notes that in most cases a commercial loan rate is appropriate. Consequently, the presence of judgment in selecting an interest rate is contemplated within the recognised method and does not convert the adjustment into impermissible \"assumptions\", at most, it requires that the interest rate selection be reasoned, consistent and market- based. Working capital adjustment is highly data-intensive and daily working capital levels would be the most reliable basis for such computation. The Ld. AR argued that while WCA is data-dependent, the proposition that daily working capital levels are a necessary precondition is not supported by accepted guidance and would make WCA impracticable in most benchmarking exercises based on publicly available financial statements. The OECD guidance does not prescribe daily data as mandatory; rather, it explicitly acknowledges the timing issue and states that year-end figures may not be representative and that averages may be used where they better reflect working capital levels over the year. Therefore, the absence of daily data cannot be a basis to deny Printed from counselvise.com 14 ITA No. 8922/Mum/2025 AY 2022-23 Packt Publishing Private Limited WCA where the adjustment can be computed on a reasonably accurate basis using representative averages/periodic data, consistent with the recognized computation method. 14. We have heard the rival submissions and perused the material available on record. The issue under consideration pertains to the grant of working capital adjustment under Rule 10B(1)(e)(iii) while benchmarking the international transactions under the TNMM. It is an undisputed position that working capital adjustment is a recognized comparability adjustment intended to neutralize differences in receivables, payables, and inventory between the tested party and the comparable companies, which materially impact profitability. We find merit in the contention of the Ld. AR that denial of working capital adjustment solely on the ground of absence of daily working capital data is not justified. The OECD Transfer Pricing Guidelines also recognize that, in the absence of daily data, reasonable approximations such as averages based on opening and closing balances can be adopted, provided they reasonably reflect the working capital position during the year. The objections raised by the DRP regarding intra-year movements and differences in cost of capital pertain to the manner of computation and do not constitute valid grounds for outright rejection of the adjustment. In our considered view, working capital adjustment is an integral part of TNMM analysis to improve comparability, and the same cannot be denied merely on the basis of practical limitations in data availability, especially when reasonably reliable data is available on record. The selection of an appropriate interest rate and methodology may involve a degree of estimation; however, such estimation is inherent in transfer pricing analysis and does not render the Printed from counselvise.com 15 ITA No. 8922/Mum/2025 AY 2022-23 Packt Publishing Private Limited adjustment invalid. Further, from the computation placed on record, it is evident that after granting working capital adjustment, the margin of the comparable companies stands at 5.88%, which is lower than the assessee’s margin of 10.14%. Accordingly, the international transactions of the assessee are at arm’s length. In view of the above discussion, we direct the Ld. AO/TPO to grant working capital adjustment to the assessee in accordance with law. Consequently, no transfer pricing adjustment survives on this issue. Accordingly, Ground No. 9 raised by the assessee is allowed. 15. Ground No. 1 This ground being general in nature does not require separate adjudication and is treated as consequential to other grounds. The Ground No-1 raised by the assessee is dismissed. 16. Ground Nos. 2 to 4, 6 to 8 & 10 to 14. Ground No. 9 relating to the grant of working capital adjustment is allowed. Consequently, the entire transfer pricing adjustment pertaining to publishing support services stands deleted. In view of this, adjudication of the remaining grounds becomes academic and is, therefore, left open. 17. Ground No. 15 – Penalty under Section 270A The initiation of penalty proceedings is premature and consequential. Since the issue relates only to initiation of penalty, the same is premature and does not require adjudication at this stage. Printed from counselvise.com 16 ITA No. 8922/Mum/2025 AY 2022-23 Packt Publishing Private Limited Ground No-15 is dismissed. 18. Ground No. 16 – Interest under Sections 234A, 234B and 234C The levy of interest is consequential in nature and shall be recomputed while giving effect to this order. 19. In the result, the appeal of the assessee bearing ITA No. 8922/Mum/2025 is allowed. Order is pronounced in the open court on 26.03.2026 Sd/- Sd/- BIJAYANANDA PRUSETH ANIKESH BANERJEE (ACCOUNTNAT MEMBER) (JUDICIAL MEMBER) Place: Mumbai Dated: 26.03.2026 Divya Ramesh Nandgaonkar Stenographer आदेशकीŮितिलिपअŤेिषत/Copy of the Order forwarded to: 1. अपीलाथŎ / The Appellant 2. ŮȑथŎ / The Respondent. 3. आयकरआयुƅ / CIT 4. िवभागीयŮितिनिध, आयकरअपीलीयअिधकरणDR, ITAT, Mumbai 5. गाडŊफाईल / Guard file. सȑािपतŮित //True Copy// आदेशानुसार / BY ORDER, सहायकपंजीकार (Asstt. Registrar) आयकरअपीलीयअिधकरण / ITAT, Bench, Mumbai. Printed from counselvise.com "