Appeal details
Counselvise Citation
[2024] 138 COUNSELVISE.COM (IT) 8497 (ITAT-MUMBAI)
Assessee PAN
Bench
Appeal Number
Duration Of Justice
3 month(s) 22 day(s)
Appellant
Respondent
Appeal Type
Income Tax Appeal
Pronouncement Date
13-12-2024
Appeal Filed By
Assessee
Order Result
Partly Allowed
Bench Allotted
J
Assessment Year
2020-2021
Appeal Filed On
21-08-2024
Judgement Text
"| आयकर अपीलीय अिधकरण \fा\nयपीठ, मुंबई | \nIN THE INCOME TAX APPELLATE TRIBUNAL \n“J” BENCH, MUMBAI \n \n \n \nBEFORE SHRI NARENDRA KUMAR BILLAIYA, HON’BLE ACCOUNTANT MEMBER \n& \nSHRI RAJ KUMAR CHAUHAN, HON’BLE JUDICIAL MEMBER \n \n \nI.T.A. No. 4210/Mum/2024 \nAssessment Year: 2020-21 \n \n \nRallis India Limited, Mumbai \nC/o Kalyaniwalla & Mistry LLP \nEsplanade House \n2nd Floor \n29, Hazarimal Somani Marg \nFort \nMumbai - 400001 \n[PAN: AABCR2657N] \n \nVs \nThe Asst. Commissioner of \nIncome tax, Circle-8(1)(1), \nMumbai \nअपीला\nथ\u0016/ (Appellant) \n \n\u0017\u0018 \nयथ\u0016/ (Respondent) \n \nAssessee by : \nShri M.M. Golwala, A/R \nRevenue by : \nShri Pankaj Kumar, CIT, D/R \n \n सुनवाई की तारीख/Date of Hearing : 21/11/2024 \n घोषणा की तारीख /Date of Pronouncement: 13/12/2024 \n \nआदेश/O R D E R \n \n \n \nPER NARENDRA KUMAR BILLAIYA, AM: \n \nThis appeal by the assessee is preferred against the order dated \n09/07/2024 framed u/s 143(3) r.w.s. 144C(13) of the Act, pertaining to \nAY 2020-21. \n2. \nThe grievance of the assessee reads as under:- \n“1. Both lower authorities erred in making a Transfer Pricing adjustment amounting \nto Rs.5,66,00,731/-. \n \n2. Both lower authorities erred in rejecting the Transfer Pricing study carried out by \nthe Applicant Company for determining the arm's length price of the transaction. \n \n3. Both lower authorities erred in holding that Tata Chemicals International Pte Ltd \nhad very little/ no role to play in the transaction under question, without \nunderstanding the facts and the business purpose behind the transaction. \n \n4. Both lower authorities erred in ignoring the Appellant company's submissions as \nregards application of \"other method\" through savings in interest costs, due to \nprompt and timely payments by TCIPL, which has ultimately resulted in a higher \nprofit on the transaction. \n\n \nI.T.A. No. 4210/Mum/2024 \n \n2 \n \n \n5. Both lower authorities erred in disallowing a further amount of Rs. 1,83,46,780/- \nu/s.14A read with Rule 8D(2). \n \n6. The Appellant submits that the Assessing Officer recorded no \"objective \nsatisfaction\" while making an addition to the disallowance u/s 14A already made by \nthe Appellant in its Return of Income. \n \n7. Without prejudice to ground nos. 5 & 6, the Appellant submits that disallowance \nof expenditure u/s. 14A be restricted to 2% of the dividend income earned by the \nAppellant, following appellate orders in the assessee's own case in earlier years. \n \n8. Without prejudice to ground nos. 5 & 6, the Applicant submits that the \ndisallowance is highly excessive and arbitrary. \n \n9. Without prejudice to ground nos. 5, 6, 7 & 8, the appellant submits that no \ndisallowance is called for u/s.14A read with Rule 8D in respect of those investments \non which no dividend income has been received during the year. \n \n10. Both lower authorities erred in including, in Book-Profit (u/s 115JB), the amount \nof disallowance made u/s 14A. The Applicant submits that the Assessing Officer be \ndirected to delete the addition to Book-Profit in respect of disallowance u/s 14A. \n \n11. Both lower authorities erred in disallowing the weighted deduction for revenue \nscientific expenditure by way of expenditure incurred for scientific research on \napproved in-house research and development facility u/s 35(2AB) of the Act, \naggregating to Rs.21,58,10,103/-. \n \n12. Both lower authorities erred in disallowing the weighted deduction u/s 35(2AB) \nof the Act, aggregating to Rs.48,00,835/-. \n \n13. Both lower authorities erred in misreading and misinterpreting the provisions of \nsection 35(2AB) of the Act. \n \n14. The Assessing Officer erred in disallowing the Applicant's claim u/s 35(2AB) by \nholding that the non-submission of report in Form 3CL by the Department of \nScientific Research, would disentitle the Applicant from its claim u/s 35(2AB). \n \n15. Both lower authorities erred in disregarding the decision of the jurisdictional \nHigh Court in the case of Astec Lifesciences Ltd v. CIT (WP No 1790 of 2022). \n \n16. The Assessing Officer erred in restricting the claim of MAT credit to Rs.19.97 \ncrores as against Rs.27.14 crores, claimed by the Appellant company. \n \n17. The Appellant company denies any liability of interest under sections 234A, \n234B & 234C, which has been erroneously levied by the Assessing Officer. \n\n \nI.T.A. No. 4210/Mum/2024 \n \n3 \n \n18. The Assessing Officer erred in not granting credit for tax deducted at source to \nthe tune of Rs.67,900/-. \n \n19. The Assessing Officer erred in not granting credit for advance tax paid to the \ntune of Rs.3,77,21,258/- \n \nThe Appellant craves leave to add to, amend, alter, modify or withdraw any or all the \ngrounds of appeal before or at the time of hearing, as they may be advised from time \nto time.” \n \n3. \nGround Nos. 1 to 4 relates to the Transfer Pricing (TP) \nadjustments. \n4. \nRepresentatives of both the sides were heard at length. Case \nrecords carefully perused and the relevant documentary evidence \nbrought on record, duly considered in light of Rule 18(6) of the ITAT \nRules, 1963. \n5. \nBriefly stated the facts of the case are that the assessee is engaged \nin the business of manufacturing and selling of agrochemicals including \npesticides and is a registered company under the India Companies Act. \nThe assessee is a group entity of Tata Enterprise and is in the agriculture \ninputs industry. It has four production facilities of which two are \nlocated in Gujarat and two in Maharashtra. \n6. \nA reference u/s 92CA(1) of the Act was made to DC/ACIT, TP \n3(3)(1), Mumbai, for computation of ALP in relation to the international \ntransactions. During the year the assessee has sold goods to its AE, Tata \nChemicals International Pte Ltd. Singapore (TCIPL). These goods are \nsold on “Bill To Ship To Model” basis i.e., the billing is done to TCIPL \nand the goods are sold directly to third party i.e., Adama Agan Ltd. The \ninternational transactions relating to sale of goods was to the tune of \nRs.1,77,65,21,572/- and the assessee adopted other method as the most \nappropriate method. \n\n \nI.T.A. No. 4210/Mum/2024 \n \n4 \n \n7. \nThe peculiar facts are that from April to 29th August, the assessee \nsold directly to Adama Agan Ltd. (AAL), but post 29th August, the \nassessee sold goods through its AE i.e., TCIPL. When the goods were \nsold directly by the assessee, the credit period allowed to AAL was 150-\n180 days for the pesticides Metribuzin (Metri) and Pendimenthalin \n(Pendi) whereas the credit period allowed to TCIPL is immediately on \nreceipt of invoice or after 7-10 days of receipt of invoice. It was \nexplained that due to the differed in credit period, Rallis India had to \ndiscount the bills from the banks and for which Rallis India had to pay \nthe bill discounting charges. Justifying its sales through TCIPL, it was \nexplained that considering the bill discounting charges, the cost of \nworking capital etc., there is net benefit on sales to TCIPL. The assessee \nalso furnished the entire party-wise calculation on the benefit of sales \nthrough TCIPL thereby justifying the transactions with respect to the \nsale of goods to AE. Consistent with the arm’s length standard from the \nIndian transfer pricing perspective. \n7.1. \nThe contentions and submissions of the assessee did not find any \nfavour with the TPO who was of the firm belief that if the assessee had \nsold the goods directly to AAL, it would have sold it at a value of \nRs.1,83,13,86,163/- whereas, the assessee has sold the goods through its \nAE, TCIPL worth Rs.1,77,65,21,572/-. Thus, the difference of \nRs.5,48,64,591/- is revenue of AE, TCIPL and, therefore, the assessee has \nincurred a loss of Rs.5.48 Crores. The AO was of the opinion that the \nprices at which the AE, TCIPL had sold the goods to AAL, should be \nconsidered as ALP. This is the rate at which the assessee would have \n\n \nI.T.A. No. 4210/Mum/2024 \n \n5 \n \nsold to third party under an uncontrolled scenario. The TPO, on the \nstrength of this belief proposed adjustments as under:- \n \nAE-TCIPL \nTCIPL-Adama Agan (ALP) \nDifference \nin \nPrices-Adjustment \nProposed \nProduct \nQty \nExport \nValue \n(USD) \nExport \nValue \n(USD) \nvalue \nValue \n(USD) \nExchang\ne Rate as \non \n31.03.20\n20 \nValue \n(In \nINR) \nPendimethalin \nPowder – 550KG \n13,55,200 \n85,21,040 \n13,55,200 \n88,14,432 \n293,392 \n75.38 \n22,115,889 \nMetribuzin Tech – \n500 KG \n(Jumbo Bag) \n560,000 \n15,830,720 \n560,000 \n16,288,200 \n457,480 \n75.38 \n34,484,842 \nTotal Adjustment \n5,66,00,731 \n \n \n7.1.1. And, \naccordingly \nproposed \nupward \nadjustment \nof \nRs.5,66,00,731/-. \n7.2. \nThe objections raised by the assessee were dismissed by the DRP \nand the final assessment order was framed accordingly. \n8. \nBefore us, the ld. Counsel for the assessee drew our attention to \nthe working capital cost, explaining the savings done by the assessee in \nentering the impugned transactions through its AE, TCIPL. It is the say \nof the ld. Counsel that both the lower authorities have completely \nmisread the statement furnished by the assessee. The ld. Counsel for the \nassessee, vehemently stated that both the TPO & DRP have completely \nignored the risk factor as explained by the assessee. The ld. Counsel, \nreiterated that earlier when it was selling directly to AAL, the credit \nperiod ranged from 150 to 180 days thereby permitting the assessee to \ndiscount the bills at a cost. When the goods were sold through AE, \nTCIPL, the assessee received payments within 8 to 10 days as explained \n\n \nI.T.A. No. 4210/Mum/2024 \n \n6 \n \nin the chart thereby showing that there was substantial savings in the \ninterest minimizing the credit risk arising from non-payment of dues by \ncustomers. The TPO and the DRP also ignored the market risk as now \nthe AE is responsible for carrying out all the sales and marketing related \nactivities for the products. Thus, the assessee does not bear the market \nrisks. The ld. Counsel for the assessee concluded by saying that the TP \nadjustment made by the AO is unwarranted and uncalled for in the \npeculiar facts and circumstances of the case. \n8.1. \nPer contra, the ld. D/R strongly supported the findings of the \nTPO. \n9. \nWe have given a thoughtful consideration to the orders of the \nauthorities below. The undisputed fact is that the assessee was selling \ngoods directly to AAL. The credit period was between 150-180 days and \nthe assessee was bearing the cost of bill discounting, credit risk arising \nfrom non-payment of dues by customers and also market risk where the \nprices keep on fluctuating in the international market. Post 29th August, \nwhen the assessee started selling its goods through its AE, TCIPL, the \nactual days of credit were between 5-21 days with no credit risk and no \nmarket risk as both have been shifted to the AE, TCIPL. \n9.1. \nWe have given a thoughtful consideration to the working capital \ncost chart exhibited at page 136 of the paper book and undisputedly we \nfind that the benefit in working capital cost is at Rs. 6,17,74,577/- \nwhereas the difference in selling price is Rs.5,48,64,591/-. Net benefit \nbeing Rs.69,09,987/-. \n9.2. \nThe following observations of the DRP are misplaced against the \nfacts of the case:- \n\n \nI.T.A. No. 4210/Mum/2024 \n \n7 \n \n“But the same has to be demonstrated based on actual savings accruing to the \nassessee by juxtaposing the alleged loss due to direct sale (when the arrangement was \nnot in place) and the so called profit accruing as a result of the arrangement. This \nrequires the following details:- \n• Actual duration taken for payment by AE in case of arrangement \n• Interest loss in the case od direct billing with actual cash flow \n• Interest bearing and non interest bearing funds available with the \nassessee \n• Advances, loans advanced to the AE by assessee, if any \n6.3.5. These details have not been submitted by the assessee and hence the notional \ninterest gain derived by the assessee cannot be taken as an acceptable adjustment as \nmandated by the Rule 10B(10(a)…” \n \n9.2.1. As mentioned hereinabove, as per the chart exhibited at page 136, \nthe assessee has clearly demonstrated the benefit in saving of interest. \nFrom the chart, it can be seen that the actual difference of credit when \nthe sales are made by AE to AAL, is much less than the credit period \nwhen sales were made by the assessee directly to AAL. Since all the \napprehensions of the DRP has been explained in the chart exhibited at \npage 136, the impugned TP adjustment was uncalled for on the facts \nmentioned hereinabove. Therefore, we direct the AO/TPO to delete the \nimpugned TP adjustment. Ground Nos. 1 to 4 are allowed. \n10. \nGround Nos. 5 to 9 relate to the addition on account of \ndisallowance made u/s 14A r.w.r. 8D. \n10.1. The assessee has challenged the impugned disallowance on the \nground that the AO has nowhere recorded any satisfaction for making \nthe impugned disallowance nor the AO has discussed anywhere the suo \nmoto disallowance made by the assessee. It was explained that the only \ntax-free receipt is the dividend income for which no amount of \nexpenditure has been incurred by the assessee towards earning of \ndividend income. It was explained that the dividend are directly \ncredited to the assessee’s bank account through ECS. It was further \n\n \nI.T.A. No. 4210/Mum/2024 \n \n8 \n \nexplained that by way of abundant caution, the assessee has suo moto \ndisallowed Rs.18,61,000/- which represents 1/10th salary of the CFO, \nTreasury head and Manager Treasure. \n11. \nBefore us, the ld. Counsel for the assessee placed strong reliance \non the decision of the Hon’ble Bombay High Court in the case of PCIT \nvs. Godrej & Boyce Mfg Co. Ltd. reported in (1029 of 2018) (Bom HC) and \nPCIT vs. Tata Capital Ltd. (1081 of 2018) (Bom HC). Both these decisions \nare by the Hon’ble Jurisdictional High Court of Bombay and further \nrelied upon the decision of the Hon’ble Supreme Court in the case of \nSouth Indian bank vs. CIT (438 ITR 1)(SC). \n12. \nPer contra, the ld. D/R supported the findings of the AO. \n13. \nWe have carefully considered the orders of the authorities below. \nThe undisputed fact is that the assessee has own interest free funds to \nthe tune of Rs. 1409 Crores and has earned cash profits during the year \nunder consideration to the tune of Rs.239.27 Crores. The interest free \nown funds are far more in excess of the investments and the cash flow \nstatement already on record suggest that no borrowings have been \ninvested in purchasing of investments. We further find that nowhere \nthe AO has recorded his dis-satisfaction insofar as the suo moto \ndisallowance of Rs. 18.61 Lakhs is concerned. The AO has simply stated \nthat some expenses need to be disallowed for earning exempt income \nwithout pointing out why the suo moto disallowance made by the \nassessee is not sufficient for earning the exempt income. On identical set \nof facts, the Hon’ble High Court of Bombay in the case of Godrej & Boyce \nMfg Co. Ltd. (supra), has held as under:- \n“11. \nIn the present case, the assessee had earned an exempt income of Rs. \n84,30,37,423/- from shares and mutual funds and submitted a computation of \n\n \nI.T.A. No. 4210/Mum/2024 \n \n9 \n \ninadmissible expenditure u/s 14A amounting to Rs. 13,66,635/-. The assessee \nclaimed that the disallowance made u/s14A was as per the books of account \nattributable to earning of exempt income! On a perusal of the assessment order we \nfind that there is no discussion by the AO with regard to the computation of \ninadmissible expenditure made by the assessee forming part of the return of income. \nFurther, the AO has not recorded any satisfaction that the working of inadmissible \nexpenditure u/s14A is incorrect with regard to the books of account of the assessee. \nThe provision u/s 14(2) does not empower the AO to apply Rule 8D straightaway \nwithout considering the correctness of the assessee's claim in respect of expenditure \nincurred in relation to the exempt income. We agree with the view of the ITAT that \nin the present case the AO has neither examined the claim in respect of expenditure \nincurred in relation to exempt income of the assessee nor has recorded any \nsatisfaction with regard to the correctness of assessee's claim with reference to the \nbooks of account. Consequently, the disallowance made by applying the Rule 8D is \nnot only against the statutory mandate but contrary to the legal principles laid down. \nIn our view too, the CIT (A) has rightly deleted the addition made on account of \ninterest expenditure as the assessee had sufficient interest free surplus fund to make \nthe investment and the ITAT has rightly deleted the disallowance made by the AO \nus 14A r.w Rule 8D. Consequently we hold that, the interest expenditure cannot be \ndisallowed u/s14A r.w. Rule 8D(2)(ii) under any circumstances.” \n \n13.1. Similar view was taken by the Hon’ble High Court of Bombay in \nthe case of Tata Capital Ltd. (supra). The relevant findings read as under:- \n“7. \nWe agree with the finding of the CIT(A) and the ITAT that though the AO \nhas stated that Assessee's explanation is not acceptable, he has not given reasons why \nit was not acceptable to him. Subsection (2) of Section 14A and Rule 8D provides \nthat if the Assessing Officer is not satisfied with the correctness of the claim in respect \nof expenditure made by Assessee in relation to income which does not form part of \nthe total income under the Act, he shall determine the amount of expenditure in \nrelation to such income in accordance with the provisions prescribed. The most \nfundamental requirement, therefore, is the Assessing Officer should record his \ndissatisfaction with the correctness of the claim of Assessee in respect of the \nexpenditure and to arrive at such dissatisfaction, he should give cogent reasons.” \n \n14. \nConsidering the facts in light of the judicial decisions discussed \nhereinabove, we do not find any merit in the impugned disallowance \nmade u/s 14A of the Act. The same is directed to be deleted. \nAccordingly, Ground Nos. 5 to 9 are allowed. \n15. \nGround No. 10 becomes otiose. \n16. \nGround Nos. 11 to 15, relate to the denial of deduction u/s \n35(2)(ab) of the Act. While scrutinising the return of income, the AO \n\n \nI.T.A. No. 4210/Mum/2024 \n \n10 \n \nfound that the assessee has claimed Rs. 71,76,25,402/- towards \nexpenditure on scientific research u/s 35(1)(i), 35(1)(ii), 36(2AB) of the \nAct. \n16.1. The AO noticed that the assessee has not filed certificate from \nDSIR in Form 3CL for claiming the above expenditure. Accordingly, \nshowcause notice was issued to the assessee. It was explained that \nunder Rule 6 of the Income Tax Rules, 1962, the Department of Scientific \n& Industrial Research (DSIR), is required to submit its report to the \nIncome Tax Authorities in Form 3CL and there is no requirement of the \nassessee to file the said Form but From No. 3CL is required to be \nsubmitted by the DSIR, therefore, failure to file the same cannot be \nattributed to the assessee. This contention of the assessee did not find \nany favour with the AO who was of the firm belief that as the assessee \nfailed to furnish the certified copy of the Form 3CL issued by the \nSecretary, DSIR, claim of the assessee lacks any merit. The AO \naccordingly denied the claim of deduction by making addition of Rs. \n22,06,10,038/-. The denial was affirmed by the DRP. \n17. \nBefore us, the ld. Counsel straightaway drew our attention to the \ndecision of the Hon’ble Bombay High Court in the case of Astec \nLifesciences Ltd. vs. ACIT (WP 1790 of 2022) (Bom. HC) and pointed out \nthat on identical set of facts, the Hon’ble High Court held as under:- \n “13. As regards the deduction under Section 35(2AB) of the Act, admittedly Form \n3CL duly filled in and certified by the Secretary of Department of Scientific and \nIndustrial Research to Director General (Income Tax Exemptions) under Section \n35(2AB) of the Act has to be submitted by the Department of Scientific and \nIndustrial Research directly to the Income Tax Authorities. The allegation of failure \nto file the said Form cannot be attributed to petitioner.” \n \n\n \nI.T.A. No. 4210/Mum/2024 \n \n11 \n \n18. \nSimilar view was taken by the Hon’ble High Court of Gujarat in \nthe case of CIT vs. Sun Pharmaceutical Industries Ltd. (250 Taxman 270) \n(Guj. HC). The relevant findings read as under:- \n“….One of the main grounds which appealed to the Commissioner was that the \nprescribed authority had not sent the intimation in Form 3CL to the Revenue, in \nabsence of which, according to the Commissioner, claim could not have been accepted. \n4. The assessee approached the Tribunal. The Tribunal by the impugned judgment \nallowed the appeal inter-alia holding that the prescribed authority shall submit its \nreport in relation to the approval of the in-house research and development in Form \n3CL to the Director General of Income Tax (Exemption) within 60 days of its \ngranting approval. In the opinion of the Tribunal, same was merely in form of \nintimation to be sent by the prescribed authority to the department. In case of the \nassessee, the research and development activity having already been approved in \nForm 3CM, the assessee thereafter, had no further role to play in the inter-\ndepartmental correspondence. The Tribunal therefore, held that the assessee was \nentitled to deduction on the capital and revenue expenses incurred on in-house \nresearch and development amounting to Rs.237,77,05,310/-. \n5. Having heard learned counsel for the parties and having perused the orders on \nrecord, we are broadly in agreement with the view of the Tribunal. Undisputedly, the \nresearch and development facility set up by the assessee was approved by the \nprescribed authority and necessary approval was granted in the prescribed format. \nThe communication in Form 3CM was thereafter, between the prescribed authority \nand the department. If the same was not so, surely, the assessee cannot be made to \nsuffer. To this extent, the Tribunal was perfectly correct and the Commissioner was \nnot, in observing that in absence of such certification, claim of deduction under \nsection 35(2AB) was not allowable. However, neither the prescribed authority nor \nthe Assessing Officer has applied the mind as to the expenditure, be it revenue or \ncapital in nature, actually incurred in developing the in-house research and \ndevelopment facility. To the limited extent, the Commissioner desired the Assessing \nOfficer to verify such figures, we would allow the Assessing Officer to do so. In other \nwords, in principle, we accept the Tribunal's reasons and conclusions. Merely \nbecause the prescribed authority failed to send intimation in Form 3CL, would not \nbe reason enough to deprive the assessee's claim of deduction under section 35(2AB) \nof the Act. However, in facts of the present case, it would be open for the Assessing \nOfficer to verify the actual expenditure incurred by the assessee.” \n \n19. \nConsidering the facts of the case in light of the judicial decisions \ndiscussed hereinabove and taking a leaf out of the decision of the \nHon’ble High Court in the case of Sun Pharmaceuticals Industries Ltd. \n(supra), in principle we accept the contention that, communication is \nbetween the prescribed authority and the Department and for the \n\n \nI.T.A. No. 4210/Mum/2024 \n \n12 \n \ndefault in same, the assessee cannot be made to suffer. However, it \nwould be open for the AO to verify the actual expenditure incurred by \nthe assessee. With these directions, Ground Nos. 11 to 15 are allowed. \n20. \nGround Nos. 16 & 18 are not pressed and, therefore, the same are \ndismissed as not pressed. \n21. \nGround No. 17 is allowability of interest. The AO is directed to \nlevy interest as per the provisions of law and Ground No. 19 is in respect \nof non-granting of advance tax paid. The AO is directed to verify the \nsame from the challan and also from the income-tax portal and allow the \nsame after verification. \n22. \nIn the result, appeal of the assessee is partly allowed. \nOrder pronounced in the Court on 13th December, 2024 at Mumbai. \n \n \n \nSd/- \n \n \n \n \n \n \nSd/- \n(RAJ KUMAR CHAUHAN) \n \n \n(NARENDRA KUMAR BILLAIYA) \nJUDICIAL MEMBER \n \n \n \n ACCOUNTANT MEMBER \n \n \n \n \n \n \n \n \n \nMumbai, Dated 13/12/2024 \n*SC SrPs\n*SC SrPs\n*SC SrPs\n*SC SrPs \n \n \n \n \nआदेश की \u0015ितिलिप अ\u001aेिषत \n/Copy of the Order forwarded to : \n \n1. \nअपीलाथ\u001c / The Appellant \n2. \n\u0015\u001dथ\u001c / The Respondent \n3. \nसंबंिधत आयकर आयु\" / Concerned Pr. CIT \n4. \nआयकर आयु\"\n)\nअपील\n (\n/ The CIT(A)- \n5. \nिवभागीय \u0015ितिनिध ,आयकर अपीलीय अिधकरण, मुंबई /DR,ITAT, Mumbai, \n6. \nगाड& फाई/ Guard file. \n \n \n \n \nआदेशानुसार/ BY ORDER, \nTRUE COPY \n \n \n \n \nAssistant Registrar \nआयकर अपीलीय अिधकरण \nITAT, Mumbai \n \n \n"
Mehul