Income Tax Appellate Tribunal - Mumbai
State Bank Of India (Successor To State ... vs Acit -Circle 2(2)(1), Mumbai on 3 March, 2021
1 आयकर अपीलीय अिधकरण "जी" ायपीठ मुंबई म ।
IN THE INCOME TAX APPELLATE TRIBUNAL "G" BENCH, MUMBAI माननीय ी महावीर िसं ह, उपा एवं माननीय ी मनोज कुमार अ वाल ,ले खा सद के सम ।
BEFORE HON'BLE SHRI MAHAVIR SINGH, VP AND
HON'BLE SHRI MANOJ KUMAR AGGARWAL, AM
आयकरअपील सं./ ITA No. 2824/Mum/2018
(िनधा रण वष / Assessment Year: 2014-15)
State Bank of India ACIT, Circle-2(2)(1)
(Successor to State Bank of Aaykar Bhawan, M.K.Road
Bikaner & Jaipur) Mumbai-400 020
बनाम/
Financial Reporting & Taxation Dept.
3rd Floor, Corporate Centre Vs.
Madam Cama Road, Nariman Point
Mumbai-400 021
%थायीले खासं ./जीआइआरसं ./PAN/GIR No. AADCS-4750-R (अ पीलाथ(/Appellant) : ()*थ( / Respondent) & आयकरअ पील सं./ ITA No. 3187/Mum/2018 (िनधा रण वष / Assessment Year: 2014-15) DCIT-2(2)(1) State Bank of India Aaykar Bhawan, M.K.Road (Successor to State Bank of Mumbai-400 020 Bikaner & Jaipur) बनाम/ Financial Reporting & taxation Dept. Vs. 3rd Floor, Corporate Centre Madam Cama Road, Nariman Point Mumbai-400 021 %थायीले खासं ./जीआइआरसं ./PAN/GIR No. AADCS-4750-R (अ पीलाथ(/Appellant) : ()*थ( / Respondent) Assessee by : Shri C.Naresh-Ld.AR Revenue by : Shri Jayant Jhaveri-Ld.CIT-DR सुनवाई की तारीख/ : 01/02/2021 Date of Hearing घोषणा की तारीख / : 03/03/2021 Date of Pronouncement 2 आदे श / O R D E R Manoj Kumar Aggarwal (Accountant Member) ::
1.1 Aforesaid cross-appeals for Assessment Year [in short referred to as 'AY'] 2014-15 contest the order of Ld. Commissioner of Income-Tax (Appeals)-5, Mumbai, [in short referred to as 'CIT(A)'], Appeal No. CIT(A)-5/ITO-2(2)(4)/IT-72/17-18 dated 31/01/2018 . 1.2 The grounds taken by the assessee read as under:-
1. Ld. Commissioner of Income Tax (Appeals) has erred on facts and in law in confirming the disallowance of expenses of Rs.12,04,31,307/- u/s 14A read with Rule 8D by not accepting the contention of assessee that assessee has not incurred any expenditure in relation to exempt income.
1.1 Ld. Commissioner of Income Tax (Appeals) has further erred on facts and in law in holding that the assessee has not come forward with the evidence that it has used its own funds in making investments ignoring that the fact is evident from the Balance Sheet itself. 1.2 Ld. Commissioner of Income Tax (Appeals) has also erred on facts and in law in not appreciating that the assessee holds shares/ securities as stock in trade and not as investment and therefore rule 8D is not applicable.
1.3 The revenue's grounds read as under:-
i. Whether on the facts and in the circumstances of the case and in law, Ld.CIT(A) was right in deleting the addition of Rs.42,47,09,377/- holding that the interest on Government and other securities has to be included in the income on due basis as against the accrual basis?
ii Whether on the facts and in the circumstances of the case and in law, Ld.CIT(A) was right in deleting the addition of Rs.27,22,94,532/- on account of amortization on HTM securities without appreciating the fact that diminution in value of investment in securities under HTM category is notional loss/capital loss which can be recognized only at the time of sale of such securities?
iii) Whether on the facts and in the circumstances of the case and in law, Ld.CIT(A) was right in deleting the addition of Rs.6,50,87,061/- made on account of depreciation on securities without appreciating the finding of AO that Global basis of depreciation applicable instead of assessee's method of charging depreciation on category wise basis?
iv) Whether on the facts and in the circumstances of the case and in law, Ld.CIT(A) was right in deleting the addition of Rs.643,51,48,054/- holding that the broken period interest on purchase of securities is deductible as business expenditure ignoring the judgment of the case of Commissioner of Income Tax V/s. Bank of Rajasthan Ltd. (2009) (316 ITR 391) which decided the issue in favour of the Revenue?
2. The learned counsel for Assessee, Shri C. Naresh, at the outset, submitted that the issues of cross-appeals stood squarely adjudicated by 3 Tribunal in assessee's own case for AY 2008-09, ITA Nos.3644/Mum/2016 & 4563/Mum/2016 order dated 03/02/2020. A copy of the order has been placed on record. The Ld. CIT-DR, though relied upon assessment framed by Ld. AO but could not controvert the fact that all the issues have already been delved into by the co-ordinate bench of this Tribunal in assessee's own case in the cited order.
3. We have carefully heard the rival submissions and gone through the orders of lower authorities and the cited order of Tribunal. Our adjudication to the subject matter of cross-appeal would be as given in succeeding paragraphs. The erstwhile assessee namely State Bank of Bikaner & Jaipur (in whose name the assessment has been framed) is a nationalized bank. An assessment was framed for the year under consideration u/s 143(3) r.w.s. 92CA on 23/02/2017 wherein certain additions / adjustments were made. However, upon further appeal, Ld. CIT(A) has granted certain relief to the assessee vide order dated 31/01/2018 and the said order has given rise to cross-appeals before us.
4. As evident from grounds of cross-appeals, the following issues form subject matter of cross-appeal before us: -
No. Nature of Addition Amt. (Rs.)
1. Disallowance u/s 14A Rs.1204.31 Lacs
2. Interest on Govt. & Other Rs.4247.09 Lacs
Securities on accrual basis instead
of due basis
3. Amortization of Securities held Rs.2722.94 Lacs
under HTM Category
4. Depreciation on Securities under Rs.650.87 Lacs
AFS and HFT category
5. Broken period interest on Rs.64351.48 Lacs
securities
The assessee is aggrieved by confirmation of disallowance u/s 14A wherein revenue is aggrieved by the action of Ld. CIT(A) in granting 4 relief to the assessee on issues tabulated at serial nos. 2 to 5. Our findings and adjudication to all the issues would be as follows.
5. Disallowance u/s 14A:-
5.1 It transpired that the assessee earned tax free income aggregating to Rs.421.18 Lacs in the form of interest on tax free bonds and dividend on shares and mutual funds. However, no disallowance was offered u/s 14A read with Rule 8D. The assessee defended its stand before Ld. AO by way of elaborate written submissions, which have already been extracted in para 2.2 of the assessment order. However, relying upon certain judicial decisions and distinguishing the decisions as relied upon by assessee, Ld. AO invoked the provisions of Rule 8D and computed aggregate disallowance of Rs.1204.31 Lacs which comprised-off of interest disallowance u/r 8D(2)(ii) for Rs.1112.28 Lacs and indirect expense disallowance u/r 8D(2)(iii) for Rs. 92.03 Lacs. Accordingly, the same was added back to the income of the assessee while framing the assessment.
5.2 The Ld. CIT(A) upheld the action of Ld. AO in computing the disallowance since the statutory requirements of Sec.14A(2) r.w.r 8D were duly complied with by Ld. AO and further, the assessee could not prove the nexus between borrowed funds and investments made. The assessee, in the opinion of Ld. CIT(A), failed to establish its claim that own funds and not borrowed funds were utilized for making investments in tax free income yielding investments and therefore, the disallowance was to be confirmed. Aggrieved, the assessee is in further appeal before us.
5.3 We find that this issue is contained in paras-38 to 49 of Tribunal's order in assessee's own case for AY 2008-09, ITA Nos.3644/Mum/2016 5 & 4563/Mum/2016 order dated 03/02/2020 wherein the issue has been concluded with following observations: -
48. We noted from the above discussion that, the issue of disallowance under section 14A of the Act read with Rule 8D(2)(ii) of the Rules in regard to interest, is covered by the decision of Hon'ble Bombay High Court in the case of HDFC Ltd.
(supra), wherein it is clearly held that no disallowance can be made in the relation to interest expenses as assessee's own non-interest bearing funds far exceed the investment as details are noted above and hence, this issue of the Revenue's appeal is dismissed.
49. As regards to the issue of disallowance u/s 14A of the Act read with Rule 8D(2)(iii) of the Rules, the administrative expenses the investment made in subsidiaries / strategic investment while computing disallowance is decided against the assessee in view of the decision of Supreme Court in the case of Maxopp Investment Ltd., (supra). However, it is to clarify that those strategic investment which have not yielded any exempt income during the year are to be excluded for the purposes of computing average value of investment. Even otherwise, the law is now settled that the investment which are giving exempt income during the year are to be considered for the purpose of disallowance u/s 14A of the Act read with Rule 8D(2)(iii) of the Rules, i.e. the administrative expenses for the purpose of computing average value of investment. We direct the AO accordingly. The AO will go into the details and will compute the disallowance in view of these observations. This issue is remanded back to the file of the AO.
Since the facts are shown to be identical this year, in principle, we hold that interest disallowance u/s 14A r.w.r. 8D(2)(ii) would not be sustainable subject to verification by Ld. AO that assessee's own funds far exceed the investments made by the assessee. The issue of expense disallowance in terms of Rule 8D(2)(iii) would stand restored back to the file of Ld. AO with similar directions. The ground, thus raised before us, stands allowed for statistical purposes. Since this is the only issue in assessee's appeal, the appeal stand allowed for statistical purposes.
6. Broken period interest:-
6.1 The term 'Broken period interest' represent interest component paid by the assessee on the interest-bearing government securities when purchased from the market. The interest on government securities is normally payable half-yearly. When the government securities are 6 traded, the purchaser has to pay to the seller not only the purchase price of the securities, but also the interest accrued on the purchased securities from the last due date of the interest till the date of purchase of the securities. This interest is referred to as the 'broken period interest'. 6.2 During the year, the assessee paid broken-period interest of Rs.64351.48 Lacs and likewise received broken-period interest of Rs.62243.31 Lacs. The differential of the two i.e. Rs.2108.16 Lacs was claimed as deduction on the reasoning that interest paid and charged to Profit & Loss Account as expenditure is offered to tax as interest income by crediting Profit & Loss Account on the receipt of coupon interest on its due date or on sale of security if it precedes the due date of interest payment. It was submitted that investments were held as stock-in-trade and could not be treated as capital outlay and therefore, interest could not be capitalized. To support the same, attention was drawn to CBDT Circular No.18/2015 dated 02/11/2015 which clarified that investments made by banking concern would form part of business of banking. 6.3 However, Ld. AO opined that the expenditure should be added to the cost of securities so purchased by the assessee as held by Hon'ble Rajasthan High Court in CIT V/s Bank of Rajasthan Ltd. 2009 316 ITR
391) which considered the decision of Hon'ble Apex Court in Vijaya Bank Ltd. V/s Addl. CIT (1991 187 ITR 341). It was concluded by Ld. AO that investments in securities were capital in nature because a bank makes long-term as well as short-term capital investment in securities.
The main business of the bank is banking and not the trading of securities and earning profit from the same. Further similar disallowances were confirmed by learned first appellate authority for AYs 2007-08 to 2012-13 as well as by Tribunal for AYs 2001-02, 2002-03 & 7 2005-06. Therefore, the broken period interest expenditure of Rs.64351.48 Lacs was disallowed and added to the income of the assessee, completely disregarding the broken period interest offered to tax by the assessee.
6.4 The Ld. CIT(A), inter-alia, noted that the assessee as a scheduled bank was required to invest in securities notified by RBI for various statutory compliances as per RBI guidelines applicable to banks and therefore, the assessee purchased / sold the securities from time to time in compliance with Banking Regulations Act, 1949. The securities were shown as investments in Balance Sheet but treated as stock-in-trade for the purpose of Income Tax computations which were evident from the fact that interest as well as gains / loss on securities were offered to tax as 'Business Income'. The aforesaid treatment was accepted by Ld. AO. It was also noted that the assessee was following this consistent system of accounting for more than last 20 years which was also accepted by Hon'ble Rajasthan High Court in assessee's own case for AYs 2000-01 to 2002-03 and 2005-06. The adjudication of Hon'ble High Court order dated 17/05/2017 was extracted in para 4.3.3 of the impugned order wherein this issue was answered in assessee's favor. It was held that broken period interest in respect of all the three categories of securities was revenue in nature as per the system of accounting regularly followed by the assessee and also on the ground that the investments were treated as stock-in-trade for Income Tax purposes. Therefore, the disallowance was to be deleted. Aggrieved, the revenue is in further appeal before us.
6.5 We find that this issue is contained in paras-115 to 119 of Tribunal's order in assessee's own case for AY 2008-09, ITA 8 Nos.3644/Mum/2016 & 4563/Mum/2016 order dated 03/02/2020 wherein a finding was rendered that similar issue stood covered in assessee's own case for AYs 1991-92 to 1994-95 (order dated 19/05/2008) which was followed by Tribunal in subsequent years. Further, Hon'ble Bombay High Court upheld decision of Tribunal by dismissing revenue's appeal for AY 1996-97 vide order dated 01/08/2016. Another fact as noted by Ld. CIT(A) is that the assessee was following same accounting policy, in this regard, for last more than 20 years. Therefore, we find no infirmity in the impugned order in deleting this disallowance. The ground raised by revenue stand dismissed.
7. Interest on Govt. & Other Securities on accrual basis instead of due basis 7.1 The assessee, in its statement of computation, deducted interest income of Rs.1548.06 Crores included in profit on accrual basis and added interest income of Rs.1505.59 Crores on due basis. It was explained that interest on government & other securities has been accounted for on accrual basis in the books of account. However, the said interest has been included in the income of the bank on due basis since the bank gets the right to receive the said interest only when it becomes due. In support, the attention was drawn to favorable decisions of Tribunal from AYs 1989-90 to 2004-05.
7.2 However, Ld. AO opined that deduction was not allowable because as per the provisions of Section 145(1) of the Income Tax Act, the taxable income was to be computed on the basis of method of accounting regularly employed by the assessee unless it was against the normal accountancy principles or there were statutory provisions giving contrary / different treatment to some items. Accordingly, deduction so 9 claimed by the assessee was not available. Consequently, the differential amount i.e. Rs.4247.09 Lacs was added to the income of the assessee.
7.3 The Ld. CIT(A) reversed the stand of Ld. AO by relying upon the order of Tribunal in assessee's own case for AYs 2009-10 to 2012-13 wherein it was held that the interest income was to be taxed on due basis and not on accrual basis. Aggrieved, the revenue is in further appeal before us.
7.4 We find that this issue is contained in paras-107 to 114 of Tribunal's order in assessee's own case for AY 2008-09 wherein the issue has been concluded in assessee's favor with following observations: -
114. We noted that this ground of appeal is covered in favour of the assessee vide the aforementioned orders of the Tribunal and Bombay High Court. The right to receive interest on securities arises on due date only, which falls after the accounting year and, accordingly, it cannot be taxed in the accounting year itself.
Hence, in view of the above discussion, we decided this issue in favor of assessee and accordingly, this ground of revenue's appeal is dismissed.
Since no change in facts has been demonstrated before us, respectfully following the above decision of Tribunal, we dismiss this ground of revenue's appeal.
8. Amortization on securities held under HTM category:-
8.1 The assessee debited a sum of Rs. 2722.94 Lacs on account of amortization in respect of the securities held under held-to-maturity (HTM) category as per RBI guidelines. In respect of HTM securities, the bank followed two different systems which were inconsistent with each other. When the purchase price of securities is less than the face value at which the security is ultimately sold, the difference is booked as profit only in the year of sale. But when the cost price is more than the face 10 value the loss is not booked in the year of sale but it is spread over the period of holding. The Ld. AO opined that if the securities are held as investments, there would be no question of allowance of any amount till such time as the securities are sold or matured. Even otherwise if the securities were held as stock-in-trade, as per RBI's guidelines, the method of valuation of closing stock adopted in respect of securities in HTM category would be cost price which was one of the two recognized method of valuation. Since the cost price would be constant, there would be no question of deduction of any amount under commercial principles even if HTM securities are accepted to be held as stock-in-trade for the assessee. Whatever loss is suffered on sale of redemption of securities will constitute loss in the year of sale or redemption. Therefore, no deduction would be available to the assessee. The assessee pointed out that RBI circular for financial year 2012-13 specifically provided that in case of permanent diminution, the excess of acquisition cost over the face value is to be amortized over the remaining period of securities.
Therefore, the action of assessee in claiming the deduction was in line with the said circular which was also the mandate of CBDT Circular No. 17/2008 dated 26/11/2008. It was also submitted that similar issue was held in assessee's favor by first appellate orders for AYs 2005-06 to 2011-12. The revenue's appeal for AY 2005-06 stood dismissed by Tribunal on this issue.
8.2 However, the assessee's submissions were rejected by Ld. AO on the ground that though the claim was made as per RBI guidelines, however, these guidelines were meant only as guiding factors to determine commercial profits for various purposes on conservatism principles. The total income has to be computed as per mandate of 11 Income Tax Act and a recognized system of accounting has to be followed u/s 145 of the Act. Therefore, the aforesaid amount was disallowed and added back to the income of the assessee. 8.3 The Ld. CIT(A) reversed the stand of Ld. AO by relying upon appellate orders for AYs 2005-06, 2006-07, 2009-10 to 2012-13 wherein it was held that deduction for amortization of premium paid on purchase of securities under HTM category would be an allowable deduction. The findings given in appellate order for AY 2009-10 has been extracted in para 7.4.2 of the impugned order. Aggrieved, the revenue is in further appeal before us.
8.4 We find that this issue is contained in paras-134 to 137 of Tribunal's order in assessee's own case for AY 2008-09 wherein the issue was found to be squarely covered in assessee's favor for AY 1995- 96 by the order of Tribunal dated 17/09/2009. This decision was followed in AY 1996-97 vide order dated 26/07/2013. Further, Hon'ble Bombay High Court dismissed revenue's appeal, on this issue, for AY 1996-97. The Ld. CIT(A) has also relied upon appellate orders for earlier years. Therefore, facts being identical, we dismiss this ground of revenue's appeal.
9. Depreciation on securities under 'Available for sale (AFS)' and 'Held for Trading (HFT) category:-
9.1 The assessee claimed depreciation of Rs.650.87 Lacs on securities held under Available-for-sale (AFS) category. There was no investment under Held-for-trading (HFT) category. The opening provision was Rs.1679.28 Lacs whereas closing provision was Rs.1638.05 Lacs. Upon perusal of details, it transpired that the closing provision was worked out 12 by adding net depreciation under different investment categories as tabulated below: -
Category Appreciation Depreciation Net Depreciation Govt. Securities Rs. 4369923 Rs. 92844995 Rs. 88475071 Other Approved securities Rs. NIL Rs. NIL Rs.NIL Shares Rs.497349058 Rs.380006795 Rs.48916899 Debentures & Bonds Rs. 80605536 Rs.8141492 Rs.NIL Subsidiaries/ Joint Ventures Rs.NIL Rs.NIL Rs.NIL Others Rs. 3783577 Rs. 30197540 Rs. 26413963 Total Rs.586108094 RS.511190822 Rs. 163805934 9.2 The Ld. AO opined that this way of working was not in coherence with guidelines laid down by CBDT in instruction No. 17 of 2008 dated 26/11/2008 which mandate that appreciation / depreciation is to be aggregated scrip wise and only net depreciation, if any is required to be provided in the accounts. As against the same, the assessee first compared the net depreciation in each of the six categories and then added the net depreciation whereas the depreciation for all the categories should be compare with appreciation with all the categories and only net depreciation should be provided. Since the differential of aggregate of appreciation and depreciation, as tabulate above, is appreciation (net) of Rs.749.17 Lacs, no depreciation is to be allowed.
The assessee defended its stand by submitting that the assessee was following consistent method of valuing its investments and the same was in conformity with policy suggested by RBI. However, the said plea could 13 not find favor with Ld. AO who disallowed this claim made by the assessee.
9.3 The Ld. CIT(A) reversed the stand of Ld. AO by relying upon order of Tribunal in assessee's own case for AYs 2002-03, 2004-05 & 2005-
06. Similar view was taken in appellate orders for subsequent years. The findings given in appellate order for 2009-10 has been extracted in para 8.4.2 of the impugned order. Aggrieved, the revenue is in further appeal before us.
9.4 We find that this issue is contained in paras-60 to 68 of Tribunal's order in assessee's own case for AY 2008-09 wherein the issue has been concluded in assessee's favor by observing as under: -
68. The assessee also relied on the judgement of the Bombay High Court in the case of Union Bank of India dated 08.02.2016 in ITA 1977 of 2013. The assessee in this case for the purpose of its books was netting off the depreciation in its securities against appreciation in other securities while for tax purpose, the assessee has been claiming gross depreciation that is without netting of the appreciation in other securities held as a part of investment. The Bombay High Court has dismissed the appeal of the Revenue and has decided the issue in favour of the assessee. It is argued that the facts of the present case are exactly same as in the aforesaid case of Union Bank of India. This issue stands covered by the judgement of the jurisdictional High Court. The facts of the assessee's case and the facts in the decision of the Bombay High Court in the case of Harinagar Sugar Mills Ltd. vs. CIT [1994] 207 ITR 901 (Bombay), relied by the AO are different. In the aforesaid decision, the assessee had changed the method of valuing stock in the year under consideration, whereas in the assessee's case, there is no change in the method of valuation. Also, in that case, sugar was valued differently by bifurcating the stock into 'levy sugar' and 'free sugar'. The Court's conclusion is based on the fact that there was no justification for bifurcation of sugar between free and levy sugar. The Mumbai Tribunal in the case of DCIT vs. Majestic Holdings and Finvest (P.) Ltd.
[2010] 2 ITR(T) 407 (Mumbai) has noted that the reliance of the Departmental Representative on the judgement of the Bombay High Court in the case of Harinagar Sugar Mills Ltd. is misconceived inasmuch as in that case there was nothing to show the bifurcation of the closing stick of sugar into levy sugar and free sugar and hence, the assessee was obligated to value the entire stock at one value. In the assessee's case as well, each scrip is different and therefore requires independent valuation. The CIT DR placed reliance on the decision of the Mumbai Tribunal in the case of JCIT vs. Dena Bank [2012] 20 taxmann.com 278 (Mumbai). In the aforementioned case, the security was purchased in year 1 at Rs. 100 and the market price at the end of the year was Rs. 90. Accordingly, the stock was valued at market price of Rs. 90 being lower than the cost. In year 2, the market price went 14 upto Rs. 95. Accordingly, the stock was valued at market price of Rs. 95 being lower than the cost. However, suppose in year 3, the market value rises to Rs. 120, in such a situation, the stock would be valued at cost i.e Rs. 100, being lower than the market price. The Mumbai Tribunal held that excess of appreciation over the cost price would not be considered for valuing the closing stock. In the present case, we are not concerned with a scenario where in the later year the depreciation provided in earlier years is reduced. Further, the decision of the Mumbai Tribunal in the case of Deutsche Bank A.G vs. DCIT [2003] 86 ITD 431 (Mumbai), relied by the AO is in connection with valuation of foreign exchange forward contracts. In this case the assessee did not account for in the financial statement the anticipated/contingent profits from the contracts to the extent not settled as on the last day of the accounting year whereas any loss on such contracts was provided for by a charge in the profit and loss account on the best estimates. The Department brought to tax the profit on such forward exchange contracts and stated that one method for valuation of the entire stock of securities should be followed. This resulted in a situation of taxing appreciation of stock, which goes against the general and settled principle of non-taxation of notional income, as laid by the Supreme Court in the case of Sanjeev Wollen Mills vs. CIT [2005] 279 ITR 434 (SC) and others discussed supra. Hence, we are of the view that this disallowance of depreciation/ reducing of depreciation on appreciation in the value of securities held as available for sale and held for trading category are allowable. We direct the AO accordingly.
The Ld. CIT(A) has also relied upon various favorable orders of earlier years while adjudicating the issue. Facts being identical, respectfully following the above decision of Tribunal, we dismiss this ground of revenue's appeal.
Conclusion
10. The assessee's appeal stand allowed for statistical purposes. The revenue's appeal stand dismissed.
Order pronounced on 03rd March, 2021
Sd/- Sd/-
(Mahavir Singh) (Manoj Kumar Aggarwal)
उपा / Vice President लेखा सद / Accountant Member
मुंबई Mumbai; िदनां क Dated : 03/03/2021
Sr.PS, Kasarla Thirumalesh/Sr.PS, Jaisy Varghese आदे शकी ितिलिपअ"ेिषत/Copy of the Order forwarded to :
1. अपीलाथ(/ The Appellant 15
2. )*थ(/ The Respondent
3. आयकरआयु1(अपील) / The CIT(A)
4. आयकरआयु1/ CIT- concerned
5. िवभागीय)ितिनिध, आयकरअपीलीयअिधकरण, मुंबई/ DR, ITAT, Mumbai
6. गाड6 फाईल / Guard File आदे शानुसार/ BY ORDER, उप/सहायक पंजीकार (Dy./Asstt.Registrar) आयकरअपीलीयअिधकरण, मुंबई / ITAT, Mumbai.