Income Tax Appellate Tribunal - Mumbai
Manas Vyapar Private Limited,Thane vs Ito Ward 1(1), Thane, Thane on 18 March, 2026
IN THE INCOME TAX APPELLATE TRIBUNAL
"F" BENCH MUMBAI
BEFORE SHRI SAKTIJIT DEY, VICE PRESIDENT &
SHRI MAKARAND VASANT MAHADEOKAR, ACCOUNTANT MEMBER
1. ITA No. 6990/Mum/2025
(Assessment Year: 2015-15)
2. ITA No. 6991/Mum/2025
(Assessment Year: 2015-15)
&
3. ITA No. 6992/Mum/2025
(Assessment Year: 2015-15)
Manas Vyapar Private ITO Ward 1(1)
Limited /PCIT, Thane,
301, Sun Flower Tower, Vs. Ashar IT Park, 6 th
Kharkar Ali, Thane, Floor, Road No. 16Z,
Maharashtra-400 601 Wagle Industrial
Estate, Thane,
Maharashtra-400604
PAN/GIR No. AACCP1408L
(Applicant) (Respondent)
Assessee by Shri Dharmesh Shah, Ld. AR
Revenue by Shri Vivek Perampurna, Ld. DR
Date of Hearing 11.03.2026
Date of Pronouncement 18.03.2026
आदे श / ORDER
PER MAKARAND VASANT MAHADEOKAR, AM:
These three appeals filed by the assessee arise out of different orders passed under the Income Tax Act, 1961 2 IT A No . 6 9 9 0 t o 6 9 9 2 / M u m / 2 0 2 5 Manas Vyapar Private Limited [hereinafter referred to as "the Act"] for Assessment Year 2015-16 and are as under:
1. ITA No. 6991/Mum/2025 - appeal against the revisionary order passed by the Principal Commissioner of Income Tax, Thane-1 [hereinafter referred to as "PCIT"]under section 263 of the Act dated 18.03.2021.
2. ITA No. 6992/Mum/2025 - appeal against the order of the Commissioner of Income Tax (Appeals), National Faceless Appeal Centre, Delhi [hereinafter referred to as "CIT(A)"] passed under section 250 of the Act dated 20.03.2024, arising from the reassessment order passed by the Assessing Officer under section 144 r.w.s. 263 of the Act dated 27.03.2022.
3. ITA No. 6990/Mum/2025 - appeal against the order of the Commissioner of Income Tax (Appeals), NFAC [hereinafter referred to as "CIT(A)"] dated 20.03.2024 confirming penalty levied under section 271(1)(c) by the Assessing Officer vide order dated 26.09.2022.
Factual Background
2. The assessee filed its return of income for the assessment year under consideration on 27.10.2015 declaring total income of Rs. 2,72,010/-. The return was initially processed under section 143(1) of the Act. Subsequently, the case was selected for scrutiny under the Computer Aided Scrutiny Selection (CASS) system for verification of large increase in investment in unlisted 3 IT A No . 6 9 9 0 t o 6 9 9 2 / M u m / 2 0 2 5 Manas Vyapar Private Limited equity shares during the year. Statutory notice under section 143(2) was issued and served upon the assessee. During the course of assessment proceedings, the assessee furnished explanations in respect of the issues raised by the Assessing Officer. The assessment was ultimately completed under section 143(3) of the Act on 12.12.2017, accepting the returned income of the assessee.
3. Subsequently, on examination of the assessment records, the PCIT formed a view that the assessment order passed under section 143(3) dated 12.12.2017 was erroneous insofar as it was prejudicial to the interests of the Revenue. Accordingly, revisionary proceedings under section 263 of the Act were initiated. During the course of revision proceedings, the PCIT observed that the assessee had shown a substantial increase in its non-current investment in unlisted shares of M/s. Manas Co- operative Industrial Sankul Ltd. The investment had increased from Rs. 33,000/- to Rs. 9,36,20,100/- during the year under consideration. According to the record, these additional shares were allotted consequent to revaluation of the assets of the cooperative society and a corresponding revaluation reserve of Rs. 9,35,87,100/- was created in the books of accounts. The PCIT noted that the assessee had not made any monetary investment for the additional shares allotted by the society and therefore the allotment was akin to bonus shares. In the view of the PCIT, the assessee had wrongly increased the value of investment in the shares of the society by Rs. 9,35,87,100/- instead of considering 4 IT A No . 6 9 9 0 t o 6 9 9 2 / M u m / 2 0 2 5 Manas Vyapar Private Limited the value of such additional shares as nil. The PCIT was therefore of the opinion that the value of such additional shares should have been offered to tax as income from other sources. On the basis of the above reasoning, the PCIT held that the assessment order passed under section 143(3) suffered from lack of proper examination and was erroneous and prejudicial to the interests of the Revenue. Accordingly, by order dated 18.03.2021, passed under section 263 of the Act, the assessment order was set aside with a direction to the Assessing Officer to examine the issue afresh.
4. Aggrieved by the aforesaid revisionary order, the assessee has filed ITA No. 6991/Mum/2025 before us challenging the validity of the assumption of jurisdiction under section 263. Following are the grounds of appeal:
1. That on the facts and in the circumstances of the case, the learned CIT erred in invoking jurisdiction under Section 263 of the Income-tax Act, 1961 without satisfying the conditions precedent thereto.
2. That the learned CIT erred in holding the assessment order passed by the Assessing Officer to be erroneous and prejudicial to the interest of the Revenue without demonstrating how the AO's order suffered from any legal OR factual error.
3. That the learned CIT failed to appreciate that the Assessing Officer had made inquiries on the very issues considered in the revisionary order and had taken a plausible view after application of mind, and hence, the assessment order could not be held to be erroneous.
4. That the revisionary jurisdiction under Section 263 cannot be exercised merely because the CIT holds a different opinion on the same facts as that of the AO, which is not permissible in law.
5. That the learned CIT failed to point out any specific error in the assessment order nor any lack of inquiry OR inadequate inquiry that could justify the assumption of jurisdiction under Section 263.
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6. That the appellant craves leave to add, alter, amend OR withdraw any of the above grounds at the time of hearing.
5. Pursuant to the directions issued by the PCIT under section 263, the Assessing Officer initiated proceedings to examine the issue relating to the increase in the value of investments in the shares of M/s. Manas Co-operative Industrial Sankul Ltd. Notice under section 142(1) of the Act dated 13.03.2022 was issued to the assessee calling for explanation in this regard. As the assessee did not furnish a satisfactory explanation during the proceedings, the Assessing Officer completed the reassessment under section 144 read with section 263 of the Act vide order dated 27.03.2022, treating the value of additional shares amounting to Rs. 9,35,87,100/- as income from other sources and adding the same to the income of the assessee. Consequently, the total income of the assessee was assessed at Rs. 9,38,59,110/-. Aggrieved by the reassessment order, the assessee filed an appeal before the CIT(A). The CIT(A) noted that the assessment had been completed under section 144 r.w.s. 263 and that the addition of Rs. 9,35,87,100/- had been made by the Assessing Officer on account of income from other sources arising from the alleged receipt of additional shares without consideration. The CIT(A), after considering the material available on record, upheld the action of the Assessing Officer and dismissed the appeal filed by the assessee.
6. Aggrieved by the order of the CIT(A), the assessee has filed ITA No. 6992/Mum/2025 before us challenging the addition 6 IT A No . 6 9 9 0 t o 6 9 9 2 / M u m / 2 0 2 5 Manas Vyapar Private Limited made in the reassessment proceedings. Following are the grounds of appeal:
1. On the facts and circumstances of the case and in law, the Ld. CIT (A) erred in upholding the additions of Rs. 9,35,87,100 made by the AO in respect of shares received by the appellant allegedly without consideration.
2. On the facts and circumstances of the case and in law, the Ld. CIT (A) erred in not appreciating the fact that the appellant has received the shares as bonus shares which are issued against capitalization of reserves of the company and there is no increase OR decrease in the wealth of the shareholders pursuant to the issue of bonus shares.
3. On the facts and circumstances of the case and in law, the Ld. CIT (A) erred in not appreciating the fact that the bonus shares received by the appellant are not received without consideration OR at a lesser consideration but the consideration is the decrease in the intrinsic value of the original shares held by the appellant and therefore no additions can be made in the instant case.
4. The appellant craves leave to add, amend, alter and/or vary any of the grounds of appeal before OR at the time of hearing.
7. Consequent to the addition made in the reassessment order, the Assessing Officer initiated penalty proceedings under section 271(1)(c) of the Act for concealment of income and furnishing inaccurate particulars of income. Thereafter, the Assessing Officer passed a penalty order dated 26.09.2022 imposing a penalty of Rs. 3,04,69,143/- under section 271(1)(c).The assessee preferred an appeal before the CIT(A), against the penalty order. The CIT(A), vide order dated 20.03.2024 passed under section 250, confirmed the penalty imposed by the Assessing Officer.
8. Aggrieved by the said order, the assessee has filed ITA No. 6990/Mum/2025 before us challenging the confirmation of penalty. Following are the grounds of appeal:
7 IT A No . 6 9 9 0 t o 6 9 9 2 / M u m / 2 0 2 5 Manas Vyapar Private Limited
1. On the facts and circumstances of the case and in law, the LD. CIT (A) erred in passing an ex-parte order upholding the penalty levied by the Assessing Officer u/s 271(1)(c)
2. On the facts and circumstances of the case and in law, the LD. CIT (A) erred in not appreciating that the additions of Rs. 9,35,87,100 made in the quantum assessment proceedings in respect of bonus shares do not represent any concealment of income by the Appellant.
3. On the facts and circumstances of the case and in law, the LD. CIT (A) erred in not appreciating that the addition made in the quantum assessment is based on allotment of bonus shares by capitalising the reserves of the company which does not tantamount to issue of shares without consideration and therefore penalty is not tenable.
4. On the facts and circumstances of the case and in law, the LD. CIT (A) failed to appreciate the alleged concealment is based on a difference of opinion and hence, does not constitute deliberate concealment of income.
5. On the facts and circumstances of the case and in law, the LD. CIT (A) failed to appreciate that the penalty order is passed in a routine manner relying solely on the assessment order and without independent application of mind.
6. The appellant craves leave to add, alter, amend OR withdraw any of the above grounds at the time of hearing.
9. As per the report of the Registry recorded in the order sheets, the present appeals filed by the assessee are delayed. The appeal in ITA No. 6991/Mum/2025, arising from the order passed under section 263 dated 18.03.2021, is delayed by 1613 days, whereas the appeals in ITA Nos. 6992/Mum/2025 and 6990/Mum/2025, arising from the orders of the CIT(A) dated 20.03.2024, are delayed by 517 days each.
10. The assessee has filed an application supported by an affidavit seeking condonation of delay in filing the present appeals. It is the contention of the assessee that the notices and orders in the aforesaid proceedings were sent to the email ID of an erstwhile director, Mr. Rajeev Anikhindi, who had resigned 8 IT A No . 6 9 9 0 t o 6 9 9 2 / M u m / 2 0 2 5 Manas Vyapar Private Limited from the directorship of the group company on 31.08.2015, and the said email ID had remained inactive. According to the assessee, the correct email ID mentioned in Form No. 35 was not used for communication and therefore the notices as well as the orders passed by the authorities below were never received by the assessee. It has been further stated that the existence of the orders came to the knowledge of the assessee only in September 2025 when the new tax consultants, M/s. M. A. Shah & Co., while verifying the income tax portal, informed the assessee about the order passed under section 263 dated 18.03.2021 and the orders of the Ld. CIT(A) dated 20.03.2024. On their advice, the assessee immediately filed the present appeals before the Tribunal on 30.10.2025 along with applications for condonation of delay. The assessee has therefore submitted that the delay occurred due to non-receipt of notices and orders on account of communications being sent to an incorrect and inactive email address and that the delay was neither intentional nor deliberate but occurred due to bona fide circumstances and professional advice.
11. The assessee has also filed a written submission along with a revised Form No. 36 stating that while filing the appeal earlier, the date of service of the order was inadvertently mentioned as 20.03.2024, being the date of the order of the Ld. CIT(A). It has been submitted that the said order was actually received by the assessee only on 01.09.2025, when it was downloaded from the Income Tax portal. According to the assessee, since the order was 9 IT A No . 6 9 9 0 t o 6 9 9 2 / M u m / 2 0 2 5 Manas Vyapar Private Limited never served earlier and the communications were sent to an incorrect email address of an erstwhile director, the correct date of service ought to be taken as 01.09.2025. It has therefore been contended that the appeal filed before the Tribunal on 30.10.2025 falls within the prescribed limitation period if the said date of service is considered. The assessee has accordingly filed a revised Form No. 36 correcting the date of service of the order and has requested that the same may be taken on record in substitution of the earlier Form No. 36 filed along with the appeal.
12. The Ld. Departmental Representative (DR) did not raise any serious objection to the condonation of delay in filing the present appeals. Considering the submissions of the assessee, the explanation placed on record along with the supporting affidavit and documents, and in the absence of any serious objection from the Revenue, we are satisfied that the assessee has shown reasonable cause for the delay in filing the appeals. Accordingly, in the interest of substantial justice, the delay in filing all the three appeals is condoned and the appeals are admitted for adjudication on merits.
13. During the course of hearing, the Ld. Authorised Representative (AR) submitted that the appeal in ITA No. 6992/Mum/2025, which relates to the quantum addition, may be taken up first and adjudicated on merits. It was further submitted that the appeals in ITA Nos. 6991/Mum/2025 and 6990/Mum/2025, arising from the order passed under section 10 IT A No . 6 9 9 0 t o 6 9 9 2 / M u m / 2 0 2 5 Manas Vyapar Private Limited 263 of the Act and the penalty order passed under section 271(1)(c) of the Act respectively, are consequential in nature and therefore the outcome of those appeals would depend upon the decision in the quantum appeal. Accordingly, it was prayed that the quantum appeal be heard and decided first and the remaining appeals be disposed of thereafter in accordance with the decision rendered therein.
14. The Ld. AR invited our attention to the audited financial statements and the list of shareholders of M/s. Manas Co- operative Industrial Sankul Ltd. and submitted that this company had revalued its land in the books of account and the revaluation reserve so created was capitalised by issuing bonus shares to the existing shareholders, as reflected in the statements placed on record (paper book page No. 11). It was submitted that the assessee, being one of the shareholders, received such bonus shares in proportion to its existing shareholding. The Ld. AR contended that issuance of bonus shares merely represents capitalisation of reserves and does not result in any real income in the hands of the shareholders. Therefore, according to him, the receipt of bonus shares cannot be regarded as income in the hands of the assessee and the addition made on this account is contrary to the settled legal position. The Ld. AR further submitted that neither the assessment order nor the order of the Ld. CIT(A) clearly specifies the provision of the Act under which the impugned addition has been made, and therefore the addition sustained by the authorities below is unsustainable in law.
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15. The Ld. AR further placed reliance on the decision of the Co- ordinate Bench in the case of Vyankatesh Narayan Kulkarni (ITA No.1849/MUM/2025), another shareholder of Manas Co- operative Industrial Sankul Ltd., wherein an identical issue arising out of the allotment of bonus shares pursuant to revaluation of land and capitalisation of revaluation reserve by the said company had come up for consideration before the Tribunal. It was submitted that in the said decision the Co- ordinate Bench had held that allotment of bonus shares to existing shareholders out of revaluation reserve does not result in any taxable income in the hands of the shareholders. The Ld. AR therefore submitted that since the facts of the present case are identical and arise from the same bonus issue by the very same company, the issue is squarely covered by the aforesaid decision of the Co-ordinate Bench and the addition sustained by the Ld. CIT(A) deserves to be deleted.
16. Per contra, the Ld. DR relied upon the orders of the Assessing Officer as well as the Ld. CIT(A).
17. We have heard the rival submissions and perused the material placed before us. The short controversy in ITA No. 6992/Mum/2025 is whether the increase in the value of shareholding of the assessee in M/s. Manas Co-operative Industrial Sankul Ltd., which thereafter stood represented by shares in the converted private limited company, could validly be brought to tax in the hands of the assessee on the footing that shares were received without consideration. The factual 12 IT A No . 6 9 9 0 t o 6 9 9 2 / M u m / 2 0 2 5 Manas Vyapar Private Limited foundation is not really in dispute. The audited financial statements of the cooperative society placed before us show that the land was revalued in the books and the revaluation reserve was correspondingly reflected in the balance sheet. The shareholder chart also shows that the existing shareholders were issued additional shares out of such revaluation reserve in proportion to their pre-existing holdings. The assessee was one such shareholder. Thus, what emerges from the record is not a case of any outsider transferring property to the assessee, nor a case of the assessee introducing fresh capital and receiving property at less than fair market value. It is, on the contrary, a case of internal capital reorganisation by capitalisation of reserve.
18. The authorities below have proceeded on the premise that since the assessee did not pay fresh consideration for the additional shares, the value thereof constituted taxable income. In our considered view, the approach is fundamentally misconceived. When reserves are capitalised and bonus shares are issued proportionately to existing shareholders, there is no real accretion of wealth in the hands of any shareholder. The shareholder's proportionate interest in the company remains the same. The form of holding changes, but the underlying economic interest remains unchanged. In substance, one capital interest gets split into a larger number of shares. Such a transaction lacks the necessary element of receipt of "property" from another person in the sense contemplated by the charging provision.
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19. At this stage, it is useful to notice the judicial exposition on the issue. In DCIT v. Smt. Mamta Bhandari ITA.No.5681/Del./2016, while affirming deletion of addition under section 56(2)(vii)(c), the Delhi Bench reproduced and approved the principles flowing from the decision in Sudhir Menon (HUF)vs. ACIT (ITA.No.4487/Mum/2013). In para 5 of the said order, the relevant propositions were extracted as under:
"(i) The provisions of section 56(2)(vii) of the Act would not apply to bonus shares..."
"(ii) Issue of bonus shares is by definition capitalization of its profit by the issuing company. There is neither any increase nor decrease in the wealth of shareholder..."
"(v) In other words, there is no receipt of any property by the shareholder, and what stands received by him is the split shares out of his own holding."
"(vi) In the case of issue of bonus shares ... no property is being conveyed to the shareholder..."
"(vii) No property however being passed on to the assessee ... no addition in terms of the provision itself shall arise in the facts of the case."
20. The same decision also noticed the legislative background of section 56(2)(vii) and the Explanatory Memorandum to the Finance Bill, 2010, emphasizing that the provision is an anti- abuse measure meant to curb laundering of unaccounted income under the guise of gifts and transfers for inadequate consideration, and not to tax ordinary internal capital restructurings. The Co-ordinate Bench recorded that the provision was introduced as a "counter evasion mechanism" and 14 IT A No . 6 9 9 0 t o 6 9 9 2 / M u m / 2 0 2 5 Manas Vyapar Private Limited that "the intent is not to tax the transactions entered into in the normal course of business or trade."
21. The principle has thereafter received approval of the Hon'ble Karnataka High Court in PCIT v. Dr. Ranjan Pai( 431 ITR 250). In para 6, the Hon'ble High Court held in clear terms:
"The issue of bonus shares by capitalization of reserves is merely a reallocation of the companies funds. There is no inflow of fresh funds..."
"when a shareholder gets a bonus shares, the value of the original share held by him goes down..."
"there is no transfer of the property and the provisions of section under section 56(2)(vii)(c) of the Act are not attracted..."
22. The above ratio directly answers the controversy before us. Once the High Court has explained that bonus shares issued on capitalization of reserves do not involve transfer of property and do not generate real income in the hands of shareholders, the very foundation of the impugned addition disappears.
23. We also find that the issue now stands covered on almost identical facts by the decision of the Co-ordinate Bench in the case of Shri Vyankatesh Narayan Kulkarni (ITA No.1849/MUM/2025), who was admittedly another shareholder in the very same concern and whose shareholding arose from the same revaluation exercise and capitalization of reserve. In paras 7.7 to 7.11, the Co-ordinate Bench considered the same factual matrix and held that the additional shares issued on conversion of the cooperative society into a private limited company could not be taxed under section 56(2)(vii)(c). The Bench observed that 15 IT A No . 6 9 9 0 t o 6 9 9 2 / M u m / 2 0 2 5 Manas Vyapar Private Limited the revaluation had occurred in the earlier year and that what subsequently happened was only conversion of the entity and distribution of shares corresponding to the already existing reserve. The Co-ordinate Benchin para 7.7 held:
"additional shares have been issued merely on account of distribution of reserve already available with the company."
"invoking of section 56(2)(vii)(c) of the Act is not applicable over the facts of the case."
"such additional shares are in the form of bonus shares, hence, also same are not taxable in the hands of the assessee."
24. Further, in para 7.8, the Co-ordinate Bench held:
"it is well-settled that revaluation of assets and consequent issuance of additional shares does not result in any real accretion of wealth to the shareholder but is merely a case of capital reallocation."
25. In para 7.11, the Bench concluded:
"The assessee‟s enhanced shareholding was merely the consequence of capitalization of revaluation reserve and subsequent conversion of the co-operative society into a company, without any inflow of new assets or benefit in real terms."
"Thus, the allotment of shares cannot be regarded as a transfer of property „without consideration‟ so as to attract section 56(2)(vii)(c)."
26. In our view, the aforesaid decision is not merely persuasive but has substantial precedential value in the present case because the transaction, the issue in concern, the revaluation event, and the legal issue are all common. Judicial discipline demands that where identical facts arising from the same transaction have already been examined by a Co-ordinate Bench, the same view ought to be followed in the absence of any 16 IT A No . 6 9 9 0 t o 6 9 9 2 / M u m / 2 0 2 5 Manas Vyapar Private Limited distinguishing feature. No such distinguishing feature was pointed out before us by the Revenue.
27. We may also notice one more infirmity in the impugned addition. The assessee is justified in contending that neither the assessment order nor the appellate order specifies with clarity the exact charging provision under which the addition is finally sustained. The reassessment order refers in substance to "income from other sources", but the legal basis is not properly articulated. Taxability cannot rest on broad notions of accretion or enhancement in capital account. There must be a clear charging provision squarely attracted to the facts. In the present case, even if one were to assume that the Revenue intended to invoke section 56(2)(vii)(c), the same, for reasons already discussed, is wholly inapplicable.
28. We are also impressed by the factual material brought by the assessee. The audited balance sheet of the society shows that the reserve and surplus included revaluation reserve and that the share capital correspondingly increased. The statement of shareholders demonstrates that bonus shares were issued across the board to all existing shareholders in proportion to their holdings. This itself negatives the theory of any selective or disguised transfer conferring independent benefit on the assessee. It was a uniform capitalization exercise. A proportionate bonus issue to all existing shareholders, by its very nature, leaves the relative rights inter se unchanged. What is increased is 17 IT A No . 6 9 9 0 t o 6 9 9 2 / M u m / 2 0 2 5 Manas Vyapar Private Limited merely the number of shares, not the shareholder's substantive ownership stake in the underlying assets.
29. For all the aforesaid reasons, we hold that the addition made in the hands of the assessee on account of receipt of additional shares/bonus shares is unsustainable in law. The transaction represents capitalization of revaluation reserve and consequential issuance of bonus shares, which does not give rise to taxable income in the hands of the shareholder. We accordingly set aside the order of the Ld. CIT(A) on this issue and direct the Assessing Officer to delete the addition of Rs. 9,35,87,100/-. Accordingly, ITA No. 6992/Mum/2025 is allowed.
30. Since the quantum addition itself has been deleted by us in ITA No. 6992/Mum/2025, the other two appeals, namely ITA No. 6991/Mum/2025 arising from the order passed under section 263 and ITA No. 6990/Mum/2025 arising from the penalty under section 271(1)(c), do not survive for separate adjudication in the present facts and have been rendered academic/infructuous. The penalty appeal obviously cannot survive once the very quantum addition has been deleted. Similarly, in view of the manner in which the parties themselves requested that the quantum appeal be taken up first and the remaining appeals be decided accordingly, we treat the appeal against section 263 as also rendered academic in the present set of facts.
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31. In the result, ITA No. 6992/Mum/2025 is allowed, whereas ITA Nos. 6991/Mum/2025 and 6990/Mum/2025 are dismissed as infructuous.
Order pronounced in the open court on 18.03.2026.
Sd/- Sd/-
(SAKTIJIT DEY) (MAKARAND VASANT MAHADEOKAR)
VICE PRESIDENT ACCOUNTANT MEMBER
Mumbai, Dated 18/03/2026
Dhananjay, Sr.PS
आदे श की प्रतितिति अग्रेतिि/Copy of the Order forwarded to :
1. अपीलाथी / The Appellant
2. प्रत्यथी / The Respondent.
3. सं बंधधत आयकर आयु क्त / The CIT(A)
4. आयकर आयु क्त(अपील) / Concerned CIT
5. धिभागीय प्रधतधनधध, आयकर अपीलीय अधधकरण, मुम्बई / DR, ITAT, Mumbai
6. गार्ड फाईल / Guard file.
आदे शानुसार/ BY ORDER, सत्याधपत प्रधत //True Copy//
1. उि/सहायक िंजीकार ( Asst. Registrar) आयकर अिीिीय अतिकरण, मुम्बई / ITAT, Mumbai