Income Tax Appellate Tribunal - Mumbai
Ashray Premises Pvt. Ltd, Mumbai vs Department Of Income Tax on 17 April, 2012
ITA Nos 2969 2970 and 4870 of
Ashray Premises Pvt Ltd Pune H Bench
IN THE INCOME TAX APPELLATE TRIBUNAL
"H" Bench, Mumbai
Before Shri B. Ramakotaiah, Accountant Member and
Shri S.S. Godara, Judicial Member
ITA Nos.2969, 2970 & 4870/Mum/2008
(Assessment Years: 2004-05 to 2006-07)
Income Tax Officer 8(1)1 Ashray Premises Pvt. Ltd
Room No.205, 2nd floor Vs Blue Hill Society, Above
Aayakar Bhavan, MK Road Nilgiriwala Deptl. Store
Mumbai 400020 Nagar Road, Yerwada
Pune 411 006
PAN No: AAACA 8294 P
(Appellant) (Respondent)
Department by: Shri Goli Srinivas Rao, CIT DR
Assessee by: Shri Rajan Vora
Date of Hearing: 17/04/2012
Date of Pronouncement: 30/04/2012
ORDER
Per Bench:
These three appeals are Revenue appeals against the orders of the CIT (A)-8 Mumbai or A.Y 2004-05 to 2006-07 on the issue of deduction under section 80IB (10).It's Assessing Officer's case that assessee was not eligible for deduction under section 80IB (10) as the said housing project should commence on or after 1/10/1998, whereas the assessee's project named "Gold Coast" started much earlier. The other reason for not considering the deduction was on the reason that the built up area of some residential units exceed 1500 sft and therefore the assessee was not eligible to claim deduction under section 80IB(10).Page 1 of 16
ITA Nos 2969 2970 and 4870 of Ashray Premises Pvt Ltd Pune H Bench
2. The CIT (A) after considering the submissions of the assessee gave relief on both issues and accordingly Revenue raised only one ground in all the three years commonly stating that the CIT (A) erred in deleting the disallowance of deduction of Rs,8,24,36,363 in AY2004-05, Rs.2,66,09,494 in AY2005-06 and Rs.2,91,58,525 in AY 2006-07 under section 80IB(10) without appreciating the facts of the case.
3. Briefly stated, assessee undertook a project named "Gold Coast" at Lohegaon, Pune. The Project was initiated in 1995-96 by purchase of land and showing some work in progress of `.4,67,701/-. First lay out plan was sanctioned on 28.8.1997. Subsequently the plans were revised twice, once on 30/05/2000 and then on 22/01/2002. The assessee got non-agricultural use permission (NA order) by 5/4/2012. Assessee started the project after the plan was approved on 22.01.2002. The first plinth checking certificate was issued by the Pune Municipal Corporation on 17.7.2002. It is also on record that Bhumi Puja of the project was started on 26.01.2002 and subsequently the assessee received advance for sale of apartment.
3.1 There was a survey on the assessee's business on 10/01/2006 and in the course of the survey, some apartments were measured by the Assessing Officer which indicated that the built up area exceed 1500 sft. A statement was recorded from one of the Director who on the basis of the measurements taken thereon and on the advice of the Counsel withdrew the claim in the course of survey. This was reiterated on the next day of the survey in the office of the Assessing Officer. However, subsequently the statement was withdrawn by filing affidavit and contending that the flats were never having an area of more than 1500 sft and in support filed architect certificate, revised plans from the Pune Municipal Page 2 of 16 ITA Nos 2969 2970 and 4870 of Ashray Premises Pvt Ltd Pune H Bench Corporation. The Assessing Officer also referred the matter to the DVO who certified that area of the flats was less than 1500 sft. In the assessment proceedings the Assessing Officer however, considered that the housing project started before 1.10.1998 and relied on the expenditure incurred by assessee towards the project as stated in Balance Sheet of those years. It was also the contention that even though the plans were revised subsequently, the date of approval was to be taken as August, 1997. Therefore, AO held that assessee was not eligible for deduction on the said project under section 80IB(10). The contention of the assessee that the N.A. permission, Bhumi Puja, receipt of advance and relying on the Pune ITAT decision in Nirmiti Constructions, 95 TTJ 117 Pune were not acceptable to AO. In addition to the above, the Assessing Officer also, based on the survey report and rejecting DEO's findings, denied the deduction under section 80IB(10) on the reason that the assessee constructed the apartment of more than 1500 sft particularly of adjoining flats which were enquired in the course of survey.
3.2 Before the CIT (A), assessee has contested all the issues, placed necessary evidences and the plans to submit that even though the plan was originally approved in 1997, the assessee could not go ahead as there was no approach land and therefore, the assessee acquired some more land and got the plans revised and re- approved and construction was according to the revised plan approved in 2002. It was also submission that plinth beams were certified in 2002 and certificate from District Collector, Pune regarding confirmation of N.A. land was also received in 2002. With reference to the built up area of the flat, assessee submitted the architect certificate, revised measurements and further relied on DVO report that the flats were less than 1500 sq. ft. On considering Page 3 of 16 ITA Nos 2969 2970 and 4870 of Ashray Premises Pvt Ltd Pune H Bench the assessee submissions, the CIT (A) gave the following findings on the two issues as under:
A) on Project commencement:
I have carefully considered the stand of the A.O. as well as the submission of the appellant. The facts which emerge are --
a) The NA order was granted by the Collector of Pune on 5th April 2002 and this is a crucial date for reckoning the whole issue.
b) The construction of housing project is in accordance with the building layout plan approved on 22nd January,2002 and is not in accordance with earlier approved plan dated 20th August 1997. The A.O. is not justified in holding that the placement of the plinths of the buildings is not an important issue as the appellant changed the building layout plan in the middle of the project. If the project would have started - before 1 October 1998 the placement of the plinths of the building would have according to the building layout plan sanctioned on 20th August 1997. In this connection, I am in agreement with the appellant that it is not possible to remove plinths.
c) The building commencement certificate is dated 22nd January 2002 which has not been properly appreciated by the A.O.
d) The first plinth checking certificate is dated 17th July 2002. The A.O. clearly fell into error in holding that speed of the work is slow then the plinth checking certificate shall be automatically at a later stage of the project. The speed can not be so much slow that construction started in 1997 would get first plinth checking certificate in the year 2002. Secondly, no expenditure is incurred by the appellant before financial year 2001-02.
e) The advertisement in the news paper regarding the commencement of the project is dated l5 May 2002 and this fact cannot be brushed aside as has been done by the A.O. Page 4 of 16 ITA Nos 2969 2970 and 4870 of Ashray Premises Pvt Ltd Pune H Bench
f) The first receipt of advance booking money was in the financial year 2002-03 is clearly indicative of the fact that the construction would have started around the date of receipt of advance.
g) The expenditure incurred before 31st March, 2002 was clearly not on the development and construction of housing project, but was for payment to land owners, development charges paid to local authority, NA charges, site survey expenses, advances paid to Architect for preparation of the plan etc. There is difference between the steps taken for the development of land for making it suitable for development and construction of project and commencement of development and construction of the project. Steps taken for development of land suitable for construction cannot be considered as commencement of housing project.
h) The A.O. is not justified in brushing aside the decision of Pune ITAT decision in the case of Nirmiti Construction even though it is not binding on him without appreciating the provisions of Maharashtra Land Revenue Code. The A.O. clearly fail into error in holding that the appellant is able to evade the penalty under the provisions of Maharashtra Land Revenue Code without making any reference to the office of collector of Pune as to whether any penalty proceedings were initiated against the appellant by the said office.
i) Statement of Mr. B L Darekar can not be taken at the face value as there are glaring inconsistencies and contradictions in the same and therefore, it can not be considered of any significance or relevance.
j) The A.O. is also not justified in holding that Bhoomi Poojan is done cording to the convenience of the appellant. Such events are very important in India.
Therefore, in view of the above facts and issues involved, I am of the view that the housing project indeed commenced during the financial year 2002-03 and not before 1st October 1998".
Page 5 of 16ITA Nos 2969 2970 and 4870 of Ashray Premises Pvt Ltd Pune H Bench B) With reference to the area of each flat:
The issues raised in this ground has been carefully perused and examined. The facts which come to light are as under:-
a) The statement of the director of the appellant company was taken after 27 hours of survey action.
b) The reconfirmation of the withdrawal of claim was recorded in the office of the A.O. with a gap of one day after the conclusion of the survey. The appellant did not get any opportunity to carry out the measurement independently.
c) Mr. Kantilal Lunkad made admission of withdrawal of claim on the basis of built up measurement of flat no D 1/701+701A was shown to him. The declaration was under the mistaken belief of fact that the built up area of the adjoining units taken together exceeds 1500 Sq. ft built up.
d) Mr. Vipin Gujarathi, Chartered Accountant advised Mr. Kantilal Lunkad on the basis of the measurement carried out by survey party and therefore, the counsel was also under mistaken belief of fact.
e) The statement recorded during the course has evidentiary value. However, the assessee can rebut the statement if it is given under mistaken belief of fact or mistaken belief of law or the assessee is able to bring out the mistake or contradiction to the surface. In case of the appellant the whole issue ranges on the built up area of the residential unit. The survey party measured the flat no D-1/701+701A at 2040 sq. ft whereas the AVO, the expert deputed by the assessing officer, measured the same flat at 1478 sq. ft. The A.O. has at no place explained or justified the built up area of 2040 sq. ft.
instead he has preferred to find faults with his own departmental vah.er. Therefore, the admission of the appellant regarding withdrawal of claim which is based solely on the area statement of the flat no Dl/701+701A is not corroborated with any material or evidence.
Page 6 of 16ITA Nos 2969 2970 and 4870 of Ashray Premises Pvt Ltd Pune H Bench The survey party recorded the statements of the flat holders/occupants at the time of survey action. The assessing officer has relied on these statements for making disallowance and the appellant has challenged the same. The A.O. reproduced the statements of the flat holders in which questions regarding two doors, structural changes, two kitchens etc were asked. The entire endeavor of the A.O. was to bring home the point that the appellant had joined the adjoining the flats and which were not separate units. However, the appellant is not disputing the same. Therefore, statements of the flat holders as far as joining of unit is not important.
As far as the built up area of the flat is concerned, the occupants/flat holders have stated super built up area. The appellant has submitted the copies of the agreement with the said flat holders from which it is clear that the appellant has sold flats on carpet area basis. The carpet area inclusive of Balcony area and Air Handling Unit area of the said flats as per agreements on record are as follows --
Name of the Flat No Carpet area Balcony Net
flat holder of the flat & AHU Carpet
including area Area
Balcony and
AHU Area
Mr.Satyendra Sain B 3/301+301A 943.78 148.11 795.68
Mr.Rajshekhar Z-1/303+303A 1089.62 149.30 9430.33
Sajjan
Mr.Adarsh Kanodia A-1/401+401A 1137.86 74.93 1062.93
Mrs. Priti Berry D-1/701+701A 1347.22 233.90 1113.32
Therefore, if the net carpet area excluding the balcony area and the air handling unit area is considered and the thickness of the wall is added the built up area of the unit can not exceed 1500 Sq. ft.
Mrs. Priti Berry stated the super built up area of the flat no D-1/701+701A at 1800 sq. ft. of the fiat under consideration is 1347 sq. ft. it is surprising to note that the measured the same flat at 1700 sq. ft (Carpet area) and 2040 built up. The appellant has submitted the reconciliation between the measurement taken by survey party and measurement certified by valuer. The A.O. has preferred not to address the reconciliation issue. There is no whisper about the same in the assessment order.
Page 7 of 16ITA Nos 2969 2970 and 4870 of Ashray Premises Pvt Ltd Pune H Bench Similarly, the appellant is not allowed the opportunity to cross examine Mrs. Priti Berry.
The claim of the appellant that Mrs. Priti Berry is not the flat purchaser and therefore, her statement can not be relied upon. I have verified the agreement of flat purchase. It is between the appellant and Mr. Sunil Berry.
During the course of survey action statements of the employees of the appellant Mr. Ratiesh Malhotra and Mr. Ramesh Kadam were recorded. No specific instances of any flat more than 1500 Sq. ft built up is shown by any of these two employees. They have made general statements that the built up area of two flats taken together is more than 1500 Sq. ft. In fact, Mr. Ratiesh Malhotra has stated that the built up area of the residential unit is about 1250 Sq. ft. Therefore, the statements of the employees are not important or relevant from the view point of determination of the issue under consideration.
The appellant has submitted a copy of "Record Plan" as approved by Pune Municipal Corporation after the completion of the buildings. Pune Municipal Corporation has approved the Record Plan along with FSI of each floor area of the buildings. From the FSI statements approved by PMC, the built up area of each residential unit seems to be much less than 1500 Sq. ft. The Assessing Officer has not considered the Recorded Plan at all. The assessment order is silent on this issue.
The A.O. has rejected the architect's certificate of built up area of residential units on the ground that the certificates has been issued without verifying the area of the units and the certificate does not mentioned that the residential units have been constructed in accordance with the approved plan. I have verified the certificate. The claim of the appellant that architect has issued certificate on the basis of Record Plan cannot be disputed and is correct. Therefore, the A.O. is not justified in rejecting the certificate as vague or incomplete.
Page 8 of 16ITA Nos 2969 2970 and 4870 of Ashray Premises Pvt Ltd Pune H Bench The appellant got two flats measured by the Government Approved Valuer and submitted the certificate during the course of assessment proceedings. The A.O. did not refer to the certificate at all in the assessment order. The Assessing Officer neither accepted nor rejected nor even acknowledged the fact that the appellant has submitted the certificate in respect of built up area issued by approved valuer.
The A.O. at Para no. 24 (d) has reproduced the area statement as per the booking/sales register found during the course of survey action and has reach the conclusion that many flats are more than 1500 Sq. ft or more. The appellant has claimed that the areas mentioned in the register are super built up areas of the flats. The appellant has reproduced the same list with the additional columns such as total carpet area of the unit including balcony and air handling unit area, balcony area, air handling unit area and net carpet area of the flats against which the built up area certified by architect is mentioned. From the list it is clear that the area mentioned in the sales register is super built up area and not the built up area.
The Assessing Officer did not accept the built up area certified by Assistant Valuation Officer entirely on the ground that the AVO has considered ½ area of the balcony and did not considered the terrace area. Accordingly to the Assessing Officer if 50% of the balcony area and terrace area is added the built up area of the flat will exceeds 1600 sft. The Assessing Officer in arriving at this conclusion has relied on the definition of "Built Up Area" as per newly inserted section 801B(14) of the Act. Section 801B(14) is brought on statue by the Finance (No. 2) Act 2004 with effect from P' April 2005. The section and the Notes on the clauses makes it clear that the newly inserted section is applicable prospectively and not retrospectively. The amendment is not clarificatory. The appellant has relied on two Supreme Court cases namely GOVINDAS AND OTHERS VS. INCOME TAX OFFICER 103 ITR 123 (1976) VIRTUAL SOFT SYSTEMTS LTD VS CIT 289 ITR 83 to substantiate the proposition that while interpreting the amending provision it is not retrospectively applicable unless expressly stated or clearly implied. I am in agreement Page 9 of 16 ITA Nos 2969 2970 and 4870 of Ashray Premises Pvt Ltd Pune H Bench with the appellant that the expression built up area should have been construed in accordance with definition of built up area as per Development Control Rule for development of Pune which excludes the balcony area.
The perusal of the built area certificate issued by the Government Approved Valuer and AVO shows that the flats of the similar type Flat for e.g. Flat No 701+7014 of Building No D-1 is measured by AVO at 1471 sq. ft. built up and Flat No 101+IOIA Building No D-1 is measured by Government Approved Valuer at .448 sq. ft. built up. From the typical floor plan of the building D-1 it is absolutely clear that Flat No 101 is exactly below the flat no 701. These flats can not have different area as per the RCC design. The built up areas certified by both the valuers is more or less same i. e 1478 sq. ft and 1448 sq.ft. the aspect which has been totally ignored by the A.O. Therefore, I am of the view that the built up area of none of the residential flat exceeded the threshold limit of 1500 sq. ft built up and the Assessing Officer is not justified in denying the deductions under section 801B(10) in respect of the profit derived from housing project.
In view of compliance of the conditions prescribed by section 80I0,), I am of the view that the appellant is entitled to deduction claimed under section 801B(10) for the assessment year 2004-05 ` 8,24,36,363/- and for the assessment year 2005-06 ` 2,66,09,494/-.
To conclude, the appellant succeeds in respect of first ground of appeal and the ground of appeal is hereby allowed.
The Revenue is aggrieved.
4. The learned Departmental Representative reiterated the arguments of the Assessing Officer to submit that the plan was originally approved in 1997 i.e. prior to 1/10/1998. He relied on Page 10 of 16 ITA Nos 2969 2970 and 4870 of Ashray Premises Pvt Ltd Pune H Bench explanation to Sec 80 IB(10) to submit that assessee was not eligible for deduction. The learned Counsel, however, reiterated the submissions made before the CIT (A) and also drew our attention to the plan approved in 1997 and plan approved in 2002 to submit that the plans were entirely revised, alignments were difficult and with reference to the expenditure incurred in every year 1995, he drew our attention to the nature of the expenditure to submit that assessee has never started the project but only incurring expenditure towards purchase of land and construction of compound wall, municipal taxes etc. and relied on the findings of the CIT (A).
5. We have examined the issue, rival contentions and facts on record. The learned Departmental Representative relied on the explanation to section 80IB(10) that where the approval was obtained more than once, such housing project shall be deemed to have been approved on the date on which the building plan of such housing project is first approved by the local authority. This explanation was brought on statute when the said provision was amended with effect from 01-04-2005. So claim in AY 2004-05, being first year of claim, cannot be disallowed on this reason. Moreover the explanation cannot be invoked for the projects approved earlier. For these reasons we are not impressed by the argument of Ld. DR. Further what was approved in 1997 was only a lay out plan and not a building plan. The entire plan was revised and the constructed project was based on the project approved in 2002.
5.2 Benefit of deduction to developers of housing projects was first introduced by the Finance Act, 1998 with effect from 1-4-1999 in the form of sub-section (4F) to section 80-IA of the Act. Those provisions read as follows:
Page 11 of 16ITA Nos 2969 2970 and 4870 of Ashray Premises Pvt Ltd Pune H Bench "This section applies to an undertaking engaged in developing and building housing projects approved by a local authority subject to the condition that the size of a plot of land has a minimum area of one acre and the residential unit has a maximum built-up area not exceeding one thousand square feet:
Provided that the undertaking such undertaking commences development and construction of the housing project on or after the 1st day of October, 1998 and completes the same before 31st day of March, 2001."
5.3 By the Finance Act, 1999 with effect from 1-4-2000, the benefit of the above deduction was available under section 80-IB(10). The said provisions read as follows:
"(10) The amount of deduction in the case of an undertaking developing and building housing projects approved by a local authority shall be hundred per cent of the profits derived in the previous year relevant to any assessment year from such housing project if,
(a)such undertaking has commenced or commences development and construction of the housing project on or after the 1st day of October, 1998 and completes the same before 31st day of March, 2003;
(b)the project is on the size of a plot of land which has a minimum area of one acre;
(c)the residential unit has a maximum built-up area of one thousand square feet where such residential unit is situated within the city of Delhi or Mumbai or within twenty-five kilometres from the municipal limits of these cities and one thousand and five hundred square feet at any other place;"
5.4 By the Finance Act, 2000 with effect from 1-4-2001, the words "Before 31st day of March, 2001" were inserted after the words "housing project approved". Thus, all conditions for grant of deduction remained the same except that the approval of local authority for the development has to be obtained before 31st day of March, 2001.
Page 12 of 16ITA Nos 2969 2970 and 4870 of Ashray Premises Pvt Ltd Pune H Bench 5.5 For assessment year 2002-03, the law applicable was that the condition regarding completion of the project before 31-3-2003 was dispensed with.
5.6 For assessment years 2003-04 and 2004-05, the law applicable was that all conditions remained the same except the condition regarding approval of the project by the local authority which could be before 31-3-2005. Another important change was that the period of completion of the construction on or before 31-3-2003 was dispensed with and there was no time-limit given for completion of the construction.
5.7 By the Finance Act, 2004 with effect from 1-4-2005, clause (d) to section 80-IB(10) was introduced which provided that built-up area of shops or other commercial establishments included in the housing project should not exceed 5 per cent of the aggregate built-up area of the housing project or 2,000 sq.ft., whichever is less. The provision as they read applicable from assessment year 2005-06 is as follows:
"(10) The amount of deduction in the case of an undertaking developing and building housing projects approved by a local authority shall be hundred per cent of the profits derived in the previous year relevant to any assessment year from such housing project if,
(a) such undertaking has commenced or commences development and construction of the housing project on or after the 1st day of October, 1998 and completes such construction :
(i) in a case where a housing project has been approved by the local authority before the 1st day of April, 2004, on or before the 31st day of March, 2008;
(ii) in a case where a housing project has been, or, is approved by the local authority on or after the 1st day of April, 2004, within four years from the end of the financial year in which the housing project is approved by the local authority.
Explanation.--For the purposes of this clause,--
Page 13 of 16ITA Nos 2969 2970 and 4870 of Ashray Premises Pvt Ltd Pune H Bench
(i) in a case where the approval in respect of the housing project is obtained more than once, such housing project shall be deemed to have been approved on the date on which the building plan of such housing project is first approved by the local authority;
(ii) the date of completion of construction of the housing project shall be taken to be the date on which the completion certificate in respect of such housing project is issued by the local authority :
Provided that nothing contained in clause (a) or clause (b) shall apply to a housing project carried out in accordance with a scheme framed by the Central Government or a State Government for reconstruction or redevelopment of existing buildings in areas declared to be slum areas under
any law for the time being in force and such scheme is notified by the Board in this behalf;
(b) the project is on the size of a plot of land which has a minimum area of one acre;
(c) the residential unit has a maximum built-up area of one thousand square feet where such residential unit is situated within the city of Delhi or Mumbai or within twenty-five kilometres from the municipal limits of these cities and one thousand and five hundred square feet at any other place;
(d) the built-up area of the shops and other commercial establishments included in the housing project does not exceed five per cent of the aggregate built-up area of the housing project or two thousand square feet, whichever is less."
As per the amended law in view of insertion of clause (d ) the built-up area of shops and other commercial establishment included in the housing project should not exceed five per cent of the aggregate built-up area of the housing project or 2,000 sq.ft., whichever is less".
Page 14 of 16ITA Nos 2969 2970 and 4870 of Ashray Premises Pvt Ltd Pune H Bench
6. As can be seen from the above explanation brought in statute, the same was not applicable to the projects approved prior to 01-04- 05 and as can be seen from the plans and the findings of the CIT (A), there is no co-relation with the project approved in 1997 by the P.M.C. to the subsequent project approved. The plans which are approved on which the basis for construction of the present building was approved in 2002 and accordingly they are within the provisions of Section 80(IB)10.
7. Moreover, the statute prescribes that 'such undertaking commenced or commences development and construction of the housing project on or after 1st day of October, 1998. Approval of plans and the date there of has no relevance unless the project commences or commenced as prescribed. The Revenue could not counter the findings of the CIT (A) that project commenced only in 2002. These findings are based on record with which we agree. AO relies on certain amounts spent prior to 2002 from A.Y 1995-96 onwards to state that the project has started much earlier. As seen from the nature of expenditure, they cannot be considered as evidencing that the project has commenced before 1st October 1998 as only cost of land, construction of compound wall and Municipal taxes and various expenditures for plan approvals were incurred. There is no expenditure on construction activity on the project. Principles laid down by Hon'ble Bombay High Court in the case of Vandana Properties in ITA no 3633 of 2009 /4361of 2010 dt 28-03- 12 also support our view. . For these reasons, we uphold the orders of the CIT (A) and agree with his findings that assessee is eligible for deduction under section 80(IB)(10).
8 With reference to the other reason on denying the claim that the assessee has sold adjoining flats of more than 1500 sft, the measurements were taken again and post survey even Page 15 of 16 ITA Nos 2969 2970 and 4870 of Ashray Premises Pvt Ltd Pune H Bench Departmental Valuation Officer has certified that even the combined flat was less than 1500 sft. In view of these, there is no need to differ from the findings of the CIT (A) who not only considered the facts but also validity of the measurements taken during the survey and subsequent statement recorded from the Director on the issue. We agree with his findings and affirm his order. Accordingly the grounds raised by the Revenue in all the three years are dismissed.
9. In the result, Revenue appeals are dismissed.
Order pronounced in the open court on 30th April, 2012.
Sd/- Sd/-
(S.S. Godara) (B. Ramakotaiah)
Judicial Member Accountant Member
Mumbai, dated 30th April, 2012.
Vnodan/sps
Copy to:
1. The Appellant
2. The Respondent
3. The concerned CIT(A)
4. The concerned CIT
5. The DR, " " Bench, ITAT, Mumbai
By Order
Assistant Registrar
Income Tax Appellate Tribunal,
Mumbai Benches, MUMBAI
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