NARENDRA KUSHALRAJ KOTHARI, MUMBAI v. DCIT 5(2), MUMBAI

ITA 6259/MUM/2012 | 2009-2010
Pronouncement Date: 29-11-2017 | Result: Dismissed

Appeal Details

RSA Number 625919914 RSA 2012
Assessee PAN AACPK6517E
Bench Mumbai
Appeal Number ITA 6259/MUM/2012
Duration Of Justice 5 year(s) 1 month(s) 18 day(s)
Appellant NARENDRA KUSHALRAJ KOTHARI, MUMBAI
Respondent DCIT 5(2), MUMBAI
Appeal Type Income Tax Appeal
Pronouncement Date 29-11-2017
Appeal Filed By Assessee
Tags No record found
Order Result Dismissed
Bench Allotted B
Tribunal Order Date 29-11-2017
Date Of Final Hearing 07-05-2015
Next Hearing Date 07-05-2015
First Hearing Date 07-05-2015
Assessment Year 2009-2010
Appeal Filed On 11-10-2012
Judgment Text
IN THE INCOME TAX APPELLATE TRIBUNAL'B' BENCH MUMB AI BEFORE SHRI G.S. PANNU ACCOUNTANT MEMBER AND SHRI PAWAN SINGH JUDICIAL MEMBER ITA NOS.6278 & 6259/MUM/2012 (ASSESSMENT YEARS: 2006-07 & 2009-10) SHRI NARENDRA KUSHALRAJ KOTHARI VS. DEPUTY COMMISSIONER OF 275 MAPLA MAHAL J.S.S. ROAD THAKURDWAR CORNER GIRGAUM MUMBAI 400004 INCOME TAX 5(2 ) MUMBAI PAN AACPK6517E APPELLANT RESPONDENT APPELLANT BY: NONE RESPONDENT BY: SHRI SUMAN KUMAR DATE OF HEARING: 08.11.2017 DATE OF PRONOUNCEMENT: 29.11.2017 O R D E R PER PAWAN SINGH J.M. THESE TWO APPEALS BY THE ASSESSEE UNDER SECTION 253 OF THE INCOME TAX ACT ARE DIRECTED AGAINST THE ORDERS OF THE CIT( A)-9 MUMBAI DATED 13.07.2012 AND 18.07.2012 FOR ASSESSMENT YEARS 2006 -07 & 2009-10 RESPECTIVELY. 2. THE ASSESSEE HAS RAISED ONE COMMON GROUNDS OF APPEA L RELATED WITH SECTION 2(22)(E) OF THE ACT THEREFORE THE APPEALS WERE CONSOLIDATED. IN A.Y. 2006-07 ASSESSEE HAS RAISED THE FOLLOWING GROUNDS O F APPEAL: - 1. ON THE FACTS AND IN THE CIRCUMSTANCES AND IN LA W THE LEARNED C.I.T. (A) ERRED IN UPHOLDING THE VALIDITY OF THE P ROCEEDINGS INITIATED U/S 147 OF THE I.T. ACT. 2. ON THE FACTS AND IN THE CIRCUMSTANCES AND IN LAW THE LEARNED C.I.T. (A) ERRED IN UPHOLDING THE VALIDITY OF THE A SSESSMENT ORDER PASSED U/S 143(3) R.W.S.147 OF THE I.T. ACT. 3. ON THE FACTS AND IN THE CIRCUMSTANCES AND IN LAW THE LEARNED C.I.T. (A) ERRED IN CONFIRMING THE ACTION OF THE A. O. AND UPHOLDING THE ADDITION MADE OF RS.6 21 306/- U/S 2(22)(E) OF THE ACT. 4. ON THE FACTS AND IN THE CIRCUMSTANCES AND IN LA W THE LEARNED C.I.T. (A) ERRED IN CONFIRMING THE ACTION OF THE A. O. AND UPHOLDING THE DISALLOWANCE OF SERVICE CHARGES AMOUNTING TO RS .34 18 011/- ITA NOS.6278 & 6259/MUM/2012 SHRI NARENDRA KUSHALRAJ KOTHARI 2 5. ON THE FACTS AND IN THE CIRCUMSTANCES AND IN LA W THE LEARNED C.I.T. (A) ERRED IN CONFIRMING THE ACTION OF THE A. O. AND UPHOLDING THE DISALLOWANCE OF EMI LOTTERY TERMINAL CHARGES AM OUNTING TO RS.15 36 000/- 6. ON THE FACTS AND IN THE CIRCUMSTANCES AND IN LA W THE LEARNED C.I.T. (A) ERRED IN CONFIRMING THE ACTION OF THE A. O. AND UPHOLDING THE DISALLOWANCE OF LOGISTICS PAPER CHARGES AMOUNTI NG TO RS.7 82 869/- 7. ON THE FACTS AND IN THE CIRCUMSTANCES AND IN LA W THE LEARNED C.I.T. (A) ERRED IN CONFIRMING THE ACTION OF THE A. O. AND UPHOLDING THE DISALLOWANCE OF MOBILE CHARGES AMOUNTING TO RS. 1 01 997/- 8. ON THE FACTS AND IN THE CIRCUMSTANCES AND IN LA W THE LEARNED C.I.T. (A) ERRED IN CONFIRMING THE ACTION OF THE A. O. AND UPHOLDING THE DISALLOWANCE MADE OF RS.15 590/- OUT OF POSTAGE & COURIER CHARGES OF RS.27 567/- AND PRINTING & STATIONERY EX PENSES OF RS. 1 28 339/- 9. ON THE FACTS AND IN THE CIRCUMSTANCES AND IN LAW THE LEARNED C.I.T. (A) ERRED IN SUSTAINING DISALLOWANCE MADE U/ S 14A TO THE EXTENT OF 5% OF THE EXEMPT INCOME. 10. ON THE FACTS AND IN THE CIRCUMSTANCES AND IN LA W THE LEARNED C.I.T. (A) ERRED IN CONFIRMING THE ACTION OF THE A. O. IN DENYING THE BENEFITS OF THE PROVISIONS OF SECTION 10(36) OF THE I.T. ACT. 3. THE VERY CRUX OF THE CASE ARE THAT THE ASSESSEE ENG AGED IN THE BUSINESS OF ONLINE LOTTERY AND COMMISSION AGENT AND IS ALSO DIRECTOR IN M/S. MODEL SALES AGENCY PVT. LTD. ASSESSEE FILED HI S RETURN OF INCOME FOR THE RELEVANT ASSESSMENT YEAR ON 01.11.2016 DECLARIN G TOTAL INCOME OF ` 15 94 758/-. THE RETURN WAS PROCESSED UNDER SECTION 143(1). SUBSEQUENTLY THE ASSESSMENT WAS REOPENED UNDER SEC TION 147. NOTICE UNDER SECTION 148 DATED 29.03.2010 WAS SERVED UPON THE ASSESSEE. THE ASSESSEE VIDE ITS REPLY DATED 07.04.2010 CONTENDED THAT THE RETURN ALREADY FURNISHED MAY BE TREATED AS RETURN IN RESPONSE TO T HE NOTICE UNDER SECTION 148. THE ASSESSMENT WAS REOPENED FOR THE FOLLOWING REASONS: - ASSESSEE HAS FILED HIS RETURN OF INCOME FOR A.Y. 2 006-07 ON 01.11.2006 DECLARING TOTAL INCOME AT RS.15 94 758/- . ASSESSEE IS ONE OF THE DIRECTORS OF M/S. MODEL SALES AGENCY PVT. LT D. HAVING 94.54% SHARE HOLDING IN THE COMPANY. DURING THE COURSE OF ASSESSMENT PROCEEDINGS U/S 143(3) IN THE CASE OF M/S. MODEL SA LES AGENCY PVT. ITA NOS.6278 & 6259/MUM/2012 SHRI NARENDRA KUSHALRAJ KOTHARI 3 LTD. IT WAS OBSERVED THAT M/S MODEL SALES AGENCY P VT. LTD. HAS ADVANCED FOLLOWING AMOUNTS TO THE CONCERNS/COMPANIE S IN WHICH MR. NARENDRA KOTHARI IS HAVING SUBSTANTIAL INTEREST : (A) RS. 1 52 408.06 M/S KUSHALRAJ LAND DEVELO PERS PVT. LTD. (29.98%) SHARE HOLDING OF MR. KOTHARI. (B) RS. 4 68 898/- M/S N.K.K. FINANCE (PROP. MR. N ARENDRA KOTHARI) MOREOVER THE ASSESSEE COMPANY I.E. M/S MODEL SALES AGENCY PVT. LTD. HAS SHOWN RESERVES & SURPLUS OF RS. 38 08 093/- IN THEIR BALANCE SHEET AS AT 31.03.2006. SINCE MR. NARENDRA KOTHARI IS HAVING SUBSTANTIAL (94.54%) INTEREST IN THE COMPANY M/S MODEL SALES AGENCY PVT. LTD. WHICH HAS ADVANCED LOAN TO COMPANIES/ CONCERNS IN WHICH MR. N ARENDRA KOTHARI IS HAVING SUBSTANTIAL INTEREST THE PROVISIONS OF SECT ION 2(22)(E) ARE APPLICABLE. I THEREFORE HAVE REASON TO BELIEVE THAT INCOME HAS ESCAPED ASSESSMENT IN THE HANDS OF MR. NARENDRA KOTHARI FOR THE A.Y. 06-0 7 NEEDS TO BE REOPENED AS PER PROVISION OF SECTION 147 OF THE I.T. ACT. 19 61. 4. THE ASSESSEE FILED ITS OBJECTION VIDE LETTER DATED 01.12.2010 AND AGAIN ON 08.12.2010. THE OBJECTIONS OF THE ASSESSEE WERE NOT ACCEPTED BY THE AO AND PROCEEDED TO MAKE RE-ASSESSMENT OF THE I NCOME. THE ASSESSMENT WAS COMPLETED UNDER SECTION 143(3) R.W.S 147 ON 30.12.010. THE AO WHILE PASSING THE ASSESSMENT ORDER MADE FOLL OWING ADDITIONS: - ADDITION UNDER SECTION 2(22)(E) RS.6 21 306/- SERVICE CHARGES RS.34 18 011/- EMI LOTTERY TERMINAL CHARGES RS.15 36 000/- LOGISTIC PAPER CHARGES RS.1 01 997/- POSTAGE AND COURIER CHARGES RS. 27 567/- STATIONERY AND PRINTING CHARGES RS. 1 28 339/- DISALLOWANCE UNDER SECTION 14A TO THE EXTENT OF 5% OF EXEMPT INCOME ON APPEAL BEFORE THE CIT(A) THE REOPENING OF ASSESS MENT AS WELL AS VARIOUS ADDITIONS/DISALLOWANCE WERE CONFIRMED. FURTHER AGG RIEVED BY THE ORDER OF THE CIT(A) THE ASSESSEE FILED PRESENT APPEAL BEFORE US. 5. NONE APPEARED ON BEHALF OF THE ASSESSEE DESPITE WAI TING. THE COPY OF AUTHORITY LETTER OF SH. R.M. SAWANT CA IS ON RECORD . THE LD AR FOR ASSESS SOUGHT ADJOURNMENT ON 30.05.2016 13.10.2016 AND AG AIN ON 30.05.2016. ITA NOS.6278 & 6259/MUM/2012 SHRI NARENDRA KUSHALRAJ KOTHARI 4 WHEN NONE APPEARED ON 27.02.2017 NOTICE THROUGH R PAD WAS ISSUED TO ASSESSEE DESPITE SERVICE OF NOTICE OF HEARING THRO UGH RPAD NONE APPEARED ON BEHALF OF ASSESSEE. HENCE WE HAVE NOT OPTION EX CEPT TO HEAR THE LEARNED D.R. FOR REVENUE AND TO PROCEED TO DECIDE THE APPEA L ON THE BASIS OF THE MATERIAL AVAILABLE ON RECORD. 6. THE LEARNED D.R. FOR REVENUE SUPPORTED THE ORDERS O F THE AUTHORITIES BELOW. THE LEARNED D.R. ARGUED THAT THE ASSESSMENT WAS REOPENED DURING THE ASSESSMENT PROCEEDINGS UNDER SECTION 143(3) IN THE CASE OF M/S. MODEL SALES AGENCY PVT. LTD. WHEREIN THE ASSESSEE IS HAVING SUBSTANTIAL INTEREST BEING ONE OF THE DIRECTORS. THE ASSESSEE H AS TAKEN ADVANCES WHICH WERE OUT OF THE SCOPE OF PROVISIONS OF SECTION 2(22 )(E) WHICH ESCAPED FROM ASSESSMENT. THUS THE CASE OF THE ASSESSEE WAS REOP ENED UNDER SECTION 147 OF THE ACT. DURING THE REASSESSMENT PROCEEDINGS THE AO MADE VARIOUS ADDITIONS/DISALLOWANCES AFTER AFFORDING FULL OPPORT UNITY TO THE ASSESSEE. THE ASSESSEE FAILED TO SUBSTANTIATE HIS CONTENTION REGARDING VARIOUS ISSUES RAISED BY THE AO. THUS THE VARIOUS ADDITIONS/DISALL OWANCES WERE MADE. ON APPEAL BEFORE THE CIT(A) THE ASSESSEE FAILED TO SUBSTANTIATE HIS CONTENTION. THUS ALL THE DISALLOWANCES WERE CONFIRM ED. THE ASSESSEE HAS NEITHER APPEARED BEFORE THE TRIBUNAL NOR SUBMITTED ANY MATERIAL TO SUBSTANTIATE THE GROUNDS OF APPEAL RAISED. 7. WE HAVE CONSIDERED THE SUBMISSIONS OF THE LEARNED D .R. FOR REVENUE AND PERUSED THE MATERIAL AVAILABLE ON RECORD. THE A SSESSMENT WAS REOPENED BY THE AO OBSERVING THAT THE ASSESSEE HAS SUBSTANTIAL INTEREST OF 94.54% IN M/S. MODEL SALES AGENCY PVT. LTD. WHICH H AS ADVANCED LOANS TO THE ASSESSEE AND HIS OTHER CONCERNS. THIS FACT CAME TO THE NOTICE OF THE AO DURING THE ASSESSMENT OF M/S. MODEL SALES AGENCY PV T. LTD. THUS IN OUR OPINION THIS INFORMATION WAS SUFFICIENT TO MAKE A B ELIEF BY THE AO THAT INCOME HAS ESCAPED ASSESSMENT. THUS THE REOPENING O F ASSESSMENT WAS VALID. THE ASSESSEE HAS NOT PACED ON RECORD ANY MAT ERIAL TO PROVE THE FACTS OTHERWISE. THUS THE RE-OPENING OF ASSESSMENT UNDER SECTION 147 IS VALID. IN THE RESULT THE GROUND NO.1 &2 ARE DISMISSED. ITA NOS.6278 & 6259/MUM/2012 SHRI NARENDRA KUSHALRAJ KOTHARI 5 8. THE GROUND NO.3 RELATES TO THE ADDITION OF DEEMED D IVIDEND UNDER SECTION 2(22)(E) OF RS. 6 21 306/-. THE AO TREATED THE ADVANCE AS DEEMED DIVIDEND HOLDING THAT THE ASSESSEE WAS HAVING SUBST ANTIAL INTEREST OF 94.54% IN MODEL SALES AGENCY PVT LTD WHICH HAS ADVA NCED LOAN TO THE CONCERN. THE LD CIT(A) CONFIRMED THE ACTION OF AO H OLDING THAT IN A COMPANY WHERE THE PUBLIC HAVE NO SUBSTANTIAL INTERE ST MAY NOT RECOVER THE LOANS OR ALLOW THEM TO BE BARRED BY TIME WHICH WOULD BE THAT THE AMOUNT OF LOAN WOULD BECOME THE INCOME OF THE SHARE HOLDER AND THEY WOULD NOT MEET THE REQUIREMENT TO PAY THE TAX ON SU CH INCOME. WE HAVE SEEN THAT THE ASSESSEE HAS NOT PLACED ON RECORD ANY MATERIAL TO CONVINCE US TO TAKE A CONTRARY VIEW; HENCE THE GROUND OF APP EAL RAISED BY ASSESSEE IS DISMISSED. 9. GROUND NO.4 RELATES TO CONFIRMING THE DISALLOWANCES OF SERVICE CHARGES OF RS. 34 18 011/- THE AO DISALLOWED THE SERVICE CHARGES HOLDING THAT NO TDS WAS MADE ON THE PAYMENT OF SERVICE CHAR GES. THE LD CITA) CONFIRMED THE ACTION OF AO HOLDING THAT THE ASSESSE E HAS ADMITTED THAT NO TDS HAS BEEN MADE. SECONDLY THE ASSESSEE HAD DEBIT ED THE EXPENSES ON THE BASIS OF DEBIT NOTES SENT BE SERVICE PROVIDER. THE SAID EXPENSES HAVE NOT PAID BY THE ASSESSEE AND CLAIMED AS NOT PAYABLE TO TRIPURA ON LINE LOTTERY SO THE EXPENSES WERE NOT PAID WHOLLY AND EX CLUSIVELY FOR THE PURPOSE OF BUSINESS. WE HAVE NOTED THE ASSESSEE HAS NOT PLACED ON RECORD ANY MATERIAL TO CONVINCE US TO TAKE A CONTRARY VIEW ; HENCE THE GROUND OF APPEAL RAISED BY ASSESSEE IS DISMISSED. 10. GROUND NO.5 RELATES TO LOTTERY TERMINAL CHARGES OF RS. 15 36 000/- AND GROUND NO. 6 RELATES LOGISTIC PAPER CHARGES OF RS. 7 82 869/-. THE AO DISALLOWED DUE TO NON DEDUCTION OF TDS AS THE PROVI SIONS OF SECTION 40(A)(IA) ARE APPLICABLE. THE LD CIT(A) CONFIRMED T HE ACTION OF AO ON BOTH THE DISALLOWANCE HOLDING THAT THE ASSESSEE HAS ADM ITTED THAT NO TDS HAS BEEN MADE. FURTHER THE ASSESSEE HAD DEBITED THE EX PENSES ON THE BASIS OF DEBIT NOTES SENT BE SERVICE PROVIDER. THE SAID EXPE NSES HAVE NOT PAID BY THE ASSESSEE AND CLAIMED AS NOT PAYABLE TO TRIPURA ON LINE LOTTERY SO THE EXPENSES WERE NOT PAID WHOLLY AND EXCLUSIVELY FOR T HE PURPOSE OF BUSINESS. ITA NOS.6278 & 6259/MUM/2012 SHRI NARENDRA KUSHALRAJ KOTHARI 6 WE HAVE NOTED THE ASSESSEE HAS NOT PLACED ON RECORD ANY MATERIAL TO CONVINCE US TO TAKE A CONTRARY VIEW; HENCE THE GROU ND OF APPEAL RAISED BY ASSESSEE ARE DISMISSED. 11. GROUND NO.7 RELATES TO DISALLOWANCE OF MOBILE CHA RGES OF RS. 1 01 997/-. THE AO DISALLOWED THE MOBILE CHARGES A LONG WITH OTHER DISALLOWANCE OF SERVICE CHARGES AND TERMINAL CHARGE S HOLDING THAT NO TDS WAS MADE. THE LD CIT(A) CONFIRMED THE SAME ALONG WI TH OTHER DISALLOWANCES WITH SIMILAR OBSERVATION AS REFERRED ABOVE. WE HAVE NOTED THAT BEFORE US NEITHER THE ASSESSEE HAS FILED ANY D OCUMENTARY EVIDENCE OR ANY WRITTEN SUBMISSION TO SUBSTANTIATE THE GROUNDS OF APPEAL. HENCE THIS GROUND OF APPEAL IS ALSO FAILED. 12. GROUND NO.8 RELATES TO DISALLOWANCE OF VARIOUS EXPE NSES POSTAGE EXPENSES COURIER EXPENSES AND STATIONARY EXPENSES. THE AO DISALLOWED 10% OF THE CLAIMS HOLDING THAT THE EXPENSES ARE NOT VERIFIABLE. WE HAVE NOTED THAT THE ASSESSEE HAS NOT RAISED ANY GROUND O F APPEAL BEFORE LD CIT(A) CHALLENGING THESE DISALLOWANCES. WE HAVE NO TED THERE IS NO ADJUDICATION OF THESE GROUNDS OF APPEAL BY LD CIT(A ). EVEN OTHERWISE THE ASSESSEE HAS NOT FILED ANY DOCUMENTARY EVIDENCES TO SUBSTANTIATE HIS CLAIM THAT ALL EXPENSES WERE MADE WHOLLY AND EXCLUS IVELY FOR BUSINESS. HENCE THIS GROUND OF APPEAL IS ALSO DISMISSED. 13. GROUND NO.9 RELATED TO DISALLOWANCE UNDER SECTION 1 4A. THE AO MADE THE DISALLOWANCE AS PER RULE 8D AND DISALLOWED RS.5 65 514/-. THE LD CIT(A) PARTLY SUSTAINED THE DISALLOWANCE @ 5% OF TH E EXEMPT INCOME ON THE BASIS OF DECISION OF HONBLE BOMBAY HIGH COURT IN G ODREJ & BOYCE MANUFACTURING COMPANY LTD. VS DCIT [2010] 234 CTR1. WE HAVE SEEN THAT IN ABSENCE OF ANY EXPLANATION OR DOCUMENTARY E VIDENCES ON RECORD THE DISALLOWANCE SUSTAINED BY LD CIT(A IS REASONABLE ON E. HENCE THIS GROUND OF APPEAL IS ALSO DISMISSED. 14. GROUND NO10 RELATES TO DENIAL OF BENEFIT OF SECTION 10(36) OF THE ACT. THE AO DENIED THE BENEFIT OF SECTION10 (36) FOR THE WANT OF EVIDENCE. THE LD CIT(A) CONFIRMED THE ACTION OF AO THAT NO PROOF WAS FURNISHED BY ASSESSEE ITA NOS.6278 & 6259/MUM/2012 SHRI NARENDRA KUSHALRAJ KOTHARI 7 EVEN AT THE STAGE OF APPEAL. WE HAVE NOT THAT THE A SSESSEE HAS NOT PLACED ANY EVIDENCE BEFORE US EXCEPT RAISING THE GROUNDS O F APPEAL. THUS WE DO NOT FIND ANY MERIT IN THE GROUND OF APPEAL; HENCE T HIS GROUND OF APPEAL IS ALSO DISMISSED. 15. IN THE RESULT THE APPEAL FILED BY THE ASSESSEE IS D ISMISSED. ITA NO. 6259/MUM/2012 A.Y. 2009-10 16. THOUGH THE ASSESSEE HAS RAISED AS MANY AS FOUR GRO UNDS OF APPEAL AS PER OUR CONSIDERED VIEW THE ONLY SUBSTANTIAL GRO UND OF APPEAL BY THE ASSESSEE RELATES TO CONFIRMATION OF ADDITION UNDER SECTION 2(22)(E) OF RS. 80 97 355/-. 17. THE LEARNED D.R. FOR REVENUE ARGUED THAT THIS GROUN D OF APPEAL IS SIMILAR TO GROUND NO. 3 OF THE APPEAL FOR A.Y. 2006 -07. THE ASSESSEE IS NOT FILED ANY DOCUMENTARY EVIDENCE NOR ANY STATEMENT OF FACT TO SUBSTANTIATE HIS CONTENTION FOR DELETING THE ADDITION. THE LEARN ED D.R. PLEADED FOR DISMISSAL OF THE APPEAL. 18. CONSIDERING THE FACT THAT THIS GROUND OF APPEAL IS SIMILAR TO GROUND NO. 3 OF APPEAL FOR A.Y. 2006-07 WHICH HAVE BEEN DI SMISSED IN THE ABSENCE OF ANY CONTENTION OR DOCUMENTARY EVIDENCE FURNISHED BY THE ASSESSEE. THUS WE DO NOT FIND ANY MERIT IN THE ABSENCE OF AN Y SUBMISSION OR ANY DOCUMENTARY EVIDENCE FURNISHED BY THE ASSESSEE. IN THE RESULT GROUNDS RAISED BY THE ASSESSEE ARE DISMISSED. 19. IN THE RESULT THE APPEALS FILED BY THE ASSESSEE AR E DISMISSED. ORDER PRONOUNCED IN THE OPEN COURT ON 29 TH NOVEMBER 2017. SD/ - SD/ - (G.S. PANNU) (PAWAN SINGH) ACCOUNTANT MEMBER JUDICIAL MEMBER MUMBAI DATED: 29 TH NOVEMBER 2017 ITA NOS.6278 & 6259/MUM/2012 SHRI NARENDRA KUSHALRAJ KOTHARI 8 COPY TO: 1. THE APPELLANT 2. THE RESPONDENT 3. THE CIT(A) -9 MUMBAI 4. THE CIT -5 MUMBAI 5. THE DR B BENCH ITAT MUMBAI BY ORDER //TRUE COPY// ASSISTANT REGISTRAR ITAT MUMBAI BENCHES MUMBAI N.P.