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2025 Supreme(Online)(ITAT) 4475

INCOME TAX APPELLATE TRIBUNAL (MUMBAI BENCH)
C V BHADANG, CJ
Assessee – Appellant
Versus
Revenue – Respondent


Advocates:
For the Appellants/Petitioners: Shri Nitesh S. Joshi, AR
For the Respondents: Shri Rakesh Ranjan-CIT-DR, Shri Leyaqat Ali Aafaqui, Sr. DR

ORDER

Per Padmavathy S, AM:

These cross appeals by the assessee and the revenue are against the separate orders of the Commissioner of Income Tax (Appeals)-4, Mumbai [In short 'CIT(A)'] passed under section 250 of the Income Tax Act, 1961 (the Act) dated 14.03.2013 for AY 2009-10, dated 07.09.2015 for AY 2011-12, dated 04.09.2015 for AY 2010- 11.

AY 2009-10 ITA

No. 4172/Mum/2013

2. The assessee is a company engaged in the business of manufacturing of Fans, Telecommunication, Transmission Line Towers, Hot Dip Galvanizing and trading in electrical appliances, Lamps, Lighting, engineering and project services and generation of wind energy. The assessee filed the return of income for AY 2009-10 on 30.09.2009 declaring a total income of Rs. 144,68,01,374/-. Subsequently the assessee filed a revised return of income on 08.02.2010 and also second time on 30.03.2011 declaring total income of Rs. 160,06,53,482/- and Rs. 145,57,22,635/- respectively. The assessee's case was selected for scrutiny and the statutory notices were duly served on the assessee. The Assessing Officer (AO) completed the assessment by making the following disallowance:

(i) Disallowance under section 14A r.w.r. 8D - Rs.

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