IN THE INCOME TAX APPELLATE TRIBUNAL MUMBAI BENCH “C” MUMBAI BEFORE SHRI OM PRAKASH KANT (ACCOUNTANT MEMBER)

AND SHRI ANIKESH BANERJEE (JUDICIAL MEMBER)

ITA No. 5118/MUM/2025 Assessment Year: 2024-2025 Pravin Prakash Magar CIT(Appeals) Ward 4, Panvel B 106 Pratiksha CHS Plot No. 55, Panvel, Maharashtra 410206 Sec 15, Koper Khairne, Kopar Vs.

Khairne S.O., Mumbai 400709 PAN NO. BPAPM1266A Appellant Respondent Assessee by : Shri.Pravin Magar (Assessee in person)

Revenue by : Shri Virabhadra Mahajan, Sr. DR (Virtually appear)

Date of Hearing : 16/10/2025 Date of : 03/11/2025 pronouncement

ORDER

PER OM PRAKASH KANT, AM This appeal by the assessee is directed against order dated

16.06.2025 passed by the Ld. Commissioner of Income-tax Appeals/ National Faceless Appeal Centre (NFAC), Delhi [in short ‘the Ld. CIT(A)’] for AY 2024-25 in relation to order u/s. 201 of the Income Tax Act, 1961 [in short the ‘Act’] passed by the AO for short deduction of tax at source on payment made for purchase of property from non-resident Indian. The relevant grounds raised by the assessee are reproduced as under:

“1. BECAUSE the “CIT(A)” has erred in law and on facts in confirming the demand raised u/s 201(1) and