IN THE INCOME TAX APPELLATE TRIBUNAL “I” BENCH, MUMBAI BEFORE SHRI PAWAN SINGH, JUDICIAL MEMBER & SHRI GIRISH AGRAWAL, ACCOUNTANT MEMBER ITA No. 4972/MUM/2025 (AY : 2017-18)

(Physical hearing)

Bharti Mukesh Chandarana, Income Tax Officer Ward No.

64, Balasinor Society, S.V. Road, Vs 2(1)(1) Mumbai, Kandivali (West), Room No. 618, 6^th Floor, Kautilya Mumbai-400067, Maharashtra Bhawan, C-41 to C-43, G Block, [PAN No. AACPC 4520F] Int Tax Ward, Bandra Kurla Complex, Bandra (East), Mumbai.

Appellant / Assessee Respondent / Revenue Assessee by Shri K. Gopal & Neha Paranjpe Advocates Revenue by Shri Krishna Kumar, Sr. DR Date of institution of appeal 08.08.2025 Date of hearing 15.10.2025 Date of pronouncement 13.11.2025 Order under section 254(1) of Income Tax Act PER PAWAN SINGH, JUDICIAL MEMBER;

1. This second appeal under section 253 of Income Tax Act (Act) is filed by assessee against the final assessment order passed by assessing officer under section 143(3)/147 read with section 144C(13), passed in pursuance of direction of Dispute Resolution Panel (DRP) Mumbai-1, dated 24^th June 2025, for assessment year (AY)2017-18. The assessee has raised following grounds of appeal;

A. Reopening is b