आयकर अपीलीय अिधकरण (cid:7008)याय पीठ मबुं ई म।(cid:7286)

IN THE INCOME TAX APPELLATE TRIBUNAL “E” BENCH, MUMBAI BEFORE SHRI ANIKESH BANERJEE, JM &

SHRI ARUN KHODPIA, AM I.T.A. No.5623/Mum/2025 (Assessment Year: 2016-17)

(Assessment Year: 2016-17)

(Assessment Year: 2016-17)

(Assessment Year: 2016-17)

(Assessment Year: 2016-17)

(Assessment Year: 2016-17)

(Assessment Year: 2016-17)

(Assessment Year: 2016-17)

Assessee by : Shri J. D. Mistri Revenue by : Shri Hemanshu Joshi, Sr. DR Date of Hearing : 11.12.2025 Date of Pronouncement : 02.01.2026 O R D E R Per Arun Khodpia, AM:

The aforesaid appeal is filed by the Revenue, against the order of ADDL/

JCIT Commissioner of Income Tax (Appeals)-7, Kolkata, [for short “ld. CIT(A)”] dated 15.07.2025 for the AY 2017-18, which in turn arises from the assessment order passed under section 201(1)/201(1A) of the Income Tax Act, 1961 (the Act) dated 21.03.2023, passed by OSD, TDS Circle 2(3), Mumbai.

2. The grounds of appeal filed by the Revenue in the present appeal are extracted, as under:

“1. "Whether, the AddI/JCIT(A) was justified in law and on facts, in deleting the addition made u/s 194H, without appreciating the facts that the relationship between the asse