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IN THE INCOME TAX APPELLATE TRIBUNAL “D” BENCH KOLKATA Before Shri Rajesh Kumar, Accountant Member and Shri Pradip Kumar Choubey, Judicial Member Assessment Year: 2021-22 Saroj Goenka….………………...………..............................……….……Appellant

110A, Ekya, 1, Queens Park, P.S. Ballygunge, Kolkata-700019, West Bengal [PAN: ADXPG1677K]

vs.

ITO, Ward-30(1), Kolkata..………….……………………...……...…..…..Respondent Appearances by:

ShriAkkal Dudhwewala, FCA,appeared on behalf of the appellant.

Shri Sanat Kr. Raha, CIT- DR, appeared on behalf of the Respondent.

Date of concluding the hearing : November 20, 2025 Date of pronouncing the order : January 12, 2026

ORDER

Per Rajesh Kumar, Accountant Member:

This is an appeal preferred by the assessee against the order of the NFAC, Delhi (hereinafter referred to as the “Ld. CIT(A)”] dated 18.08.2025 passed u/s 250 of the Income Tax Act (hereinafter referred to as the ‘Act’)for the AY 2021-22.

2. The only effective issue raised in the grounds of appeal is against the order of the Ld. CIT(A) wrongly upholding the order of AO wherein the AO has denied the benefit of exemption claimed u/s

54F of the Act of Rs.26,77,72,881/-.

3. Th