IN THE INCOME TAX APPELLATE TRIBUNAL, ‘A’ BENCH MUMBAI BEFORE: SHRI AMIT SHUKLA, JUDICIAL MEMBER &

SHRI MAKARAND VASANT MAHADEOKAR, ACCOUNTANT MEMBER ITA No.4000/Mum/2025 (Assessment Year :2015-16 (Assessment Year :2015-16 (Assessment Year :2015-16 (Assessment Year :2015-16 (Assessment Year :2015-16 (Assessment Year :2015-16 (Assessment Year :2015-16 (Assessment Year :2015-16 (Assessment Year :2015-16 (Assessment Year :2015-16 (Assessment Year :2015-16 Assessee by Shri Ravi Ganatra Revenue by Shri Surendra Mohan, Sr.

DR Date of Hearing 19/01/2026 Date of Pronouncement 27/01/2026 / O R D E R आदेश PER AMIT SHUKLA (J.M):

The aforesaid appeal has been filed by the Revenue against the order dated 17/03/2025 passed by the learned CIT(A)-47, Mumbai, for the quantum of assessment framed under section 143(3) of the Income-tax Act, 1961, for the Assessment Year 2015-16.

2. In the grounds of appeal, the Revenue has raised the following grounds:

(i) Whether on the facts and in the circumstances of the case, the learned CIT(A) erred in deleting the disallowance of provisions for gratuity and leave encashment, without appreciating that such provisions do not constitute “utilization of funds” under se