IN THE INCOME-TAX APPELLATE TRIBUNAL “F” BENCH, MUMBAI BEFORE SHRI NARENDER KUMAR CHOUDHRY, JUDICIAL MEMBER &

SHRI PRABHASH SHANKAR, ACCOUNTANT MEMBER ITA No.954/MUM/2025 (A.Y. 20 12-13)

(A.Y. 20 12-13)

(A.Y. 20 12-13)

(A.Y. 20 12-13)

(A.Y. 20 12-13)

(A.Y. 20 12-13)

(A.Y. 20 12-13)

Appellant by : Shri Surendra Singh Sabharwal, AR Respondent by : Ms. Kavitha Kaushik (Sr. DR)

Date of Hearing 12.12.2025 Date of Pronouncement 05.01.2026 आदेश / O R D E R PER PRABHASH SHANKAR [A.M.] :-

The present appeal arising from the appellate order dated

12.04.2024 is filed by the assessee against the order passed by the Learned Commissioner of Income-tax (Appeals)/National Faceless Appeal Centre, Delhi [hereinafter referred to as “CIT(A)”] pertaining to assessment order passed u/s. 143(3) r.w.s. 147 of the Income-tax Act, 1961 [hereinafter referred to as “Act”] dated 07.12.2017 as passed by the DCIT, Circle-13(3)(1), Mumbai for the Assessment Year [A.Y.] 2012-13.

2. The grounds of appeal are as under:-

“1. The learned AO has grossly erred in treating capital gains as short term gains which is bad in law whereas the facts figures and documents clearly prove long term nature of the asset. Your appellant had decla