IN THE INCOME TAX APPELLATE TRIBUNAL “E” BENCH, MUMBAI BEFORE MS. KAVITHA RAJAGOPAL, JM AND SMT. RENU JAUHRI, AM ITA No. 4625/Mum/2024 (Assessment Year: 2022-23)

DCIT-CC-7(1), Mumbai Kopran Ltd.

Room No. 653, 6^th Floor, Aaykar 1076, Parijat House, Dr E Mosses Vs.

Bhavan, M. K. Road, Mumbai – Road, Worli, Mumbai – 400018.

400020.

PAN/GIR No. AAACK3202D (Assessee) : (Respondent Assessee by : Shri. Bhupendra Karkhanis a/w. Shri.

Jay Dharod Respondent by : Shri. Biswanath Das-CIT DR Date of Hearing : 22.01.2025 Date of Pronouncement : 17.04.2025

O R D E R

Per Kavitha Rajagopal, J M:

This appeal has been filed by the revenue, challenging the order of the learned Commissioner of Income Tax (Appeals)-49, Mumbai (‘ld. CIT(A)’ for short), National Faceless Appeal Centre (‘NFAC’ for short) passed u/s.250 of the Income Tax Act, 1961 (‘the Act'), pertaining to the Assessment Year (‘A.Y.’ for short) 2022-23.

2. The revenue has challenged the deletion of addition made by the CPC amounting to Rs.

23,41,32,000/- as without considering the provisions of Section 40 and Section 43B of the Act through Notification No. 28/2021, dated 01.04.2021.

3. Briefly stated that the assessee had filed its return of income d