IN THE INCOME TAX APPELLATE TRIBUNAL “G” BENCH, MUMBAI BEFORE SHRI SAKTIJIT DEY, VICE PRESIDENT &

MS PADMAVATHY S, AM I.T.A. No. 3815/Mum/2025 (Assessment Year: 2018-19) I.T.A. No. 3816/Mum/2025 (Assessment Year: 2020-21)

DCIT, CC-2(1), Gateway Distriparks Ltd. , 804, 8^th Floor, Pratishtha Bhavan, Container Freight Station VPT Exim Maharshi Karve Road, park, Opp. GAIL Near Ayyappa Mumbai-400020. Vs. Swami Temple, Sheela Nagar Vishakhapatanam, Andhra Pradesh-530012.

PAN: AABCV1938N Appellant) : Respondent Revenue / Appellant by : Shri Swapnil Choudhary, Sr. DR Assessee / Respondent by : Shri Ashok Kumar Jain, AR Date of Hearing : 25.08.2025 Date of Pronouncement : 03.09.2025 O R D E R Per Padmavathy S, AM:

These appeals by the revenue are against the separate orders of the Commissioner of Income Tax (Appeals)-48, Mumbai [In short 'CIT(A)'] passed under section 250 of the Income Tax Act, 1961 (the Act) both dated 12.03.2025 for Assessment Years (AY) 2018-19 & 2020-21. The revenue has raised the following the grounds of appeal:

“1. Whether on the facts and circumstances of the case and in law, The Ld. CIT(A) is right in law in holding that the assessee is entitled to deduction u/s. 801A(4)