IN THE INCOME TAX APPELLATE TRIBUNAL, ‘H (SMC)’ BENCH MUMBAI BEFORE: SHRI PAWAN SINGH, JUDICIAL MEMBER AND SHRI GIRISH AGRAWAL, ACCOUNTANT MEMBER ITA No. 3117/MUM/2025(AY: 2013–14)

Akshaya Holdings Pvt ltd. Vs Income Tax officer Ward 3(1)(1), C-9, Elder House, Dalia Mumbai, Aayakar Ind Estate, Andheri (W) Bhawan,Mumbai- 400020 off Veera Desai Road, Mumbai- 400053 PAN: AABCA 0224 E (Appellant) .. (Respondent ITA No. 3369/MUM/2025(AY: 2013–14)

Income Tax officer Ward Vs. Akshaya Holdings Pvt ltd.

3(1)(1), Aayakar Bhawan, C-9, Elder House, Dalia

6^th Floor, Room No. 666, IND. Estate, Andheri (W)

M.K. Road, Churchgate, off Veera Desai Road, Mumbai- 400020 Mumbai- 400053 PAN: AABCA 0224 E (Appellant) .. (Respondent Assessee by Shri. Prateek Jain CA Revenue by Shri. Pravin Salunkhe, Sr. DR Date of Hearing 07/10/2025 Date of Pronouncement 08/10/2025 Order under section 254(1) of Income Tax Act PER PAWAN SINGH, JUDICIAL MEMBER:

1. These two cross appeal by the assessee as well as revenue are directed against the order of Learned Commissioner of Income Tax (Ld. CIT(A)) dated

30.03.2025. The assessee in its appeal has raised following ground of appeal:-

“The following grounds of appeal are without pr