IN THE INCOME TAX APPELLATE TRIBUNAL “A” BENCH MUMBAI BEFORE SHRI SAKTIJIT DEY, HON'BLE VICE PRESIDENT AND SHRI GIRISH AGRAWAL, ACCOUNTANT MEMBER ITA No. 4292/MUM/2025 Assessment Year: 2018-19 DCIT-CC-8(4), Savita Oil Technologies Limited Mumbai 66-67 Nariman Bhavan, Vs. Nariman Point, Mumbai 400021, PAN: AAACS7934A (Appellant) (Respondent)

Present for:

Assessee : Shri Yogesh Thar and Shri Chaitanya Joshi, CAs Revenue : Shri Rajesh Kumar Yadav, CIT DR Date of Hearing : 13.08.2025 Date of Pronouncement : 10.11.2025

O R D E R

PER GIRISH AGRAWAL, ACCOUNTANT MEMBER:

This appeal filed by the Revenue is against the order of CIT (A) 50, Mumbai, vide order no. ITBA/APL/S/250/2025-26/1075632908(1), dated 15.04.2025 passed against the assessment order by ACIT,CC- 8(4), Mumbai, u/s.143(3) of the Income-tax Act, 1961 (hereinafter referred to as the “Act”), dated 24.08.2021 for AY 2018-19.

2. Grounds taken by the Revenue are reproduced as under:

“1. Whether on the facts and in the circumstances of the case, the Hon'ble CIT(A) was justified in law in allowing deduction under section 80-IA(4) of the Income- tax Act, 1961, without adjusting the losses incurred by the eligible undertaking prior to the in