आयकरअपीलीयअिधकरण(cid:586)ायपीठमुंबईम(cid:336)।

IN THE INCOME TAX APPELLATE TRIBUNAL “SMC” BENCH, MUMBAI BEFORE SHRI PAWAN SINGH, JM &

SHRI ARUN KHODPIA, AM I.T.A. No.7048/Mum/2025 (Assessment Year: 2010-11)

Samira Realty Projects Pvt. Ltd. ACIT, Circle-10(2), 126/127, B Wing, Shrikant Kautilya Bhavan, G Block, Chambers, Sion Tromboy Road, BKC, Bandra Kurla Complex, Vs.

Chembur, Bandra East, Mumbai-400071.PAN: Mumbai-400051.

AALCS6413P Assessee - अपीलाथ(cid:334) / Appellant Revenue -(cid:366)(cid:529)थ(cid:334)/ Respondent :

Assessee by : Ms. Vinita Shah, AR Revenue by : Smt. Bhoomika Patel, Sr. DR (Virtually appeared)

Date of Hearing : 07.01.2026 Date of Pronouncement : 27.03.2026 O R D E R Per Arun Khodpia, AM:

The captioned appeal is preferred by theassesseeagainst the order of Commissioner of Income Tax (Appeals)-54, Mumbai [in short “Ld. CIT(A)”] dated 05.09.2025 for the Assessment Year (AY) 2010-11, which in turn arises from the order under section 143(3) of the Income Tax Act, 1961 (the Act)

passedon 29.12.2012 by the ACIT, Circle-10(2), Mumbai.

2. The sole ground of appeal raised by the assessee, reads as under: “On the facts and circumstances of the case as well as in law, the Learne