IN THE INCOME TAX APPELLATE TRIBUNAL MUMBAI BENCH “A”, MUMBAI BEFORE SHRI OM PRAKASH KANT, ACCOUNTANT MEMBER AND SHRI ANIKESH BANERJEE, JUDICIAL MEMBER ITA No.481/Mum/2026 (Assessment year: 2020-21) ITA No.482/Mum/2026 (Assessment year: 2021-22)

Income Tax Officer vs Arvind Ratanchand Jain

515, Piramal Chambers, 210/214, Bhikashu Sadan, Prem Lalbaug, Parel, Mumbai- Kumar Sharma Road, Bhuleshwar, 400012 Mumbai-400002 PAN: AFHPJ4084P APPELLANT RESPONDENT Assessee by : NONE Respondent by : Shri Rajesh Kumar Yadav (CIT DR)

Date of hearing : 13/04/2026 Date of pronouncement : 16/04/2026 O R D E R Per: Anikesh Banerjee (JM):

Both the appeals of the revenue filed against the order of the NFAC, Delhi [for brevity the “Ld. CIT(A)”], order passed under section 250 of the Income Tax Act 1961 (for brevity ‘the Act’) for Assessment Year 2020-21 and 2021-22, date of orders 24.11.2025 and 27.11.2025 respectively. The impugned orders emanated from the order of the Assessment Unit Income Tax Department (for brevity the ‘Ld. AO’) order passed under section 143(3) r.w.s. 144B of the Act date of order

26.09.2022 and 19.12.2022 for A.Y. 2020-21 and 2021-22 respectively.

2. When the appeal was called for hear