IN THE INCOME TAX APPELLATE TRIBUNAL “K” BENCH MUMBAI BEFORE SHRI PAWAN SINGH, JUDICIAL MEMBER &

SHRI MAKARAND VASANT MAHADEOKAR, ACCOUNTANT MEMBER ITA No. 453/Mum/2026 (Assessment Year: 2022-23)

Siddh Exports LLP ITO Ward - 14(1)(1), Unit No. 7, CTS No. 97, Mumbai Lajja Silk Mill Vs. Aayakar Bhavan, M.

Compound, Village K. Road, Mumbai –

Mogra, Andheri (E), 400 020 Mumbai-400 069 PAN/GIR No. ADRFS2375Q (Applicant) (Respondent)

Assessee by Shri Nilesh Kariya, Ld. AR Revenue by Shri Bhagirath Ramawat, Ld. DR Date of Hearing 16.03.2026 Date of Pronouncement 21.04.2026 आदेश / ORDER PER MAKARAND VASANT MAHADEOKAR, AM:

This appeal by the assessee is directed against the final assessment order passed by the Assessing Officer pursuant to the directions of the Dispute Resolution Panel(hereinafter referred to as “DRP”) under section 144C of the Income Tax Act, 1961 (hereinafter referred to as “the Act”) for Assessment Year 2022–

23.

2. Brief background and chronology of events is such that the assessee is engaged in the business of trading, wholesale and export of mobile phones and accessories. The assessee filed its return of income for the Assessment Year 2022–23 on 05.10.2022 declaring total inc