IN THE INCOME TAX APPELLATE TRIBUNAL “E” BENCH MUMBAI BEFORE HON’BLE SHRI SANDEEP GOSAIN, JUDICIAL MEMBER HON’BLE SHRI BIJAYANANDA PURUSETH, ACCOUNTANT MEMBER ITA No. 217/Mum/2026 (Assessment Year: 2025-26)

With ITA No. 218/Mum/2026 (Assessment Year: 2025-26)

With ITA No. 219/Mum/2026 (Assessment Year: 2025-26)

With ITA No. 220/Mum/2026 (Assessment Year: 2025-26)

Hotkaru Mitra Mandal CIT (Exemption), Pune

201, Kamal Pandurang Room no. 322, 3rd floor, Apartment, J S Road, Opp. Vs. Income Tax Office, PMT Prabhat Takies, Bhandarali, Building, Shankar Seth Thane, Maharashtra 400601 Road, Pune, Maharashtra 411037 PAN/GIR No. AAATH7010D (Applicant) (Respondent)

Assesseeby Shri Subodh Ratnaparkhi Revenue by Shri Hemanshu Joshi, (SR. DR)

Date of Hearing 01.04.2026 Date of Pronouncement 23.04.2026 आदेश / ORDER PER SANDEEP GOSAIN, JM:

ITA No. 217/Mum/2026, A.Y. 2025-26 The present appeal has been filed by the Assessee challenging the impugned order dated 13.08.2024 passed u/s 12A of the Income Tax Act, 1961 (‘the Act’), by the CIT (Exemption), Pune for the Assessment Year 2025-2026. The following grounds are reproduced below:

"Ground No.1: On the facts and in the circumstances of the case and in law,