IN THE INCOME TAX APPELLATE TRIBUNAL “C” BENCH MUMBAI BEFORE HON’BLE SHRI SANDEEP GOSAIN, JUDICIAL MEMBER &

HON’BLE SHRI JAGADISH, ACCOUNTANT MEMBER ITA No. 5909/Mum/2024 (Assessment Year: 2021-22)

DCIT – 1(2)1, Mumbai Vs. Patil Construction and

535, 5th Floor, Aayakar Infrastructure Limited Bhavan, M.K. Road, Flat No. 2, Swadhin Mumbai - 400020 Sadan, C – Road, Churchgate Mumbai - 400021 PAN GIR No. AAFCP4151P /

Applicant Respondent ( ) ( )

Assessee by Shri Neelkanth Khandelwal, CA (Virtually appeared)

Revenue by Shri Virabhadra, (SR. DR.)

Date of Hearing 05.03.2026 Date of Pronouncement 30.04.2026 आदेश ORDER /

PER SANDEEP GOSAIN, JM:

The present appeal has been filed by the Revenue challenging the impugned order dated 14.08.2024 passed u/s 250 of the Income Tax Act, 1961 (‘the Act’), by the National Faceless Appeal Centre, Delhi (NFAC) for the assessment year 2018-19. The following grounds are reproduced below:

“(i) "Whether on the facts and in the circumstances of the case and in law, the Ld.CIT(A) was right in law in deleting the addition of Rs.80,91,958/-, without appreciating the factual aspect and by ignoring the manifest evidence relied upon by the Assessing Officer during the assess