Loading...

⚠ ✕
❮ Top
☎ Help
☰
×

By creating an account you can:

Logo TaxTMI
Call Us / Help / Feedback✕

Contact Us At :

✉ E-mail: [email protected]

✆ Call / WhatsApp at: +91 99117 96707

For more information, Check Contact Us

FAQs :

To know Frequently Asked Questions, Check FAQs

Most Asked Video Tutorials :

For more tutorials, Check Video Tutorials

Submit Feedback/Suggestion :

Email :
Please provide your email address so we can follow up on your feedback.
Category :
Description :
Min 15 characters 0/2000
Make Most of Text Search ✕
  1. Checkout this video tutorial: How to search effectively on TaxTMI.
  2. Put words in double quotes for exact word search, eg: "income tax"
  3. Avoid noise words such as : 'and, of, the, a'
  4. Sort by Relevance to get the most relevant document.
  5. Press Enter to add multiple terms/multiple phrases, and then click on Search to Search.
  6. Text Search
  7. The system will try to fetch results that contains ALL your words.
  8. Once you add keywords, you'll see a new 'Search In' filter that makes your results even more precise.
  9. Text Search
╳
Add to...
You have not created any category. Kindly create one to bookmark this item!
✕
Create New Category
Hide
Title :
Description :
❮❮ Hide
❮ Default View
Expand ❯❯
Close ✕
🔎 Filters / Advanced Search ❯
TEXT

Press 'Enter' to add multiple search terms. Rules for Better Search

Search In
Main Text + AI Text ❯
  • Main Text
  • Main Text + AI Text
  • AI Text
Law:
---- All Laws---- ❯
  • ---- All Laws----
  • Benami Property
  • Bill
  • Central Excise
  • Companies Law
  • Customs
  • DGFT
  • FEMA
  • GST
  • GST - States
  • IBC
  • Income Tax
  • Indian Laws
  • Money Laundering
  • SEBI
  • SEZ
  • Service Tax
  • VAT / Sales Tax
Types:
---- All Types ---- ❯
  • ---- All Types ----
  • Act Rules
  • Case Laws
  • Circulars
  • Manuals
  • News
  • Notifications
Sort By: ?
In Sort By 'Default', exact matches for text search are shown at the top, followed by the remaining results in their regular order.
Relevance Default Date
    Manuals Income Tax
    What is the basic monetary limit required for PANCARD for amount deposit in mutual fund and shares?
    Manuals Income Tax
    What is the basic limit for PANCARD for payment to foreign country?
    Manuals Income Tax
    Whether PANCARD is require for opening account in bank?
    Manuals Income Tax
    What is the limit of PANCARD for amount depositing in securities.?
    Manuals Income Tax
    Is PANCARD is required for time deposit exceed a time of ₹ 5 lakhs?
    Manuals Income Tax
    What is the Basic limit of PANCARD for sale purchase of immovable property?
    Manuals Income Tax
    Is Permission is Required For Filing Of Revised Return?
    Manuals Income Tax
    How Much Time Revised Return Can Be Revised?
    Manuals Income Tax
    Can Revised Return Substitute Original Return?
    Manuals Income Tax
    Is It Possible To File Auditor Report With Revised Return?
    Manuals Income Tax
    Whether Assessment Made Under Section 143(1) Would Be Considered as Assessment For Revised Return?
    Manuals Income Tax
    X Ltd., closely held company issues 1,000 shares to Mr. A (resident) whose face value is 10, issue p...
    Manuals Income Tax
    X Ltd., closely held company receives shares of A Ltd. (a listed public company) for 10,000 whose fa...
    Manuals Income Tax
    Example: 3) X gets by way of gift a plot of land in Pune from a partnership firm. The partnership fi...
    Manuals Income Tax
    Example: 2) X gets a gift of 43,000 from C, who is cousin of his father and he also gets a gift of 2...
    Manuals Income Tax
    Example: 1) X purchases a house property situated in Nagpur from A on 31st March, 2013. The purchase...
    Manuals Income Tax
    Example:- Loan Taken on 01-05-2006 of ₹ 5,00,000. Construction ends on 07-09-2012. Rate of int...
    Manuals Income Tax
    Example: 4) The details of House property are as follows: Municipal value: 80,000, Fair rent: 78,00...
    Manuals Income Tax
    Example: 3) The details of House property are as follows: Municipal value: 60,000, Fair rent: 65,00...
    Manuals Income Tax
    Example: 2) The details of House property are as follows: Municipal value: 60,000, Fair rent: 68,00...
❮
❯
❯❯
Maximize Maximize Maximize
0 / 200
Expand Note
Add to Folder

No Folders have been created

+

Are you sure you want to delete "My most important" ?

NOTE:

Notes
Showing Results for :
Reset Filters
Results Found:
Show All Summaries Hide All Summaries
Manuals Income Tax
Show AI Summary
PAN requirement for mutual fund and share deposits triggers mandatory identification and reporting when payments reach the statutory threshold.
Quoting a Permanent Account Number (PAN) is mandatory for deposits into mutual funds and for share purchases when the payment amount is fifty thousand rupees or more, under the PAN provisions and implementing rules governing income-return and reporting obligations.
Manuals Income Tax
Show AI Summary
PAN requirement for foreign travel payments: cash disbursements above prescribed limit require PAN for travel, tour, or currency purchases.
A PAN must be furnished where a single-instance cash payment connected with travel to a foreign country exceeds the prescribed cash threshold; this covers cash payments for fare, payments to travel agents or tour operators, payments to authorized persons under foreign exchange law, and purchases of foreign currency, while excluding travel to neighbouring countries and specified pilgrimage locations.
Manuals Income Tax
Show AI Summary
Permanent Account Number requirement: PAN is mandatory for opening bank accounts under income tax rules with no monetary threshold.
Permanent Account Number (PAN) is mandatory for opening a bank account under the income tax statutory framework and implementing rules; the requirement applies generally and the source does not specify any monetary threshold limiting the obligation, reflecting PAN's function as an identification and compliance mechanism in return of income and assessment procedure contexts.
Manuals Income Tax
Show AI Summary
PAN requirement for securities transactions mandates furnishing PAN for deposits exceeding prescribed threshold to enable identity verification.
A PAN furnishing requirement applies to sale and purchase of securities: where consideration in a securities transaction exceeds the statutory high-value threshold, the person transacting must furnish their Permanent Account Number to the counterparty, implementing identity verification and enabling tax reporting obligations under the income-tax rules.
Manuals Income Tax
Show AI Summary
PAN requirement for time deposits: PAN must be furnished when a time deposit exceeds the prescribed regulatory threshold.
A PAN must be furnished when a depositor makes a time deposit with a bank, banking company, or banking institution that exceeds the prescribed monetary threshold; this imposes an identification and reporting obligation under the income tax PAN provisions and rules.
Manuals Income Tax
Show AI Summary
PAN requirement for immovable property transactions: PAN must be furnished where property value meets the statutory threshold.
A Permanent Account Number (PAN) must be furnished for sale or purchase of immovable property when the transaction reaches the statutory value threshold, as part of PAN-related obligations in return of income and assessment procedure; this requirement applies to parties to the transaction to ensure tax documentation and compliance.
Manuals Income Tax
Show AI Summary
Right to file revised return: no prior permission required and permission-application cannot substitute for revision.
No prior permission is required to file a revised return; the assessee has a right to submit a revised return. An application framed as seeking permission to revise the originally filed return cannot be treated as, or substitute for, a valid revised return, and therefore does not meet the statutory mechanism for revision.
Manuals Income Tax
Show AI Summary
Revised return can be filed multiple times within the limitation period when omissions or errors are discovered in the original filing.
An assessee may file a revised return multiple times so long as each revision is within the applicable limitation period and corrects an omission or wrong statement discovered in the earlier return, permitting successive amendments prior to expiry of the statutory time bar.
Manuals Income Tax
Show AI Summary
Revised return substitutes the original return, while mere corrections leave the original filing intact for assessment.
A validly filed revised return withdraws and substitutes the original return for assessment purposes; corrections or amendments made to a filed return without filing a revised return do not change the filing's character and therefore do not effect such substitution.
Manuals Income Tax
Show AI Summary
Auditor's report: may be filed with a revised return to rectify omission from the original tax return.
Where an assessee obliged to furnish an auditor's report with its income tax return fails to submit it with the original filing, the auditor's report may be furnished subsequently with the revised return, permitting rectification of that omission under the return amendment regime.
Manuals Income Tax
Show AI Summary
Assessment under section 143(1) not an assessment; revised return filed after intimation remains valid for consideration.
An intimation issued under section 143(1) is procedural and does not constitute a formal assessment; therefore a revised return filed after such an intimation but within the statutory period must be treated as duly filed and considered by the Assessing Officer.
Manuals Income Tax
Show AI Summary
Share premium taxation under Section 56(2)(viib): excess consideration over fair market value is taxable on closely held companies.
Taxability of share premium for a closely held company turns on whether consideration per share exceeds fair market value; if FMV exceeds consideration (FMV 42, consideration 40) no tax arises, whereas if consideration exceeds FMV (consideration 40, FMV 31) the excess per share (9) is taxable under the provision governing share premium receipts.
Manuals Income Tax
Show AI Summary
Taxability of discounted transfers to closely held companies: listed company shares are excluded from gift inclusion, so not taxable.
Receipt of listed public company shares by a closely held company for consideration below fair market value does not attract tax under the provision addressing gifts to firms and closely held companies, because shares of a listed company are excluded from that inclusion and therefore are not characterized as taxable income from other sources under that rule.
Manuals Income Tax
Show AI Summary
Taxability of gifts: transfers from a partnership firm to an individual are taxable when the firm is not a relative.
A gift of immovable property from a partnership firm to an individual is taxable under the gift provisions because a partnership firm is not a "relative" even if the partners are relatives; the stamp duty valuation of the plot is noted for valuation reference.
Manuals Income Tax
Show AI Summary
Taxability of gifts: gifts received from non-relatives are taxable under the gifts provision, not excluded as relative transfers.
Gifts received by an individual or HUF from persons who do not qualify as "relatives" are taxable as income from other sources; in the example, gifts from a father's cousin and from the recipient's grandfather's elder brother are excluded from the relative exemption and the aggregate amount received from those non-relatives is taxable.
Manuals Income Tax
Show AI Summary
Gift taxation: stamp duty valuation excess over purchase price becomes taxable from the amendment's effective date under income rules.
The amendment taxes, as Income from Other Sources, the difference between stamp duty value and actual purchase price where consideration is below stamp duty valuation, applying only from the amendment's effective date; transactions concluded prior to that date are not subject to this valuation-based charge.
Manuals Income Tax
Show AI Summary
Pre-construction interest deduction allows spreading pre-acquisition interest across subsequent assessment years, with current-year interest treated separately.
Pre-construction interest under Sec. 24 is computed for the period from loan drawal to the day before completion; the total pre-construction interest (here computed as principal x months x rate) is capitalised and apportioned equally across the prescribed subsequent assessment years as the annual deduction. Interest accruing in the fiscal year of completion is allowed in that year and amounts accruing between the fiscal year start and actual completion date are excluded from the pre-construction spread.
Manuals Income Tax
Show AI Summary
Gross Annual Value calculation: vacancy adjustment reduces taxable house property value under applicable law provision.
Annual Lettable Value is the higher of Municipal Value or Fair Rent but capped by Standard Rent, fixed here at 80,000. Annual receipts excluding unrealised rent are 54,000. Deducting vacancy loss of 18,000 from the Annual Lettable Value produces a Gross Annual Value of 62,000 as the taxable base for house property income.
Manuals Income Tax
Show AI Summary
Gross Annual Value under Section 23 caps assessed value at standard rent; vacancy adjustment affects the GAV calculation.
Gross Annual Value under Section 23 applies the higher of municipal value or fair rent but not exceeding standard rent (63,000) as the Actual Lettable Value; after excluding unrealised rent and adjusting for vacancy, the Annual Rent Receivable is 42,000, taken as the Gross Annual Value under the cited provision.
Manuals Income Tax
Show AI Summary
Gross Annual Value rule for house property: higher of municipal or fair rent subject to standard rent cap.
Determination of Gross Annual Value requires taking the higher of municipal value or fair rent as the annual lettable value, provided it does not exceed the standard rent; the Gross Annual Value is then the greater of this lettable value and the actual annual rent received excluding unrealised rent.

TMI Notes

Back

All TMI Notes

Showing Results for :
Reset Filters
No Records Found

TMI Notes

Back

All TMI Notes

Renewal of Registration under Section 12AB for Charitable Hospitals Engaged in Medical Relief: Retrospective Cancellation

19 September, 2026

Contents
Acts
Rules & Regulations
Plus +
Summary
Note

Note

-

Bookmark

Print

Print

This is a neutral professional article. The judgment is analysed in the context of its factual background, issues framed, and conclusions reached by the Court.

2026 (7) TMI 783 - ITAT MUMBAI

At a Glance

  • Section 2(15) treats "medical relief" as an independently enumerated charitable purpose. The statutory restriction concerning trade, commerce or business is textually attached to the residual category of advancement of any other object of general public utility.
  • For renewal, Section 12AB(1)(b) permits inquiry into the genuineness of activities and compliance with requirements of other laws only where those requirements are material to achieving the trust's objects.
  • High tariffs, premium accommodation, sophisticated infrastructure, substantial receipts, professional management and financial scale do not, by themselves, displace the charitable character of a hospital engaged in medical relief.
  • The material inquiry is whether the hospital continues to pursue medical relief through genuine activities and whether its income and assets remain devoted to its charitable objects rather than private gain or non-charitable deployment.
  • Where alleged breach of another regulatory law is relied on, the statutory safeguards concerning a "specified violation", including the requirement of an order, direction or decree under the other law in the circumstances covered by Explanation (f) to section 12AB(4), assume central importance.
  • Retrospective cancellation in a renewal proceeding requires a distinct and sustainable statutory foundation. A rejection of renewal and cancellation from the inception of registration have materially different consequences.

Background & Context

Renewal of registration under section 12AB is often contentious for hospitals that combine advanced clinical facilities, paid services, concessional treatment and philanthropic funding. The central question is not whether modern healthcare can generate significant receipts or require substantial expenditure. The legal question is whether the institution continues to exist and function for the charitable purpose of medical relief within the statutory framework.

The decision reported as 2026 (7) TMI 783 - ITAT MUMBAI addresses this question in the context of a hospital trust whose renewal application in Form No. 10AB was rejected, whose existing registration was retrospectively cancelled, and whose connected approval was consequentially denied. The Tribunal set aside the rejection and cancellation, holding that premium healthcare features, receipts and operational scale did not establish that the hospital had ceased to pursue medical relief.

The decision is particularly significant because it separates three matters that can overlap factually but must remain distinct in law: charitable character under the Income-tax Act; compliance with regulatory obligations imposed under another enactment; and an authority's view of how an ideal charitable hospital ought to structure access, tariffs or patient outreach. Registration jurisdiction is governed by the first two statutory inquiries; it is not an open-ended review of healthcare policy.

Key Issues / Provisions

Medical relief as a charitable purpose

Section 2(15) provides that "charitable purpose" includes "relief of the poor, education, yoga, medical relief" and specified further categories, including the residual limb of "advancement of any other object of general public utility". The proviso states that advancement of the residual object is not charitable if it involves the prescribed trade, commerce or business activity for consideration, unless the stated statutory conditions are met, including the twenty per cent receipts condition.

The statutory placement matters. Medical relief is expressly listed and is not part of the residual general-public-utility limb. The Tribunal consequently held that the commerciality analysis applicable to the residual limb cannot be mechanically imported merely because a hospital charges patients or has substantial receipts.

Renewal procedure and scope of inquiry

Under Section 12A(1)(ac)(ii), an institution whose registration period is due to expire must apply "at least six months prior to expiry of the said period". The prescribed procedural route is Form No. 10AB. Rule 17A requires a Form No. 10AB applicant to furnish, as applicable, the constitutive instrument, registration records, existing registration order, annual accounts for up to three immediately preceding years, relevant business accounts and audit reports, documents evidencing modification of objects, and a note on activities.

Section 12AB(1)(b)(i) authorises the Commissioner to call for documents, information or make inquiries necessary to satisfy the authority about: "(A) the genuineness of activities of the trust or institution; and (B) the compliance of such requirements of any other law for the time being in force ... as are material for the purpose of achieving its objects." If satisfied about the objects, genuineness and such material-law compliance, registration is granted for five years. If not satisfied in a renewal case covered by section 12A(1)(ac)(ii), the application may be rejected and registration cancelled, but only "after affording a reasonable opportunity of being heard". The order in such a case must be passed within six months from the end of the quarter in which the application was received.

Income, application and business-related questions

Section 11(1)(a) exempts "income derived from property held under trust wholly for charitable or religious purposes" to the extent it is applied to such purposes in India, while allowing accumulation or setting apart up to fifteen per cent of such income. The provision thus proceeds on the basis that a charitable institution may derive income. It regulates application and accumulation; it does not prescribe a cap on receipts, hospital scale or infrastructure.

Where income consists of profits and gains of business, Section 11(4A) requires that the business be incidental to attainment of the objects and that separate books be maintained. The Tribunal held that running a hospital to provide medical relief could not, on the facts before it, be treated as an extraneous business activity merely because medical operations were systematic, professionally managed or revenue-generating.

Specified violations and other-law compliance

Section 12AB(4) provides a separate cancellation framework upon the occurrence of a specified violation. Explanation (f) treats non-compliance with a requirement of another law, referred to in section 12AB(1)(b)(i)(B), as a specified violation where "the order, direction or decree" holding that such non-compliance has occurred has either not been disputed or has attained finality.

This language connects the initial renewal inquiry with the cancellation framework. It limits relevance to requirements that are material for achieving the objects and, in the specified-violation setting, recognises the significance of a determination by the authority competent under the other law.

Detailed Analysis

1. The statutory test is medical relief, genuineness and lawful charitable application

The Tribunal found no dispute that the hospital was operational, medical services were being delivered, the trust's objects were charitable, and the activities were not fictitious. Its reasoning therefore returns the inquiry to its statutory core: whether the actual activities remain genuine and in furtherance of medical relief.

It held that affordability comparisons based on household-income data, room tariffs or treatment costs could not become independent statutory tests. Neither section 2(15) nor section 12AB prescribes an affordability index, a ceiling on fees, a bar on premium rooms, or a restriction against tertiary and super-speciality treatment. An authority cannot convert its assessment of desirable healthcare policy into a condition for registration that Parliament has not enacted.

2. Scale, surplus and premium facilities are not conclusive evidence of commerciality

The decision recognises that sophisticated medical treatment necessarily requires substantial capital investment, specialist personnel, technology, compliance systems and continuing expenditure. Premium accommodation or differential pricing may be commercially rational within a charitable institution, including as a means of supporting broader patient care. What matters is not whether receipts arise, but their destination and application.

The Tribunal noted the absence of findings of diversion of income, private enrichment, profit distribution, abandonment of objects or deployment of assets for non-charitable purposes. It also distinguished gross receipts from net surplus and noted that earmarked donations and designated funds cannot automatically be treated as commercially distributable profit. In this setting, organisational efficiency and financial sustainability are legally neutral unless linked to a failure of statutory charitable conditions.

3. Regulatory compliance cannot be independently recast by a tax authority

Alleged non-compliance with the State-law regime applicable to charitable hospitals formed the other foundation of the rejection. The Tribunal held that the tax authority could not assume the role of the specialised regulator by independently interpreting the scheme, calculating alleged deficiencies and treating those conclusions as an established violation without an adverse order from the competent authority.

The Tribunal also accepted the distinction between reservation or availability of beds for specified categories and actual occupancy by such patients. Unless the governing scheme clearly makes a prescribed occupancy level mandatory, lower utilisation cannot automatically establish breach. Further, an earmarked patient fund functioning across accounting periods must be evaluated cumulatively where the scheme permits adjustment of surplus or shortfall in later months.

The principle is not that regulatory obligations lack relevance. Rather, section 12AB confines the inquiry to legal requirements material to achieving the trust's objects, and the specified-violation architecture does not authorise a parallel adjudication under every law regulating a charitable institution.

4. Renewal and retrospective cancellation must not be conflated

The application originated as a renewal application. The Tribunal held that retrospective cancellation from the original grant date required a stronger and independent foundation. The impugned reasoning rested substantially on later operational data, while there was no finding that registration had originally been procured by fraud, misrepresentation or suppression, or that the hospital's activities were not genuine at the time registration was granted.

On that reasoning, later concerns regarding the manner of functioning could not by themselves retrospectively erase an otherwise valid grant from its inception. The Tribunal accordingly restored registration, allowed renewal for five years and set aside the consequential refusal of approval.

5. Related authorities: statutory discipline in renewal and cancellation proceedings

In 2026 (3) TMI 1124 - BOMBAY HIGH COURT, renewal was held not to depend on an express irrevocability or dissolution clause absent from the statute. The decision reinforces that section 12AB is an objective inquiry into charitable objects, genuine activities and material legal compliance; a procedural form or an extra-statutory condition cannot add a threshold not enacted by law.

2025 (4) TMI 592 - ITAT MUMBAI similarly held that the verification under section 12AB must be restricted to compliance with laws "material for the purpose of achieving" the institution's objects. A possibility of application outside India was not itself a basis for denying registration. This supports the narrower construction of the other-law inquiry adopted in the hospital-renewal decision.

In 2014 (10) TMI 581 - PUNJAB & HARYANA HIGH COURT, renewal of approval was sustained where medical education and medical care were factually available without discrimination. The authority illustrates the evidentiary value of demonstrating actual medical services, concessional care and non-discriminatory operation when charitable medical character is questioned.

2025 (5) TMI 1303 - ITAT DELHI separately addressed cancellation and held that the specified-violation framework could not be used retrospectively for years preceding its operative statutory date. It also held, on its facts, that the predominance of beneficiaries from a particular community did not negate public charitable objects or genuineness where demographic conditions explained the beneficiary profile.

In 2025 (6) TMI 1615 - ITAT DELHI, cancellation founded on alleged specified violations pertaining to earlier periods was set aside. The decision underscores the need for proper jurisdiction, a valid statutory foundation and adherence to the applicable cancellation mechanism rather than retrospective application of a later framework.

Finally, 2024 (10) TMI 712 - GUJARAT HIGH COURT distinguishes registration from the later determination of exemption. It held that the objection under section 13(1)(b) was to be considered at the exemption stage rather than used as a standalone basis for refusing registration. Although the context differs, the decision is consistent with the requirement that registration cannot be denied by prematurely importing tests belonging to another stage of the statutory scheme.

Practical Implications

Hospitals seeking renewal should prepare the Form No. 10AB record around the statutory tests, not merely around financial magnitude. The activity note should map each clinical, research, outreach and patient-support activity to the objects clause and to "medical relief" under section 2(15). Annual accounts, fund schedules and management explanations should distinguish operational receipts, corpus or earmarked donations, designated patient-support funds, capital expenditure and actual application towards healthcare objects.

Where a hospital has varied accommodation categories, the renewal record should explain the operational rationale without suggesting that differential tariff alone determines charity. Patient-treatment data should be maintained in a manner that shows actual services, concessions, free treatment, outreach and the treatment of reserved-category patients. If a separate patient-support scheme operates on a rolling basis, opening balances, additions, utilisation and carry-forward adjustments should be presented cumulatively as well as year-wise.

For other-law compliance, a trust should identify laws that are genuinely material to its ability to lawfully carry out medical relief, preserve licences and regulatory filings, and maintain records of inspections, reports and correspondence. If an adverse order is made by a competent regulator, the trust must assess its effect under section 12AB immediately. Conversely, where a tax authority alleges regulatory breach without an order from the competent regulator, the response should distinguish the regulatory issue from the statutory conditions for registration.

Procedural objections should be addressed expressly. If cancellation, especially retrospective cancellation, is proposed during renewal proceedings, the institution should require a specific notice identifying the statutory source, precise allegations, period proposed, supporting material and the intended effective date. A full response should separately deal with renewal, cancellation, natural justice, genuineness, application of income and material-law compliance.

Key Takeaways

  • Medical relief is expressly charitable under section 2(15); it is not to be assessed through an unstated affordability or scale-based standard.
  • Revenue generation, premium facilities and advanced medical infrastructure do not by themselves establish a profit motive or destroy charitable status.
  • The decisive inquiry remains whether activities are genuine, undertaken in furtherance of medical relief, and supported by application of resources towards charitable objects without private diversion.
  • Section 12AB permits inquiry into other laws only where their requirements are material to achieving the objects; the tax authority does not become a substitute regulator under specialised enactments.
  • Renewal rejection and retrospective cancellation are distinct actions. The latter requires a clearly sustainable statutory and factual foundation.
  • For charitable hospitals, a carefully documented record of objects, patient services, funds, regulatory compliance and hearing submissions is essential to keep the renewal inquiry anchored to the statutory framework.

 


Full Text:

2026 (7) TMI 783 - ITAT MUMBAI

Topics

Acts Income Tax