JAYSHREE CHANDRASINGH KABALI,MUMBAI vs. DCIT CIRCLE 27 (1), MUMBAI

ITA 7226/MUM/2025Status: DisposedITAT Mumbai21 November 2025AY 2017-18Bench: SHRI SAKTIJIT DEY, HON'BLE (Vice President), SHRI GIRISH AGRAWAL (Accountant Member)1 pages
AI SummaryRemanded

What did the Tribunal hold?

The Tribunal held that the CIT(A)'s dismissal of the appeals in limine was invalid, especially since notices for hearing were issued. The Tribunal condoned the delay in filing the appeals and remanded the matter back to the AO for denovo adjudication on merits.

What were the facts?

The assessee's case was reopened under Section 147 due to undisclosed fixed deposits totaling Rs. 7 crores. The Assessing Officer (AO) made a best judgment assessment treating the amount as unexplained investment. The assessee's appeals against the reassessment and penalty orders were dismissed by the CIT(A) as barred by limitation.

What were the issues?

Whether the CIT(A) was justified in dismissing the appeals as barred by limitation without adjudicating on merits, and whether the delay in filing the appeals should be condoned.

Which sections of the Income-tax Act were involved?

Section 147,Section 144,Section 271AAC(1),Section 249(3),Section 5

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Income Tax Appellate Tribunal, “F” BENCH

Before: SHRI SAKTIJIT DEY, HONBLE & SHRI GIRISH AGRAWAL

Hearing: 14.11.2025Pronounced: 21.11.2025

PER GIRISH AGRAWAL, ACCOUNTANT MEMBER:

These two appeals filed by the assessee are against the orders of CIT(A), National Faceless Appeal Centre (NFAC), Delhi vide order nos. ITBA/NFCA/S/250/2025-26/1080151012(1) and ITBA/NFCA/S/250/2025-26/1080177826(1) dated 29.08.2025 passed against the assessment and penalty orders by National Faceless Assessment Centre, Delhi, u/s. 147 r.w.s. 144 r.w.s. 144B and 271AAC(1) of the Income-tax Act, 1961 (hereinafter referred to AY 2017-18

as the “Act”), dated 23.09.2021 and dated 10.02.2022 for AY 2017-

18.2.

Before us, assessee has moved the stay applica

The order continues below.

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