BHARTI MUKESH CHANDARANA ,MUMBAI vs. INCOME TAX OFFICER (INT. TAX) WARD 2(1)(1), MUMBAI

ITA 4972/MUM/2025Status: DisposedITAT Mumbai13 November 2025AY 2017-18Bench: SHRI PAWAN SINGH (Judicial Member), SHRI GIRISH AGRAWAL (Accountant Member)1 pages
AI SummaryAllowed

What did the Tribunal hold?

The Tribunal held that the addition of ₹2.50 crore was not justified as the promissory note lacked corroborative evidence, the assessee's signature, and was not found in her possession. The AO failed to bring on record any direct or corroborative evidence to support the alleged loan transaction.

What were the facts?

The Assessing Officer (AO) initiated reassessment proceedings based on a promissory note found during a search action, alleging the assessee had given an unexplained cash loan of ₹2.50 crore. The assessee, a non-resident, denied the transaction, stating she had only lent ₹50.00 lac through banking channels and was not in India on the date of the promissory note.

What were the issues?

Whether the addition of ₹2.50 crore under Section 69A is sustainable based solely on a promissory note found from a third party without corroborative evidence, and whether the reassessment proceedings were validly initiated and completed within the prescribed time limits.

Which sections of the Income-tax Act were involved?

Section 148,Section 151,Section 147,Section 144C,Section 69A,Section 132(4),Section 292C,Section 153

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IN THE INCOME TAX APPELLATE TRIBUNAL “I” BENCH, MUMBAI BEFORE SHRI PAWAN SINGH, JUDICIAL MEMBER & SHRI GIRISH AGRAWAL, ACCOUNTANT MEMBER (Physical hearing) Bharti Mukesh Chandarana, Income Tax Officer Ward No. 64, Balasinor Society, S.V. Road, Vs 2(1)(1) Mumbai, Room No. 618, 6th Floor, Kautilya Kandivali (West), Mumbai-400067, Maharashtra Bhawan, C-41 to C-43, G Block, [PAN No. AACPC 4520F] Int Tax Ward, Bandra Kurla Complex, Bandra (East), Mumbai. Appellant / Assessee Respondent / Revenue

Assessee by Shri K. Gopal & Neha Paranjpe Advocates Revenue by Shri Krishna Kumar, Sr. DR Date of institution of appeal 08.08.2025 Date of hearing 15.10.2025 Date of pronouncement 13.11.2025

Order under section 254(1) of Income Tax Act

PER PAWAN SINGH, JUDICIAL MEMBER;

1.

This second appeal under section 253 of Income Tax Act (Act) is filed

by assessee against the final assessment order passed by assessing

officer under section 143(3)/147 read with section 144C(13), passed

in pursuance of direction of Dispute Resolution Panel (DRP) Mumbai-1,

dated 24th June 2025, for assessment year (AY)2017-18. The assessee

has raised following grounds of appeal;

A. Reopening is bad in law:

(1) The

The order continues below.

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