DCIT(CC)-8(3), MUMBAI vs. 63 MOONS TECHNOLOGIES LIMITED, MUMBAI

ITA 2111/MUM/2025Status: DisposedITAT Mumbai22 September 2025AY 2012-13Bench: SHRI SANDEEP GOSAIN (Judicial Member), SHRI GIRISH AGRAWAL (Accountant Member)1 pages
AI SummaryDismissed

What did the Tribunal hold?

The Tribunal upheld the CIT(A)'s decision, finding that the reassessment proceedings were invalid as they were initiated beyond four years and based on a mere change of opinion. The exemptions under Section 10A/10AA were also rightly allowed by the CIT(A) as the assessee had provided sufficient documentary evidence.

What were the facts?

The Revenue appealed against the CIT(A)'s orders which quashed reassessment proceedings and allowed exemptions under Section 10A/10AA. The reassessment was initiated beyond four years, and the CIT(A) found it was based on a change of opinion without sufficient tangible material.

What were the issues?

Whether reassessment proceedings initiated beyond four years were valid, and whether the denial of exemptions under Section 10A/10AA was justified.

Which sections of the Income-tax Act were involved?

Section 147,Section 143(3),Section 10A,Section 10AA,Section 35(1)(ii)

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Cases cited in this judgment(4)Show list

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Income Tax Appellate Tribunal, “D” BENCH MUMBAI

Before: SHRI SANDEEP GOSAIN & SHRI GIRISH AGRAWAL

Hearing: 21.07.2025Pronounced: 22.09.2025

PER GIRISH AGRAWAL, ACCOUNTANT MEMBER:

These three appeals filed by Revenue are against the orders of ld. CIT(A)- 50, Mumbai, vide

i. Order no. ITBA/APL/S/250/2024-25/1072723393(1), dated 30.01.2025 passed against the assessment order by DCIT CC- 8(3), Mumbai, u/s. 143(3) r.w.s 147 of the Income-tax Act, 1961 (hereinafter referred to as the “Act”), dated 18.12.2018 for Assessment Year 2011-12. ii. Order no. ITBA/APL/S/250/2024-25/1072723823(1), dated 30.01.2025 passed against the assessment order by DCIT CC- 63 Moons Technologies Ltd. AY 2011-12, 2012-13 and 2013-14 8(3), Mumbai, u/s. 143(3) r.w.s 147

The order continues below.

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