RAVI DILIP WAGHELA,MUMBAI vs. INCOME TAX OFFICER WARD, 23(3)(1), MUMBAI

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ITA 1799/MUM/2025Status: DisposedITAT Mumbai21 September 2026AY 2012-1316 pages
AI SummaryAllowed

What did the Tribunal hold?

The Tribunal held that the notice under section 148 was not validly served as it was sent to incorrect addresses and affixed at a locked room without establishing the assessee's connection. Consequently, the Assessing Officer lacked jurisdiction to proceed with the reassessment.

What were the facts?

The assessee challenged additions made under sections 69C and 68 during reassessment proceedings. The primary contention was that the notice initiating reassessment under section 148 was never validly served upon him.

What were the issues?

Whether the reassessment proceedings were validly initiated due to proper service of the notice under section 148. Whether the assessee's objection to non-service of notice was raised before the completion of assessment.

Which sections of the Income-tax Act were involved?

Section 147,Section 148,Section 69C,Section 68,Section 292BB,Section 144

AI-generated summary — verify with the full judgment below

Before: SHRI AMIT SHUKLA & SHRI ARUN KHODPIA

For Appellant: Shri Prakash Jotwani
Hearing: 11.09.2026Pronounced: 21.09.2026

आदेश की प्रतितलतप अग्रेतिि/Copy of the Order forwarded to : 1. अपीलार्थी / The Appellant प्रत्यर्थी / The Respondent. 2. 3. आयकर आय क्त / CIT 4. दिभागीय प्रदिदनदि, आयकर अपीलीय अदिकरण DR, ITAT, Mumbai 5. गार्ड फाईल / Guard file.

सत्यादपि प्रदि //True Copy// आदेशानुसार/ BY ORDER,

उप/सहायक पंजीकार (Dy./Asstt. Registrar) आयकर अपीलीय अतिकरण/ ITAT, Bench, Mumbai.

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