JURIS MATRIX ADVISORS PRIVATE LIMITED,MUMBAI vs. ITO WARD 12(3)(1), MUMBAI

ITA 1831/MUM/2026Status: DisposedITAT Mumbai11 September 2026AY 2016-1714 pages
AI SummaryAllowed

What were the facts?

The assessee's appeal concerns the assessment year 2016-17, where the primary dispute revolves around the year of sale/transfer of stock-in-trade (a property). The assessee claims the transaction concluded in FY 2013-14, while the revenue authorities, relying on a later registered deed, considered it in FY 2015-16.

What did the Tribunal hold?

The Tribunal decided that the sale/transfer of the property (stock-in-trade) was concluded in FY 2013-14, not FY 2015-16 as held by the lower authorities. This was based on the assessee receiving full consideration, handing over possession, and substantial rights being transferred in FY 2013-14.

What were the issues?

The key issues were determining the correct financial year for the sale/transfer of stock-in-trade and the consequent taxability, as well as the applicability of Section 43CA and the validity of penalty proceedings.

Which sections of the Income-tax Act were involved?

Section 143(3),Section 28,Section 145,Section 43CA,Section 53A,Section 55A,Section 43CA(2),Section 50C(2),Section 271(1)(c)

AI-generated summary — verify with the full judgment below

Income Tax Appellate Tribunal, “F” BENCH, MUMBAI

Before: SHRI PAWAN SINGH, JM & SHRI ARUN KHODPIA, AM

For Appellant: Ms. Saile Gujarathi, CA, Shri Vibhor Badoni, Sr. DR
Hearing: 11.09.2026

Per Arun Khodpia, AM: This appeal is preferred by the assessee, directed against the order of the Commissioner of Income Tax Appeals, National Faceless Appeal Centre (NFAC), Delhi [in short, “the Ld. CIT(A)”], dated 22.12.2025 for the Assessment Year (AY) 2016-17, arises from the assessment order under section 143(3) of the Income Tax Act, 1961 [in short, “the Act”] dated 07.12.2018, passed by Income Tax Officer Ward 12(3)(1), Mumbai [in short, “the Ld. AO”]. Juris Matrix Advisors Private Limited

2.

The grounds of appeal raised by the assessee are as under: “Ground No. 1-Erroneous

The order continues below.

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