MANPREET ESTATES LLP,MUMBAI vs. ACIT, CENTRAL CIRCLE 8(3), MUMBAI

ITA 4386/MUM/2026Status: DisposedITAT Mumbai11 September 2026AY 2020-218 pages
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What were the facts?

The assessee's appeal concerns additions made by the AO for AY 2020-21. Crucially, a corporate insolvency resolution process (CIRP) was initiated against the assessee, and a resolution plan was approved by the NCLT. The Income Tax Department did not file any claim during the CIRP.

What did the Tribunal hold?

The Tribunal held that since the Income Tax Department did not file any claim during the CIRP, and the resolution plan was approved by the NCLT, the reassessment proceedings and consequential demand are extinguished and non-operational as per Supreme Court and High Court judgments.

What were the issues?

Whether reassessment proceedings initiated after the approval of a resolution plan under the IBC are valid when no claim was filed by the tax department during the CIRP.

Which sections of the Income-tax Act were involved?

Section 68,Section 115BBE,Section 148A,Section 148,Section 14,Section 238,Section 31,Section 143(3),Section 147

AI-generated summary — verify with the full judgment below

Income Tax Appellate Tribunal, MUMBAI

Before: SHRI CHALLA NAGENDRA PRASAD & SHRI PRABHASH SHANKAR

Pronounced: 11/09/2026

PER SHRI CHALLA NAGENDRA PRASAD, JUDICIAL MEMBER:

This appeal is filed by the assessee against the order of the learned Commissioner of Income Tax (Appeals)-50, Mumbai, dated 28.02.2026 for the assessment year 2021-22. 2. The Assessee has raised the following grounds of appeal:

ITA 4386/MUM/2026

1) 2. (b) The CIT(A) erred in confirming the addition made by the AO of Rs. 4,50,00,0

The order continues below.

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