LATE PRADIP BHAJANLAL PARASRAMPURIA (THROUGH LEGAL HEIR ASHA PRADIP PARASRAMPURIA),MUMBAI vs. THE ITO -41(3)(3), MUMBAI, MUMBAI

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ITA 3564/MUM/2026Status: DisposedITAT Mumbai31 August 2026AY 2014-1510 pages

In favour of the Revenue: the assessee's appeal was dismissed. From the AI summary of this appeal.

AI SummaryDismissed

What did the Tribunal hold?

The Tribunal upheld the authorities below, stating that the assessee's failure to disclose income and bank accounts in the original, belatedly filed return, and the subsequent attempt to claim set-offs via a revised computation during assessment, were not permissible under the Act.

What were the facts?

The assessee, engaged in real estate agency and share trading, initially filed a return of income with a lower commission receipt. During scrutiny, undisclosed bank accounts and additional commission income were discovered. The assessee attempted to set off derivative and share trading losses and commission expenses against this income.

What were the issues?

Whether undisclosed commission income can be treated as taxable under Section 115BBE and whether losses and expenses can be set off against such income when the original return was belated and lacked full disclosure.

Which sections of the Income-tax Act were involved?

Section 115BBE,Section 139(1),Section 44AB

AI-generated summary — verify with the full judgment below

Before: SHRI SANDEEP GOSAIN & SHRI PRABHASH SHANKAR

For Appellant: Shri Fenil Bhatt a/w Ms Nidhi Garodia, ARs
For Respondent: Ms. Kanika Naroola, DR
Hearing: 02.07.2026Pronounced: 31.08.2026

आदेश की प्रतितलति अग्रेतिि/Copy of the Order forwarded to : अपीलार्थी / The Appellant 1.

P a g e | 10 ITA No. 3564/Mum/2026 A.Y. 2014-15 Late Pradip Bhajanlal Parasrampuria-(Through Legal Heir Asha Pradip Parasrampuria) 2. प्रत्यर्थी / The Respondent. 3. आयकर आयुक्त / CIT 4. विभागीय प्रविविवि, आयकर अपीलीय अविकरण DR, ITAT, Mumbai 5. गार्ड फाईल / Guard file. सत्यावपि प्रवि //True Copy// आदेशानुसार/ BY ORDER,

उि/सहायक िंजीकार (Dy./Asstt. Registrar) आयकर अिीलीय अतधकरण/ ITAT, Bench, Mumbai.

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