MANSI GEMS PRIVATE LIMITED,SURAT vs. ITO WARD 1(1)(3), SURAT

ITA 1068/SRT/2025Status: DisposedITAT Surat17 August 2026AY 2015-168 pages
AI SummaryAllowed

What did the Tribunal hold?

The Tribunal held that the reassessment proceedings were barred by limitation and without jurisdiction, following the Supreme Court's decision in Union of India v. Rajeev Bansal. Consequently, the reassessment order was quashed.

What were the facts?

The assessee's case for AY 2015-16 was reopened under Section 147 based on information about an alleged accommodation entry of Rs. 3,62,12,000/-. Notices for reopening were issued after April 1, 2021, which the assessee challenged as time-barred.

What were the issues?

The primary issue was the validity of reassessment notices issued after April 1, 2021, for Assessment Year 2015-16, considering the provisions of the Taxation and Other Laws (Relaxation and Amendment of Certain Provisions) Act, 2020.

Which sections of the Income-tax Act were involved?

Section 147,Section 148,Section 68

AI-generated summary — verify with the full judgment below

Income Tax Appellate Tribunal, SURAT BENCH, SURAT

For Respondent: Shri Ravi Kant Gupta, CIT(DR)

Per B.M. Biyani, AM:

Feeling aggrieved by order of first appeal dated 14.08.2025 passed by learned Commissioner of Income-Tax (Appeals)-National Faceless Appeal Centre, Delhi [“CIT(A)”], which in turn arises out of assessment-order dated 18.05.2023 passed by learned Assessment Unit of Income-tax Department [“AO”] u/s 147 r.w.s. 144B of Income-tax Act, 1961 [“the Act”] for Assessment- Year [“AY”] 2015-16, the assessee has filed this appeal. Mansi Gems Private Limited

2.

The background facts leading to present appeal are as under:

(i) The assessee-company filed return of income of AY 2015-16 declaring a total income of Rs. 5,79,540/- u/s 139 which was duly

The order continues below.

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