KAVEETA SATRAMDAS MANDHWANI,ULHASNAGAR KALYAN vs. INCOME TAX ASSESSING OFFICER 3(2), KALYAN THANE ULHASNAGAR

ITA 8165/MUM/2025Status: DisposedITAT Mumbai20 July 2026AY 2019-2010 pages
AI SummaryRemanded

What were the facts?

The assessee, Kaveeta Satramdas Mandhwani, passed away before the assessment order was passed. The appeal was filed by her legal heir, Mahendra Satramdas Mandhwani, with a delay of 41 days. The CIT(A) dismissed the appeal in limine due to the delay and the fact that it was filed in the name of a deceased person.

What did the Tribunal hold?

The Tribunal condoned the delay of 41 days in filing the appeal before the CIT(A), emphasizing that substantial justice should prevail over technical lapses. The Tribunal also noted that the entire proceedings were undertaken in the name of the deceased person, which is an illegality.

What were the issues?

The primary issues were the validity of reassessment proceedings initiated and conducted in the name of a deceased person, and the condonation of delay in filing the appeal before the CIT(A).

Which sections of the Income-tax Act were involved?

Section 147,Section 148,Section 151A,Section 44AD,Section 40(a)(3)

AI-generated summary — verify with the full judgment below

Income Tax Appellate Tribunal, “E” BENCH MUMBAI

Before: SHRI SANDEEP GOSAIN & SHRI GIRISH AGRAWAL

Hearing: 21.04.2026Pronounced: 20.07.2026

PER GIRISH AGRAWAL, ACCOUNTANT MEMBER:

This appeal filed by the assessee is against the order of ld. CIT (A), National Faceless Appeal Centre (NFAC), vide order No. ITBA/NFAC/S/250/2025-26/1081307487(1), dated 29.09.2025, passed against the assessment order by ITO, Ward 3(2), Kalyan, u/s. 147 r.w.s 144 of the Income-tax Act (hereinafter referred to as the “Act”), dated 12.03.2025, for Assessment Year 2019-20..

2.

Grounds taken by the assessee are reproduced as under:

2 Mahendra Satramdas Mandhwani (Legal heir of Late Kaveeta Satramdas Mandhwani) AY 2019-20

GROUND NO 1 – Notice u/s 148 issued without proper juri ictio

The order continues below.

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