ACIT CC 2(4) MUMBAI, MUMBAI vs. GIRAFFE DEVELOPERS PVT LTD, MUMBAI

ITA 1969/MUM/2026Status: DisposedITAT Mumbai15 July 2026AY 2014-157 pages
AI SummaryDismissed

What were the facts?

The Revenue appealed against an assessment order that was passed pursuant to a revisional order under Section 263. The assessee argued that the Section 263 order had been quashed by a coordinate bench of the Tribunal, rendering the assessment order invalid.

What did the Tribunal hold?

The Tribunal held that since the foundational revisional order under Section 263 was annulled, the consequential assessment order could not survive. Furthermore, a coordinate bench had already decided that the interest income was assessable as business income.

What were the issues?

Whether an assessment order based on a quashed revisional order is valid, and whether interest income has a direct nexus with business activities.

Which sections of the Income-tax Act were involved?

Section 263,Section 143(3),Section 271AA,Section 271BA,Section 271(1)(c),Section 92E

AI-generated summary — verify with the full judgment below

Income Tax Appellate Tribunal, MUMBAI BENCH “G” MUMBAI

Before: SHRI OM PRAKASH KANT & SHRI PAWAN SINGH

For Appellant: Shri Fenil Bhatt, Adv
For Respondent: Shri Basavaraj Hiremath – CIT DR a/w Shri Rajgopal Parthasarathi –, DR. : 13/07/2026
Hearing: 15/07/2026

PER OM PRAKASH KANT, AM:

This appeal has been preferred by the Revenue against the order dated 12.12.2025, passed by the learned Commissioner of Income-Tax (Appeals) – 49, Mumbai [in short, ‘the Ld. CIT(A)’], for Assessment Year (in short ‘A.Y’), 2014-15, raising following grounds:-

Giraffe Developers Private Limited 2 “1. On the facts and circumstances of the case and in law the assessment order u/s 143(3) r.w.s 263 of the Income Tax Act is bad in law, infractious, void ab- initio and needs to be struck down.

2.

On the facts and ci

The order continues below.

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