INCOME TAX OFFICER, WARD-41(3)(1), MUMBAI, MUMBAI vs. AJIT H LOLADIYA HUF, MUMBAI

ITA 987/MUM/2026Status: DisposedITAT Mumbai10 July 2026AY 2012-138 pages
AI SummaryDismissed

What were the facts?

The Revenue appealed against the deletion of an addition made on account of alleged client code modification in commodity trading. The Assessing Officer treated a benefit of Rs. 9,96,000/- as unexplained money under Section 69A based on information from the Investigation Wing.

What did the Tribunal hold?

The Tribunal upheld the deletion, finding that the Assessing Officer relied on generalized information without specific evidence linking the assessee to client code modification. The Tribunal also noted the possibility of double taxation and the incorrect invocation of Section 69A.

What were the issues?

Whether the addition made on account of alleged client code modification was substantiated by evidence, and if Section 69A was correctly applied to alleged trading profits.

Which sections of the Income-tax Act were involved?

Section 69A,Section 147,Section 144,Section 43(5)

AI-generated summary — verify with the full judgment below

Income Tax Appellate Tribunal, MUMBAI BENCH “J” (SMC

Before: SHRI OM PRAKASH KANT & SHRI ANIKESH BANERJEE

For Appellant: Ms. Dharan Gandhi, Adv, Ms. Jayshree Thakur (Sr. DR)
Hearing: 10/07/2026

PER OM PRAKASH KANT, AM

This appeal filed by the Revenue is directed against the order dated 27.11.2025 passed by the Ld. Additional Commissioner of Income-tax (Appeals), -2 Chennai [ in short the Ld. CIT(A)] for Assessment Year [In short the AY], 2012–13, raising following grounds;-

Ajit H. Loladiya 2 i. Whether on the facts and in the circumstances of the case and in law, the Ld. Addl. CIT(A) has erred in deleting the addition made by the Assessing Officer on account of income arising from client code modification in National Multi Commodities Exchange (NMCE), without proper

The order continues below.

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