KOMAL MALHOTRA,C/O AKUL AGARWAL AND ASSOCIATES vs. ACIT, CENTRAL CIR 13, DELHI, INCOME TAX DEPARTMENT

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ITA 7746/DEL/2025Status: DisposedITAT Delhi08 July 2026AY 2018-1914 pages

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

AI SummaryAllowed

What did the Tribunal hold?

The Tribunal held that the AO did not provide the relied-upon materials nor an opportunity for cross-examination. Considering the assessee as a regular investor and the lack of evidence to prove sham transactions, the addition made by the AO was deleted.

What were the facts?

The assessee claimed a short-term capital loss from mutual fund investments with JM Financial. The Assessing Officer (AO) reopened the assessment, disallowed the loss, and made an addition, holding the transactions as sham. The CIT(A) dismissed the assessee's appeal.

What were the issues?

Whether the reassessment proceedings were valid without providing relied-upon material and cross-examination opportunity, and whether the claimed capital loss was genuine.

Which sections of the Income-tax Act were involved?

Section 147,Section 143(3),Section 148A,Section 10(35),Section 94(7)

AI-generated summary — verify with the full judgment below

Income Tax Appellate Tribunal, DELHI BENCH ‘E’: NEW DELHI

For Appellant: Shri Ankul Aggarwal, FCA
For Respondent: Ms. Ankush Kalra, Sr. DR
Hearing: 22/04/2026Pronounced: 08/07/2026

IN THE INCOME TAX APPELLATE TRIBUNAL DELHI BENCH ‘E’: NEW DELHI

BEFORE SHRI MAHAVIR SINGH, VICE PRESIDENT AND SHRI MANISH AGARWAL, ACCOUNTANT MEMBER ITA No.7746/Del/2025 (ASSESSMENT YEAR 2018-19) Komal Malhotra, ACIT, Plot No. D2/20, Sector-10, Central Circle-13, DLF, Faridabad, Vs. Delhi. Haryana-121006. PAN-ANYPM0732A (Appellant) (Respondent) Assessee by Shri Ankul Aggarwal, FCA. Department by Ms. Ankush Kalra, Sr. DR Date of Hearing 22/04/2026 Date of Pronouncement 08/07/2026 O R D E R PER MANISH AGARWAL, AM: This appeal is filed by the Assessee against the order of Learned Commissioner of Income Tax (Appeals) -26, Delhi [Ld. CIT(A)] dated 17.10.2025 in Appeal No. CIT(A), Delhi-26/10611/2017-18 u/s 250 of the Income Tax Act, 1961 (“the Act” in short) arising out of the assessment order passed u/s 147 r.w.s. 143(3) of the Act dated 17.03.2023 for Assessment Year 2018-19.

2.

Brief facts of the case are that the assessee is an individual and filed her original return of income on 25.07.2018 declaring total income at Rs.1,29,79,100/-. The assessment was completed u/s 153A r.w.s. 143(3) on 25.03.2021 accepting the returned income. Thereafter information was gathered during the course of survey

2 ITA No.7746/Del/2025 Komal Malhotra vs. ACIT carried out u/s 133A of the Act in the case of M/s JM Financial Asset Management Limited (“JM Financial”) on 15.02.2021, that that the company was engaged in the sham transactions of losses in the mutual fund schemes floated by it where the exempt income was distributed as dividend and thereafter, losses were booked by the respective investors on such investments after redemption of the same at the lower price. It was found that assessee has claimed fictitious Short term capital loss STCL) of Rs. 63,91,238/- from the sale of mutual fund of JM Financial and, accordingly, the case of the assessee was reopened u/s 147 of the Act after passing the order u./s 148A(d) of the Act. The AO thereafter, completed the reassessment order and vide order dated 17.03.2023 passed u/s 147 r.w.s 143(3) of the Act has disallowed the STCL of Rs.63,91,238/- holding the same as fictitious loss and further made the addition of Rs. 8,57,675/- as short term capital gain (STCG). Accordingly, the total income of the assessee was assessed at Rs.2,02,28,013/-.

3.

Aggrieved by the said order, the assessee has filed the appeal before the Ld. CIT(A), who vide order dated 17.10.2025 has dismissed the appeal of the assessee. Therefore, the assessee is in appeal before the Tribunal by taking various grounds of appeal wherein the assessee has challenged the reopening of assessment, based on the information found from the possession of third persons during the course of survey without providing copy of relied upon material to the assessee including the statements of employees of JM Financial and further not allowing the opportunity to cross examine such employees to the assessee and further challenged the additions on merits also. Thus, all the grounds of appeal of the assessee are taken together for consideration.

3 ITA No.7746/Del/2025 Komal Malhotra vs. ACIT 4. Before us, the Ld. AR for the assessee submits that the case of the assessee was reopened on the basis of information gathered during the course of survey in the case of M/s JM Financials where it was gathered that the said company was engaged in providing bogus STCL to various investors and assessee was one of those investors who received the dividend on the investments in mutual funds being exempt u/s 10(35) of the Act and thereafter sold the units at a loss. As per Ld. AR it was not the sole transactions of investment made by the assessee and she was regularly making investments in equities and mutual funds and received dividend income from such mutual fund investment. The redemption of the mutual funds was taken without having any direct or indirect nexus with any of the official of M/s JM Financial. The Ld. AR further submits that at no stage of proceedings information / material gathered during the course of survey including the statements of so called officials of M/s JM Financial wherein they have admitted that they were indulged into providing bogus STCL through sham transactions was supplied to the assessee. Ld. AR further submits that the case of the assessee is reopened on the basis of the information as could be observed from the notice issued u/s 148A(b) of the Act however, no material was supplied to the assessee nor any opportunities to cross examine the officials of JM Financial was provided and the entire exercise was done solely on the basis of such alleged information gathered, therefore, the consequent order passed based on such material is bad in law. The ld. AR placed reliance on the judgment of the Hon’ble Supreme Court in the case of M/s Andaman Timber Industries vs. Commissioner of Central Excise, Kolkata reported in [2015] 62 taxmann.com 3 (SC) wherein it is held that the not-providing the opportunity to cross examine the third party whose statements were relied upon for taking adverse view against the assessee constitutes gross violation of principle of nature justice and held the entire proceedings as invalid. Ld. AR submits that in the instant case,

4 ITA No.7746/Del/2025 Komal Malhotra vs. ACIT satisfaction of escapement of income was recorded on the basis of alleged information gathered from M/s JM Financial and since the statements of employees of JM Financials are the witness of the Revenue, therefore, not allowing the opportunity to cross examine them rendered the reassessment proceeding as bad in law.

5.

The Ld. AR further submits that the assessee has made investment in the mutual funds of JM Financial and received dividend which was exempt u/s 10(35) and thereafter, the assessee redeems the mutual funds and suffered STCL which should be treated as a normal investment transactions and therefore, addition made by the AO without brining record any corroborative material, deserves to be deleted. Ld. AR further drew our attention to the assessment order passed in the case of assessee for immediately succeeding assessment year i.e. AY 2019-20 wherein the case of the assessee was reopened on the same issue however, no addition was finally made. The copy of the said order is placed at pages 155 to 156 of paper book. He thus prayed that as a principle of consistency also, the addition made should be deleted. He prayed accordingly.

6.

On the other hand, the Ld. DR vehemently supported the order of the lower authorities and submits that during the course of survey carried in the case of M/s JM Financial it was found that the company has violated the SEBI Act and was indulged in the sham transactions with various investors. The company was found to have manipulated its financial whereby dividend was distributed out of Reserves and thereafter, value of mutual funds was reduced to facilitate the investors to book losses by redemption of their units. Ld. AR submits that in this process JM Financial in connivance with the investors operated in a manner where the investors have made

5 ITA No.7746/Del/2025 Komal Malhotra vs. ACIT investment in its mutual fund scheme where dividend income was manipulated to reduce the value of the units to enable the Investors to book losses by redemption of the said mutual fund at a lower price. He, therefore, prayed that the orders of the lower authorities be sustained.

7.

We have heard the rival submissions and perused the materials available on record. During the year under appeal the assessee has claimed loss of Rs.45,60,767/- from the investments in mutual funds etc. out of which loss of Rs. 63,91,238/- was from the redemption of mutual funds of JM Financial which could be seen from the computation of income placed at Pages 20 to 22 of the PB. Assessee has declared total income of Rs. 42,60,992/- under the head Income from Capital Gains. Besides this, assessee has claimed exempt income in the shape of dividend from mutual funds of Rs. 1,14,35,439/-. The assessee further drew our attention to the statements of investment as on 31.03.2018 as per which the assessee was holding investment of Rs. 8,61,10,000/- in various mutual funds. The assessee claimed that it had acquired units of mutual fund scheme of M/s JM Financials which were approved by SEBI and total sum of Rs. 1.30 Crs. were invested on 23rd March, 2017, part of which were redeemed on 19th March, 2018 for Rs. 66.08 lacs. It was the claim of the assessee that the said loss cannot be disallowed in terms of section 94(7) where the time period of nine months is provided for sale of units from the date of declaration of dividend. It is further observed that AO based on the information gathered during the course of survey carried out at JM Financials that it had violated the SEBI provisions and had declared dividend and later reduced the price of its mutual fund/investment to enable the investors to book losses and assessee was found as one of the beneficiary who had incurred losses of Rs.63,91,238/- which was declared as STCL. Further the assessee had received dividend of Rs.52,82,154/- from JM

6 ITA No.7746/Del/2025 Komal Malhotra vs. ACIT Financial, therefore, the AO by adding the dividend to the sale consideration of Rs.66,08,762/- as worked out the short term capital gain of Rs. 8,57,675/- and accordingly, the short term capital loss of Rs. 63,91,238/- was disallowed and addition of Rs.8,57,875/- on account of short term capital gain was made. It was the claim of the assessee that despite of repeated request no relied upon material was provided based on which it was concluded that assessee has taken the bogus entry of short term capital loss. Further neither the statements of the persons relied upon by the AO were supplied nor any opportunity to cross examine those persons was allowed though such statements were used against the assessee. The Hon’ble Supreme Court in the case of Union of India vs. Rajiv Bansal reported in [2024] 464 ITR 46 (SC) vide para 101 has made following observations: “101. Under Section 148A(b), the assessing officer has to comply with two requirements: (i) issuance of a show cause notice; and (ii) supply of all the relevant information which forms the basis of the show cause notice. The supply of the relevant material and information allows the assessee to (1992) 3 SCC 1 PART F respond to the show cause notice. The deemed notices were effectively incomplete because the other requirement of supplying the relevant material or information to the assesses was not fulfilled. The second requirement could only have been fulfilled by the Revenue by an actual supply of the relevant material or information that formed the basis of the deemed notice.

8.

In the aforesaid order, the Hon’ble Supreme Court has specifically directed the lower authorities to supply all the relevant information and materials so as to allow the assessee to response the show cause notice. This view is further supported by the judgment of Hon’ble Jurisdictional High Court in the case of Sarswati Petrochem Pvt. Ltd. vs. ITO reported in [2024] 470 ITR 47 (Delhi High Court), where in for this issue, the Hon’ble Court observed as follows:- "17. It is against the backdrop of these facts that one must arrive at a conclusion as to whether the AO had triggered the reassessment proceedings in accordance with well-established principles enunciated by the courts.

7 ITA No.7746/Del/2025 Komal Malhotra vs. ACIT 17.1 The first and foremost principle of law, to which the AO must be wedded, is the obligation cast on him to furnish material and information that helped him to form a belief that income, otherwise chargeable to tax, had escaped assessment. Admittedly, the AO had in his possession a letter dated 12.03.2018 addressed to him by ITO (Nahan), which in turn contained the intimation supplied by ADIT (Inv)/Unit-4(2). It appears that the information furnished suggested that cash deposits had been made in the account bearing no. 083005000211 maintained with the ICICI bank by Ram Singh, the proprietor of Para Impex Chem, out of which monies were remitted via RTGS to the two bank accounts of the petitioner/assessee maintained with HDFC Bank. Neither the letter nor the intimation of the ADIT(Inv)/Unit-4(2), New Delhi was furnished to the petitioner/assessee.” ……… “19. We are of the opinion that the AO did not have the tangible material on record that could have persuaded him to form a belief that income, otherwise chargeable to tax, had escaped assessment. The AO did not carry forward the enquiry process once he had received communication from ITO (Nahan). As noticed above, the AO did not furnish either the letter dated 12.03.2018 received from ITO (Nahan) or the relevant intimation received from the ADIT(Inv)/Unit- 4(2) New Delhi, along with the document containing “reason to believe.‟ Had the AO furnished the documents, he would have been able to reach a firmer conclusion that crossed the threshold of suspicion and conjecture.”

9.

The Hon’ble Rajasthan High Court decision in case of Micro Marbles Pvt. Ltd vs ITO 457 ITR 569, was also relied where, Hon’ble High Court held as follows:- “The petitioner in the grounds to the petition has taken a categorical stand that the respondents failed to furnish the information which formed the basis for reopening the assessment. It was not even provided with the statement of Deepak Jain, on which heavy reliance was being placed. There is no averment in the reply of the respondents anywhere that any such information or a copy of the statement was supplied to the petitioner along with the reasons to believe. 28. In view of the above, the reasons to believe, as supplied to the petitioner, on the face of it are incomplete and do not afford the petitioner due and proper opportunity to file objections against such reassessment. The non-supply of the above material is within the teeth of the directions of the Division Bench of the Delhi and Bombay High Courts. 29. The submission of Shri Bissa that reasons to believe cannot be equated with the final conclusion and as long as the Assessing Officer has sufficient material to demonstrate that he had bonafidely formed the opinion that the income chargeable to tax has escaped assessment, the requirement of law stands

8 ITA No.7746/Del/2025 Komal Malhotra vs. ACIT satisfied is of no avail as there are no two opinions on the above aspect. Sufficiency of material is one thing and supply of the same is another, which is mandatory in nature. Therefore, the non-supply of the material referred to in the reasons to believe would be enough to render the proceedings bad, even though the material for forming the opinion may be sufficient. 30. The argument of Shri Bissa is that information furnished by the Deputy Director of Income Tax, Investigation, by itself is sufficient for reopening the proceedings, more particularly when the said information was confirmed from other sources. Again the sufficiency of the information is not in question, nor its confirmation. What is questionable is the effect of its non-supply, to which there is no answer. 31. Thus, in the light of the decisions of the Delhi and the Bombay High Courts, as referred to above, the non-supply of the material, especially the documents of entry in the books of M/s. Sanmatri GemsPvt. Ltd. and the statement of Deepak Jain recorded under Section 132 (4) of the Act, is sufficient to vitiate the proceedings.”

10.

On the issue of not allowing the opportunity to cross examine the witnesses of the revenue, the Hon’ble Supreme Court in the case of Andman Timber (supra) has categorically held that “not allowing the assessee to cross examine the witnesses whose statements were made the basis of the impugned order is serious flow which makes the order a nullity”. In the instant case as could be seen from the assessment order, the AO has relied upon the statements of some of the employees of JM Financials recorded during eth course of survey wherein they stated to have been admitted that the company JM Financial was indulged in providing entries of short term loss to various beneficiaries. Neither these statements were provided to the assessee nor any opportunity of cross examination these persons was allowed to the assessee. Under these circumstances, we are of the view that the AO has violated the principle of natural justice and consequently the assessment order passed is bad in law.

11.

Coming to the merits of the additions, we find that assessee is regular and genuine investor in market rand received dividend from such investment to the tune

9 ITA No.7746/Del/2025 Komal Malhotra vs. ACIT of Rs.1,14,35,439/- out of which Rs. 52,82,154/- was received from M/s JM Financial and the balance amount was received from other mutual funds and all the dividend was claimed as exempt u/s 10(35) of the Act. This clearly shows that the dividend received is a part of strategic investment made by the assessee in the mutual fund and such claim of the assessee was denied and short term capital loss was disallowed. Firstly, on the basis of survey carried out in the case of M/s JM Financial wherein it was found that the said company has manipulated its accounting methodology to distribute profits. Based on such information, the AO concluded that the dividend received by the investors was part of sham transactions. The AO further relied upon the SEBI Circular No. SEBI/IMD/CIR No.18/198647/ 2010 which had clearly instructed that the Unit Premium Reserve shall be treated at par with Unit Capital and cannot be utilized to declare dividends and the mutual fund houses cannot distribute dividends from Unit Premium Reserves. The AO also referred some statements of employees of M/s JM Financials recorded during the course of survey. Before going further, we refer the provisions of section 94(7) which is reproduced as under: “Where (a) any person buys or acquires any securities or unit within a period of three months prior to the record date; (b) such person sells or transfers- (i) such securities within a period of three months after such date; or (ii) such unit within a period of nine months after such date; (c) the dividend or income on such securities or unit received or receivable by such person is exempt, then, the loss, if any, arising to him on account of such purchase and sale of securities or unit, to the extent such loss does not exceed the amount of dividend or income received or receivable on such securities or unit, shall be ignored for the purposes of computing his income chargeable to tax."

12.

As per aforesaid provisions losses incurred on account of dividend declaration could be disallowed when record date falls within the period stipulated in the said

10 ITA No.7746/Del/2025 Komal Malhotra vs. ACIT section. In the instant case, the assesse has hold the mutual funds beyond the period stipulated u/s 94(7) and, therefore, the loss incurred from the redemption of mutual funds cannot be disallowed u/s 94(7) of the Act. Further reliance placed on the SEBI Circular is based on the general remarks and nowhere in the statements recorded or any materials was brought on record to show that the assessee was involved in manipulation done by the M/s JM Financials. There is no whisper that M/s JM Financials provided exempt dividend to the assessee to provide tax benefits. Further there was no live nexus between the JM Financial or as per the statements of the its employees. Under similar circumstances, the Hon’ble Mumbai High Court in the case of Karan Maheshwari vs. ACIT & Ors. W.P. (L) No.37211 of 2022 (Bombay High Court) vide order dated 08.03.2024 had made following observations: “17. In the notice issued under Section 148A(b) of the Act, it is alleged that petitioner was one of the persons who claimed fictitious short term capital loss. There is nothing in the notice to indicate on what basis it is alleged that the short term capital loss claimed was fictitious. Petitioner had, based on public announcement, invested in the mutual fund. The fact that petitioner received tax free dividend fund cannot be held against petitioner. The fact that petitioner had suffered a loss also cannot be held against petitioner. Even assuming that the transaction was pre-planned, there is nothing to impeach the genuineness of the transaction. Petitioner was free to carry on his business which he did within the four corners of law. Mere tax planning without any motive to evade taxes through colourable devices is not frowned upon even by the judgment of the Apex Court in McDowell & Co. Ltd. V/s. Commercial Tax Officer. Paragraphs 18 and 20 of the judgment of the Apex Court in Commissioner of Income Tax, Mumbai V/s. Walfort Share & Stock Brokers (P). Ltd. read as under: 18. The next point which arises for determination is whether the "loss" pertaining to exempted income was deductible against the chargeable income. In other words, whether the loss in the sale of units could be disallowed on the ground that the impugned transaction was a transaction of dividend stripping. The AO in the present case has disallowed the loss of Rs. 1,82,12,862 on the sale of 40% tax- free units of the mutual fund. The AO held that the assessee had purposely and in a planned manner entered into a pre-meditated transaction of buying and selling units yielding exempted income with the full knowledge about the guaranteed fall in the market value of the units and the payment of tax-free dividend, hence, disallowance of the loss. xxxxxxxxxxxx

11 ITA No.7746/Del/2025 Komal Malhotra vs. ACIT 20. The real objection of the Department appears to be that the assessee is getting tax-free dividend; that at the same time it is claiming loss on the sale of the units; that the assessee had purposely and in a planned manner entered into a pre- meditated transaction of buying and selling units yielding exempted dividends with full knowledge about the fall in the NAV after the record date and the payment of tax-free dividend and, therefore, loss on sale was not genuine. We find no merit in the above argument of the Department. At the outset, we may state that we have two sets of cases before us. The lead matter covers assessment years before insertion of Section 94(7) vide Finance Act, 2001 w.e.f. 1.4.2002. With regard to such cases we may state that on facts it is established that there was a "sale". The sale-price was received by the assessee. That, the assessee did receive dividend. The fact that the dividend received was tax-free is the position recognized under Section 10(33) of the Act. The assessee had made use of the said provision of the Act. That such use cannot be called "abuse of law". Even assuming that the transaction was pre-planned there is nothing to impeach the genuineness of the transaction. With regard to the ruling in McDowell & Co. Ltd. v. Commercial Tax Officer [154 ITR 148(SC)), it may be stated that in the later decision of this Court in Union of India v. Azadi Bachao Andolan (263 ITR 706(SC)] it has been held that a citizen is free to carry on its business within the four corners of the law. That, mere tax planning, without any motive to evade taxes through colourable devices is not frowned upon even by the judgment of this Court in McDowell & Co. Ltd.'s case (supra). Hence, in the cases arising before 1.4.2002, losses pertaining to exempted income cannot be disallowed. However, after 1.4.2002, such losses to the extent of dividend received by the assessee could be ignored by the AO in view of Section 94(7). The object of Section 94(7) is to curb the short term losses. Applying Section 94(7) in a case for the assessment year(s) falling after 1.4.2002, the loss to be ignored would be only to the extent of the dividend received and not the entire loss. In other words, losses over and above the amount of the dividend received would still be allowed from which it follows that the Parliament has not treated the dividend stripping transaction as sham or bogus. It has not treated the entire loss as fictitious or only a fiscal loss. After 1.4.2002, losses over and above the dividend received will not be ignored under Section 94(7). If the argument of the Department is to be accepted, it would mean that before 1.4.2002 the entire loss would be disallowed as not genuine but, after 1.4.2002, a part of it would be allowable under Section 94(7) which cannot be the object of Section 94(7) which is inserted to curb tax avoidance by certain types of transactions in securities. There is one more way of answering this point. Sections 14A and 94(7) were simultaneously inserted by the same Finance Act, 2001. As stated above, Section 14A was inserted w.e.f. 1.4.1962 whereas Section 94(7) was inserted w.e.f. 1.4.2002. The reason is obvious. Parliament realized that several public sector undertakings and public sector enterprises had invested huge amounts over last couple of years in the impugned dividend stripping transactions so also declaration of dividends by mutual fund are being vetted and regulated by SEBI for last couple of years. If Section 94(7) would have been brought into effect from 1.4.1962, as in the case of Section 14A, it would have resulted in reversal of large number of

12 ITA No.7746/Del/2025 Komal Malhotra vs. ACIT transactions. This could be one reason why the Parliament intended to give effect to Section 94(7) only w.e.f. 1.4.2002. It is important to clarify that this last reasoning has nothing to do with the interpretations given by us to Sections14A and 94(7). However, it is the duty of the court to examine the circumstances and reasons why Section 14A inserted by Finance Act 2001 stood inserted we.f. 1.4.1962 while Section 94(7) inserted by the same Finance Act as brought into force we.f. 1.4.2002. (emphasis supplied)”

13.

The Co-ordinate Bench of ITAT, Delhi in the case of ACIT vs. Ashok Kumar Minda in ITA No.133/Del/2020 vide order dated 28.06.2023 has held that the addition cannot be made on the basis of mere suspicion when transactions were entered with non-related parties.

14.

It is also a matter of fact that in the case of the assessee herself reassessment proceedings u/s 147 were initiated for Assessment Year 2019-20 where the case was reopened by alleging that assessee has claimed fictitious losses of Rs. 50,66,853/- through M/s JM Financials, however, the reassessment order was passed without making any addition and returned income was accepted.

15.

In view of above discussion and looking to the entirety of facts and circumstances and further considering the fact that the AO has not provided the relied upon materials nor the opportunity of cross examination of the witness of the department and further assessee is a regular investors in mutual funds and shares where she is having income in the shape of dividend exempted u/s 10(35) of the Act, it cannot be said that the transactions in mutual fund scheme of M/s JM Financials was sham transactions incurred for bogus short term capital losses and, accordingly,

13 ITA No.7746/Del/2025 Komal Malhotra vs. ACIT the entire addition made by the AO is hereby deleted. All the grounds of appeal of the assessee are thus allowed.

16.

In the result, the appeal of the assessee is allowed. Order pronounced in the open Court on 08 .07.2026.

Sd/- Sd/- /- - (MAHAVIR SINGH) (MANISH AGARWAL) VICE PRESIDENT ACCOUNTANT MEMBER Dated: 08.07.2026. *PK, Sr. PS* Copy forwarded to: 1. Appellant 2. Respondent 3. CIT 4. CIT(Appeals) 5. DR: ITAT ASSISTANT REGISTRAR ITAT NEW DELHI

14 ITA No.7746/Del/2025 Komal Malhotra vs. ACIT

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