MONA AMARCHAND NARANG ,MUMBAI vs. INCOME TAX OFFICER WARD 23(2)(1), MUMBAI

ITA 1537/MUM/2026Status: DisposedITAT Mumbai06 July 2026AY 2016-1713 pages
AI SummaryAllowed

What were the facts?

The assessee invested Rs. 60 lakh in equity shares of a family-owned company, which were valued at Rs. 1,51,56,000. The Assessing Officer added the difference of Rs. 91,56,000 to the income under Section 56(2)(vii)(c). The reassessment proceedings were initiated after more than three years from the end of the assessment year.

What did the Tribunal hold?

The Tribunal held that the sanction for reassessment under Section 151(i) was invalid as it should have been obtained from a higher authority under Section 151(ii) for reassessment initiated after three years. Consequently, the reassessment notice and order were quashed.

What were the issues?

Whether the sanction for reassessment proceedings initiated after three years was obtained from the appropriate authority as per Section 151 of the Income Tax Act, and whether the reassessment notice and order are valid.

Which sections of the Income-tax Act were involved?

Section 147,Section 148,Section 148A,Section 151,Section 56(2)(vii)(c)

AI-generated summary — verify with the full judgment below

Before: SHRI AMIT SHUKLA & SHRI PRABHASH SHANKAR

For Appellant: Ms. Rutuja Pawar & Ms. Pranaya Muthathyan, ARs
For Respondent: Shri Swapnil Choudhari,(Sr. DR)
Hearing: 06.05.2026Pronounced: 06.07.2026

PER PRABHASH SHANKAR [A.M.] :- The instant appeal emanating from the appellate order dated 18.12.2025 is preferred by the assessee against the order passed by the Learned Commissioner of Income-tax (Appeals)/National Faceless Appeal Centre, Delhi [hereinafter referred to as “CIT(A)”] pertaining to assessment order passed u/s. 147 r.w.s. 144B of the Income-tax Act, 1961

P a g e | 2 A.Y. 2016-17 Mona Amarchand Narang [hereinafter referred to as “Act”] dated12.05.2023 for the Assessment Year [A.Y.] 2016-17. 2. The grounds of appeal are as under:

1.

That on the fact

The order continues below.

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