JEEVAK CONSULTANTS LLP,MUMBAI vs. INCOME TAX OFFICER, WARD 20(2)(1) , MUMBAI

ITA 1723/MUM/2026Status: DisposedITAT Mumbai19 May 2026AY 2018-194 pages
AI SummaryAllowed

What were the facts?

The assessee filed an appeal with a delay of 171 days, claiming it was due to a misunderstanding of the CIT(A)'s order. The AO had made an addition under Section 56(2)(x) based on the difference between the sale consideration and the stamp duty valuation. The CIT(A) directed the AO to re-compute the addition based on the DVO's report.

What did the Tribunal hold?

The Tribunal condoned the delay in filing the appeal. On merits, it held that the difference between the DVO's valuation and the agreement value was within the permissible limit of 10%, considering the retrospective application of the enhanced safe harbor limit.

What were the issues?

Whether the delay in filing the appeal should be condoned. Whether the addition under Section 56(2)(x) is sustainable when the difference between the property's FMV and sale consideration is within the safe harbor limit, considering the retrospective application of the enhanced limit.

Which sections of the Income-tax Act were involved?

Section 56(2)(x),Section 143(3),Section 250,Section 155(15),Section 50C

AI-generated summary — verify with the full judgment below

Income Tax Appellate Tribunal, MUMBAI BENCHES, MUMBAI

Before: SHRI NARENDER KUMAR CHOUDHRY & SHRI JAGDISH

For Respondent: Shri Saurabh Raskar, (SR. DR)
Pronounced: 19.05.2026

PER NARENDER KUMAR CHOUDHRY, JUDICIAL MEMBER:

This appeal has been preferred by the assessee against the order dated 30.06.2025, impugned herein, passed by National Faceless Appeal Centre (NFAC), Delhi/ Ld. Commissioner of Income Tax (Appeals), (in short ‘Ld. Commissioner’) u/s. 250 of the Income Tax Act, 1961 (in short ‘the Act’) for the A.Y. 2018-19. 2. At the outset, it is observed that there is a del

The order continues below.

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