INCOME TAX OFFICER-19(1)(1), MUMBAI vs. GEETA KIRIT MUCHHALA, MUMBAI

ITA 9038/MUM/2025Status: DisposedITAT Mumbai20 April 2026AY 2015-168 pages
AI SummaryDismissed

What were the facts?

The revenue appealed against the CIT(A)'s order which quashed the assessment order on procedural grounds. The CIT(A) held that the reassessment proceedings were invalid due to non-compliance with the faceless assessment scheme and the Hon'ble Bombay High Court's decision in the assessee's own case.

What did the Tribunal hold?

The Tribunal upheld the CIT(A)'s order, following the binding precedent of the Hon'ble jurisdictional High Court. The Tribunal found that the reassessment proceedings were invalid due to non-compliance with Section 151A and also noted that the reassessment was time-barred.

What were the issues?

Whether the reassessment proceedings were validly initiated under the faceless assessment scheme and within the prescribed limitation period.

Which sections of the Income-tax Act were involved?

Section 68,Section 115BBE,Section 73,Section 151A,Section 148,Section 147,Section 144,Section 149

AI-generated summary — verify with the full judgment below

Income Tax Appellate Tribunal, “G” BENCH, MUMBAI

Before: SMT. BEENA PILLAI & SHRI JAGADISH

For Appellant: Shri Satish Mody, A/R
For Respondent: Shri Suni Mathews, Sr. D/R
Hearing: 07.04.2026Pronounced: 20.04.2026

Per Smt. Beena Pillai, JM: The present appeal filed by the revenue arises out of the order dated 22/12/2025 passed by the NFAC, Delhi [hereinafter the “Ld.CIT(A)”] for A.Y. 2015-16 on following grounds of appeal:-

1.

“Whether on the facts and in the circumstances of the case and in law, the Ld. CIT(A) erred in not appreciating the facts of the case thereby deleting the addition of Rs.1,61,94,390/- made by the AO u/s 68 of the Income Tax Act, 1961, without appreciating that the assessee failed to discharge the onus of proving the genuineness of transactions and source of funds with supporting evidence, despite repeated opportunities.” 2. “Whether on the facts and in the circumstances of the cas

The order continues below.

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