DCIT, CC-4(1), MUMBAI, AIR INDIA BUILDINGS vs. LATE SH. HARSHAD MEHTA (THROUGH LEGAL SMT. JYOTI MEHTA) HEIR , WORLI

ITA 975/MUM/2024Status: DisposedITAT Mumbai14 May 2026AY 1993-94147 pages
AI SummaryPartly Allowed

What were the facts?

The assessee, the legal heir of late Harshad S. Mehta, is in appeal against an order concerning assessment year 1993-94. The case involves multiple rounds of litigation and significant additions related to money market and share market transactions, as well as unexplained credits and investments.

What did the Tribunal hold?

The Tribunal, following its own prior decision in the assessee's own case for AY 1992-93, deleted an addition of Rs. 13,91,00,000/- made on account of alleged liabilities shown as 'other income not shown in the books'. This addition was based on an estimation of interest on funds allegedly utilized by the assessee.

What were the issues?

The primary issue was whether an addition based on an estimation of interest on funds allegedly utilized by the assessee, without proof of accrual or receipt, is sustainable. The appeal also involved numerous other grounds concerning various additions and deductions.

Which sections of the Income-tax Act were involved?

Section 250,Section 144,Section 249(4)(b),Section 5,Section 234A,Section 234B,Section 234C,Section 220

AI-generated summary — verify with the full judgment below

Before: SHRI SANDEEP GOSAIN & SHRI BIJAYANANDA PRUSETH

For Appellant: Shri Vijay Mehta A/w Shri Dharmesh, Ms. Mitali Parekh
For Respondent: Dr. P Daniel Spl. Counsel for the department (virtually appeared)
Hearing: 14.05.2026Pronounced: 10.08.2026

PER BENCH:

These cross appeals filed by the assessee and revenue emanate from the order

passed under section 250 of the Income-tax Act, 1961 (in short, ‘Act’) by the Commissioner of Income-tax (Appeals)-52, Mumbai [in short, ‘CIT(A)’], dated

19.12.

2023 for the assessment year (AY) 1993-94. The assessee had initially raised 35

ITA No.42 & 975/MUM/

The order continues below.

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