SMT REVATI NARAYAN JANGAM,MUMBAI vs. ITO-42(1)(4), MUMBAI

IN THE INCOME TAX APPELLATE TRIBUNAL “K” (SMC) BENCH, MUMBAI BEFORE SHRI PAWAN SINGH, JUDICIAL MEMBER AND SHRI MAKARAND VASANT MAHADEOKAR, ACCOUNTANT MEMBER ITA No. 8110/MUM/2025 (AY: 2019-2020) (Physical hearing) Smt Revati Narayan Jangam ITO- 42(1)(4), C/506 Shree Complex, Plot No. Vs Kautilya Bhavan, Mumbai 106/112, Sector-14 Kamothe, Maharashtra- 400051 Navi Mumbai, Maharashtra- 410210 [PAN: APIPJ4676E] Appellant / Assessee Respondent /Revenue Assessee by Ms. Harsha Thelasaria, C.A. Revenue by Shri Bhagirath Ramawat, Sr. DR (Virtually) Date of hearing 24.03.2026 Date of pronouncement 04.06.2026 Order under section 254(1) of Income Tax Act PER PAWAN SINGH, JUDICIAL MEMBER: 1. This appeal by assesseeis directed against the order of Ld. CIT(A) / NFAC dated 26.09.2025 for assessment year (A.Y.) 2019-20. The assessee has raised following grounds of appeal; i. The Ld. Commissioner of Income Tax (Appeals), National Faceless Appeal Centre [CIT(A)] erred in not admitting the appeal for the reason that appeal has been filed belatedly. ii. The Appellant prays that the CIT(A) ought to have admitted the appeal and decided the grounds on merits by considering the facts of the case. Therefore, the order passed by the CIT(A) deserves to be set aside. iii. The Ld. CIT(A) erred in not adjudicating the action of AO in issuing the notice u/s 148 of the Income Tax Act, 1961 (Act) and passing the order u/s 147 r.w.s 144B of the Act. iv. The Appellant submits that the notice issued u/s 148 of the Act and order passed u/s 147 r.w.s. 144B of the Act is against the provision of the law, ultra vires and without jurisdiction; hence, the same shall be quashed.

ITA No. 8110/MUM/2025 Smt. Revati Narayan Jangam

v. The Ld. CIT(A) erred in not adjudicating the action of AO in making the addition of Rs. 20,00,000/- being alleged unexplained investment u/s 69 of which nature and source is not explained by the Appellant. vi. The Appellant submits that he has made investment in debentures through funds advanced by a Non-Banking Financial Corporation named as M/s. ECL Finance Limited through IPO Financing. Nature and source of investment is fully explained; hence, the addition made by the AO shall be deleted. 2. Rival submissions of both the parties have been heard and record perused. The Ld. Authorized Representative ( ‘AR’) fairly submits that there was a delay of 92 days in filing appeal before the first Appellate Authority/ CIT(A). The first Appellate Authority did not condone the delay and resultantly the appeal was not admitted and dismissed in limine. The Ld. AR of the assessee further submits that on similar set of fact appeal for AY 2016-17 in ITA No. 8107/Mum/2025v vide order dated 25.02.2025 has been restored by Tribunal to the file of Ld. CIT(A) with the direction to take a liberal view and condone the delay and decide the appeal on merit after providing reasonable opportunity to the assessee. While explaining the fact, the Ld. AR of the assessee submits that the assessing officer (AO) made addition on account of purchase of debenture Rs. 20.00 Lacs. The amount of Rs. 20.00 Lacs was financed from ECL Finance Ltd. (‘ECL’) a Non Banking Finance Company (NBFC) and part of Edelweiss Group. The Ld. AR also filed copy of decision of Tribunal in assessee’s own case for AY 2016-17 and submits that the same order may be followed and matter may be restored back to ld CIT(A).

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ITA No. 8110/MUM/2025 Smt. Revati Narayan Jangam

MUMBAI, Dated: 04/06/2026 Z.U., P.S Copy of the order forwarded to: (1) The Assessee; (2) The Revenue; (3) The PCIT / CIT (Judicial); By Order (4) The DR, ITAT, Mumbai; and (5) Guard file. Assistant Registrar ITAT, Mumbai

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