GURUPREET KAUR GURJIT SINGH MATTA ,MUMBAI vs. INCOME TAX OFFICER WARD 41(1)(2), MUMBAI

ITA 2014/MUM/2026Status: DisposedITAT Mumbai08 October 2026AY 2018-193 pages
AI SummaryRemanded

What did the Tribunal hold?

The Tribunal held that the assessment proceedings were substantially conducted during the Covid-19 period, and notices under section 142(1) were issued preceding the severe second wave. Considering the extraordinary circumstances, the assessee had a reasonable cause for not placing the requisite evidence before the Assessing Officer. The Tribunal found that the Ld. Commissioner ought to have considered the additional evidence, potentially after obtaining a remand report from the Assessing Officer, instead of rejecting it solely on the grounds of earlier non-compliance. Therefore, the matter was restored to the file of the Ld. Commissioner for fresh adjudication on merits after considering the additional evidence. The Ld. Commissioner was directed to obtain a remand report if necessary and decide the issues after affording a reasonable opportunity to the assessee. The assessee was directed to file the requisite evidence afresh and cooperate. The appeal was allowed for statistical purposes.

What were the facts?

The assessee, Gurpreet Kaur Gurjit Singh Matta, filed an appeal against the order dated 07.01.2026 passed by the National Faceless Appeal Centre (NFAC), Delhi, for Assessment Year 2018-19. The Assessing Officer, in an order dated 07.04.2021 under section 143(3) read with sections 143(3A) and 143(3B) of the Income Tax Act, 1961, made additions of Rs.9,41,72,182/- to 'Profit and Loss from Business or Profession' and Rs.2,00,000/- for unexplained unsecured loans under section 68. During the first appellate proceedings, the assessee submitted additional evidence. However, the NFAC declined to accept this evidence, citing failure to furnish justifiable supporting documents and material despite opportunities during assessment.

What were the issues?

1. Whether the Ld. Commissioner erred in declining to accept the additional evidences filed by the assessee in appeal, despite the assessment proceedings being conducted during the Covid-19 pandemic? (Question of law and fact, turning on the interpretation of principles of natural justice and reasonable cause in the context of extraordinary circumstances). Assessee's contention: The assessee argued that the assessment proceedings were significantly impacted by the Covid-19 pandemic, and the inability to furnish requisite documents earlier was due to these extraordinary circumstances. Therefore, the additional evidence should have been considered. Revenue's contention: The judgment records no specific contention from the revenue regarding the acceptance of additional evidence.

Which sections of the Income-tax Act were involved?

Section 250,Section 143(3),Section 143(3A),Section 143(3B),Section 68,Section 142(1)

AI-generated summary — verify with the full judgment below

Income Tax Appellate Tribunal, MUMBAI BENCH “G”, MUMBAI

Before: SHRI NARENDER KUMAR CHOUDHRY & SHRI PRABHASH SHANKAR

Pronounced: 08.10.2026

Per : Narender Kumar Choudhry, Judicial Member

This appeal has been preferred by the Assessee against the order dated 07.01.2026, impugned herein, passed by the Ld. National Faceless Appeal Centre (NFAC), Delhi (in short, “Ld. Commissioner”) under section 250 of the Income Tax Act, 1961 (in short, “the Act”) for the A.Y. 2018-19. 2. In the instant case, the Assessing Officer, vide order dated 07.04.2021 passed under section 143(3) read with sections 143(3

The order continues below.

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