ZEE MEDIA CORPORATION LIMITED ,MUMBAI vs. DCIT, CENTRAL CIRCLE 2(4), MUMBAI

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ITA 6871/MUM/2025Status: HeardITAT Mumbai07 October 2026AY 2019-2024 pages
AI SummaryPartly Allowed

What did the Tribunal hold?

The Tribunal held that the reassessment proceedings in ITA No. 6869/MUM/2025 (AY 2019-20) were bad in law, as they were based on borrowed reasons and lacked independent application of mind by the AO. This decision was applied mutatis mutandis to the identical ground in ITA No. 6871/MUM/2025. Regarding the disallowance of depreciation, the Tribunal found that an identical issue in the case of a sister concern, Zee Akaash News P.Ltd (ITA No. 6869/Mum/2025), was allowed for statistical purposes. Therefore, for ITA No. 6871/MUM/2025 (AY 2019-20) and ITA No. 6870/MUM/2025 (AY 2022-23), the grounds relating to depreciation disallowance were set aside and remanded to the AO for de novo consideration. The issue of interest under Section 234B was not explicitly decided in the provided excerpt.

What were the facts?

The appeals filed by M/s Zee Akaash News Private Limited and M/s Zee Media Corporation Limited (the assessees) challenge orders from the CIT(A)-48, Mumbai, concerning assessment years 2019-20 and 2022-23. The assessments were made under Section 147, 143(3), and 143(3) read with Section 147 of the Income-tax Act, 1961. The cases were reopened based on information from the Investigation wing, Kolkata, regarding Watkins Infrastructure Private Limited (WIPL), alleged to be involved in issuing fraudulent GST invoices and availing irregular input tax credit. The assessee appeared in WIPL's list for transactions totaling Rs. 5.07 crore (AY 2019-20) and Rs. 3,54,46,814/- (AY 2019-20, specific figure from later part of judgment) and Rs. 3,00,39,673/- (AY 2022-23). The AO disallowed depreciation claimed on civil and interior work and furniture purchased from WIPL.

What were the issues?

1. Whether the reassessment proceedings initiated under Section 147 read with Section 148A of the Act are bad in law, being based on borrowed reasons and without independent application of mind by the Assessing Officer (AO), as argued by the assessee. The revenue contended that the reopening was based on credible information from a third party and not mere suspicion. 2. Whether the Learned Commissioner of Income-tax (Appeals) erred in upholding the disallowance of depreciation amounting to Rs. 27,43,850/- (AY 2019-20) and Rs. 27,27,632/- (AY 2022-23) claimed under Section 32 of the Act in respect of civil and interior work and furniture purchased from Watkins Infrastructure Private Limited (WIPL), as argued by the assessee. The assessee contended it discharged its onus to prove the genuineness of the transactions by furnishing documents, audited financials, and tax audit reports. The revenue argued that WIPL did not comply with a notice under Section 133(6) of the Act, and the assessee failed to discharge its onus. 3. Whether the Learned Commissioner of Income-tax (Appeals) erred in confirming the excess levy of interest under Section 234B of the Act amounting to Rs. 4,79,400/- for AY 2019-20, despite the assessee having paid advance tax exceeding 90% of the assessed income, as argued by the assessee. The judgment does not record specific arguments from the revenue on this point.

Which sections of the Income-tax Act were involved?

Section 147,Section 143(3),Section 148A,Section 148,Section 32,Section 234B,Section 133(6),Section 133A,Section 139(5)

AI-generated summary — verify with the full judgment below

Before: SHRI NARENDER KUMAR CHOUDHRY & SHRI PRABHASH SHANKAR

For Appellant: Shri Madhur Agrawal / Fenil Bhatt, ARs
For Respondent: Shri Basavraj Hiremath, CIT-DR
Hearing: 24.08.2026Pronounced: 07.10.2026

आदेश की प्रतितलति अग्रेतिि/Copy of the Order forwarded to : 1. अपीलार्थी / The Appellant 2. प्रत्यर्थी / The Respondent. 3. आयकर आयुक्त / CIT 4. विभागीय प्रविविवि, आयकर अपीलीय अविकरण DR, ITAT, Mumbai 5. गार्ड फाईल / Guard file.

P a g e | 24 ITA No. 6869, 6870 & 6871/Mum/2025 A.Y. 2019-20 & 2022-23 M/s Zee Akaash News Pvt. Ltd. & M/s Zee Media Corporation Ltd. सत्यावपि प्रवि //True Copy// आदेशानुसार/ BY ORDER,

उि/सहायक िंजीकार (Dy./Asstt. Registrar) आयकर अिीलीअतिकरण

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