TATA MOTORS LIMITED ,MUMBAI vs. DEPUTY COMMISSIONER OF INCOME TAX CIRCLE 3(4), MUMBAI

ITA 3511/MUM/2025Status: DisposedITAT Mumbai12 August 2025AY 2014-1527 pages
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What did the Tribunal hold?

The Tribunal held that the reopening of assessment was based on a mere change of opinion and not on any new tangible material. The original assessment order did not contain any adverse observation regarding the deduction claimed under Section 32AC.

What were the facts?

The assessee company's assessment was reopened under Section 147 of the Income Tax Act. The reasons for reopening included alleged non-acquisition of assets within the prescribed period for deduction under Section 32AC and incorrect allowance of tax credit against income assessed under Section 115BBD.

What were the issues?

Whether the reopening of assessment under Section 147 was valid when it was based on a change of opinion without new tangible material, and whether the deduction under Section 32AC was correctly disallowed.

Which sections of the Income-tax Act were involved?

Section 147,Section 148,Section 32AC,Section 115BBD,Section 115JB

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Income Tax Appellate Tribunal, MUMBAI BENCH E, MUMBAI

Before: SHRI AMIT SHUKLA, HONBLE & SHRI ARUN KHODPIA, HONBLE

Heard together (2 matters)

ITA No. 3511/Mum/2025
ITA No. 3512/Mum/2025

Read from the judgment's own cause title. This page is filed under one of them.

PER ARUN KHODPIA, AM:

The captioned appeals filed by the assessee are directed against the separate orders of Commissioner of Income Tax, Appeals (In short "Id. CIT(A)"), National Faceless Appeal Centre, dated 27.03.2025 for A.Y. 2014-15 & 2015-16, which in turn arises from the order passed by the Assessing officer (in short "Ld. AO"), National Faceless Assessment Centre, u/s 147 r.w.s.144B of the Income Tax Act (In short "The Act") dated 30.03.2022, for both the aforesaid assessment years.

2 Both the aforesaid appeals pertain to the same assessee having similar facts,

The order continues below.

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