PARTAB GULABRAI TULSIANI,DELHI vs. ACIT, INT. TAX CIRCLE 4(2)(1),, MUMBAI

ITA 448/MUM/2025Status: DisposedITAT Mumbai29 July 2025AY 2006-0755 pages
AI SummaryAllowed

What did the Tribunal hold?

The Tribunal held that the AO erred in reopening the assessment and making additions to the income of the assessees. The Tribunal found that the assessees were non-residents and the income in question was earned outside India.

What were the facts?

The appeals concern the reopening of assessments for AYs 2006-07 and 2007-08 for multiple assessees. The Assessing Officer (AO) made additions based on foreign bank account balances, which the assessees argued were not taxable in India as they were non-residents.

What were the issues?

Whether the reopening of assessment under Section 147 was valid and whether foreign income of non-residents is taxable in India.

Which sections of the Income-tax Act were involved?

Section 147,Section 149,Section 6

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Cases cited in this judgment(1)Show list

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IN THE INCOME TAX APPELLATE TRIBUNAL MUMBAI “I” BENCH : MUMBAI BEFORE SHRI AMIT SHUKLA, JUDICIAL MEMBER AND SHRI VIKRAM SINGH YADAV, ACCOUNTANT MEMBER

| ITA No. | Α.Υ. | Appellant | Respondent | |--------------|--------|---------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|------------------------------------| | 448/Mum/2025 | 2006-07| Pratab Gulabrai Tulsiani, C/o. Ashok Khandelwal Associates, Chartered Accountants, 912-B, Indraprakash, 21, Barakhamba Road, New Delhi-110001 [PAN: AURPT4816C] | ACIT, Int. Tax. Circle-4(2)(1), Room No. 1708, 17th Floor, Air India Building, Nariman Point, Mumbai | | 449/Mum/2025 | 2007-08| | | 464/Mum/2025 | 2006-07| Naraindas Gulabrai Tulsiani, C/o. Ashok Khandelwal Associates, Chartered Accountants, 912-B, Indraprakash, 21, Barakhamba Road, New Delhi-110001 [PAN: ANQPT0488C] | | 463/Mum/2025 | 2007-08| Sham Gulabrai Tulsyani, C/o. Ashok Khandelwal Associates, Chartered Accountants, 912-B, Indraprakash, 21, Barakhamba Road, New Delhi-110001 [PAN: ARYPT4091R] | | 482

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