VIJAY NARAINDAS BRIJWANI,KALYAN vs. ASSESSING OFFICER, KALYAN

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ITA 6744/MUM/2024Status: DisposedITAT Mumbai19 May 2025AY 2015-167 pages

In favour of the assessee: the assessee's appeal was allowed. From the AI summary of this appeal.

AI SummaryAllowed

What did the Tribunal hold?

The Tribunal held that the notice issued under section 148 of the Act on 10.07.2022 for AY 2015-16 was barred by limitation. Consequently, the reassessment proceedings and the assessment order were quashed.

What were the facts?

The assessee's assessment order for AY 2015-16 was passed under section 147 r.w.s. 144 of the Income-tax Act. The Assessing Officer added Rs. 1,06,38,592/- as unexplained income under section 69A, which was upheld by the CIT(A).

What were the issues?

The primary issue was whether the reassessment proceedings initiated for AY 2015-16 were barred by limitation, considering the Supreme Court's decision in the Rajeev Bansal case regarding the applicability of TOLA.

Which sections of the Income-tax Act were involved?

Section 147,Section 144,Section 69A,Section 148,Section 148A,Section 149

AI-generated summary — verify with the full judgment below

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Before: SHRI AMIT SHUKLA & SHRI PRABHASH SHANKAR

For Appellant: Shri M Subramaniam, AR
For Respondent: Ms. Kavitha Kaushik (Sr. DR)
Hearing: 08.05.2025Pronounced: 19.05.2025

आदेश की प्रयियलयि अग्रेयिि/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

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