APTIVAA MIDDLE EAST FZE,DUBAI vs. DEPUTY COMMISSIONER OF INCOME TAX, CIRCLE 1(1)(2), INTERNATIONAL TAXATION , MUMBAI

ITA 1985/MUM/2024Status: DisposedITAT Mumbai15 April 2025AY 2014-15Bench: SHRI AMIT SHUKLA (Judicial Member), MS PADMAVATHY S (Accountant Member)12 pages
AI SummaryAllowed

What did the Tribunal hold?

The Tribunal held that the notice under Section 148 was not validly served on the assessee as it was sent to an incorrect address. Consequently, the entire reassessment proceedings initiated based on this invalid notice were quashed.

What were the facts?

The assessee, a UAE-based non-resident company, had its assessment reopened under Section 147. The primary issue was the validity of the notice issued under Section 148, which the assessee claimed was not served at its correct address.

What were the issues?

Whether the reassessment proceedings are valid when the notice under Section 148 was not properly served on the assessee at its correct address.

Which sections of the Income-tax Act were involved?

Section 147,Section 148,Section 148A,Section 149,Section 282

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Cases cited in this judgment(4)Show list

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Income Tax Appellate Tribunal, “I” BENCH, MUMBAI

Before: SHRI AMIT SHUKLA, JM &

For Appellant: Shri Khirendra M. Gupta, AR
For Respondent: Shri Krishna Kumar- Sr. DR
Hearing: 27.03.2025Pronounced: 15.04.2025

Heard together (2 matters)

I.T.A. No.1985/Mum/2024
S.A. No.55/Mum/2024

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

Per Padmavathy S, AM:

This appeal and Stay Application (SA) by the assessee are against the order of the Deputy Commissioner of Income Tax. International Tax Circle-1(1)(2), Mumbai passed under section 147 r.w.s. 144C(13) of the Income Tax Act, 1961 (the Act)

2 ITA 1985 & CO 55/Mum/2024 Aptivaa Middle East FZE dated 18.03.2024 for AY 2014-15. The assessee raised the following grounds of appeal:

“1. On the facts a

The order continues below.

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