MAHAZARIN FEROZE DASTOOR ,MUMBAI vs. INCOME TAX OFFICER , MUMBAI

सुिवधई की िधरीख / Date of Hearing 10.03.2025 घोर्णध की िधरीख/Date of Pronouncement 28.03.2025 आदेश / O R D E R PER RENU JAUHRI [A.M.] :- This appeal is filed by the assessee against the order of the Learned Commissioner of Income-tax (Appeals), Mumbai/National Faceless Appeal Centre, Delhi [hereinafter referred to as “CIT(A)”] dated 10.05.2024 passed u/s. 250 of the Income-tax Act, 1961 [hereinafter referred to as “Act”] for Assessment Year [A.Y.] 2014-15.

A.Y. 2014-15 Mahazarin Feroze Dastoor “1) In the facts and circumstances of the case and in law, the learned A. O. erred in reopening the assessment u/s 148 and the learned CIT(A), NFAC also erred in confirming the reopening u/s. 148 a only on the basis of borrowed satisfaction without making any inquiry of the said information received b. relying upon information from website c. without any clear nexus between reasons recorded and information received d. reopening for AY 2014-15 was time barred under new provision and old provisions both as per several judgements of Bombay and other high courts e. approval was mechanically granted 2) In the facts and in the circumstances of the case and in law, the Ld. AO erred in making the addition of the long-term capital gain of Rs. 3,29,15,679 instead of Rs. 203,73,141/even though the same was not taxable as per the scheme of Wipro. 3) In the facts and circumstances of the case and in law, the learned A.O. erred in levying and the learned CIT(A), NFAC also erred in confirming interest u/s 234 & initiation of penalty u/s 271[1][c] and 271[1][b]”