GANESHARAM GALBARAM MALI ,MUMBAI vs. DCIT CENTRAL CIRCLE 4(2), MUMBAI

ITA 8347/MUM/2025Status: DisposedITAT Mumbai12 March 2026AY 2019-20Bench: SHRI ANIKESH BANERJEE (Judicial Member), SHRI JAGADISH (Accountant Member)1 pages
AI SummaryAllowed

What did the Tribunal hold?

The Tribunal held that the addition of Rs. 4,00,000/- was not sustainable as it was based solely on third-party documents and statements without independent corroboration. The assessee was also denied the opportunity to cross-examine the key witness.

What were the facts?

The assessee purchased a shop where the Assessing Officer (AO) alleged that a portion of the payment was made in cash as 'on-money'. This allegation was based on seized Excel sheets and statements from third parties involved in the sale.

What were the issues?

Whether additions can be made based solely on third-party seized material and statements without corroboration and opportunity for cross-examination. Whether the provisions of Section 153C were correctly applied.

Which sections of the Income-tax Act were involved?

Section 153C,Section 69C,Section 69

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Cases cited in this judgment(7)Show list

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Income Tax Appellate Tribunal, MUMBAI BENCH “G”, MUMBAI

For Appellant: Shri Bharat Kumar, CA
For Respondent: Shri Arun Kanti Datta (CIT DR)
Hearing: 09/03/2026Pronounced: 12/03/2026

Per Bench : A bunch of appeal of the same assessee filed against the order of the Ld.

Commissioner of Income Tax appeal 52, Mumbai [for brevity the ‘Ld. CIT(A)’], order passed under section 250 of the Income Tax Act 1961 (for brevity ‘the Act’) for assessment year 2017-18 to 2019-20, date of order 03.09.2025. The impugned order emanated from the order of the Ld. Assistant Commissioner of Income Tax C.C.-4(2) Mumbai (for brevity the ‘Ld. AO’) order passed under section 153C of the A

The order continues below.

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