INCOME TAX OFFICER , MUMBAI vs. JITENDRA VALLABHJI DEDHIA, MUMBAI

ITA 9207/MUM/2025Status: DisposedITAT Mumbai12 March 2026Bench: SHRI SAKTIJIT DEY (Vice President), SHRI MAKARAND VASANT MAHADEOKAR (Accountant Member)1 pages
AI SummaryDismissed

What did the Tribunal hold?

The Tribunal dismissed the Revenue's appeal. It held that the appeal was not maintainable due to low tax effect below the CBDT's monetary limit and also found no infirmity in the CIT(A)'s finding that the AO lacked concrete evidence to substantiate the addition.

What were the facts?

The Assessing Officer (AO) made an addition of Rs. 46,00,000/- to the assessee's income under Section 68, alleging it was unexplained cash loans advanced through a third party. The assessee denied this, stating no evidence supported the claim and that the alleged intermediary denied receiving cash loans from the assessee.

What were the issues?

Whether the addition under Section 68 was justified without concrete evidence, and whether the Revenue's appeal was maintainable given the low tax effect.

Which sections of the Income-tax Act were involved?

Section 68,Section 143(3),Section 147,Section 148,Section 132,Section 132(4)

AI-generated summary — verify with the full judgment below

Income Tax Appellate Tribunal, “F” BENCH MUMBAI

For Appellant: Shri Subhodh Ratnaparkhi, Ld. AR
For Respondent: Shri Nayanjyoti Nath, Ld. DR, Shri Subhodh Ratnaparkhi, Ld. AR
Hearing: 11.03.2026Pronounced: 12.03.2026

PER MAKARAND VASANT MAHADEOKAR, AM: This appeal by the Revenue is directed against the order passed by the learned Commissioner of Income Tax (Appeals), National Faceless Appeal Centre, Delhi [hereinafter referred to as "CIT(A)"] dated 08.10.2025 for the Assessment Year 2012–13, arising out of the assessment order passed by the Assessing

2 Jitendra Vallabhji Dedhia Officer under section 143(3) read with section 147 of the Income Tax Act, 1961, [hereinafter referred to as "the Act"] dated 24.12.2019. Facts of the Case

2.

The assessee is an individual. The assessee filed the original return of income for the Assessment Year 2012–13 on 29.09.2012

The order continues below.

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