TILAKNAGAR INDUSTRIES LTD,MUMBAI vs. DCIT CC 1(1), MUMBAI

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ITA 6357/MUM/2017Status: DisposedITAT Mumbai28 August 2020AY 2009-1010 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 reopening of assessment was invalid as it was based on a change of opinion and lacked tangible material. The AO had already considered the relevant information during the original assessment.

What were the facts?

The assessee's assessment for AY 2009-10 was reopened based on information obtained during a survey regarding payments for astrological fees. The Assessing Officer (AO) made additions, and the CIT(A) partly allowed the assessee's appeal. The assessee appealed to the Tribunal.

What were the issues?

Whether the reopening of assessment under Section 147 was valid when based on a change of opinion without new tangible material. Whether the disallowance of depreciation on architectural fees and interest expenses were justified.

Which sections of the Income-tax Act were involved?

Section 147,Section 148,Section 143(3),Section 36(1)(iii)

AI-generated summary — verify with the full judgment below

Cases cited in this judgment(2)Show list

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Income Tax Appellate Tribunal, MUMBAI BENCHES “E”, MUMBAI

Before: SHRI M. BALAGANESH (AM) & SHRI RAM LAL NEGI (JM)

For Appellant: Shri Dr. K. Shivram/Rahul Hakani (ARs)
For Respondent: Shri Amit Pratap Singh / Mohd. Rizwan
Hearing: 25/08/2020Pronounced: 28/08/2020

आदेश प्रतितिति अग्रेतिि/Copy of the Order forwarded to : 1. अपील र्थी / The Appellant 2. प्रत्यर्थी / The Respondent. 3. आयकर आय क्त(अपील) / The CIT(A)- 4. आयकर आय क्त / CIT 5. दिभ गीय प्रदिदनदि, आयकर अपीलीय अदिकरण, म ुंबई /

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