GOVIND CORPORATION ,MUMBAI vs. DCIT CENTRAL CIRCLE 8(1), MUMBAI

ITA 3229/MUM/2025Status: DisposedITAT Mumbai09 March 2026AY 2014-1521 pages
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What did the Tribunal hold?

The Tribunal held that additions based solely on uncorroborated and retracted statements, without independent material, are not sustainable. The reliance on an excel sheet without corroboration was also found to be insufficient.

What were the facts?

The assessee's assessments were reopened under Section 148 of the Income Tax Act. Additions were made under Section 69A/69B for cash applied towards land purchase, and the CIT(A) enhanced these additions. The assessee argued that the reopening was bad in law and the additions were based on surmises and uncorroborated retracted statements.

What were the issues?

Whether reopening of assessment under Section 148 was valid and whether additions based on uncorroborated retracted statements and unverified documents are sustainable.

Which sections of the Income-tax Act were involved?

Section 148,Section 69A,Section 69B,Section 132(4),Section 251(2),Section 119

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Income Tax Appellate Tribunal, “G” BENCH MUMBAI

Before: SMT. BEENA PILLAI & SHRI GIRISH AGRAWAL

Hearing: 06.01.2026Pronounced: 09.03.2026

PER GIRISH AGRAWAL, ACCOUNTANT MEMBER:

These appeals filed by the assessee against the order of CIT(A)-50, Mumbai, vide order nos. ITBA/APL/S/250/2024-25/1074711566(1), ITBA/APL/S/250/2024-25/1074749571(1) and ITBA/APL/S/250/2024-25/1074752057(1) dated 19.03.2025, dated 20.03.2025, respectively, passed against the assessment order by DCIT, CC-8(1), Mumbai, u/s. 143(3) r.w.s. 147 of the Income-tax Act (hereinafter referred to as the “Act”), dated 28.03.2023 and 31.03.2023, respectively, for Assessment Year 2012-13 to 2014-15. 2. Grounds taken by assessee are reproduced as under: “Ground.no. 1 T

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