GOVIND CORPORATION ,MUMBAI vs. DEPUTY COMMISSIONER OF INCOME TAX CENTRAL CIRCLE -8(1), MUMBAI

ITA 3233/MUM/2025Status: DisposedITAT Mumbai09 March 2026AY 2012-1321 pages
AI SummaryAllowed

What did the Tribunal hold?

The Tribunal held that additions made solely on the basis of uncorroborated and retracted statements are not sustainable. The seized excel sheet was also considered insufficient evidence without corroboration.

What were the facts?

The assessee is appealing against the reopening of assessment and additions made under sections 69A/69B for cash applied towards land purchase. The additions were based on a statement that was later retracted, and the assessee argued it lacked corroboration.

What were the issues?

Whether additions can be made based on retracted statements and uncorroborated documents. Whether reopening of assessment was valid and if the assessment order was issued without DIN.

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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Cases cited in this judgment(2)Show list

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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

The order continues below.

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