VIMALA JITENDRA JAIN ,MUMBAI vs. ASST, CIT.CENTRALCIRCLE4(2), MUMBAI

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ITA 5570/MUM/2025Status: DisposedITAT Mumbai27 February 2026AY 2019-2018 pages
AI SummaryAllowed

What did the Tribunal hold?

The Tribunal noted that the assessment was based on third-party statements and documents found during a search on a group, but the assessee denied the cash payments. Crucially, the Assessing Officer failed to provide an opportunity for cross-examination of the third parties whose statements were relied upon.

What were the facts?

The assessee challenged assessment orders for AY 2019-20 and 2020-21, primarily disputing the validity of notices under Section 153C and additions made under Section 69. The additions were based on alleged cash payments for shop premises over the agreement value, relying on third-party statements.

What were the issues?

Whether the assessment framed under Section 153C was valid and whether additions made under Section 69 were sustainable without providing an opportunity for cross-examination of third parties.

Which sections of the Income-tax Act were involved?

Section 153C,Section 69,Section 147,Section 148,Section 115BBE

AI-generated summary — verify with the full judgment below

Income Tax Appellate Tribunal, F BENCH MUMBAI

Before: HON’BLE SHRI SANDEEP GOSAIN& HON’BLE SHRI BIJAYANANDA PRUSETH

For Appellant: Shri Bharat Kumar
For Respondent: Shri Vivek Perampurna, CIT DR
Hearing: 26.02.2026Pronounced: 27.02.2026

आदेश की �ितिलिप अ�ेिषत/Copy of the Order forwarded to : अपीलाथ� / The Appellant 1. ��थ� / The Respondent. 2. संबंिधत आयकर आयु� / The CIT(A) 3. आयकर आयु�(अपील) / Concerned CIT 4. िवभागीय �ितिनिध, आयकर अपीलीय अिधकरण,मु�बई/ DR, ITAT, Mumbai 5. गाड� फाईल / Guard file. 6.

आदेशानुसार/BY ORDER, स�ािपत �ित //True Copy//

उप/सहायक पंजीकार ( Asst. Registrar) आयकर अपीलीय अिधकरण, मु�बई मु�बई / ITAT, Mumbai मु�बई मु�बई

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