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

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ITA 5571/MUM/2025Status: DisposedITAT Mumbai27 February 2026AY 2020-2118 pages
AI SummaryAllowed

What did the Tribunal hold?

The Tribunal noted that similar issues were decided in favor of the assessee by coordinate benches. Specifically, the Tribunal found that the addition was based on third-party statements without corroborative material and without providing an opportunity for cross-examination, thus violating principles of natural justice.

What were the facts?

The assessee challenged the validity of notices and assessments made under Section 153C, arguing that Section 147/148 should have applied. The assessee also contended that the addition of Rs. 2,50,000/- as unexplained investment was based on uncorroborated third-party statements and lacked material evidence for the relevant assessment year.

What were the issues?

Whether the assessment framed under Section 153C was valid and whether the addition of unexplained investment was substantiated without corroborative evidence and cross-examination opportunity.

Which sections of the Income-tax Act were involved?

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

AI-generated summary — verify with the full judgment below

Income Tax Appellate Tribunal, F BENCH MUMBAI

Before: HON’BLE SHRI SANDEEP GOSAIN& HONBLE 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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