BHARAT KANTILAL DOSHI,MUMBAI vs. DEPUTY COMMISSIONER OF INCOME TAX, CIRCLE 27(1), NAVI MUMBAI

ITA 7169/MUM/2025Status: DisposedITAT Mumbai23 February 2026AY 2014-158 pages
AI SummaryN/A

What did the Tribunal hold?

The ITAT found that the CIT(A) failed to adjudicate all grounds of appeal, including the validity of reopening, natural justice violations, the addition under Section 68, and other issues like TDS credit and interest. The ITAT, therefore, remanded the matter back to the CIT(A) for a denovo adjudication of all grounds on merits, providing the assessee a proper opportunity of hearing and to submit evidence.

What were the facts?

The assessee's assessment for AY 2014-15 was reopened under Section 147 after a search revealed an alleged undisclosed cash loan of Rs. 50,00,000/- from the assessee to M/s. Evergreen Enterprises. The AO made an addition under Section 68, which the CIT(A) confirmed, dismissing the appeal without adjudicating several key grounds raised by the assessee, including those related to the validity of reopening and violations of natural justice.

What were the issues?

1. Whether the CIT(A) erred in not adjudicating all grounds of appeal, including the validity of assessment reopening and the addition under Section 68. 2. Whether the CIT(A) violated principles of natural justice by denying a personal hearing and not providing relied-upon documents. 3. Correctness of addition made under Section 68 and non-grant of TDS/self-assessment tax credits and wrong charging of interest/penalty proceedings.

Which sections of the Income-tax Act were involved?

Section 250,Section 147,Section 143(1),Section 143(2),Section 142(1),Section 132,Section 144B,Section 68,Section 115BBE,Section 199,Section 234A,Section 271(1)(c),Section 154

AI-generated summary — verify with the full judgment below

Income Tax Appellate Tribunal, “B” BENCH, MUMBAI

Before: SHRI OM PRAKASH KANT, AM AND

For Appellant: Shri Paresh Shaparia, AR
For Respondent: Shri Swapnil Choudhari, Sr. AR
Pronounced: 19.02.2026

Per Bench: The captioned appeals are filed by the assessee, challenging the order of the Learned Commissioner of Income Tax [‘Ld. CIT(A)' for short], National Faceless Appeal Centre ('NFAC' for short) passed u/s. 250 of the Income Tax Act, 1961 (‘the Act') pertaining to the Assessment Year (‘A.Y.' for short) 2014-15, 2016-17 & 2017-18. As the facts are identical, we hereby pass a consolidated order by taking ITA No.7069/M/2025 pertaining to A.Y. 2014-15 as the lead case.

2.

The assessee has raised the following grounds of appeal:

“1. GROUNDS OF APPEAL NOT ADJUDICATED BY CIT(A) a. Ground 1- Re-

The order continues below.

Read the full judgment

A free account opens 10 full judgments a month. Re-reading one you have already opened does not count again.

Create a free accountSign in

See plans and prices

The summary, the parties, the sections and the citations above are open to everyone and always will be. Only the text of the order and the PDF are metered.

More judgments on Section 147

All 49,210 judgments and leading authorities on Section 147 →

Recent GST High Court judgments

Search GST case law →