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

ITA 7171/MUM/2025Status: DisposedITAT Mumbai23 February 2026AY 2017-188 pages
AI SummaryAllowed

What did the Tribunal hold?

The ITAT found that the CIT(A) had failed to adjudicate all grounds raised by the assessee, including those challenging the reopening and the merits of the addition under section 68. The tribunal noted that the CIT(A)'s order was cryptic and lacked a speaking order.

What were the facts?

The assessee's case was reopened under section 147 based on information from a search and survey, leading to an addition of Rs. 50,00,000/- for an alleged cash loan. The CIT(A) dismissed the assessee's appeal, stating non-compliance and failure to prove the source of the loan.

What were the issues?

Whether the CIT(A) properly adjudicated all grounds of appeal, including the validity of reopening and the substance of additions, or if a remand for fresh adjudication is necessary.

Which sections of the Income-tax Act were involved?

Section 250,Section 147,Section 148,Section 143(1),Section 132,Section 143(2),Section 142(1),Section 144B,Section 68,Section 115BBE,Section 199,Section 234A,Section 271(1)(c)

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
Hearing: 19.02.2026Pronounced: 23.02.2026

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. Groun

The order continues below.

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