ACIT22(1), MUMBAI vs. SPR ASSOCIATES, MUMBAI

ITA 6562/MUM/2025Status: DisposedITAT Mumbai17 February 2026Bench: SMT. BEENA PILLAI (Judicial Member), SHRI ARUN KHODPIA, ( (Accountant Member)1 pages
AI SummaryDismissed

What did the Tribunal hold?

The Tribunal held that the reassessment notice issued under Section 148 was invalid due to non-compliance with Section 151 of the Act regarding the approval of the appropriate authority. Consequently, the reassessment proceedings were quashed.

What were the facts?

The Revenue appealed against the CIT(A)'s order deleting an addition made by treating a receipt as dividend income. The assessee filed a cross-objection challenging the validity of the reassessment notice issued under Section 148.

What were the issues?

The primary issue was the validity of the reassessment notice under Section 148, specifically whether the approval obtained for its issuance complied with the requirements of Section 151 of the Income Tax Act.

Which sections of the Income-tax Act were involved?

Section 148,Section 148A,Section 151

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Cases cited in this judgment(4)Show list

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Income Tax Appellate Tribunal, “G” BENCH, MUMBAI

Before: SMT. BEENA PILLAI & SHRI ARUN KHODPIA

For Appellant: Ms. Mitali Parekh, Adv
For Respondent: Shri Dr. Raghvendra P. Chambolkar, Sr. DR
Hearing: 11.02.2026Pronounced: 17.02.2026

Heard together (2 matters)

I.T.A. No. 6562/Mum/2025
C.O. No. 53/Mum/2026

Read from the judgment's own cause title. This page is filed under one of them.

Per Smt. Beena Pillai, JM: The present appeal filed by the Revenue and the cross- objection filed by Assessee arise out of the order dated 13/10/2025 passed by the Ld.CIT(A) for A.Y. 2018-19. 2. The revenue has raised the following grounds of appeal:-

2 C.O. No. 53/Mum/2026 “1. Whether on the facts and in the circumstances of the case and in law, the Ld. CIT(A) erred in deleting the addition made by the Assessing Officer by treating the receipt as dividend income, ignoring the fact that t

The order continues below.

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