SPICE OF LIFE HOTELS AND ESTATES PRIVATE LIMITED,MUMBAI vs. DCIT-2(3)(1), MUMBAI

ITA 7704/MUM/2025Status: DisposedITAT Mumbai17 February 2026AY 2014-15Bench: SMT. BEEBA PILLAI (Judicial Member), SHRI ARUN KHODPIA (Accountant Member)1 pages
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What did the Tribunal hold?

The Tribunal held that the reopening of assessment under Section 148 beyond four years was invalid as there was no failure on the part of the assessee to disclose fully and truly all material facts. Consequently, the reassessment order and the penalty were quashed.

What were the facts?

The assessee's case was reopened under Section 147 for AY 2014-15, leading to additions under Section 14A and a penalty under Section 271(1)(c). The assessee challenged the validity of the reassessment proceedings, arguing that there was no failure to disclose material facts.

What were the issues?

The primary issue was the validity of reassessment proceedings initiated beyond four years without demonstrating the assessee's failure to disclose material facts. The secondary issue was the consequential penalty levied.

Which sections of the Income-tax Act were involved?

Section 147,Section 148,Section 14A,Section 271(1)(c)

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Cases cited in this judgment(15)Show list

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Income Tax Appellate Tribunal, “G” BENCH, MUMBAI

Before: SMT. BEEBA PILLAI, JM & SHRI ARUN KHODPIA, AM

For Appellant: Shri Chaitanya Joshi &, Shri Siddhi Jain, AR
For Respondent: Dr. Raghvendra P. Chambolkar
Hearing: 11.02.2026Pronounced: 17.02.2026

Heard together (2 matters)

I.T.A. No. 7703/Mum/2025
I.T.A. No. 7704/Mum/2025

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

Per Arun Khodpia, AM: The captioned appeals are filed by the assessee against the order of Commissioner of Income Tax (Appeals)/ National Faceless Appeal Centre (NFAC), Delhi (in short “Ld. CIT(A)”, dated 23.09.2025 for AY 2014-15

ITA Nos. 7703 & 7704/Mum/2025 Spice Life Hotels and Estates Pvt. Ltd.

challenging the quantum additions made vide order under section 147 r.w.s. 143(3) dated 28.03.2022 and penalty order under section 271(1)(c) of Income Tax Act, 196

The order continues below.

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