ACIT-6(1)(1), MUMBAI, MUMBAI vs. ARMSTRONG ENERGY PVT. LTD., MUMBAI

ITA 2940/MUM/2025Status: DisposedITAT Mumbai16 February 2026AY 2008-09Bench: SHRI SANDEEP GOSAIN (Judicial Member), SHRI PRABHASH SHANKAR (Accountant Member)1 pages
AI SummaryAllowed

What did the Tribunal hold?

The Tribunal held that the reassessment proceedings were vitiated because no income had actually escaped assessment, as identical additions were already made in AY 2009-10. Consequently, the reopening of assessment and the reassessment order were quashed.

What were the facts?

The assessee and revenue filed cross-appeals against the CIT(A)'s order. The CIT(A) had set aside the assessment order for fresh assessment. The assessee argued that reassessment proceedings were invalid as the same income was already taxed in a prior assessment year, leading to duplication.

What were the issues?

Whether the reassessment proceedings were validly initiated when the income sought to be taxed had already been assessed in a previous year, leading to duplication. Whether the approval for reopening was granted with due application of mind.

Which sections of the Income-tax Act were involved?

Section 147,Section 148,Section 151(2),Section 68,Section 143(3),Section 251(1)(a)

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Cases cited in this judgment(2)Show list

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Income Tax Appellate Tribunal, “A” BENCH MUMBAI

For Appellant: Shri Nishit Gandhi
For Respondent: Shri Rajesh Kumar Yadav (CIT-DR)
Hearing: 10.12.2025Pronounced: 16.02.2026

PER SANDEEP GOSAIN, JM: M/s. Armstrong Energy Pvt. Ltd.

These cross-appeals have been filed by the assessee as well as the Revenue against the common order dated 19.02.2025 passed by the National Faceless Appeal Centre, Delhi [hereinafter referred to as “Ld. CIT(A)”] for the Assessment Year 2008-09. Since the issues involved in both the appeals are common and arise out of the same impugned order

The order continues below.

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