MEGHJI MANSUKHLAL DODHIA,BHIWANDI vs. DCIT-CC-3, THANE, THANE

ITA 2224/MUM/2025Status: DisposedITAT Mumbai11 February 2026AY 2013-1430 pages
AI SummaryRemanded

What did the Tribunal hold?

The Tribunal held that the lower authorities erred in upholding additions based on seized documents without sufficient corroborative evidence and without addressing the assessee's contentions about the nature of the documents. It also noted issues with reliance on retracted statements and lack of opportunity for cross-examination.

What were the facts?

A search and seizure operation was conducted on the assessee and associated entities. During the assessment, the Assessing Officer relied on seized documents (hundi papers and promissory notes) to make additions, treating them as cash borrowings. The assessee contended these were proposed transactions or 'dumb documents' without materialization.

What were the issues?

Whether additions made under Section 69D based on seized hundi papers and promissory notes are valid without corroborative evidence and proper consideration of the assessee's defense. Whether additions under Section 68 for unsecured loans are justified when based on third-party statements without cross-examination and with retracted affidavits.

Which sections of the Income-tax Act were involved?

Section 132,Section 153A,Section 69D,Section 68,Section 271(1)(c),Section 234A,Section 234B,Section 234C

AI-generated summary — verify with the full judgment below

Heard together (6 matters)

S.A. No. 79/Mum/2025
ITA No. 2224/Mum/2025
S.A. No. 80/Mum/2025
S.A. No. 81/Mum/2025
S.A. No. 82/Mum/2025
S.A. No. 83/Mum/2025

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

IN THE INCOME TAX APPELLATE TRIBUNAL "A" BENCH MUMBAI BEFORE SHRI AMIT SHUKLA, JUDICIAL MEMBER & SHRI MAKARAND VASANT MAHADEOKAR, ACCOUNTANT MEMBER

1.

IT(SS)A No. 2226/Mum/2025 S.A. No. 79/Mum/2025 (Assessment Year: 2012-13) Mansukhlal Meghji Dodhia House No. 104, Dodhia House, New Mavji Compound, Narpoli, Maharashtra-421 302 (Applicant) DCIT CC-3, Thane Vs. Room No. 12, A Wing, 6th floor, Ashar IT Park, Thane, West, Maharashtra - 400 604 PAN/GIR No. AASPD6746L (Respondent)

2.

ITA No. 2224/Mum/2025 S.A. No. 80/Mum/2025 (Assessment Year: 2013-14)

3.

IT(SS)A No. 2223/Mum/2025 S.A. No. 81/Mum/2025 &

4.

IT(SS)A No. 2222/Mum/2025 S.A. No. 82/Mum/2025 (Assessment Year: 2015-16)

5.

IT(SS)A No. 2225/Mum/2025 S.A. No. 83/Mum/2025 (Assessment Year: 2016-17) Meghji Mansukhlal Dodhia House No. 104, Dodhia House, New Mavji Compound, Narpoli, Maharashtra-421 302 (Applicant) DCIT CC-3, Thane Vs. Room No. 12, A Wing, 6th floor, Ashar IT Park, Thane, West, Maharashtra - 400 604 PAN/GIR No. AASPD6746L (Respondent) (2) IT(SS)A No. 2226, 2223, 2222 & 2225/Mum/2025 & Mansukhlal Meghji Dodhia Assessee by Revenue by Date of Hearing Date of Pronouncement Ms. Simran Dhawan, Ld. AR Shr

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