ACIT-19(3), MUMBAI, MUMBAI vs. HOSHANG MANEKJI HAVEWALA, MUMBAI

ITA 6192/MUM/2025Status: DisposedITAT Mumbai10 February 2026AY 1999-0021 pages
AI SummaryAllowed

What did the Tribunal hold?

The Tribunal found the AO's addition to be based on insufficient and unauthenticated information, lacking evidence of foreign account ownership or transactions. The estimation of income was deemed arbitrary, and the AO's failure to provide relied-upon material and deny cross-examination constituted a violation of natural justice.

What were the facts?

The Revenue appealed against the deletion of additions made by the Assessing Officer (AO) related to alleged undisclosed foreign bank accounts. The AO's additions were based on information from French authorities, estimating income at a 17% return on investment, while the assessee argued the assessment lacked concrete evidence and violated natural justice.

What were the issues?

Validity of additions based on foreign information without concrete evidence or cross-examination opportunity; Justification of penalty under Section 271(1)(c) when the primary addition is deleted.

Which sections of the Income-tax Act were involved?

Section 250,Section 144,Section 147,Section 143(3),Section 271(1)(c),Section 139(1),Section 148,Section 131,Section 142(1)

AI-generated summary — verify with the full judgment below

Heard together (8 matters)

I.T.A No.6192/Mum/2025
I.T.A. No.6193/Mum/2025
I.T.A. No.6194/Mum/2025
I.T.A. No.6195/Mum/2025
I.T.A. No.6209/Mum/2025
I.T.A. No.6211/Mum/2025
C.O.338/Mum/2025
C.O.341/Mum/2025

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

IN THE INCOME TAX APPELLATE TRIBUNAL MUMBAI BENCH “E”, MUMBAI BEFORE SHRI OM PRAKASH KANT, ACCOUNTANT MEMBER AND SHRI ANIKESH BANERJEE, JUDICIAL MEMBER I.T.A No.6192/Mum/2025 A.Y.: 1999-2000 I.T.A. No.6193/Mum/2025 A.Y.: 1997-1998 I.T.A. No.6194/Mum/2025 A.Y. : 2000-01 I.T.A. No.6195/Mum/2025 A.Y. : 1996-1997 I.T.A. No.6209/Mum/2025 A.Y. : 1998-1999 I.T.A. No.6211/Mum/2025 A.Y. : 1996-1997 ACIT- 19(3), Mumbai vs Hoshang Manekji Havewala Room No.513, 5th floor, 58, Jami Lodge, 618, Jame Jamshed Piramal Chambers, Parel, Road, Dadar, Mumbai-400014 Mumbai-400012 PAN: AAAΑΡΗ3372C APPELLANT RESPONDENT C.O.338/Mum/2025 (Arising out of I.T.A No.6192/Mum/2025 A.Y.: 1999-2000) C.O.340/Mum/2025 (Arising out of I.T.A. No.6193/Mum/2025 A.Y. : 1997-98) C.O.337/Mum/2025 (Arising out of I.T.A. No.6194/Mum/2025 A.Y. : 2000-01) C.O.336/Mum/2025 (Arising out of I.T.A. No.6211/Mum/2025 A.Y. : 1996-97) ITA Nos.6192, 6193, 6194, 6195, 6209 & 6211/Mum/2025 CO NOS.338, 340, 337, 336, 341 & 339/Mum/2025 Hoshang Manekji Havewala C.O.341/Mum/2025 (Arising out of I.T.A. No.6209/Mum/2025 A.Y. : 1998-99) C.O.339/Mum/2025 (Arising out of I.T.A. No.6195/Mum/2025 A.Y. : 1996-97)

Hoshang Manekji Havewala 58, Jami L

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