ACIT-19(3), MUMBAI, MUMBAI vs. HOSHANG MANEKJI HAVEWALA, MUMBAI
What did the Tribunal hold?
The Tribunal held that the AO's additions were based on mere presumptions and unauthenticated information, lacking cogent evidence. The denial of cross-examination to the assessee also violated principles of natural justice.
What were the facts?
The revenue appealed against the deletion of additions made by the Assessing Officer (AO) concerning undisclosed foreign bank accounts, based on information from the French government. The assessee had also filed cross-objections challenging the AO's assessment methods and procedural fairness.
What were the issues?
Whether additions based on foreign information without proper evidence and denial of cross-examination are valid. Whether the AO's estimation of income was arbitrary.
Which sections of the Income-tax Act were involved?
Section 250,Section 144,Section 147,Section 143(3),Section 271(1)(c)
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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 : AAAPH3372C 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) 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 vs ACIT- 19(3), Mumbai 58, Jami Lodge, 618, Jame Room No.
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