SUMAN JAGANNATH SANKHE,MUMBAI vs. ITO WARD 41.4.4, KAUTILYA BHAVAN, MUMBAI

ITA 7528/MUM/2025Status: DisposedITAT Mumbai06 February 2026AY 2016-17Bench: SMT. BEENA PILLAI ( (Judicial Member)1 pages
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What did the Tribunal hold?

The Tribunal held that the reassessment notice issued under Section 148 was bad in law due to non-compliance with the provisions of Section 151 regarding prior approval for reassessment beyond three years when the escaped income was below Rs. 50 lakhs. Consequently, the reassessment proceedings were quashed.

What were the facts?

The assessee filed a return of income for AY 2016-17, and later filed a revised return in response to a notice under Section 148. The Assessing Officer (AO) made an addition of Rs. 15,00,000/- as unexplained cash credit. The assessee appealed to the CIT(A), but the appeal was dismissed for non-compliance.

What were the issues?

The primary issues were the validity of the reassessment proceedings initiated under the new regime, specifically concerning the proper sanction under Section 151, and the merits of the addition made under Section 68.

Which sections of the Income-tax Act were involved?

Section 148,Section 148A,Section 151,Section 68,Section 115BBE

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Cases cited in this judgment(4)Show list

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Income Tax Appellate Tribunal, “SMC” BENCH, MUMBAI

Before: SMT. BEENA PILLAI

For Appellant: Shri Nishit Gandhi, AR
For Respondent: Shri Limbasiya Kavan Nareshkumar, Sr. DR
Hearing: 03.02.2026Pronounced: 06.02.2026

Per Smt. Beena Pillai, JM: Present appeal filed by assessee arises out of order dated 14/10/2025 passed by NFAC, Delhi [hereinafter “the Ld.CIT(A)”], for Assessment Year 2016-17 on following grounds of appeal:-

“ON NATURAL JUSTICE:

1.

1 In the facts and circumstances of the case and in law, the order passed by the Ld. Commissioner of Income Tax (Appeals), National Faceless Appeal Centre (NFAC) [“the Ld. CIT(A)”] deserves to be quashed since the same is passed in gross violation of the principles of Natural Justice and also based on totally extraneous considerations while ignoring the relevant, material considerations and submissions made by the Appellant. ⸻ ON VALIDITY OF

The order continues below.

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