SHIVRAM S SHETTY,MUMBAI vs. INCOME TAX OFFICER WARD 2(1), THANE

ITA 5653/MUM/2024Status: DisposedITAT Mumbai04 February 2026AY 2015-1625 pages
AI SummaryRemanded

What did the Tribunal hold?

The Tribunal admitted the additional ground regarding the validity of the notice under Section 148. It noted that the approval for issuing the notice under Section 148 was granted by the Principal CIT instead of the Joint CIT as required by Section 151.

What were the facts?

The assessee's case was reopened under Section 147 due to cash deposits in bank accounts. The Assessing Officer made an addition of Rs. 34,93,714/- as estimated business income. The CIT(A) upheld this addition.

What were the issues?

The primary issue was the validity of the notice issued under Section 148 due to improper approval under Section 151. Another issue was the jurisdiction for passing the assessment order under Section 144B prior to the relevant notification.

Which sections of the Income-tax Act were involved?

Section 148,Section 147,Section 144,Section 144B,Section 151,Section 148A,Section 149

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Cases cited in this judgment(10)Show list

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Income Tax Appellate Tribunal, “H(SMC

Before: AND SHRI PRABHASH SHANKAR, AM

For Appellant: Shri Kumar Kale, Adv
For Respondent: Shri Pravin Salunkhe, SR. DR
Hearing: 14.11.2025Pronounced: 04.02.2026

Per Kavitha Rajagopal, J M: The captioned appeals have been filed by the assessee, challenging the order of the learned Commissioner of Income Tax (Appeals) Delhi (‘ld. CIT(A)' for short), National Faceless Appeal Centre (‘NFAC' for short) passed u/s. 250 of the Income Tax Act, 1961 ('the Act'), pertaining to the Assessment Year (‘A.Y.' for short) 2014-15 and 2015-16. 2. As the facts are identical, we hereby pass a consolidated order by taking ITA No.5653/Mum/2024 for A.Y. 2015-16 as the lead case. ITA No. 5653/Mum/2024 for A.Y. 2015-16

3.

The assessee has raised the following gr

The order continues below.

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