MRS. DEEPALI VIKKI AJMERA,MULUND vs. ITO WARD 27(1)(1), MUMBAI, NAVI MUMBAI
In the result, appeal filed by the Assessee is allowed
ITA 4981/MUM/2025[2020-21]Status: DisposedITAT Mumbai30 Dec 2025AY 2020-21
Bench: Shri Narender Kumar Choudhryassessment Year: 2020-21 Mrs. Deepali Vikki Ajmera, Ito Ward 27 (1) (1), 5Th Floor, Prem Ratna Building, Tower 6, Vashi Station Ambedkar, Road Opp. Balaji Vs. Complex, Navi Mumbai – Temple, Mulund West, Mumbai 400703. – 400080. Pan – Agvps 7279 Q (Appellant) (Respondent) Present For: Assessee By : Shri Piyush Bafna, Ca (Virtually Appear) Revenue By : Shri A.M.K. Mahadevan, Sr. D.R. Date Of Hearing : 19.11.2025 Date Of Pronouncement : 30.12.2025 O R D E R Per : Narender Kumar Choudhry: This Appeal Has Been Preferred By The Assessee Against The Order Dated 30.08.2024, Impugned Herein, Passed By The National Faceless Appeal Centre (Nfac)/Ld. Commissioner Of Income Tax (Appeals) (In Short Ld. Commissioner) U/S 250 Of The Income Tax Act, 1961 (In Short ‘The Act’) For The A.Y. 2020-21. 2. At The Outset, It Is Observed That There Is A Delay Of 281 Days In Filing The Instant Appeal, On Which The Assessee Has Claimed As Under :- Affidavit For Condonation Of Delay 1, Mrs. Deepali Vikki Ajmera, Age About 45 Years, Residing At 5Th Floor, Prem Ratna Building, Ambedkar Road, Opp Balaji Temple
For Appellant: Shri Piyush Bafna, CAFor Respondent: Shri A.M.K. Mahadevan, SR. D.R
Section 250
…rganization. We take strength from decisions Sir Kikabhai Premchand v. CIT[1953] 24 ITR 506(SC); ITO v. Murlidhar Bhagwan Das[1964] 52 ITR 335 (SC); CIT v. British Paints India Ltd. [1991] 188 ITR 44/54 Taxman 499 (SC) and CIT v. Basant Rai Takht Singh [1933] 1 ITR 197 (SC) for the proposition that each 'previous year' is a distinct unit of time for the purposes of assessment and further, that the profits made; and the liabilities of losses made before or after the relevant previous year are immaterial in assessing income of a particular year, unless in accordance with proviso to Section 4(1) of I.T. Act, there i…