“reliance on third party statement”

RAMESH PURSHOTTAM MODI ,MUMBAI vs. INCOME TAX OFFICER CIRCLE 22(1), MUMBAI

In the result, the appeal of the assessee is allowed

Bench: Shri Saktijit Dey & Shri Makarand Vasant Mahadeokarramesh Purshottam Ito Circle 22(1) Modi Income Tax 303, Modi House, Linking Vs. Department, Road, Khar West, Piramal Chamber, Mumbai-400 052 Dr. Ss Rao Marg, Parel, Mumbai 0 400 012 Pan/Gir No. Aahpm2793F (Applicant) (Respondent) Assessee By Shri Ashwani Kumar A/W Ms. Deepali Aggarwal, Ld. Ars Revenue By Shri Umashankar Prasad, Ld. Dr Date Of Hearing 12.02.2026 Date Of Pronouncement 19.02.2026

sale were accepted, dividend could not be treated as unexplained. The assessee objected to inconsistent reference to sections 69A and 68, reliance on third party statements without furnishing copies or cross examination, and initiation of penalty. An additional ground was raised alleging violation of faceless procedure under section 151A