HASHMAT ISHAQ PARAR,RATNAGIRI vs. INCOME TAX OFFICER, MUMBAI
ITA 3973/MUM/2025[2018-19]Status: DisposedITAT Mumbai14 Jan 2026AY 2018-19
Bench: Shri Anikesh Banerjee & Shri Prabhash Shankarι.Τ.Α No.4071/Mum/2025 Α.Υ. 2015-16 Ι.Τ.Α. No.3973/Mum/2025 Α.Υ. 2018-19 Hashmat Ishaq Parker Vs Income Tax Officer 1, Furus, Tal-Khed, District- Ratnagiri, Maharashtra- 415710 Pan : Αχορρ1815Η Appellant Income Tax Office, Ward 17(3)(1), Mumbai-400051 Respondent Assessee By : Shri Dharan Gandhi Respondent By : Shri Hemanshu Joshi (Sr Dr) Date Of Hearing : 08/01/2026 Date Of Pronouncement : 14/01/2026 Order Per Bench: Both The Appeal Was Filed By The Assessee By Challenging The Order Of The Nfac Delhi [For Brevity, ‘Ld.Cit(A)'] Order Passed Under Section 250 Of The Income-Tax Act, 1961 (For Brevity, ‘The Act), Date Of Order 20/12/2024 & 06/12/2024 Related To Assessment Year 2015-16 & 2018-19 Respectively. The Impugned Orders Emanated From The Order Of The Learned Income Tax Officer Ward 1 Ratinagiri (For Brevity, ‘The Ld.Ao') Order Passed U/S 147 R.W.S. 144 Of The Act, Date Of Orders 20/03/2023 & 21/03/2023 For Assessment Years 2015-16 & 2018-19. 2. Since All The Appeals Pertain To The Same Assessee, Involving Similar Issues Arising Out Of A Similar Factual Matrix, These Appeals Were Heard Together As A Matter Of Convenience & Are Being Decided By Way Of This Consolidated Order. With The Consent Of The Parties, The Appeal For The Assessment Year 2015-16 Is Treated As A Lead Case & The Decision Rendered Therein Shall Apply Mutatis Mutandis To Other Appeal For Ay 2018-19 Before Us.
For Appellant: Shri Dharan GandhiFor Respondent: Shri Hemanshu Joshi (SR DR)
Section 144Section 147Section 148Section 148ASection 250Section 251(1)(a)Section 282A
Section 282A and Rule 127.
b. There being no power to the JAO to issue notice u/s 148 in terms of Circular No.18/2022 dated 29.03.2022 the notice so issued is invalid."
4. The registry informed that both the appeals have been filed with a delay. The Ld. AR stated that for A.Y. 2015-16 the appeal was filed delay