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INCOME TAX APPELLATE TRIBUNAL (MUMBAI BENCH)
Amit Shukla, J, Renu Jauhri, ACJ
ITO-42(1)(4), Mumbai – Appellant
Versus
Parul Kishor Patel – Respondent
| Table of Content |
|---|
| 1. income declaration and its genuineness under relevant tax sections. (Para 2 , 4 , 5) |
| 2. reference to prior decisions establishing case precedent. (Para 3 , 8) |
| 3. court's emphasis on evidentiary standard in tax assessments. (Para 6 , 7 , 9 , 10) |
| 4. the ultimate dismissal of the revenue's appeal. (Para 12) |
Assessee by Shri Prakash Jotwani Revenue by Shri Virabhadra Mahajan, Sr. DR Date of Hearing 15/07/2025 Date of Pronouncement 29/07/2025 / O R D E R आदेश PER AMIT SHUKLA (J.M):
The aforesaid appeal has been filed by the Revenue against order dated 06/02/2025 passed by FAC, Delhi for the quantum of assessment passed u/s.143(3) r.w.s. 147.
2. In its grounds of appeal, the Revenue has assailed the Rs.
deletion of an addition of 97,21,227 made under Section 68 of the Act, being the income declared exempt under Section 10(38) on account of sale of shares. It has also challenged the Rs.
deletion of a notional commission addition of 2,91,637 made under Section 69C by estimating commission at 3%.
3. At the outset, it was submitted that the issues raised in the present appeal stand squarely covered by the decision of this Tribunal in the case of the assessee’s husband, Shri Harsh
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