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2025 Supreme(Online)(ITAT) 6818

INCOME TAX APPELLATE TRIBUNAL (AHMEDABAD BENCH)
DR. BRR KUMAR, VP, SHRI SIDDHARTHA NAUTIYAL, JM
Mohit Vijaykumar Gupta – Appellant
Versus
The DCIT – Respondent


Advocates:
For the Appellants/Petitioners: Shri J. C. Desai, CA
For the Respondents: Shri B.P. Srivastava, Sr.DR

Table of Content
1. introduction of the appeal and context. (Para 1 , 2)
2. details of assessment and grounds for appeal. (Para 3 , 4)
3. final verdict and legal implications. (Para 9 , 12)
4. court's findings on income tax assessment. (Para 10 , 11)

आदेश/ORDER

PER SIDDHARTHA NAUTIYAL, JM:

The present appeal has been preferred by the assessee against the order of the Learned Commissioner of Income Tax (Appeals), National Faceless Appeal Centre (NFAC), Delhi [hereinafter referred to as ‘CIT(A)’] dated 14/12/2025 passed u/s.250 of the Income Tax Act, 1961 (hereinafter referred to as ‘the Act’) for the Assessment Year (AY) 2021-2022.

2. The assessee has raised the following grounds of appeal:

1. “(a) The Ld. CIT(Appeal)/The National Faceless Appeal Centre('NFAC') has erred in confirming addition of . 7,43,199 as deemed rent in respect of five flats situated at Mumbai as against the deemed rent considered Nil as per provisions of section 23(1)(c) of the Act by your Appellant.

(b) Your appellant prays that, on the facts and circumstances of the case, the Ld. A O may be directed to delete the addition made to the total income.

2. (a) The Ld. CIT (Appeal)/The National Faceless Appeal Centre('NFAC

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