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INCOME TAX APPELLATE TRIBUNAL (MUMBAI BENCH)
SHRI OM PRAKASH KANT, ACM, SHRI RAJ KUMAR CHAUHAN, JM
Lekhraj J. Jain – Appellant
Versus
DCIT 19(1) – Respondent
| Table of Content |
|---|
| 1. reopening proceedings require accurate facts for jurisdiction. (Para 4) |
| 2. assessing officers must establish valid grounds and independent belief for reopening assessment. (Para 5 , 6) |
| 3. the appeal was allowed based on invalid jurisdiction of reassessment. (Para 7) |
ORDER
PER OM PRAKASH KANT, AM
This appeal by the assessee is directed against order dated 10.06.2025 passed by the Ld. Commissioner of Income-tax (Appeals) – National Faceless Appeal Centre, Delhi [in short ‘the Ld. CIT(A)’] for assessment year 2014-15, raising following grounds:
1. On the facts and in the circumstances of the case and in law, the assumption of jurisdiction by the Ld. AO was bad in law as the conditions laid down for initiating assessment proceedings u/s 147 of the Income Tax Act, 1961 have not been fulfilled.
2. On the facts and circumstances of the case and in law, the Ld. CIT(A) erred in confirming the addition of Rs. 55,49,342/- as unexplained cash credits u/s 68 of the Act, being sale proceeds received through banking channel on sale of shares of Matra Kaushal Enterprises Limited on recognised stock exchange, disregarding the ample documentary evidences furnished by the appellant to p
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