IN THE INCOME TAX APPELLATE TRIBUNAL “I” BENCH MUMBAI BEFORE SHRI SAKTIJIT DEY, HON'BLE VICE PRESIDENT AND SHRI GIRISH AGRAWAL, ACCOUNTANT MEMBER ITA No. 4199/MUM/2025 Assessment Year: 2016-17 Preity G Zinta Income Tax Officer, Int Tax, 403 Parishram, Ward 4(3)(1), Smt. Nergish Dutt Road, Mumbai Bandra West Vs.

MUMBAI - 400050 PAN: AAAPZ2650B (Appellant) (Respondent)

Present for:

Assessee : Shri. Dharan Gandhi and Ms. Vinita Nara, Advocates Revenue : Shri Krishna Kumar, Sr. DR Date of Hearing : 21.08.2025 Date of Pronouncement : 17.11.2025

O R D E R

PER GIRISH AGRAWAL, ACCOUNTANT MEMBER:

This appeal filed by the assessee is against the assessment order passed under the directions of order of Dispute Resolution Panel-2, Mumbai, vide order no. ITBA/DRP/F/144C(5) r.w.s. 254_260A/2024- 25/1075167929(1), dated 28/03/2025, passed u/s. 144C(5) r.w.s. 254/260A of the Income-tax Act, 1961 (hereinafter referred to as the “Act”), for Assessment Year 2016-17.

2. Grounds taken by the assessee are reproduced as under:

“1. The reopening of the assessment u/s 147 of the Act vide notice u/s 148 dated 30.03.2021 is bad in law and without jurisdiction, therefore should be set aside. 2. The Ld. AO and the Ld