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INCOME TAX APPELLATE TRIBUNAL (MUMBAI BENCH)
SHRI AMIT SHUKLA, J, SHRI GIRISH AGRAWAL, ACJ
Income Tax officer (International) – Appellant
Versus
Shapoorji Pallonji Mistry – Respondent
| Table of Content |
|---|
| 1. details of appeals filed and basic case facts. (Para 1 , 2) |
| 2. arguments from revenue about validity of notices. (Para 3 , 6 , 8) |
| 3. court's analysis and observations on notice validity. (Para 4 , 5 , 7 , 9 , 12) |
| 4. determining the impact of tola and case law on notice. (Para 10 , 11 , 13) |
| 5. court's conclusion on notice validity and appeals. (Para 14 , 15 , 16) |
ORDER
PER GIRISH AGRAWAL, ACCOUNTANT MEMBER:
These appeals filed by the Revenue and Cross Objections filed by the assessee are against the orders of CIT (A) 57, Mumbai-
i) vide order No. ITBA/APL/S/250/2024-25/1074571063(1), dated 17.03.2025 passed against the assessment order of Income Tax Officer (International Taxation)-3(2)(1), Mumbai u/s. 147 r.w.s.144C(3) of the Income-tax Act, 1961 (hereinafter referred to as the “Act”), dated 28.07.2023 for AY 2015-16.
ii) vide order No. ITBA/APL/S/250/2024-25/1074573456(1), dated 17.03.2025 passed against the assessment order of Income Tax Officer (International Taxation)-3(2)(1), Mumbai u/s. 147 r.w.s.144C(3) of the Act, dated 28.07.2023 for AY 2016-17.
2. Grounds taken by the Revenue are reproduced as under:
ITA No. 3674/MUM/2025
1. Whether on the facts and in the circums
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