IN THE INCOME TAX APPELLATE TRIBUNAL “B” BENCH, MUMBAI BEFORE SHRI PAWAN SINGH, JUDICIAL MEMBER&

SHRI ARUN KHODPIA, ACCOUNTANT MEMBER ITA No. 6514/MUM/2025 (AY: 2012-13)

(Physical hearing)

NishaRajendraMavani Legal Heir of ITO – 19(2)(4), Mumbai NavnitDharamsiParmani Vs Piramal Chambers, 7-B, Ganga Laheri Apartment CHS, Mumbai – 400012.

Building No. 19, Banganga Road, Walkeshwar, Mumbai – 400006.

[PAN : ABDVPP8756R]

Appellant / Assessee Respondent / Revenue Assessee by Shri Ashish Thakurdesai,CA Revenue by Shri Leyaqat Ali Aafaqui, Sr. DR Date of Institution 11.10.2025 Date of hearing 12.01.2026 Date of pronouncement 11.02.2026 Order under section 254(1) of Income Tax Act PER PAWAN SINGH, JUDICIAL MEMBER;

1. This appeal by assessee is directed against the order of ld. CIT(A)/NFAC dated 13.08.2025 for Assessment Year (AY) 2012-13. The assessee has raised following grounds of appeal:

“1. On facts, in circumstances of the case and in law, the learned Commissioner of Income Tax Appeals, National Faceless Appeal Centre ought to have held that the reopening of assessment of the appellant u/s 147/148 of Income Tax Act, 1961 is bad in law.

2. On facts, in circumstances of the case and in law, the l