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2026 Supreme(Online)(ITAT) 3094

INCOME TAX APPELLATE TRIBUNAL (MUMBAI BENCH)
Pawan Singh, Judicial Member, Arun Khodpia, Accountant Member
Nirmala Pennechand Sarda – Appellant
Versus
ITO, Ward – 42(2)(4), Mumbai – Respondent


Advocates:
For the Appellants/Petitioners: Ramesh Kumar Malpani, CA
For the Respondents: Leyaqat Ali Aafaqui, Sr. DR

Table of Content
1. appeal against cit(a) upholding ao's on-money addition. (Para 1 , 2)
2. assessee challenges addition based on third-party loose papers. (Para 3 , 4)
3. cit(a) upholds addition relying on search evidence. (Para 5)
4. tribunal hears assessee's arguments against presumptive addition. (Para 6 , 7 , 9)
5. revenue defends addition via coded seized materials. (Para 8)
6. no addition without corroborative evidence linking assessee. (Para 10 , 11 , 12)
7. appeal allowed; addition deleted. (Para 13)

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 23.09.2025 for Assessment Year (AY) 2023-24. The assessee has raised following grounds of appeal:

“1. That on the facts and circumstances of the case as well as in law, the Id CIT (A), NFAC, Delhi [CIT (A)) has erred in upholding the validity of the assessment order u/s 143(3) of the Act passed by the Income Tax Officer, Ward-42(2) (4). Mumbai (JAO), whereas the assessment order so passed is clearly invalid, bad-in-law and contrary to the provisions of law. Appellant prays for quashing the assessment order so passed.

2. That on th

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