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2026 Supreme(Online)(ITAT) 4202

INCOME TAX APPELLATE TRIBUNAL (MUMBAI BENCH)
Saktijit Dey, Vice-President, Makarand Vasant Mahadeokar, Accountant Member
Mumbadevi Vehicles – Appellant
Versus
ITO Ward 41(4)(2) – Respondent


Advocates:
For the Appellants/Petitioners: Ms. Dinkle Hariya, Ms. Sruti Kalyanikar
For the Respondents: Shri Annavaram Kosuri

आदेश/ORDER

PER MAKARAND VASANT MAHADEOKAR, AM:

This appeal by the assessee is directed against the order dated 19.09.2025 passed under section 250 of the Income-tax Act, 1961 [hereinafter referred to as “the Act”] by the Commissioner of Income-tax (Appeals), National Faceless Appeal Centre, Delhi [hereinafter referred to as “CIT(A)”], arising out of the penalty order passed under section 271(1)(c) of the Act.

Facts of the Case

2. The assessee is a partnership firm engaged in the business of supply of vanity vans on hire. For Assessment Year 2014–15, the assessee had not filed its return of income under section 139 of the Act within the prescribed time. Based on information available in the system regarding substantial TDS credits and financial transactions reflected in Form 26AS, the Assessing Officer initiated reassessment proceedings. Notice under section 148 of the Act was issued on 30.03.2021 after obtaining approval under section 151 of the Act. In response to the said notice, the assessee filed its return of income on 30.04.2021 declaring total income of Rs. 40,50,371/-.

3. Subsequently, notice under section 143(2) was issued. The proceedings were thereafter transferred to the Fac

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