IN THE INCOME TAX APPELLATE TRIBUNAL “F” BENCH, MUMBAI BEFORE SMT. BEENA PILLAI (JUDICIAL MEMBER)

&

SHRI MAKARAND VASANT MAHADEOKAR (ACCOUNTANT MEMBER)

Assessment Year: 2017-18 JM Financial Foundation Vs. Income Tax Officer

141, Maker Chambers III (Exem.), Ward -1(4), Nariman Point Mumbai Mumbai - 400021 [PAN: AAATJ2474M]

(Appellant) (Respondent)

Assessee by Dr. K Shivram, A/R Revenue by Ms. Kavitha Kashik, Sr. DR Date of Hearing 10.12.2025 Date of Pronouncement 29.12.2025 ORDER Per Bench:

Present appeal filed by assessee arises out of order dated

15/08/2025 and 16/08/2025 passed by NFAC, Delhi [hereinafter “the Ld. CIT(A)”] for assessment years 2017-18 and 2018-19 respectively, on the following grounds:-

Assessment Year – 2017-18 “1. That on the facts and circumstances of the case and in law the Ld. National Faceless Appeal Centre (NFAC) has erred on facts and in law in confirming reopening the assessment of the appellant u/s. 147 on the ground of addition of CR contribution received during the year without appreciating that there did not exist any reason to believe that income escaped assessment and reopening is on the basis of borrowed satisfaction and hence reopening of assessment is ba