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INCOME TAX APPELLATE TRIBUNAL (MUMBAI BENCH)
SANDEEP SINGH KARHAIL, Judicial Member, BIJAYANANDA PRUSETH, Accountant Member
Income Tax Officer – 28(3)(1) – Appellant
Versus
Vinod Bhanji Shah – Respondent
| Table of Content |
|---|
| 1. assessee's business and reassessment triggered by cash deposits. (Para 1 , 8 , 9 , 10 , 11) |
| 2. revenue and assessee challenge cit(a) order on merits and jurisdiction. (Para 2 , 3 , 4) |
| 3. jurisdictional issues in reassessment admitted for adjudication. (Para 5 , 6 , 7) |
| 4. section 148/151 requires specified authority approval for notices. (Para 12 , 13 , 14 , 15) |
| 5. invalid pcit approval post-3-year limit voids reassessment. (Para 16 , 17 , 18 , 19) |
| 6. cross-objection allowed; revenue appeal dismissed. (Para 20 , 21 , 22) |
ORDER
PER SANDEEP SINGH KARHAIL, J.M.
The present appeal by the Revenue and cross-objection by the assessee has been filed against the impugned order dated 17/10/2025, passed under section 250 of the Income Tax Act, 1961 (“the Act”) by the learned Commissioner of Income Tax (Appeals), National Faceless Appeal Centre, Delhi, [“learned CIT(A)”], for the assessment year 2017-18.
2. In its appeal, the Revenue has raised the following grounds: -
“(i) Whether on the facts and in the circumstances of the case and in law, the Ld. CIT (A), NFAC has erred in deleting the addition made on account of unexplained cash deposits during the demonetization period without ap
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