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2026 Supreme(Online)(ITAT) 9648

INCOME TAX APPELLATE TRIBUNAL (MUMBAI BENCH)
Pawan Singh, Judicial Member, Makarand Vasant Mahadeokar, Accountant Member
Pooja Developers – Appellant
Versus
ITO – Respondent


Advocates:
For the Appellants/Petitioners: Hardik Sharma
For the Respondents: Vivek Singh

Table of Content
1. ao added unsecured loan increase as s.68 cash credit; cit(a) partly upheld. (Para 2 , 3 , 4 , 5 , 6 , 7 , 8)
2. assessee contests creditworthiness proof via confirmations. (Para 9 , 10 , 11)
3. remand verifications establish identity and genuineness. (Para 12 , 13 , 14 , 15 , 16)
4. non-filing returns insufficient; s.68 burden discharged by primary evidences. (Para 17 , 18 , 19 , 20 , 21 , 22 , 23 , 24 , 25)
5. delete addition; vacate tax, penalty, interest consequentially. (Para 26 , 27 , 28 , 29)

आदेश/ORDER

PER MAKARAND VASANT MAHADEOKAR, AM:

This appeal by the assessee is directed against the order passed by the Commissioner of Income Tax (Appeals), National Faceless Appeal Centre, Delhi[hereinafter referred to as "CIT(A)"], u/s 250 of the Income-tax Act, 1961[hereinafter referred to as "the Act"], dated 02/07/2025, for A.Y. 2017-18, arising from the assessment order passed by the Income Tax Officer, Ward 26(2)(7), Mumbai[hereinafter referred to as "Assessing Officer or AO"], u/s 143(3) of the Act dated 24/12/2019.

Facts of the Case

2. The assessee filed its return of income declaring total income of Rs. 85,300/-. The return was processed under section 143(1) of the Ac

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