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Arunkumar Jayantilal Muchhla vs DCIT

Case No: I.T.A. No. 5395/Mum/2025 to I.T.A. No. 5400/Mum/2025
Court: INCOME TAX APPELLATE TRIBUNAL, ‘A’ BENCH, MUMBAI
Date: 1/27/2026

Parties Involved

AppellantArunkumar Jayantilal Muchhla
RespondentDCIT

Facts Summary

The present appeals have been filed by the assessee, Arunkumar Jayantilal Muchhla, challenging the different impugned orders dated 13.06.2025 passed under section 250 of the Income Tax Act, 1961, by the National Faceless Appeal Centre (NFAC) / CIT(A) for the assessment years 2006-07 to 2012-13. The assessee raised several grounds of appeal, primarily concerning the addition of Rs. 39,75,937/- on account of deemed dividend under section 2(22)(e) of the Act. The assessee argued that the payer company did not possess 'accumulated profits' and that certain amounts were wrongly added as deemed dividend. The case involved multiple rounds of litigation, with previous orders being set aside and the matter being remanded for fresh adjudication.

Decision in favour of

Assessee

Legal Issues

  • 1. Erroneous addition of Rs. 39,75,937/- on account of deemed dividend u/s. 2(22)(e) of the Act
  • 2. Failure to appreciate lack of 'accumulated profits' at the beginning of FY 2005-06
  • 3. Erroneous addition of Rs. 17,20,937/- on account of current account transactions and Director's Remuneration
  • 4. Erroneous addition of Rs. 22,55,000/- on account of amounts received by M/s. Shiv Sai Developers

Judgment Outcome

Decided in favour of Assessee.

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Arunkumar Jayantilal Muchhla vs DCIT | I.T.A. No. 5395/Mum/2025 to I.T.A. No. 5400/Mum/2025 | 2026 | Opakhya