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Chandulal Navjibhai Patel Vs. Income Tax Officer, Ward 28(1)(1), Mumbai

Case No: ITA No.8372/Mum/2025
Court: Income Tax Appellate Tribunal, ‘J (SMC)’ Bench Mumbai
Date: 1/12/2026

Parties Involved

appellantChandulal Navjibhai Patel
respondentIncome Tax Officer, Ward 28(1)(1), Mumbai

Facts Summary

The present appeal has been preferred by the assessee, Chandulal Navjibhai Patel, assailing the order dated 25.10.2025 passed by the National Faceless Appeal Centre, Delhi, arising out of the assessment framed under section 147 of the Income Tax Act, 1961 for the assessment year 2016–17. The assessee raised multiple grievances, primarily challenging the ex parte nature of the appellate order passed by the learned Commissioner of Income Tax (Appeals), the assumption of jurisdiction under section 147 of the Act for reopening the completed assessment, and the addition of Rs. 30,30,500/- made by the Assessing Officer by invoking the provisions of section 69C of the Act. The assessee claimed that the notices issued by the learned CIT(A) could not be effectively received, resulting in the assessee being unrepresented and deprived of an opportunity to place its case on merits.

Decision in favour of

Assessee

Legal Issues

  • 1. Ex parte nature of the appellate order passed by the learned Commissioner of Income Tax (Appeals)
  • 2. Assumption of jurisdiction under section 147 of the Act for reopening the completed assessment
  • 3. Addition of Rs. 30,30,500/- made by the Assessing Officer by invoking the provisions of section 69C of the Act

Judgment Outcome

Decided in favour of Assessee.

Precedents Relied Upon

1 precedent cited in this judgement.

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Chandulal Navjibhai Patel Vs. Income Tax Officer, Ward 28(1)(1), Mumbai | ITA No.8372/Mum/2025 | 2026 | Opakhya