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Comfort Intech Limited batch

Case No: ITA No. A.Y. 2573/Mum/24 2011-12, 2926/Mum/24 2012-13, 2218/Mum/24 2011-12, 2216/Mum/24 2012-13, 2212/Mum/24 2014-15
Court: INCOME TAX APPELLATE TRIBUNAL MUMBAI “C” BENCH : MUMBAI
Date: 27 Sept 2024

Parties Involved

appellantComfort Intech Limited
respondentAssistant Commissioner of Income Tax-4(1)(1)

Facts Summary

Comfort Intech Limited, a company engaged in providing inter corporate loans, personal loans, trade financing, bill discounting, syndication of Indian and foreign currency loans, other types of loans, project appraisal etc., filed returns of income for the assessment years 2011-12, 2012-13, and 2014-15. The assessee challenged the validity of the reopening of assessments for these years by the Assistant Commissioner of Income Tax. The assessee argued that the reopening was invalid as it was based on incorrect facts and unreliable statements. The Tribunal found that the Assistant Commissioner did not apply his mind properly and relied on incorrect facts, leading to an invalid reopening of assessments.

Decision in favour of

Partly Assessee / Partly Revenue

Legal Issues

  • 1. Validity of reopening of assessment for AY 2011-12
  • 2. Validity of reopening of assessment for AY 2012-13
  • 3. Validity of reopening of assessment for AY 2014-15

Judgment Outcome

Decided in favour of Partly Assessee / Partly Revenue.

Precedents Relied Upon

3 precedents cited in this judgement.

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