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Devi Manubhai Shah Vs Income Tax Officer – Circle 32(1), Mumbai

Case No: ITA No.7005/MUM/2025
Court: Income Tax Appellate Tribunal, 'D' Bench, Mumbai
Date: 1/8/2026

Parties Involved

appellantDevi Manubhai Shah
respondentIncome Tax Officer – Circle 32(1), Mumbai

Facts Summary

The case involves Devi Manubhai Shah, who filed a return of income for the Assessment Year 2012-2013 declaring a total income of Rs.24,04,600/-. The Assessing Officer initiated reassessment proceedings based on information received from the DDIT(Inv) 4(2), Mumbai, indicating high-value investments and income from buyback of shares. The Assessing Officer disallowed an exemption claimed by the assessee under Section 54F of the Income Tax Act, 1961, adding INR.83,43,016/- to the assessee's income. The assessee challenged this addition, arguing that it was not one of the reasons recorded for reopening the assessment.

Decision in favour of

Assessee

Legal Issues

  • 1. Whether the Assessing Officer had jurisdiction to disallow the exemption claimed under Section 54F of the Act without making any addition in respect of the issues/reasons recorded for reopening the assessment.

Judgment Outcome

Decided in favour of Assessee.

Precedents Relied Upon

5 precedents cited in this judgement.

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Devi Manubhai Shah Vs Income Tax Officer – Circle 32(1), Mumbai | ITA No.7005/MUM/2025 | 2026 | Opakhya