JAP Overseas Private Limited vs. ITO Ward, 10(2)(1)
Case No: ITA No. 7228/MUM/2025
Court: Income-Tax Appellate Tribunal, Mumbai 'F' Bench
Date: 1/29/2026
Parties Involved
appellantJAP Overseas Private Limited
respondentITO Ward, 10(2)(1)
Facts Summary
The assessee, JAP Overseas Private Limited, filed its return of income electronically on 14.10.2010 declaring a total income of Rs.12,49,437/-. The company is engaged in trading in licenses and derivatives. The case was processed under section 143(1) of the Income-tax Act, 1961. Subsequently, the case was re-opened and a notice under section 148 of the Act was issued on 24.03.2015. The re-opening was based on information received from the DIT(I&CI), Mumbai, indicating that the client code modifi…
Decision in favour of
Assessee
Legal Issues
- 1. Validity of jurisdiction assumed by the ITO under section 147 of the Act.
- 2. Dismissal of Gr.No. 2 challenging the action of the AO of commencing the assessment proceedings by issue of notices under sections 143(2) & 142(1) of the Act without first furnishing the reasons recorded.
3 more legal issues analysed in this judgement.
Precedents Relied Upon
7 precedents cited in this judgement.