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Nayana Digant Kapadia Vs. Income Tax Officer

Case No: ITA No. 3173/MUM/2025
Court: INCOME TAX APPELLATE TRIBUNAL “H(SMC)” BENCH, MUMBAI
Date: 1/6/2026

Parties Involved

appellantNayana Digant Kapadia
respondentIncome Tax Officer

Facts Summary

The assessee, Nayana Digant Kapadia, filed her original return of income on 28.07.2017 which was revised on 25.03.2019, reporting total income at Rs.4,35,340/-. The income included salary and other sources, with interest reported from bank and fixed deposits. The assessee carried forward a claim for TDS of Rs.2,74,297/- in respect of gross interest of Rs.27,42,972/- appearing in Form 26AS for the year under consideration, reflected by DLK Commercial Pvt. Ltd. The reason for the carry forward was that the assessee did not receive the said interest as reflected in Form 26AS and follows a cash system of accounting u/s.145 for her interest income. While processing the return, the Centralized Processing Center (CPC) included the interest income from DLK Commercial Pvt. Ltd. by making an adjustment, citing inconsistency between other source incomes in the return and Form 26AS. The assessee submitted a dynamic reconciliation statement in the e-proceedings explaining the error description.

Decision in favour of

Assessee

Legal Issues

  • 1. Whether the Learned Commissioner of Income Tax (Appeals)-32 erred in confirming the order made u/s 143(1) wherein the Interest Income of Rs 26,49,581/- from DLK Commercial Pvt Ltd was added as income of the Appellant on accrual basis despite the Appellant opting for receipt basis u/s 145 of the Income Tax Act, 1961.

Judgment Outcome

Decided in favour of Assessee.

Precedents Relied Upon

2 precedents cited in this judgement.

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