Neptune Fincot Pvt. Ltd. Vs ACIT, Circle-15(1)(2), Mumbai

Parties Involved

Facts Summary

This appeal by Neptune Fincot Pvt. Ltd. is directed against the order of the ld. CIT(A)/NFAC dated 09.07.2024 for A.Y. 2014-15. The assessee raised several grounds of appeal, primarily challenging the validity of reassessment proceedings under section 147 of the Income Tax Act initiated on 01.04.2021. The assessee argued that the notice under section 148 was issued beyond the statutory period and hence invalid. The Revenue, on the other hand, contended that the notice was valid as it was generated and uploaded on the ITBA portal on 31.03.2021. The assessee provided evidence showing the actual issuance date of the notice as 01.04.2021.…

Legal Issues

• 1. Validity of reassessment proceedings under section 147 of the Income Tax Act.
• 2. Whether the mandate of Section 147 of the Act was satisfied before reopening the assessment.
• 3. Confirmation of the addition of Rs.77,32,714/- made by the Ld. AO under section 69A of the Act on account of alleged unexplained money.

Judgment Outcome

Decided in favour of Assessee.

Precedents Relied Upon

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