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Piyali Trading Company Private Limited vs. ITO -7(3)(1), Mumbai

Case No: ITA 2526/MUM/2026, ITA 2527/MUM/2026, ITA 2528/MUM/2026
Court: Income Tax Appellate Tribunal, Mumbai
Date: 9/10/2026

Parties Involved

appellantPiyali Trading Company Private Limited
respondentITO -7(3)(1), Mumbai

Facts Summary

Piyali Trading Company Private Limited, an assessee, filed appeals against the reassessment orders passed by the Income Tax Officer, Mumbai for the Assessment Years 2013-14, 2014-15, and 2015-16. The reassessment was based on information that the assessee had provided unsecured loans and advances to certain parties, which were not commensurate with the return of income filed by the assessee. The assessee argued that the loans and advances reported in its balance sheet were historical opening balances and not fresh transactions during the assessment years. The assessee also contested the jurisdictional validity of the reassessment proceedings.

Decision in favour of

Assessee

Legal Issues

  • 1. Whether the reassessment order passed by the Commissioner of Income-tax (Appeals) is sustainable under the provisions of the Income-tax Act.
  • 2. Whether the addition made by the Assessing Officer for unsecured loans and advances is justified.
  • 3. Whether the reassessment proceedings are valid and within jurisdiction.

Judgment Outcome

Decided in favour of Assessee.

Precedents Relied Upon

2 precedents cited in this judgement.

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Piyali Trading Company Private Limited vs. ITO -7(3)(1), Mumbai | ITA 2526/MUM/2026, ITA 2527/MUM/2026, ITA 2… | Opakhya