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Sandip Foundation v/s Deputy Commissioner of Income Tax

Case No: ITA No.6031/MUM/2025
Court: INCOME TAX APPELLATE TRIBUNAL, ‘F’ BENCH, MUMBAI
Date: 1/19/2026

Parties Involved

appellantSandip Foundation
respondentDeputy Commissioner of Income Tax

Facts Summary

The assessee, Sandip Foundation, filed an appeal against the order dated 02.07.2025 passed by the learned Commissioner of Income Tax (Appeals), National Faceless Appeal Centre, Delhi, which arose from an order passed under section 154 of the Income Tax Act, 1961, for the assessment year 2018-19. The assessee raised several grounds of appeal, including breach of natural justice, lack of jurisdiction in the rectification order, and unjustified additions to income under sections 13(2)(c) and 13(2)(d) of the Act. The assessee also contested the levy of interest under sections 234A, 234B, and 234C. The assessee failed to file written submissions before the learned CIT(A), leading to an ex parte order.

Decision in favour of

Assessee

Legal Issues

  • 1. Whether the order dated 02.07.2025 is passed in breach of the principle of natural justice.
  • 2. Whether the order passed under section 154 is without jurisdiction and bad-in-law.
  • 3. Whether the addition of Rs. 11,96,93,441/- under section 13(2)(c) is unjustified.
  • 4. Whether the addition of Rs. 27,96,600/- under section 13(2)(d) is unjustified.

Judgment Outcome

Decided in favour of Assessee.

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