Navrang Hospitality Private Limited Vs ITO (ITAT Mumbai)
The Mumbai ITAT condoned a 34-day delay in filing the appeal after accepting that the assessee genuinely believed its tax consultant had filed the Tribunal appeal. The lapse came to light only when the assessee received a demand notice and discovered that no appeal had been filed.
Both the reassessment under Sections 147 read with 144B and the first appeal had been decided ex parte, as the assessee failed to furnish proper replies before the AO and the CIT(A).
The assessee contended that the addition was based solely upon a third-party statement, without incriminating material, corroborative evidence or any demonstrated nexus with income escaping assessment. It sought an opportunity to produce the relevant information now available with it.
Without deciding the addition on merits, the Tribunal restored the matter to the AO for a fresh assessment after granting adequate opportunity of hearing. However, the remand was made conditional upon the assessee depositing ₹50,000 as costs in the Prime Minister’s Relief Fund within 30 days of receiving the order.
FULL TEXT OF THE ORDER OF ITAT MUMBAI
This appeal is filed by the assessee against the order of the learned CIT(A)-NFAC, Delhi, dated 11.09.2025 for the assessment year 2013- 14.
