Matrix Arch Technologies Private Limited Vs Ward 12(3)(1) (ITAT Mumbai)
Summary: The Income Tax Appellate Tribunal Mumbai in Matrix Arch Technologies Private Limited Versus ITO, Ward 12(3)(1), Mumbai, ITA/4116/MUM/2026 dated 03/09/2026 deleted the additions made u/s 68 of the Income Tax Act 1961, holding that an assessee’s documentary evidence cannot be disregarded merely based on third party material without providing a nexus between such adverse material and the particular transactions of the taxpayer.
The reassessment stemmed from Investigation Wing information on the Pravin Kumar Jain group, alleging that share application money received by the assessee were accommodation entries. Against an original addition of Rs. 50,00,000/- under Section 68, the Ld. CIT(A) had already deleted Rs. 20,00,000/- on remand, sustaining Rs. 30,00,000/-.
Before the Tribunal, it was demonstrated that the assessee had discharged its onus through complete documentary evidence for the three genuine subscribers share application forms, board resolutions, PAN, ITRs, audited financials, bank statements, and Form 20B/ROC records with funds routed entirely through banking channels, supported by Pravin Kumar Jain’s retraction affidavit and coordinate bench precedents including M/s. Lalwani Estates & Realtors Pvt. Ltd. (ITA No. 3370/Mum/2023).
Accordingly, the entire additions were deleted.
Cases Discussed
- M/s. Lalwani Estates & Realtors Pvt. Ltd. v. Income Tax Officer — ITA No.3370/Mum/2023, order dated 08.03.2024 (ITAT Mumbai).
FULL TEXT OF THE ORDER OF ITAT MUMBAI
