https://www.taxtmi.com/caselaws?id=244137 The ITAT Mumbai held that the AO lacked jurisdiction to make additions under section 153A as no valid notice under section 143(2) was issued and the conditions for invoking section 153A were not met. Consequently, the additions under section 153A were deleted. Regarding additions under sections 68 and 2(22)(e), the Tribunal found that the alleged gift was actually a loan taken prior to the relevant assessment year and converted into a gift later, with the source admitted by the AO. The current year's profit was correctly excluded by the CIT(A), and no addition under section 2(22)(e) was warranted. The decision was in favor of the assessee. en-us Fri, 16 Nov 2012 00:00:00 +0530 Tue, 05 Aug 2025 14:50:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=244137 The ITAT Mumbai held that the AO lacked jurisdiction to make additions under section 153A as no valid notice under section 143(2) was issued and the conditions for invoking section 153A were not met. Consequently, the additions under section 153A were deleted. Regarding additions under sections 68 and 2(22)(e), the Tribunal found that the alleged gift was actually a loan taken prior to the relevant assessment year and converted into a gift later, with the source admitted by the AO. The current year's profit was correctly excluded by the CIT(A), and no addition under section 2(22)(e) was warranted. The decision was in favor of the assessee. Case-Laws Income Tax Fri, 16 Nov 2012 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=244137