https://www.taxtmi.com/caselaws?id=774976 ITAT Mumbai dismissed multiple grounds raised by the assessee challenging the validity of notice u/s.148 issued by jurisdictional AO instead of faceless AO, and notice issued with incorrect sanction u/s.151 lacking valid DIN. The tribunal held both notices were valid, following precedent in J Kumar Infraprojects Ltd. case. Regarding substantive additions, ITAT sustained 12.50% disallowance for bogus purchases and confirmed Rs. 7.93 lakhs addition u/s.69C for unexplained expenditure based on diary entries from search action. However, protective additions u/s.69A for unexplained money and gold investments were deleted, as substantive additions were already made in related corporate entity's case. For long-term capital gains on property sale, ITAT directed AO to re-compute by including disputed amount as sale consideration rather than treating it u/s.69A. The tribunal found no evidence supporting cash purchase of gold bars, accepting assessee's explanation that diary entries related to business cash transfers. Overall, the appeal was partly allowed with directions for consequential relief. en-us Thu, 03 Jul 2025 00:00:00 +0530 Thu, 17 Jul 2025 08:19:12 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=774976 ITAT Mumbai dismissed multiple grounds raised by the assessee challenging the validity of notice u/s.148 issued by jurisdictional AO instead of faceless AO, and notice issued with incorrect sanction u/s.151 lacking valid DIN. The tribunal held both notices were valid, following precedent in J Kumar Infraprojects Ltd. case. Regarding substantive additions, ITAT sustained 12.50% disallowance for bogus purchases and confirmed Rs. 7.93 lakhs addition u/s.69C for unexplained expenditure based on diary entries from search action. However, protective additions u/s.69A for unexplained money and gold investments were deleted, as substantive additions were already made in related corporate entity's case. For long-term capital gains on property sale, ITAT directed AO to re-compute by including disputed amount as sale consideration rather than treating it u/s.69A. The tribunal found no evidence supporting cash purchase of gold bars, accepting assessee's explanation that diary entries related to business cash transfers. Overall, the appeal was partly allowed with directions for consequential relief. Case-Laws Income Tax Thu, 03 Jul 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=774976