2026 (3) TMI 384

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....1.2025. The impugned orders emanated from the order of the Ld. Income Tax Officer, TDS Ward 2(2)(4), Mumbai [hereinafter referred to as "Ld. AO"] order passed u/s. 201(1)/201(1A) of the Act, date of all the orders 27.06.2024. 2. Since all the appeals pertain to the same assessee, involving similar issues arising out of a similar factual matrix, these appeals were heard together as a matter of convenience and are being decided by way of this consolidated order. With the consent of the parties, ITA No. 8284/Mum/2025 is taken as lead case and the decision rendered therein shall apply mutatis mutandis to other appeal before us. 3. The brief facts of the case are that the assessee is a Limited Liability Partnership (LLP) engaged in the bus....

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....bmitted that the assessee has placed additional evidence on record on the ground that the deductee has already discharged the tax liability on the said income. Accordingly, the additional evidence has been filed before the Bench along with a detailed list and supporting documents, which are reproduced hereunder. Sr. No. Nature of Documents Page No. From To 1 Extract of ITR Form filed for the A.Y. 2022-23 in the case of Shri. Aditya Javeri 01 04 2 Extract of ITR Form filed for the A.Y. 2021-22 in the case of Smt. Asha Pendurkar 05 08 3 Extract of ITR Form filed for the A.Y. 2022-23 & A.Y. 2021-22 in the case of Smt. Mangala Madkikar 09 19 4 Extract of ITR Form filed for the A.Y. 2021-2....

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....n certificate was obtained during the said AY. However, before us no new material is brought on record to substantiate that the income offered in AY 2024-25 includes capital gains. We notice in this regard that the FAA has upheld the order of the AO for the same reason that the assessee did not submit any details in this regard. Therefore, we are remitting the appeal back to AO with a direction to verify the claim of the assessee that Shri PremalDayalalDoshi has offered the impugned payments to tax in AY 2024-25. The AO is further directed to allow the claim if supported by evidences as may be submitted by the assessee and not to deny the claim on the ground that Form 26A has not been filed for the years under consideration taking into acco....