PR COMMISSIONER OF INCOME TAX 27 MUMBAI vs ACCOST MEDIA LLP (AY 2021 22 ITA 4561 MUM 2024)

Judgment text excerpt

1 of 15 25.ITXA.753.2025.DOC IN THE HIGH COURT OF JUDICATURE AT BOMBAY ORDINARY ORIGINAL CIVIL JURISDICTION INCOME TAX APPEAL NO.753 OF 2025 Accost Media LLP Appellant versus Deputy Commissioner of Income Tax, Circle 27(1), Navi Mumbai-400071. Respondent WITH INCOME TAX APPEAL (L) NO.25904 OF 2025 Deputy Commissioner of Income Tax, Circle 27, Navi Mumbai-400071. Appellant versus Accost Media LLP Respondent _______ Mr.Gunjan Kakkad i/by Mint & Confreres for Appellant in ITXA.753/2025 and for Respondent in ITXA(L).25904/2025. Mr.Arjun Gupta for Revenue in both matters. _______ CORAM: G. S. KULKARNI & AARTI SATHE, JJ. DATE: 19th June 2026 ORAL JUDGMENT - (Per - Aarti Sathe, J.) :- 1. This Appeal has been filed by the Appellant-Assessee under Section 260A of the Income Tax Act, 1961 (hereinafter referred to as “the Act”) challenging the order dated 10th December 2024 (hereinafter referred to as the impugned order) passed by the Income Tax Appellate Tribunal (hereinafter referred to as “ITAT”) dismissing the Appeal bearing No. ITA No. 4553/MUM/2024 filed by the Appellant-Assessee before the ITAT. By way of the M.S.Thatte 2 of 15 25.ITXA.753.2025.DOC impugned order, the ITAT upheld the order passed by the Commissioner of Income Tax - Appeals (CIT(A)) dated 9 th July 2024, against which the Appellant- Assessee had filed the Appeal in the ITAT. The assessment year (A.Y.) in question is A.Y. 2021-2022. By the present Appeal the Appellant-Assessee has raised the following substantial questions of law - i. Whether on the facts and circumstances of the case and in law, the Tribunal has erred by not setting aside the assessment order which has been passed without complying with the mandatory provisions of section 144B of the Act? ii. Whether on the facts and in the circumstances of