ACIT v. Rajesh Jhaveri Stock Brokers Pvt. Ltd.

291 ITR 500Supreme Court of India2007#41 most cited

What is ACIT v. Rajesh Jhaveri Stock Brokers Pvt. Ltd. authority for?

For initiating reassessment proceedings under Section 147, the Assessing Officer needs only prima facie material providing a reason to believe that income has escaped assessment. Conclusive proof or the sufficiency/correctness of the material is not required at the stage of issuing the notice under Section 148.

1,030

judgments rely on this decision, according to BharatTax’s citation analysis of 367,164 Indian tax judgments — from 2008 to 2026.

Also referred to as

ACIT v. Rajesh Jhaveri Stock Brokers Pvt. Ltd. · Rajesh Jhaveri · 291 ITR 500 · Section 147 · Section 148 · reason to believe · income escaping assessment · prima facie material · tangible material · validity of reopening · initiation of reassessment · sufficiency of material

Sections most often in play

Section 147Section 148Section 143(3)Section 143(1)Section 142(1)Section 68Section 133ASection 143(2)
Read the full judgment

Issues it is cited on

section 147(a)fresh tangible materiallive linkmaterial facts necessary for assessmentmere change of opinionkelvinatortangible materialchange of opinionreason to believeescapement of incomeborrowed satisfactionincome escaping assessment

Judgments citing ACIT v. Rajesh Jhaveri Stock Brokers Pvt. Ltd.

M/S Grand Slam Pvt. Ltd., New Delhi vs. ITO, New Delhi

In the result, the appeal of the assessee is allowed partly for statistical purpose

ITA 1791/DEL/2013[2003-04]Status: DisposedITAT Delhi09 Jun 2017AY 2003-04

Bench: Sh. I.C. Sudhir & Sh. O.P. Kantassessment Year: 2003-04

Section 131Section 13aSection 143(1)Section 143(2)Section 147Section 148Section 68

…I.B.M. World Trade Corporation (1993) 115 CTR (Bom) 103 : (1995) 216 ITR 811 (Bom); Hindustan Lever Ltd. vs. R.B. Wadkar (2004) 190 CTR (Bom) 166 : (2004) 268 ITR 332 (Bom); Asstt. CIT vs. Rajesh Jhaveri Stock Brokers (P) Ltd. (2007) 210 CTR (SC) 30 : (2007) 291 ITR 500 (SC); SFIL Stock Broking Ltd. (2010) 325 ITR 285 ( Delhi); GKN Driveshafts (India) Ltd. vs. ITO & Ors. (2002) 257 ITR 702 (Delhi) Sarthak Securities Co. (P) Ltd. vs. ITO, Writ Petn. No. 6087 of 2010, decided on 18th Oct., 2010 [reported at (2010) 236 CTR (Del) 362 : (2010) 47 DTR (Del) 201—Ed.]. In the background of above decision, the Hon’ble Hi…

Ajay J Doshi (HUF), Mumbai vs. ITO 12(2)(4), Mumbai

In the result, the assessee’s appeal is allowed

ITA 121/MUM/2015[2005-06]Status: DisposedITAT Mumbai31 May 2017AY 2005-06

Bench: Shri Joginder Singh & Shri N.K. Pradhanassessment Year: 2005-06 Shri Ajay J. Doshi-Huf, Income Tax Officer-12(2)(4), 21, Marker Tower ‘L’ Aayakar Bhavan, बनाम/ G.D. Somani Marg, M.K. Road, Vs. Cuff Parade, Mumbai Mumbai-400005 ("नधा"रती /Assessee) (राज"व /Revenue) P.A. No.Aacha8912M

Section 143(1)Section 148Section 151

…आयकर अपील"य अ"धकरण, मुंबई "यायपीठ, सी, मुंबई । IN THE INCOME TAX APPELLATE TRIBUNAL MUMBAI BENCHES “C”, MUMBAI "ी जो"ग"दर "संह, "या"यक सद"य एवं "ी एन. के. "धान, लेखा सद"य, के सम" Before Shri Joginder Singh, Judicial Member, and Shri N.K. Pradhan, Accountant Member Assessment Year: 2005-06 Shri Ajay J. Doshi-HUF, Income Tax Officer-12(2)(4), 21, Marker Tower ‘L’ Aayakar Bhavan, बनाम/ G.D. Somani Marg, M.K. Road, Vs. Cuff Parade, Mumbai Mumbai-400005 ("नधा"रती /Assessee) (राज"व /Revenue) P.A. No.AACHA8912M "नधा"रती क" ओर से / Assessee by Shri Sashi Tulsiyan राज"व क" ओर से / Revenue by Shri Rajat Mittal -DR 04/05…

Kailashpati Overseas Pvt. Ltd., Delhi vs. ITO, New Delhi

In the result, the appeal is allowed for statistical purposes

ITA 1033/DEL/2013[2003-04]Status: DisposedITAT Delhi31 May 2017AY 2003-04

Bench: Shri R.S. Syal, Vice-Assessment Year : 2003-04 Kailashpati Overseas Pvt. Ltd., Vs. Ito, C/O Kapil Goel, Advocate, Ward 5(1), A-1/25, Sector-15, Rohini, New Delhi. Delhi. Pan : Aaack1244M

For Appellant: Shri Kapil Goel &For Respondent: Ms Bedobani, DR
Section 131Section 133(6)Section 142(1)Section 148Section 68

…eve about the escapement of income at the stage of initiation of reassessment proceedings. Sufficiency or correctness of such material cannot be considered at that stage. The Hon’ble Apex Court has held in ACIT vs. Rajesh Jhaveri Stock Broker (P) Ltd. (2007) 291 ITR 500 (SC) that : `The word "reason" in the phrase "reason to believe" would mean cause or justification. If the AO has cause or justification to know or suppose that income had escaped assessment, it can be said to have reason to believe that an income had escaped assessment. The expression cannot be read to mean that the AO should have finally ascer…

Pitney Bowes India (P) Ltd., New Delhi vs. DCIT, New Delhi

In the result, out of the five appeals of the assessee, the ITA Nos

ITA 289/DEL/2013[2005-06]Status: DisposedITAT Delhi29 May 2017AY 2005-06

Bench: Sh. I.C. Sudhir & Sh. O.P. Kant

Section 143(3)Section 147Section 32

…IN THE INCOME TAX APPELLATE TRIBUNAL DELHI BENCH: ‘F’, NEW DELHI BEFORE SH. I.C. SUDHIR, JUDICIAL MEMBER AND SH. O.P. KANT, ACCOUNTANT MEMBER ITA Nos. 289 to 293/Del/2013 Assessment Years: 2005-06 to 2009-10 Vs. DCIT, Circle-14(1) / Addl.CIT, M/s. Pitney Bowes India (P) Ltd., 2nd Floor, 45, Okhla Industrial Range-14 / Income Tax Officer, Estate, Phase-III, New Delhi Ward -14(3), New Delhi PAN : AADCP3417C (Appellant) (Respondent) Appellant by S/sh. G.C. Srivastava, Adv.; Manoneet Dalal, Adv.; Anubhav Jain and Anshul Kumar, CA Respondent by Sh. F.R. Meena, Sr.DR Date of hearing 30.03.2017 Date of pronouncement 29.…

ITO 22(3)(1), Navi Mumbai vs. Crescent Construction, Navi Mumbai

The appeal of the assessee is allowed and of the Revenue is dismissed

ITA 865/MUM/2014[2005-06]Status: DisposedITAT Mumbai26 May 2017AY 2005-06

Bench: Shri Joginder Singh & Shri N.K. Pradhanassessment Year: 2005-06

Section 14Section 143(1)Section 143(2)Section 143(3)Section 147Section 154

…, 20, 48) CIT v. Kelvinator of India Ltd. [2010] 320 ITR 561 (SC) (paras 2, 28) CIT v. Khemchand Ramdas [1938] 6 ITR 414 (PC) (para 50) CIT v. P. V. S. Beedies P. Ltd. [1999] 237 ITR 13 (SC) (para 18) CIT (Asst.) v. Rajesh Jhaveri Stock Brokers P. Ltd. [2007] 291 ITR 500 (SC) (paras 4, 12) CIT v. Sharma (H. P.) [1980] 122 ITR 675 (Delhi) (para 9) Consolidated Photo and Finvest Ltd. v. Asst.CIT [2006] 281 ITR 394 (Delhi) (paras 9, 11) Dalmia P. Ltd. v. CIT [2012] 348 ITR 469 (Delhi) (para 17) G. R. Ramachari and Co. v. CIT [1961] 41 ITR 142 (Mad) (paras 38, 61) Hari Iron Trading Co. v. CIT [2003] 263 ITR 437 (P&H)…

Crescent Construction Co., Navi Mumbai vs. Asst CIT 22(3), Navi Mumbai

The appeal of the assessee is allowed and of the Revenue is dismissed

ITA 658/MUM/2014[2005-06]Status: DisposedITAT Mumbai26 May 2017AY 2005-06

Bench: Shri Joginder Singh & Shri N.K. Pradhanassessment Year: 2005-06

Section 14Section 143(1)Section 143(2)Section 143(3)Section 147Section 154

…, 20, 48) CIT v. Kelvinator of India Ltd. [2010] 320 ITR 561 (SC) (paras 2, 28) CIT v. Khemchand Ramdas [1938] 6 ITR 414 (PC) (para 50) CIT v. P. V. S. Beedies P. Ltd. [1999] 237 ITR 13 (SC) (para 18) CIT (Asst.) v. Rajesh Jhaveri Stock Brokers P. Ltd. [2007] 291 ITR 500 (SC) (paras 4, 12) CIT v. Sharma (H. P.) [1980] 122 ITR 675 (Delhi) (para 9) Consolidated Photo and Finvest Ltd. v. Asst.CIT [2006] 281 ITR 394 (Delhi) (paras 9, 11) Dalmia P. Ltd. v. CIT [2012] 348 ITR 469 (Delhi) (para 17) G. R. Ramachari and Co. v. CIT [1961] 41 ITR 142 (Mad) (paras 38, 61) Hari Iron Trading Co. v. CIT [2003] 263 ITR 437 (P&H)…

Lodha Building and Construction P.Ltd, Mumbai vs. DCIT Cen Cir 7(3), Mumbai

In the result, all the appeals of the assessee are allowed

ITA 5511/MUM/2016[2008-09]Status: DisposedITAT Mumbai17 May 2017AY 2008-09

Bench: Shri D.T. Garasia & Shri N.K. Pradhanassessment Year: 2009-10

Section 143(3)Section 147Section 148Section 245CSection 245D(1)

…the case for A Y 2008-09, hence reopening the same within the meaning of section 147 does not need to meet the stringent requirements of proviso to section 147/148. Reliance is placed on the case law in the case of ACIT v. Rajesh Jhaveri Stock Brokers P. Ltd 291 ITR 500(SC). Hence, I have reason to believe that income chargeable to tax has escaped assessment for AY 2008-09 in the case of the assessee within the meaning of section 147 of the Income-tax Act, 1961” 3. The assessee has filed the writ before the High Court and it was dismissed. The notice was issued and assessee did not object the proceedings initia…

Ashtavinayak Estate Company P. Ltd, Mumbai vs. DCIT Cen Cir 7(3), Mumbai

In the result, all the appeals of the assessee are allowed

ITA 5510/MUM/2016[2008-09]Status: DisposedITAT Mumbai17 May 2017AY 2008-09

Bench: Shri D.T. Garasia & Shri N.K. Pradhanassessment Year: 2009-10

Section 143(3)Section 147Section 148Section 245CSection 245D(1)

…the case for A Y 2008-09, hence reopening the same within the meaning of section 147 does not need to meet the stringent requirements of proviso to section 147/148. Reliance is placed on the case law in the case of ACIT v. Rajesh Jhaveri Stock Brokers P. Ltd 291 ITR 500(SC). Hence, I have reason to believe that income chargeable to tax has escaped assessment for AY 2008-09 in the case of the assessee within the meaning of section 147 of the Income-tax Act, 1961” 3. The assessee has filed the writ before the High Court and it was dismissed. The notice was issued and assessee did not object the proceedings initia…

Lodha Land Developers P. Ltd, Mumbai vs. DCIT Cen Cir 7(3), Mumbai

In the result, all the appeals of the assessee are allowed

ITA 5508/MUM/2016[2007-08]Status: DisposedITAT Mumbai17 May 2017AY 2007-08

Bench: Shri D.T. Garasia & Shri N.K. Pradhanassessment Year: 2009-10

Section 143(3)Section 147Section 148Section 245CSection 245D(1)

…the case for A Y 2008-09, hence reopening the same within the meaning of section 147 does not need to meet the stringent requirements of proviso to section 147/148. Reliance is placed on the case law in the case of ACIT v. Rajesh Jhaveri Stock Brokers P. Ltd 291 ITR 500(SC). Hence, I have reason to believe that income chargeable to tax has escaped assessment for AY 2008-09 in the case of the assessee within the meaning of section 147 of the Income-tax Act, 1961” 3. The assessee has filed the writ before the High Court and it was dismissed. The notice was issued and assessee did not object the proceedings initia…

Lodha Designed Construction P. Ltd, Mumbai vs. DCIT Cen Cir 7(3), Mumbai

In the result, all the appeals of the assessee are allowed

ITA 5507/MUM/2016[2008-09]Status: DisposedITAT Mumbai17 May 2017AY 2008-09

Bench: Shri D.T. Garasia & Shri N.K. Pradhanassessment Year: 2009-10

Section 143(3)Section 147Section 148Section 245CSection 245D(1)

…the case for A Y 2008-09, hence reopening the same within the meaning of section 147 does not need to meet the stringent requirements of proviso to section 147/148. Reliance is placed on the case law in the case of ACIT v. Rajesh Jhaveri Stock Brokers P. Ltd 291 ITR 500(SC). Hence, I have reason to believe that income chargeable to tax has escaped assessment for AY 2008-09 in the case of the assessee within the meaning of section 147 of the Income-tax Act, 1961” 3. The assessee has filed the writ before the High Court and it was dismissed. The notice was issued and assessee did not object the proceedings initia…

Lodha Designed Construction P. Ltd, Mumbai vs. DCIT Cen Cir 7(3), Mumbai

In the result, all the appeals of the assessee are allowed

ITA 5506/MUM/2016[2009-10]Status: DisposedITAT Mumbai17 May 2017AY 2009-10

Bench: Shri D.T. Garasia & Shri N.K. Pradhanassessment Year: 2009-10

Section 143(3)Section 147Section 148Section 245CSection 245D(1)

…the case for A Y 2008-09, hence reopening the same within the meaning of section 147 does not need to meet the stringent requirements of proviso to section 147/148. Reliance is placed on the case law in the case of ACIT v. Rajesh Jhaveri Stock Brokers P. Ltd 291 ITR 500(SC). Hence, I have reason to believe that income chargeable to tax has escaped assessment for AY 2008-09 in the case of the assessee within the meaning of section 147 of the Income-tax Act, 1961” 3. The assessee has filed the writ before the High Court and it was dismissed. The notice was issued and assessee did not object the proceedings initia…

Anantnath Constructoins and Farms P.Ltd, Mumbai vs. DCIT Cen Cir 7(3), Mumbai

In the result, all the appeals of the assessee are allowed

ITA 5505/MUM/2016[2009-10]Status: DisposedITAT Mumbai17 May 2017AY 2009-10

Bench: Shri D.T. Garasia & Shri N.K. Pradhanassessment Year: 2009-10

Section 143(3)Section 147Section 148Section 245CSection 245D(1)

…the case for A Y 2008-09, hence reopening the same within the meaning of section 147 does not need to meet the stringent requirements of proviso to section 147/148. Reliance is placed on the case law in the case of ACIT v. Rajesh Jhaveri Stock Brokers P. Ltd 291 ITR 500(SC). Hence, I have reason to believe that income chargeable to tax has escaped assessment for AY 2008-09 in the case of the assessee within the meaning of section 147 of the Income-tax Act, 1961” 3. The assessee has filed the writ before the High Court and it was dismissed. The notice was issued and assessee did not object the proceedings initia…

Dr.K.Sridhara, Chennai vs. Ait, Chennai

In the result, appeal of the assessee is allowed

ITA 1388/CHNY/2016[2005-06]Status: DisposedITAT Chennai03 May 2017AY 2005-06

Bench: Shri Abraham P. George]

For Appellant: Shri. T. Banusekar, C.AFor Respondent: Shri. M. Murali Mohan, JCIT
Section 143(1)Section 148

…d to in the reasons. As per ld. Departmental :- 4 -: Representative , original assessment was only a processing under section 143(1) of the Act and by virtue of the judgment of Hon’ble Apex Court in the case of ACIT vs. Rajesh Jhaveri Stock Brokers P. Ltd, 291 ITR 500, the reopening was valid. I have considered the rival contentions and perused the 4. orders. Housing loan interest claimed by the assessee against the self occupied property was "1,15,647/- and per paper book page 4 which gives the computation of income filed. Notice for reopening was dated 29.03.2012. Reasons for the reopening given by the l…

ACIT, New Delhi vs. M/S Pacl India Ltd., Jaipur

In the result, the appeal of the Revenue is allowed partly for statistical purposes, whereas appeal of the assessee is allowed for statistical purpose

ITA 3779/DEL/2011[2007-08]Status: DisposedITAT Delhi28 Apr 2017AY 2007-08

Bench: Sh. I.C. Sudhir & Sh. O.P. Kant

Section 143Section 143(3)Section 153A

…formation received subsequent to the passing of original assessment order constituted valid and sufficient ground for reopening. It is well settled law, as has been held by Apex Court in the case of ACIT vs. Rajesh Jhaveri Stock Brokers Pvt. Ltd. reported in (291 ITR 500) that “section 147 authorises and permits the Assessing Officer to assess or reassess income chargeable to tax if he has reason to believe that income for any assessment year has escaped assessment”. It was further held as under: “The word "reason" in the phrase "reason to believe" would mean cause or justification. If the Assessing Officer has c…

Pacl India Ltd., New Delhi vs. ACIT, Delhi

In the result, the appeal of the Revenue is allowed partly for statistical purposes, whereas appeal of the assessee is allowed for statistical purpose

ITA 2894/DEL/2010[2001-02]Status: DisposedITAT Delhi28 Apr 2017AY 2001-02

Bench: Sh. I.C. Sudhir & Sh. O.P. Kant

Section 143Section 143(3)Section 153A

…formation received subsequent to the passing of original assessment order constituted valid and sufficient ground for reopening. It is well settled law, as has been held by Apex Court in the case of ACIT vs. Rajesh Jhaveri Stock Brokers Pvt. Ltd. reported in (291 ITR 500) that “section 147 authorises and permits the Assessing Officer to assess or reassess income chargeable to tax if he has reason to believe that income for any assessment year has escaped assessment”. It was further held as under: “The word "reason" in the phrase "reason to believe" would mean cause or justification. If the Assessing Officer has c…

Usha Anandan, Chennai vs. ITO, Chennai

In the result, appeals of the assessee are allowed

ITA 434/CHNY/2017[2006-07]Status: DisposedITAT Chennai26 Apr 2017AY 2006-07

Bench: Shri Abraham P. George]

For Appellant: Shri.M. Murali Mohan, IRS, JCIT
Section 139Section 143(1)Section 148Section 27

…Shri. V. Anandan. Further, according to him, for assessment year 2010-2011, assessee had not filed a return within the time allowed u/s.139 of the Act. Relying on the judgment of Hon’ble Apex Court in the case of ACIT vs. Rajesh Jhaveri Stock Brokers P. Ltd 291 ITR 500, ld. Departmental Representative submitted that original assessment having been completed u/s.143(1) of the Act, the reopening done for the impugned assessment years were valid. I have considered the rival contentions and perused the 5. orders of the authorities below. Reasons given by the ld. Assessing Officer for reopening the assessment fo…

Suresh L. Satyani, Mumbai vs. ITO 23(3)(4), Mumbai

In the result, appeal filed by the assessee in ITA No

ITA 3452/MUM/2016[2010-11]Status: DisposedITAT Mumbai25 Apr 2017AY 2010-11

Bench: Shri C.N. Prasad & Shri Ramit Kochar

For Appellant: Shri Biren GabhawalaFor Respondent: Shri B.S. Bist, DR
Section 143(1)Section 143(2)Section 143(3)Section 147Section 148

…tune of Rs. 19,31,040/-. The original return was processed u/s 143(1) of the Act, and thus no opinion was formed and hence there is no change of opinion. Reliance is placed on the decision of Hon’ble Supreme Court in the case of ACIT v. Rajesh Jhaveri, (2007) 291 ITR 500 (SC), wherein Hon’ble Supreme Court vide orders dated 23-05-2007 has held as under : “11. It is to be noted that substantial changes have been made to section 143(1) with effect from June 1, 1999. Up to March 31, 1989, after a return of income was filed the Assessing Officer could make an assessment under section 143(1) without requiring the pre…

M/S. Shri Shaym Sunder Infrastructure (P) Ltd., New Delhi vs. ACIT, New Delhi

In the result, the appeal of the assessee is allowed in the manner as indicated above

ITA 6216/DEL/2013[2005-06]Status: DisposedITAT Delhi07 Apr 2017AY 2005-06

Bench: Shri Chandra Mohan Garg & Shri L.P. Sahu

For Appellant: Shri Sanjeev Bindal, AdvFor Respondent: Shri S.S. Rana, CIT DR
Section 153ASection 68

…IN THE INCOME TAX APPELLATE TRIBUNAL DELHI BENCH: ‘G’: NEW DELHI BEFORE SHRI CHANDRA MOHAN GARG, JUDICIAL MEMBER, AND SHRI L.P. SAHU, ACCOUNTANT MEMBER, ITA No. 6216/Del /2013 Assessment Year: 2005-06 Shri Shyam Sunder Infrastructure [P] Ltd Vs. The A.C.I.T G – 18 & 19, Mamram Majesty Mall Central Circle –15 Plot No. 2, Road No. 43, Guru Harkishan Marg New Delhi Pitampura, Delhi PAN : AAECM 1207G [Appellant] [Respondent] Date of Hearing : 12.01.2017 Date of Pronouncement : 07.04.2017 Appellant by : Shri Sanjeev Bindal, Adv Respondent by : Shri S.S. Rana, CIT DR ORDER PER CHANDRA MOHAN GARG, JUDICIAL MEM…

Ratnagiri Stainless P. Ltd, Mumbai vs. ITO 5(3)(1), Mumbai

In the result, appeal filed by the assessee in ITA No

ITA 4463/MUM/2016[2009-10]Status: DisposedITAT Mumbai04 Apr 2017AY 2009-10

Bench: Shri C.N. Prasad & Shri Ramit Kocharआयकर अपील सं./I.T.A. No. 4463/Mum/2016 ("नधा"रण वष" / Assessment Year : 2009-10) M/S Ratnagiri Stainless Pvt. Income Tax Officer 5(3)(1), बनाम/ Ltd., Mumbai. V. 21/23, Laxmi Niwas, 2 Nd Parsiwada Lane, Opp V.P. Road Police Station, Mumbai – 400 004. "थायी लेखा सं./Pan : Aadcr2993P (अपीलाथ" /Appellant) .. (""यथ" / Respondent)

For Appellant: Shri N.M. PorwalFor Respondent: Ms. Pooja Swaroop,DR
Section 143(3)Section 147Section 148Section 234A

…ne of Rs. 2,39,83,261/-. The original return was processed u/s 143(1) of the Act, and thus no opinion was formed and hence there is no change of opinion. Reliance is placed on the decision of Hon’ble Supreme Court in the case of ACIT v. Rajesh Jhaveri, (2007) 291 ITR 500 (SC), wherein Hon’ble Supreme Court vide orders dated 23-05-2007 has held as under : “11. It is to be noted that substantial changes have been made to section 143(1) with effect from June 1, 1999. Up to March 31, 1989, after a return of income was filed the Assessing Officer could make an assessment under section 143(1) without requiring the pre…

Disha N . Lalwani, Mumbai vs. ITO WD 23(2)(2), Mumbai

The appeal of the assessee is dismissed

ITA 6398/MUM/2012[2003-04]Status: DisposedITAT Mumbai22 Mar 2017AY 2003-04

Bench: Shri Joginder Singh & Shri N.K. Pradhanassessment Year: 2003-04 Disha N. Lalwani, Income Tax Officer- J-301, Vardhaman Nagar 23(2)(2), बनाम/ Jn. Of R.P. Rd. & M.G. Rd. C-10-Pratyakshkar Vs. Mulund (W), Bhavan, 02Nd Floor, Mumbai-400080 Bandra Kurla Complex, Bandra, Mumbai-400007 ("नधा"रती/Assessee) (राज"व /Revenue) P.A. No. Aaapl6056H

Section 143(1)Section 143(3)Section 147Section 148

…आयकर अपील"य अ"धकरण, मुंबई "यायपीठ, डी, मुंबई । IN THE INCOME TAX APPELLATE TRIBUNAL MUMBAI BENCHES “D”, MUMBAI "ी जो"ग"दर "संह, "या"यक सद"य एवं "ी एन. के. "धान, लेखा सद"य, के सम" Before Shri Joginder Singh, Judicial Member, and Shri N.K. Pradhan, Accountant Member Assessment Year: 2003-04 Disha N. Lalwani, Income Tax Officer- J-301, Vardhaman Nagar 23(2)(2), बनाम/ JN. Of R.P. Rd. & M.G. Rd. C-10-Pratyakshkar Vs. Mulund (W), Bhavan, 02nd Floor, Mumbai-400080 Bandra Kurla Complex, Bandra, Mumbai-400007 ("नधा"रती/Assessee) (राज"व /Revenue) P.A. No. AAAPL6056H "नधा"रती क" ओर से / Assessee by Shri M. Subramanian S…