Capital G LP v. ACIT, Abhin Anil Kumar Shah v. ITO

MR. SACHIV SAHNI,MUMBAI vs. ACIT, CC-2(3), MUMBAI

In the result the appeal filed by the assessee stands partly allowed statistical purposes

Bench: Shri Sandeep Gosain & Shri Omkareshwar Chidara

…aid down by the Hon'ble Bombay High Court in Hexaware Technologies Ltd. v. ACIT has since been consistently followed by the same Court in Capital G LP v. ACIT, Abhin Anil Kumar Shah v. ITO [(2024) 468 ITR 350 (Bom)), and Ganesh Nivrutti Jagtap v. ACIT [(2024) 166 Taxmann.com 168 (Bom)], thereby fortifying the principle that the faceless assessment regime under section 151A is not a matter of administrative convenience but a jurisdictional imperative. The High Court in these decisions has unambiguously held that once jurisdiction is statutorily vested in the Faceless Assessing Officer, any notice issued by the Jur…

MR. SACHIV SAHNI,MUMBAI vs. ACIT, CC-2(3), MUMBAI

In the result the appeal filed by the assessee stands partly allowed statistical purposes

Bench: Shri Sandeep Gosain & Shri Omkareshwar Chidara

…aid down by the Hon'ble Bombay High Court in Hexaware Technologies Ltd. v. ACIT has since been consistently followed by the same Court in Capital G LP v. ACIT, Abhin Anil Kumar Shah v. ITO [(2024) 468 ITR 350 (Bom)), and Ganesh Nivrutti Jagtap v. ACIT [(2024) 166 Taxmann.com 168 (Bom)], thereby fortifying the principle that the faceless assessment regime under section 151A is not a matter of administrative convenience but a jurisdictional imperative. The High Court in these decisions has unambiguously held that once jurisdiction is statutorily vested in the Faceless Assessing Officer, any notice issued by the Jur…

MR. SACHIV SAHNI,MUMBAI vs. ACIT, CC-2(3), MUMBAI

In the result the appeal filed by the assessee stands partly allowed statistical purposes

Bench: Shri Sandeep Gosain & Shri Omkareshwar Chidara

…aid down by the Hon'ble Bombay High Court in Hexaware Technologies Ltd. v. ACIT has since been consistently followed by the same Court in Capital G LP v. ACIT, Abhin Anil Kumar Shah v. ITO [(2024) 468 ITR 350 (Bom)), and Ganesh Nivrutti Jagtap v. ACIT [(2024) 166 Taxmann.com 168 (Bom)], thereby fortifying the principle that the faceless assessment regime under section 151A is not a matter of administrative convenience but a jurisdictional imperative. The High Court in these decisions has unambiguously held that once jurisdiction is statutorily vested in the Faceless Assessing Officer, any notice issued by the Jur…

VEDA REAL ESTATE CORPORATION PRIVATE LIMITED,MUMBAI vs. DEPUTY COMMISSIONER OF INCOME TAX CENTRAL CIRCLE -8(1), MUMBAI

In the result, the appeal filed by the assessee stands allowed

Bench: Hon’Ble Shri Sandeep Gosain& Hon’Ble Shri Om Prakash Kant

…ombay High Court in Hexaware Technologies Ltd. v. ACIT (supra), which has been consistently followed in Capital G LP v. ACIT (Writ Petition No. 15289 of 2024), Abhin Anil Kumar Shah v. ITO [(2024) 468 ITR 350 (Bom)], and Ganesh Nivrutti Jagtap v. ACIT [(2024) 166 Taxmann.com 168 (Bom)). The dismissal of the Special Leave Petition by the Hon'ble Supreme Court in Deepanjan Roy v. ADIT [SLP (C) No. 18753/2025] lends further imprimatur to this legal position. Thus, we have no 12 Veda Real Estate Corporation Private Limited0 hesitation in holding that the reassessment orders impugned before us are void ab initio, bo…

VEDA REAL ESTATE CORPORATION PRIVATE LIMITED,MUMBAI vs. DEPUTY COMMISSIONER OF INCOME TAX CENTRAL CIRCLE -8(1), MUMBAI

In the result, the appeal filed by the assessee stands allowed

Bench: Hon’Ble Shri Sandeep Gosain& Hon’Ble Shri Om Prakash Kant

…ombay High Court in Hexaware Technologies Ltd. v. ACIT (supra), which has been consistently followed in Capital G LP v. ACIT (Writ Petition No. 15289 of 2024), Abhin Anil Kumar Shah v. ITO [(2024) 468 ITR 350 (Bom)], and Ganesh Nivrutti Jagtap v. ACIT [(2024) 166 Taxmann.com 168 (Bom)). The dismissal of the Special Leave Petition by the Hon'ble Supreme Court in Deepanjan Roy v. ADIT [SLP (C) No. 18753/2025] lends further imprimatur to this legal position. Thus, we have no 12 Veda Real Estate Corporation Private Limited0 hesitation in holding that the reassessment orders impugned before us are void ab initio, bo…

VEDA REAL ESTATE CORPORATION PRIVATE LIMITED,MUMBAI vs. DEPUTY COMMISSIONER OF INCOME TAX CENTRAL CIRCLE -8(1), MUMBAI

In the result, the appeal filed by the assessee stands allowed

Bench: Hon’Ble Shri Sandeep Gosain& Hon’Ble Shri Om Prakash Kant

…ombay High Court in Hexaware Technologies Ltd. v. ACIT (supra), which has been consistently followed in Capital G LP v. ACIT (Writ Petition No. 15289 of 2024), Abhin Anil Kumar Shah v. ITO [(2024) 468 ITR 350 (Bom)], and Ganesh Nivrutti Jagtap v. ACIT [(2024) 166 Taxmann.com 168 (Bom)). The dismissal of the Special Leave Petition by the Hon'ble Supreme Court in Deepanjan Roy v. ADIT [SLP (C) No. 18753/2025] lends further imprimatur to this legal position. Thus, we have no 12 Veda Real Estate Corporation Private Limited0 hesitation in holding that the reassessment orders impugned before us are void ab initio, bo…

VEDA REAL ESTATE CORPORATION PRIVATE LIMITED ,MUMBAI vs. DEPUTY COMMISSIONER OF INCOME TAX CENTRAL CIRCLE -8(1), MUMBAI

In the result, the appeal filed by the assessee stands allowed

Bench: Hon’Ble Shri Sandeep Gosain& Hon’Ble Shri Om Prakash Kant

…ombay High Court in Hexaware Technologies Ltd. v. ACIT (supra), which has been consistently followed in Capital G LP v. ACIT (Writ Petition No. 15289 of 2024), Abhin Anil Kumar Shah v. ITO [(2024) 468 ITR 350 (Bom)], and Ganesh Nivrutti Jagtap v. ACIT [(2024) 166 Taxmann.com 168 (Bom)). The dismissal of the Special Leave Petition by the Hon'ble Supreme Court in Deepanjan Roy v. ADIT [SLP (C) No. 18753/2025] lends further imprimatur to this legal position. Thus, we have no 12 Veda Real Estate Corporation Private Limited0 hesitation in holding that the reassessment orders impugned before us are void ab initio, bo…

DCIT, CENTRAL CIRCLE-8(1), MUMBAI, MUMBAI vs. EI RESORTS & CLUBS PVT LTD, MUMBAI

3213/Mum/2025

Bench: SHRI AMIT SHUKLA (Judicial Member), SHRI ARUN KHODPIA (Accountant Member)

…aid down by the Hon‟ble Bombay High Court in Hexaware Technologies Ltd. v. ACIT has since been consistently followed by the same Court in Capital G LP v. ACIT, Abhin Anil Kumar Shah v. ITO [(2024) 468 ITR 350 (Bom)], and Ganesh Nivrutti Jagtap v. ACIT [(2024) 166 Taxmann.com 168 (Bom)], thereby fortifying the principle that the faceless assessment regime under section 151A is not a matter of administrative convenience but a jurisdictional imperative. The High Court in these decisions has unambiguously held that once jurisdiction is statutorily vested in the Faceless Assessing Officer, any notice issued by the Jur…

DCIT, CENTRAL CIRCLE-8(1), MUMBAI, MUMBAI vs. E I RESORTS AND CLUBS PVT LTD, MUMBAI

3213/Mum/2025

Bench: SHRI AMIT SHUKLA (Judicial Member), SHRI ARUN KHODPIA (Accountant Member)

…aid down by the Hon‟ble Bombay High Court in Hexaware Technologies Ltd. v. ACIT has since been consistently followed by the same Court in Capital G LP v. ACIT, Abhin Anil Kumar Shah v. ITO [(2024) 468 ITR 350 (Bom)], and Ganesh Nivrutti Jagtap v. ACIT [(2024) 166 Taxmann.com 168 (Bom)], thereby fortifying the principle that the faceless assessment regime under section 151A is not a matter of administrative convenience but a jurisdictional imperative. The High Court in these decisions has unambiguously held that once jurisdiction is statutorily vested in the Faceless Assessing Officer, any notice issued by the Jur…

EI BENEFICIARY TRUST ,MUMBAI vs. DEPUTY COMMISSIONER OF INCOME TAX CENTRAL CIRCLE -8(1), MUMBAI

…as\n\n34\nITA No.3230/Mum/2025& Others\nGovind Corporation & Others\n\nbeen consistently followed in Capital G LP v. ACIT (Writ\nPetition No. 15289 of 2024), Abhin Anil Kumar Shah v.\nΙΤΟ [(2024) 468 ITR 350 (Bom)], and Ganesh Nivrutti\nJagtap v. ACIT [(2024) 166 Taxmann.com 168 (Bom)]. The\ndismissal of the Special Leave Petition by the Hon'ble\nSupreme Court in Deepanjan Roy v. ADIT [SLP (C) No.\n18753/2025] lends further imprimatur to this legal position.\nThus, we have no hesitation in holding that the reassessment\norders impugned before us are void ab initio, both for want of\njurisdiction\nrequire.57.\nand…

EI BENEFICIARY TRUST ,MUMBAI vs. DEPUTY COMMISSIONER OF INCOME TAX CENTRAL CIRCLE -8(1), MUMBAI

…hich has\n34\nITA No.3230/Mum/2025 & Others\nGovind Corporation & Others\nbeen consistently followed in Capital G LP v. ACIT (Writ Petition No. 15289 of 2024), Abhin Anil Kumar Shah v. ITO [(2024) 468 ITR 350 (Bom)], and Ganesh Nivrutti Jagtap v. ACIT [(2024) 166 Taxmann.com 168 (Bom)]. The dismissal of the Special Leave Petition by the Hon'ble Supreme Court in Deepanjan Roy v. ADIT [SLP (C) No. 18753/2025] lends further imprimatur to this legal position. Thus, we have no hesitation in holding that the reassessment orders impugned before us are void ab initio, both for want of jurisdiction and for breach of manda…

EI BENEFICARY TRUST ,MUMBAI vs. DEPUTY COMMISSIONER OF INCOME TAX CENTRAL CIRCLE -8(1), MUMBAI

3230/Mum/2025 Govind

Bench: SHRI AMIT SHUKLA (Judicial Member), SHRI ARUN KHODPIA (Accountant Member)

…ombay High Court in Hexaware Technologies Ltd. v. ACIT (supra), which has been consistently followed in Capital G LP v. ACIT (Writ Petition No. 15289 of 2024), Abhin Anil Kumar Shah v. ITO [(2024) 468 ITR 350 (Bom)], and Ganesh Nivrutti Jagtap v. ACIT [(2024) 166 Taxmann.com 168 (Bom)]. The dismissal of the Special Leave Petition by the Hon’ble Supreme Court in Deepanjan Roy v. ADIT [SLP (C) No. 18753/2025] lends further imprimatur to this legal position. Thus, we have no hesitation in holding that the reassessment orders impugned before us are void ab initio, both for want of jurisdiction and for breach of manda…

GOVIND CORPORATION,MUMBAI vs. DEPUTY COMMISSIONER OF INCOME TAX CENTRAL CIRCLE -8(1), MUMBAI

…as\n\n30\nITA No.3230/Mum/2025& Others\nGovind Corporation & Others\n\nbeen consistently followed in Capital G LP v. ACIT (Writ\nPetition No. 15289 of 2024), Abhin Anil Kumar Shah v.\nΙΤΟ [(2024) 468 ITR 350 (Bom)], and Ganesh Nivrutti\nJagtap v. ACIT [(2024) 166 Taxmann.com 168 (Bom)]. The\ndismissal of the Special Leave Petition by the Hon'ble\nSupreme Court in Deepanjan Roy v. ADIT [SLP (C) No.\n18753/2025] lends further imprimatur to this legal position.\nThus, we have no hesitation in holding that the reassessment\norders impugned before us are void ab initio, both for want of\njurisdiction\nrequire.57.\nand…

GOVIND CORPORATION ,MUMBAI vs. DEPUTY COMMISSIONER OF INCOME TAX CENTRAL CIRCLE -8(1), MUMBAI

…has\n\n34\nITA No.3230/Mum/2025 & Others\nGovind Corporation & Others\n\nbeen consistently followed in Capital G LP v. ACIT (Writ Petition No. 15289 of 2024), Abhin Anil Kumar Shah v. ITO [(2024) 468 ITR 350 (Bom)], and Ganesh Nivrutti Jagtap v. ACIT [(2024) 166 Taxmann.com 168 (Bom)]. The dismissal of the Special Leave Petition by the Hon'ble Supreme Court in Deepanjan Roy v. ADIT [SLP (C) No. 18753/2025] lends further imprimatur to this legal position.\n\nThus, we have no hesitation in holding that the reassessment orders impugned before us are void ab initio, both for want of jurisdiction and for breach of ma…

VEDA REAL ESTATE CORPORATION PRIVATE LIMITED ,MUMBAI vs. DEPUTY COMMISSIONER OF INCOME TAX CENTRAL CIRCLE -8(1), MUMBAI

…own by the Hon'ble Bombay\nHigh Court in Hexaware Technologies Ltd. v. ACIT has since\nbeen consistently followed by the same Court in Capital G LP\nv. ACIT, Abhin Anil Kumar Shah v. ΙΤΟ [(2024) 468 ITR\n350 (Bom)], and Ganesh Nivrutti Jagtap v. ACIT [(2024)\n166 Taxmann.com 168 (Bom)], thereby fortifying the\nprinciple that the faceless assessment regime under section\n151A is not a matter of administrative convenience but a\njurisdictional imperative. The High Court in these decisions\nhas unambiguously held that once jurisdiction is statutorily\nvested in the Faceless Assessing Officer, any notice issued by\nt…

EI RESORTS AND CLUBS PVT LTD ,MUMBAI vs. DEPUTY COMMISSIONER OF INCOME TAX CENTRAL CIRCLE -8(1), MUMBAI

…own by\nthe Hon'ble Bombay High Court in Hexaware Technologies\nLtd. v. ACIT has since been consistently followed by the same\nCourt in Capital G LP v. ACIT, Abhin Anil Kumar Shah v.\nΙΤΟ [(2024) 468 ITR 350 (Bom)], and Ganesh Nivrutti\nJagtap v. ACIT [(2024) 166 Taxmann.com 168 (Bom)],\nthereby fortifying the principle that the faceless assessment\nregime under Section 151A is not a matter of administrative\nconvenience but a jurisdictional imperative. The High Court in\nthese decisions has unambiguously held that once jurisdiction\nis statutorily vested in the Faceless Assessing Officer, any\nnotice issued by t…

DCIT, CENTRAL CIRCLE-8(1), MUMBAI, MUMBAI vs. THE ESTATE INVESTMENT COMPANY PVT LTD, MUMBAI

…own by\nthe Hon'ble Bombay High Court in Hexaware Technologies\nLtd. v. ACIT has since been consistently followed by the same\nCourt in Capital G LP v. ACIT, Abhin Anil Kumar Shah v.\nΙΤΟ [(2024) 468 ITR 350 (Bom)], and Ganesh Nivrutti\nJagtap v. ACIT [(2024) 166 Taxmann.com 168 (Bom)],\nthereby fortifying the principle that the faceless assessment\nregime under section 151A is not a matter of administrative\nconvenience but a jurisdictional imperative. The High Court in\nthese decisions has unambiguously held that once jurisdiction\nis statutorily vested in the Faceless Assessing Officer, any\nnotice issued by t…

DCIT, CENTRAL CIRCLE-8(1), MUMBAI, MUMBAI vs. THE ESTATE INVESTMENT COMPANY PVT LTD, MUMBAI

…own by\nthe Hon'ble Bombay High Court in Hexaware Technologies\nLtd. v. ACIT has since been consistently followed by the same\nCourt in Capital G LP v. ACIT, Abhin Anil Kumar Shah v.\nΙΤΟ [(2024) 468 ITR 350 (Bom)], and Ganesh Nivrutti\nJagtap v. ACIT [(2024) 166 Taxmann.com 168 (Bom)],\nthereby fortifying the principle that the faceless assessment\nregime under section 151A is not a matter of administrative\nconvenience but a jurisdictional imperative. The High Court in\nthese decisions has unambiguously held that once jurisdiction\nis statutorily vested in the Faceless Assessing Officer, any\nnotice issued by t…

THE ESTATE INVESTMENT COMPANY PRIVATE LIMITED,MUMBAI vs. DCIT CENTRAL CIRCLE 8(1), MUMBAI

…own by\nthe Hon'ble Bombay High Court in Hexaware Technologies\nLtd. v. ACIT has since been consistently followed by the same\nCourt in Capital G LP v. ACIT, Abhin Anil Kumar Shah v.\nΙΤΟ [(2024) 468 ITR 350 (Bom)], and Ganesh Nivrutti\nJagtap v. ACIT [(2024) 166 Taxmann.com 168 (Bom)],\nthereby fortifying the principle that the faceless assessment\nregime under section 151A is not a matter of administrative\n\n41\nITA No.3012/Mum/2025 and others\nThe Estate Investment Company Pvt. Ltd. and others\nconvenience but a jurisdictional imperative. The High Court in\nthese decisions has unambiguously held that once jur…

THE ESTATE INVESTMENT COMPANY PRIVATE LIMITED,MUMBAI vs. DCIT CENTRAL CIRCLE 8(1), MUMBAI

3012/Mum/2025

Bench: SHRI AMIT SHUKLA (Judicial Member), SHRI ARUN KHODPIA (Accountant Member)

…aid down by the Hon‘ble Bombay High Court in Hexaware Technologies Ltd. v. ACIT has since been consistently followed by the same Court in Capital G LP v. ACIT, Abhin Anil Kumar Shah v. ITO [(2024) 468 ITR 350 (Bom)], and Ganesh Nivrutti Jagtap v. ACIT [(2024) 166 Taxmann.com 168 (Bom)], thereby fortifying the principle that the faceless assessment regime under section 151A is not a matter of administrative The Estate Investment Company Pvt. Ltd. and others convenience but a jurisdictional imperative. The High Court in these decisions has unambiguously held that once jurisdiction is statutorily vested in the Facel…