Prashant S. Joshi v. ITO

324 ITR 154High Court2010#538 most cited

What is Prashant S. Joshi v. ITO authority for?

Reasons recorded under Section 148 for reopening an assessment are jurisdictional facts that form the sole basis for assuming power and cannot be changed, supplemented, or corrected later. Such reasons must be based on fresh tangible material indicating income escapement.

179

judgments rely on this decision, according to BharatTax’s citation analysis of 366,470 Indian tax judgments — from 2016 to 2026.

Also referred to as

Prashant S. Joshi v. ITO · 324 ITR 154 · Section 147 · Section 148 · reasons recorded · reassessment validity · reasons cannot be supplemented · tangible material · jurisdictional facts · reopening of assessment · escapement of income

Also reported as

189 Taxmann 1190 CTR 166

Sections most often in play

Section 147Section 148Section 143(3)Section 68Section 151Section 153CSection 132(4)Section 143(1)
Read the full judgment

Issues it is cited on

books or books of accountsection 2(12a)section 2(40)section 148(2)going concerndumb documentsborrowed satisfactionescapement of incometangible materialkelvinatorreopening of assessmentreason to believe

Judgments citing Prashant S. Joshi v. ITO

Mdlr Builders P.Ltd, New Delhi vs. DCIT, Central Circle-14, New Delhi

In the result, both the appeals filed by the respective assessees are partly allowed for statistical purpose

ITA 8214/DEL/2018[2008-09]Status: DisposedITAT Delhi11 Jun 2019AY 2008-09

Bench: Sh. R. K. Panda & Sh. Kuldip Singhassessment Year: 2008-09

Section 142Section 144Section 153ASection 264

…IT(A) is invalid. 14. Referring to the following decisions he submitted that sum received on retirement from partnership firm which is outstanding as capital balance to the credit of account of partners account is not taxable :- 1. Prashant S. Joshi Vs. ITO 324 ITR 154 (Bom) 2. Chalasani Venkatesara Rao Vs. ITO 349 ITR 423 (A. P.) 3. CIT Vs. Dynamic Enterprises 359 ITR 83 (Kar) 4. CIT Vs. Mohanbhai Pamabhai 91 ITR 393 (Guj) He also relied on various decisions of the coordinate benches of the Tribunal on this proposition. 15. Referring to the following decisions he submitted that sum standing to the credit…

Smt. Vidhya Agarwal, Agra vs. I.T.O., Ward-4(4), Agra

The appeal is allowed

ITA 335/AGR/2014[2000-01]Status: DisposedITAT Agra22 Mar 2019AY 2000-01

Bench: Shri Sudhanshu Srivastava & Dr. Mitha Lal Meena

Section 148

…IN THE INCOME TAX APPELLATE TRIBUNAL AGRA BENCH: AGRA BEFORE SHRI SUDHANSHU SRIVASTAVA, JUDICIAL MEMBER AND DR. MITHA LAL MEENA, ACCOUNTANT MEMBER I.T.A No. 216 /Agra/2012: (A.Y.1999-00) I.T.A. No.217/Agra/2012: (A.Y. 2000-01) Smt. Shanta Balani W/o Shri Ramesh Vs. ITO, Ward-2(4), Chand Balani, B-66, Alok Nagar, Jaipur Agra House, Agra. PAN:ABTPB4266B (Appellant) (Respondent) I.T.A. No.218/Agra/2012: (A.Y. 1999-00) I.T.A. No.219/Agra/2012: (A.Y. 2000-01) Ravindra Balani, B-66, Alok Nagar, Jaipur Vs. ITO, Ward-2(4), House, Agra. PAN:AAPPB5000Q Agra (Appellant) (Respondent) I.T.A. No. 220/Agra/2012: (A.Y. 20…

ITO 16(3)(3), Mumbai vs. Ramal P. Advani, Mumbai

In the result, the appeals filed by the Revenue stand dismissed

ITA 6491/MUM/2016[2010-11]Status: DisposedITAT Mumbai27 Aug 2018AY 2010-11

Bench: Shri Shamim Yahya, Am & Shri Pawan Singh, Jm

For Appellant: Shri Nilesh Zaveri
Section 55F

…f the assessee placed reliance on several case laws which reads as under:  CIT vs. R. Lingmallu Raghukar (124 Taxman 127 (SC))  ACIT vs. Mohanbhai Pamabhai (165 ITR 166 (SC))  CIT vs. Riyaz A. Sheikh (41 taxmann.com 455)(Bom)  Prashant S. Joshi vs. ITO (324 ITR 154) (Bom.)  Sharadha Terry Products Ltd vs. Asst. CIT (180 TTJ 284) (Chennai-Trib)  Chalasani Venkateswara Rao vs. ITO (349 ITR 423) (AP)  ACIT vs. N. Prasad (153 ITD 257) (Hyd.)  Mahul Construction Corporation vs. ITO (88 taxmann.com 181) (Mum-Trib)  Amit Kumar Choudhury vs. DCIT (2018) (2 TMI 1368)(Kol)  Shri Sachin Bhausaheb Nikam vs. DCIT…

ACIT (E) 20(3), Mumbai vs. Seema Dilip Vora, Mumbai

The appeal of the Revenue is dismissed

ITA 582/MUM/2017[2007-08]Status: DisposedITAT Mumbai13 Aug 2018AY 2007-08

Bench: Shri Joginder Singh & Shri Manoj Kumar Aggarwalassessment Year:2007-08 Acit-20(3), Ms. Seema Dilip Vora, Room No.622, 71/72, Rajkamal Apartment बनाम/ Piramal Chambers, Lalbaug, Rajkamal Marg, Rajkamal Vs. Mumbai Studio, Near Gandhi Hospital, Parel, Mumbai-400012 (राज"व /Revenue) ("नधा"रती /Assessee) Pan. No. Aabpv0816C

Section 143(1)Section 143(2)Section 143(3)Section 147Section 148

…) on the issue of reopening u/s 147/148 of the Act, considering various judicial pronouncements like Hindustan Lever Ltd. vs ACIT (2004) 268 ITR 332 (Bom.), CIT vs K Mohan & Company (2012) 349 ITR 653 (Bom.), Prashant S. Joshi vs Income Tax Officer (2010) 324 ITR 154 (Bom.) held that the notice issued 41 Ms. Seema Dilip vora u/s 148 of the Act cannot be sustained as the same is without jurisdiction, therefore, we find no infirmity in the conclusion drawn by the Ld. Commissioner of Income Tax (Appeal). It is upheld, resultantly, the appeal of the Revenue is dismissed. Finally, the appeal of the Revenue is d…

A.C.I.T., Circle-2, Hoogly, Hooghly vs. Swapan Kumar Mondal, Hooghly

In the result, appeal of the revenue is dismissed

ITA 1952/KOL/2013[2008-09]Status: DisposedITAT Kolkata13 Jul 2018AY 2008-09

Bench: Sri J. Sudhakar Reddy & Sri Aby T. Varkey) Assessment Year: 2008-09 Assistant Commissioner Of Income Tax, Circle-2, Hooghly……...……...………………...……..Appellant Swapan Kumar Mondal..…….…..…….……………………..…………………………………..……….…..Respondent Uttarayan Station Road Chinsurah R.S. Dist. Hooghly Pin – 712 102 [Pan : Aedpm 6336 A]

Section 133ASection 143(1)Section 147Section 148Section 250Section 68

…r not the original assessment has been completed under scrutiny assessment or summary assessment, it is necessary that conditions precedent for invoking section 147 have to be satisfied. Hon'ble Bombay High Court, in the case of Prashant S Joshi v. ITO [2010] 324 ITR 154/189 Taxman 1 had an occasion to deal with this question and also consider the scope of Hon'ble Supreme Court's judgment in the case of Asstt. CIT v. Rajesh Jhaveri Stock Brokers (P.) Ltd. [2007] 291 ITR 500/161 Taxman 316 in this regard. After elaborately considering Hon'ble Supreme Court in the case of Rajesh Jhaveri Stock Brokes (P.) Ltd. (supr…

DCIT, Jaipur vs. Vimal Chand Surana HUF, Jaipur

In the result, the appeal of the revenue stands dismissed

ITA 437/JPR/2017[2007-08]Status: DisposedITAT Jaipur17 May 2018AY 2007-08
For Appellant: Shri S.R. Sharma &For Respondent: Shri Varinder Mehta (CIT) fu/kZkfjrh dh vksj ls@
Section 131Section 139(1)Section 143Section 143(3)Section 147Section 148Section 151Section 292C

…perusal of the above provided reasons for re- opening are the only reasons that can be considered when the formation of belief of “Income chargeable to tax has escaped assessment” is challenged. The Hon’ble Bombay High court in Prashant S. Joshi v. ITO [2010] 324 ITR 154 (Bom)held that “The basic postulate which underlines section 147 is the formation of the belief by the Assessing Officer that any income chargeable to tax has escaped ITA 437/JP/2017_ 7 DCIT Vs. Vimal Chand Surana (HUF) assessment for any assessment year. The Assessing Officer must have reason to believe that such is the case before he proceeds…

Hasmukh I Gandhi, Mumbai vs. DCIT Cen Cir 1, Mumbai

In the result, all the appeals filed by the assessee’s stand dismissed

ITA 5006/MUM/2014[2005-06]Status: DisposedITAT Mumbai15 Nov 2017AY 2005-06

Bench: Shri Shamim Yahya, Am & Shri Amarjit Singh, Jm

For Appellant: Shri P. J. PardiwalaFor Respondent: Shri Girish Dave &
Section 147

…ld. Counsel of the assessee submitted that any liability in this regard should be fastened on the settler and not the assessee. The ld. Counsel referred to the Hon'ble Bombay High Court decision in the case of Joshi & Dattaram Shridhar Bhosale Vs. ITO & Anr.324 ITR 154 (Bom). He submitted that this decision was rendered after considering the decision of CIT(A) Vs. Rajesh Jhaveri Stock Brokers P. Ltd, 291 ITR 500 (SC). He further referred to the decision of Hon'ble Bombay High Court in the case of Khubchandani Healthparks Pvt. Ltd. vs Income Tax Officer (2016) 384 ITR 322 (Bom.). 12. On merits, the ld. Couns…

Chintan H Gandhi, Mumbai vs. DCIT Cen Cir 1, Mumbai

In the result, all the appeals filed by the assessee’s stand dismissed

ITA 2798/MUM/2011[2002-03]Status: DisposedITAT Mumbai15 Nov 2017AY 2002-03

Bench: Shri Shamim Yahya, Am & Shri Amarjit Singh, Jm

For Appellant: Shri P. J. PardiwalaFor Respondent: Shri Girish Dave &
Section 147

…ld. Counsel of the assessee submitted that any liability in this regard should be fastened on the settler and not the assessee. The ld. Counsel referred to the Hon'ble Bombay High Court decision in the case of Joshi & Dattaram Shridhar Bhosale Vs. ITO & Anr.324 ITR 154 (Bom). He submitted that this decision was rendered after considering the decision of CIT(A) Vs. Rajesh Jhaveri Stock Brokers P. Ltd, 291 ITR 500 (SC). He further referred to the decision of Hon'ble Bombay High Court in the case of Khubchandani Healthparks Pvt. Ltd. vs Income Tax Officer (2016) 384 ITR 322 (Bom.). 12. On merits, the ld. Couns…

Hasmukh I Gandhi, Mumbai vs. DCIT Cen Cir 1, Mumbai

In the result, all the appeals filed by the assessee’s stand dismissed

ITA 2795/MUM/2011[2002-03]Status: DisposedITAT Mumbai15 Nov 2017AY 2002-03

Bench: Shri Shamim Yahya, Am & Shri Amarjit Singh, Jm

For Appellant: Shri P. J. PardiwalaFor Respondent: Shri Girish Dave &
Section 147

…ld. Counsel of the assessee submitted that any liability in this regard should be fastened on the settler and not the assessee. The ld. Counsel referred to the Hon'ble Bombay High Court decision in the case of Joshi & Dattaram Shridhar Bhosale Vs. ITO & Anr.324 ITR 154 (Bom). He submitted that this decision was rendered after considering the decision of CIT(A) Vs. Rajesh Jhaveri Stock Brokers P. Ltd, 291 ITR 500 (SC). He further referred to the decision of Hon'ble Bombay High Court in the case of Khubchandani Healthparks Pvt. Ltd. vs Income Tax Officer (2016) 384 ITR 322 (Bom.). 12. On merits, the ld. Couns…

ACIT, Cir-40, Kolkata vs. Sundarlal Mohanlal Sarda & Others, Kolkata

In the result, Revenue’s appeal is dismissed as infructuous

ITA 116/KOL/2014[2007-08]Status: DisposedITAT Kolkata31 Oct 2017AY 2007-08

Bench: Shri N.V.Vasudevan & Shri Waseem Ahmedassessment Year :007-08

Section 147Section 148

…ice of TDS Division, Bhubaneswar. Thus the argument of the ld. DR cannot be accepted. Moreover the reasons recorded by the AO for reopening the case cannot be improved further as held by the Bombay High Court in the case of Prashant S Joshi vs ITO reported in 324 ITR 154. The relevant extract of the order is reproduced below : “ The reasons, which are recorded by the Assessing Officer for reopening an assessment, are the only reasons which can be considered when the formation of the belief is impugned. The recording of reasons distinguishes an objective from a subjective exercise of power. The requirement of rec…

Crystal Natural Food Processors P.Ltd, Mumbai vs. ITO WD 5(1)(3), Mumbai

In the result appeal of the assessee is allowed in terms indicated hereinabove

ITA 1513/MUM/2017[2008-09]Status: DisposedITAT Mumbai06 Oct 2017AY 2008-09

Bench: Shri R.C.Sharma, Am M/S. Crystal Natural Food Vs. Ito Wd 5(1)(3) Processor Pvt. Ltd., Aayakar Bhavan My Home Apartments, M.K. Road Forjet Cross Road Mumbai – 400 020 Gowali Tank Mumbai – 400 036 Pan/Gir No. Aadcc5431H Appellant) Respondent) ..

Section 143(1)Section 143(3)Section 148Section 151

…the requirement of fresh tangible material is not altered at all due to the original assessment being a summary assessment u/s. 143(1) of the Act. For this proposition, reliance was placed by learned AR on the following decisions:  Prashant S. Joshi Vs. ITO 324 ITR 154 (Bom.)  Inductotherm India P. Ltd. Vs. DCIT 356 ITR 481 (Guj)  C1T Vs. Atul Kumar Swami 362 ITR 693 (Del.)  Mohan Gupta HUF Vs. CIT (WP No. 7660/2012)(Del HC) - itatonline.org  Telco Dadajee Dhakjee Ltd. Vs. Dy. CIT (ITA No. 4613/Mum/2005) (Mum)(TM) -itatonline.org 11. With regard to merit of the addition, it was submitted by learned AR that…

Smt. Taruna Verma, Delhi vs. ITO, New Delhi

In the result appeal of the assessee is allowed

ITA 2833/DEL/2016[2007-08]Status: DisposedITAT Delhi19 Sept 2017AY 2007-08

Bench: Shri I.C.Sudhir & Shri Prashant Maharishismt Taruna Verma, Vs. Ito, A-340, Shastri Nagar, Delhi Ward-19(3), Pan:Akfpv1950P New Delhi (Appellant) (Respondent)

For Appellant: Shri Ajay Wadhwa, AdvFor Respondent: Shri Anshu Prakash, Sr. DR
Section 142(1)Section 147Section 148Section 69A

…INCOME TAX APPELLATE TRIBUNAL DELHI BENCH “B”: NEW DELHI BEFORE SHRI I.C.SUDHIR, JUDICIAL MEMBER AND SHRI PRASHANT MAHARISHI, ACCOUNTANT MEMBER Smt Taruna Verma, Vs. ITO, A-340, Shastri Nagar, Delhi Ward-19(3), PAN:AKFPV1950P New Delhi (Appellant) (Respondent) Assessee by : Shri Ajay Wadhwa, Adv Revenue by: Shri Anshu Prakash, Sr. DR Date of Hearing 05/09/2017 Date of pronouncement 19/09/2017 O R D E R PER PRASHANT MAHARISHI, A. M. 1. This is an appeal filed by the assessee against the order of the ld CIT(A)-12, New Delhi dated 28.03.2016 for the Assessment Year 2007-08. 2. The assessee has raised the following…

M/S. Meditronics India Pvt. Ltd., Delhi vs. ITO, New Delhi

The appeal is allowed

ITA 6251/DEL/2012[2004-05]Status: DisposedITAT Delhi12 Sept 2017AY 2004-05

Bench: Shri I. C. Sudhir & Shri L. P. Sahui. T. Appeal No. 6251/Del/2012 Assessment Year : 2004-2005. M/S. Meditronics India Pvt. Ltd., Income Tax Officer, 41, Pocket–Ii, Jasola, Vs. Ward : 6 (3), D E L H I – 110 025. New Delhi. Pan : Aadcm 3622 Q (Appellant) (Respondent)

For Appellant: Shri Salil Aggarwal, Adv.; &For Respondent: Shri Gudrun Nehra, Sr. D. R
Section 147

…rd Member Jay Bharat Maruti Ltd. vs CIT ix. 324 ITR 289 Delhi High Court Shipra Srivastava vs ACIT x. 319 ITR 221 Delhi High Court CIT vs Batra Bhatta Co. xi. 174 Taxman 444 Delhi High Court Prashant S. Joshi and Dattaram Shridhar Bhosale vs xii. ITO and UOI 324 ITR 154 Bombay High Court ACIT vs O.P. Chawla xiii. 114 ITD 69 ITAT Third Member Dy.CIT Vs. M/s SPA Enterprises Limited xiv. 10 I. T. Appeal No. 6251/Del/2012 Assessment Year : 2004-2005. (ITA No.496/Del/2010 dated 2nd August, 2013) Sh. Gopi G Nambiar vs. JCIT xv. (ITA no. 1083/Del/2010 dated 26th July, 2013) Sri Sushil Kr. Chopra Vs. Dy. Commissioner o…

K.Suresh, Chennai vs. DCIT, Chennai

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

ITA 572/CHNY/2017[2012-13]Status: DisposedITAT Chennai19 Jun 2017AY 2012-13

Bench: Shri Chandra Poojari & Shri G. Pavan Kumar

For Appellant: Shri K. Ravi, AdvocateFor Respondent: Shri Supriyo Pal, JCIT
Section 148

…572/M/17 consequence notice u/s.148 of the Act was quashed. This view was also adopted in the case of Gurpal Singh Vs. ITO (71 taxmann.com 108 (Amritsar-Trib.) 4.10 He relied on the judgement of Bombay High Court in the case of Prashant S. Joshi Vs. ITO (324 ITR 154) [Bom.], it was held that reasons which are recorded by the AO for reopening an assessment, are only reasons which can be considered when formation of belief is impugned; such reasons cannot be allowed to grow with age and ingenuity by devising new grounds in replies and affidavits not envisage when reasons for reopening an assessment were re…

K.Suresh, Chennai vs. DCIT, Chennai

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

ITA 571/CHNY/2017[2011-12]Status: DisposedITAT Chennai19 Jun 2017AY 2011-12

Bench: Shri Chandra Poojari & Shri G. Pavan Kumar

For Appellant: Shri K. Ravi, AdvocateFor Respondent: Shri Supriyo Pal, JCIT
Section 148

…572/M/17 consequence notice u/s.148 of the Act was quashed. This view was also adopted in the case of Gurpal Singh Vs. ITO (71 taxmann.com 108 (Amritsar-Trib.) 4.10 He relied on the judgement of Bombay High Court in the case of Prashant S. Joshi Vs. ITO (324 ITR 154) [Bom.], it was held that reasons which are recorded by the AO for reopening an assessment, are only reasons which can be considered when formation of belief is impugned; such reasons cannot be allowed to grow with age and ingenuity by devising new grounds in replies and affidavits not envisage when reasons for reopening an assessment were re…

K.Suresh, Chennai vs. DCIT, Chennai

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

ITA 570/CHNY/2017[2010-11]Status: DisposedITAT Chennai19 Jun 2017AY 2010-11

Bench: Shri Chandra Poojari & Shri G. Pavan Kumar

For Appellant: Shri K. Ravi, AdvocateFor Respondent: Shri Supriyo Pal, JCIT
Section 148

…572/M/17 consequence notice u/s.148 of the Act was quashed. This view was also adopted in the case of Gurpal Singh Vs. ITO (71 taxmann.com 108 (Amritsar-Trib.) 4.10 He relied on the judgement of Bombay High Court in the case of Prashant S. Joshi Vs. ITO (324 ITR 154) [Bom.], it was held that reasons which are recorded by the AO for reopening an assessment, are only reasons which can be considered when formation of belief is impugned; such reasons cannot be allowed to grow with age and ingenuity by devising new grounds in replies and affidavits not envisage when reasons for reopening an assessment were re…

K.Suresh, Chennai vs. DCIT, Chennai

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

ITA 569/CHNY/2017[2009-10]Status: DisposedITAT Chennai19 Jun 2017AY 2009-10

Bench: Shri Chandra Poojari & Shri G. Pavan Kumar

For Appellant: Shri K. Ravi, AdvocateFor Respondent: Shri Supriyo Pal, JCIT
Section 148

…572/M/17 consequence notice u/s.148 of the Act was quashed. This view was also adopted in the case of Gurpal Singh Vs. ITO (71 taxmann.com 108 (Amritsar-Trib.) 4.10 He relied on the judgement of Bombay High Court in the case of Prashant S. Joshi Vs. ITO (324 ITR 154) [Bom.], it was held that reasons which are recorded by the AO for reopening an assessment, are only reasons which can be considered when formation of belief is impugned; such reasons cannot be allowed to grow with age and ingenuity by devising new grounds in replies and affidavits not envisage when reasons for reopening an assessment were re…

K.Suresh, Chennai vs. DCIT, Chennai

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

ITA 568/CHNY/2017[2008-09]Status: DisposedITAT Chennai19 Jun 2017AY 2008-09

Bench: Shri Chandra Poojari & Shri G. Pavan Kumar

For Appellant: Shri K. Ravi, AdvocateFor Respondent: Shri Supriyo Pal, JCIT
Section 148

…572/M/17 consequence notice u/s.148 of the Act was quashed. This view was also adopted in the case of Gurpal Singh Vs. ITO (71 taxmann.com 108 (Amritsar-Trib.) 4.10 He relied on the judgement of Bombay High Court in the case of Prashant S. Joshi Vs. ITO (324 ITR 154) [Bom.], it was held that reasons which are recorded by the AO for reopening an assessment, are only reasons which can be considered when formation of belief is impugned; such reasons cannot be allowed to grow with age and ingenuity by devising new grounds in replies and affidavits not envisage when reasons for reopening an assessment were re…

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

…A No.622/Mum/2014) (Page 107 to 11 of the paper book), Pankaj Gas Cylinders vs ACIT (ITA No.5273/Del./2013) dated 03/05/2016, R.M.G. Plyvinxl (I) Ltd. (2016) 48 ITR (Trib.) 674 (Del.), Hon'ble jurisdictional High Court in Prashant Joshi vs Income Tax Officer (324 ITR 154)(Bom.), Godrej Industries 13 Ajay J. Doshi Ltd. vs DCIT & Ors. (2015) 377 ITR 1(Bom.) supports the case of the assessee. In the present appeal, the assessee, during assessment proceedings, furnished the necessary documents, as claimed in the paper book (filed before this Tribunal), which is summarized hereunder for ready reference and analysis:…

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…