Union of India v. Ashish Agarwal

444 ITR 1Supreme Court of India2022#126 most cited

What is Union of India v. Ashish Agarwal authority for?

Notices issued under the unamended Section 148 of the Income-tax Act between April 1, 2021, and May 4, 2022, must be treated as notices issued under the new Section 148A(b) of the amended law. This requires the Assessing Officer to follow the procedure prescribed under the amended reassessment provisions, including issuing an order under Section 148A(d) before a fresh notice under Section 148.

524

judgments rely on this decision, according to BharatTax’s citation analysis of 366,005 Indian tax judgments — from 2022 to 2026.

Also referred to as

Union of India v. Ashish Agarwal · Section 148 notice validity · reassessment notices after April 1 2021 · amended reassessment provisions · Section 148A(b) conversion · Article 142 directions · unamended Section 148 · reopening assessment procedure · Section 148A(d) order · time limit for reassessment

Also reported as

138 Taxmann.com 642022 SCC OnLine SC 543286 Taxmann 1831 SCC 617

Sections most often in play

Section 148Section 147Section 148ASection 151Section 149Section 144BSection 143(3)Section 250
Read the full judgment

Issues it is cited on

section 149a(c)section 149a(d)section 148a(c)section 149asection 151(i)section 148 noticesection 149(1)(a)section 148a(a)section 3(1)section 151(ii)order under section 148a(d)section 149(1)

Judgments citing Union of India v. Ashish Agarwal

Comfort Intech Limited, Mumbai vs. Assistant Commissioner of Income Tax 4(1)(1) Mumbai, Aaykar Bhawan Mumbai

In the result, the appeals filed by the Assessee are allowed and the appeals of the Revenue are dismissed

ITA 2573/MUM/2024[2011-12]Status: DisposedITAT Mumbai27 Sept 2024AY 2011-12

Bench: Shri B.R. Baskaran & Shri Anikesh Banerjee

For Appellant: Shri Rajiv Khandelwal&For Respondent: Shri Yogendra T. Wakare, Sr.DR
Section 132Section 143(1)Section 143(3)Section 148

…ed the assessment of this year and accordingly, it was contended that the AO could not have placed reliance on the decision rendered by the Hon‟ble Supreme Court in the case of Union of India vs. Ashish Agarwal (Civil Appeal No. 3005/2022 dated 4th May, 2022; 444 ITR 1)(SC). 14. We notice that the above said contention of the assessee finds support from the decision rendered by Hon‟ble jurisdictional Bombay High 10 Comfort Intech Limited batch Court in the case of New India Assurance Company Ltd vs. ACIT (2024)(158 taxmann.com 367)(Bom). The above said case was related to AY. 2013-14 and the Revenue issued noti…

Assistant Commissioner of Income Tax- 4(1)(1), Mumbai vs. Comfort Intech Limited, Mumbai

In the result, the appeals filed by the Assessee are allowed and the appeals of the Revenue are dismissed

ITA 2218/MUM/2024[2011-12]Status: DisposedITAT Mumbai27 Sept 2024AY 2011-12

Bench: Shri B.R. Baskaran & Shri Anikesh Banerjee

For Appellant: Shri Rajiv Khandelwal&For Respondent: Shri Yogendra T. Wakare, Sr.DR
Section 132Section 143(1)Section 143(3)Section 148

…ed the assessment of this year and accordingly, it was contended that the AO could not have placed reliance on the decision rendered by the Hon‟ble Supreme Court in the case of Union of India vs. Ashish Agarwal (Civil Appeal No. 3005/2022 dated 4th May, 2022; 444 ITR 1)(SC). 14. We notice that the above said contention of the assessee finds support from the decision rendered by Hon‟ble jurisdictional Bombay High 10 Comfort Intech Limited batch Court in the case of New India Assurance Company Ltd vs. ACIT (2024)(158 taxmann.com 367)(Bom). The above said case was related to AY. 2013-14 and the Revenue issued noti…

Assistant Commissioner of Income Tax-4(1)(1), Mumbai vs. Comfort Intech Limited, Mumbai

In the result, the appeals filed by the Assessee are allowed and the appeals of the Revenue are dismissed

ITA 2216/MUM/2024[2012-13]Status: DisposedITAT Mumbai27 Sept 2024AY 2012-13

Bench: Shri B.R. Baskaran & Shri Anikesh Banerjee

For Appellant: Shri Rajiv Khandelwal&For Respondent: Shri Yogendra T. Wakare, Sr.DR
Section 132Section 143(1)Section 143(3)Section 148

…ed the assessment of this year and accordingly, it was contended that the AO could not have placed reliance on the decision rendered by the Hon‟ble Supreme Court in the case of Union of India vs. Ashish Agarwal (Civil Appeal No. 3005/2022 dated 4th May, 2022; 444 ITR 1)(SC). 14. We notice that the above said contention of the assessee finds support from the decision rendered by Hon‟ble jurisdictional Bombay High 10 Comfort Intech Limited batch Court in the case of New India Assurance Company Ltd vs. ACIT (2024)(158 taxmann.com 367)(Bom). The above said case was related to AY. 2013-14 and the Revenue issued noti…

Assistant Commissioner of Income Tax- 4(1)(1), Mumbai vs. Comfort Intech Limited, Mumbai

In the result, the appeals filed by the Assessee are allowed and the appeals of the Revenue are dismissed

ITA 2212/MUM/2024[2014-15]Status: DisposedITAT Mumbai27 Sept 2024AY 2014-15

Bench: Shri B.R. Baskaran & Shri Anikesh Banerjee

For Appellant: Shri Rajiv Khandelwal&For Respondent: Shri Yogendra T. Wakare, Sr.DR
Section 132Section 143(1)Section 143(3)Section 148

…ed the assessment of this year and accordingly, it was contended that the AO could not have placed reliance on the decision rendered by the Hon‟ble Supreme Court in the case of Union of India vs. Ashish Agarwal (Civil Appeal No. 3005/2022 dated 4th May, 2022; 444 ITR 1)(SC). 14. We notice that the above said contention of the assessee finds support from the decision rendered by Hon‟ble jurisdictional Bombay High 10 Comfort Intech Limited batch Court in the case of New India Assurance Company Ltd vs. ACIT (2024)(158 taxmann.com 367)(Bom). The above said case was related to AY. 2013-14 and the Revenue issued noti…

International Hospital Limited vs. DCIT Circle 12 (2)

ITA/116/2023HC Delhi26 Sept 2024

Bench: HON'BLE MR. JUSTICE RAVINDER DUDEJA,HON'BLE MR. JUSTICE YASHWANT VARMA

…for proceedings to be taken forward in accordance with law. 10. It becomes pertinent to note that although Instruction No. 1/2022 dated 11 May 2022 issued by the Central Board of Direct Taxes13 12 (2023) 1 SCC 617 13 CBDT Digitally Signed By:KAMLESH KUMAR Signing Date:26.09.2024 19:44:08 Signature Not Verified ITA 116/2023 & other connected matters Page 20 of 52 also formed subject matter of challenge in some of the writ petitions forming part of this batch, no arguments were addressed on that score. We thus c…

G D Mother Educational Society, Muzaffarpur vs. ACIT Central Circle, Muzaffarpur

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

ITA 309/PAT/2024[2020-21]Status: DisposedITAT Patna25 Sept 2024AY 2020-21

Bench: Shri Rajpal Yadav, Vice-(Kz) & Dr. Manish Boradi.T.A. Nos. 307, 308 & 309/Pat/2024 Assessment Years: 2018-19, 2019-20 & 2020-21 G D Mother Educational Society,…..…….……Appellant Akharaghat Road, Muzzaffarpur-842001, Bihar [Pan:Aaaag3023A] -Vs.- Assistant Commissioner Of Income Tax,..…Respondent Central Circle, Muzaffarpur, Aayakar Bhawan, Near Nehru Stadium, Sikandarpur, Muzzaffarpur-842001, Bihar Appearances By: Shri S.K. Tulsiyan, Advocate & Puja Somani, Ca, Appeared On Behalf Of The Assessee Smt. Rinku Singh, Cit(Dr), Appeared On Behalf Of The Revenue Date Of Concluding The Hearing: September 04, 2024 Date Of Pronouncing The Order: September 25, 2024 O R D E R

Section 148Section 249Section 253Section 3Section 5

…ITA No. 307/PAT/2024 (A.Y. 2018-2019) ITA No. 309/PAT/2024 (A.Y. 2020-2021) G D Mother Educational Society IN THE INCOME TAX APPELLATE TRIBUNAL, KOLKATA-PATNA ‘e-COURT’, KOLKATA [Hybrid Court Hearing] Before Shri Rajpal Yadav, Vice-President (KZ) & Dr. Manish Borad, Accountant Member I.T.A. Nos. 307, 308 & 309/PAT/2024 Assessment Years: 2018-19, 2019-20 & 2020-21 G D Mother Educational Society,…..…….……Appellant Akharaghat Road, Muzzaffarpur-842001, Bihar [PAN:AAAAG3023A] -Vs.- Assistant Commissioner of Income Tax,..…Respondent Central Circle, Muzaffarpur, Aayakar Bhawan, Near Nehru Stadium, Sikandarpur, Mu…

G D Mother Educational Society, Muzaffarpur vs. ACIT Central Circle, Muzaffarpur

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

ITA 308/PAT/2024[2019-20]Status: DisposedITAT Patna25 Sept 2024AY 2019-20

Bench: Shri Rajpal Yadav, Vice-(Kz) & Dr. Manish Boradi.T.A. Nos. 307, 308 & 309/Pat/2024 Assessment Years: 2018-19, 2019-20 & 2020-21 G D Mother Educational Society,…..…….……Appellant Akharaghat Road, Muzzaffarpur-842001, Bihar [Pan:Aaaag3023A] -Vs.- Assistant Commissioner Of Income Tax,..…Respondent Central Circle, Muzaffarpur, Aayakar Bhawan, Near Nehru Stadium, Sikandarpur, Muzzaffarpur-842001, Bihar Appearances By: Shri S.K. Tulsiyan, Advocate & Puja Somani, Ca, Appeared On Behalf Of The Assessee Smt. Rinku Singh, Cit(Dr), Appeared On Behalf Of The Revenue Date Of Concluding The Hearing: September 04, 2024 Date Of Pronouncing The Order: September 25, 2024 O R D E R

Section 148Section 249Section 253Section 3Section 5

…ITA No. 307/PAT/2024 (A.Y. 2018-2019) ITA No. 309/PAT/2024 (A.Y. 2020-2021) G D Mother Educational Society IN THE INCOME TAX APPELLATE TRIBUNAL, KOLKATA-PATNA ‘e-COURT’, KOLKATA [Hybrid Court Hearing] Before Shri Rajpal Yadav, Vice-President (KZ) & Dr. Manish Borad, Accountant Member I.T.A. Nos. 307, 308 & 309/PAT/2024 Assessment Years: 2018-19, 2019-20 & 2020-21 G D Mother Educational Society,…..…….……Appellant Akharaghat Road, Muzzaffarpur-842001, Bihar [PAN:AAAAG3023A] -Vs.- Assistant Commissioner of Income Tax,..…Respondent Central Circle, Muzaffarpur, Aayakar Bhawan, Near Nehru Stadium, Sikandarpur, Mu…

G D Mother Educational Society, Muzaffarpur vs. ACIT Central Circle, Muzaffarpur

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

ITA 307/PAT/2024[2018-19]Status: DisposedITAT Patna25 Sept 2024AY 2018-19

Bench: Shri Rajpal Yadav, Vice-(Kz) & Dr. Manish Boradi.T.A. Nos. 307, 308 & 309/Pat/2024 Assessment Years: 2018-19, 2019-20 & 2020-21 G D Mother Educational Society,…..…….……Appellant Akharaghat Road, Muzzaffarpur-842001, Bihar [Pan:Aaaag3023A] -Vs.- Assistant Commissioner Of Income Tax,..…Respondent Central Circle, Muzaffarpur, Aayakar Bhawan, Near Nehru Stadium, Sikandarpur, Muzzaffarpur-842001, Bihar Appearances By: Shri S.K. Tulsiyan, Advocate & Puja Somani, Ca, Appeared On Behalf Of The Assessee Smt. Rinku Singh, Cit(Dr), Appeared On Behalf Of The Revenue Date Of Concluding The Hearing: September 04, 2024 Date Of Pronouncing The Order: September 25, 2024 O R D E R

Section 148Section 249Section 253Section 3Section 5

…ITA No. 307/PAT/2024 (A.Y. 2018-2019) ITA No. 309/PAT/2024 (A.Y. 2020-2021) G D Mother Educational Society IN THE INCOME TAX APPELLATE TRIBUNAL, KOLKATA-PATNA ‘e-COURT’, KOLKATA [Hybrid Court Hearing] Before Shri Rajpal Yadav, Vice-President (KZ) & Dr. Manish Borad, Accountant Member I.T.A. Nos. 307, 308 & 309/PAT/2024 Assessment Years: 2018-19, 2019-20 & 2020-21 G D Mother Educational Society,…..…….……Appellant Akharaghat Road, Muzzaffarpur-842001, Bihar [PAN:AAAAG3023A] -Vs.- Assistant Commissioner of Income Tax,..…Respondent Central Circle, Muzaffarpur, Aayakar Bhawan, Near Nehru Stadium, Sikandarpur, Mu…

Pr. Commissioner of Income Tax -Central -1 vs. Ve Commercial Vehicles Ltd

ITA/330/2023HC Delhi24 Sept 2024

Bench: HON'BLE MR. JUSTICE YASHWANT VARMA,HON'BLE MR. JUSTICE RAVINDER DUDEJA

Section 11(4)Section 12ASection 148Section 148A

…W.P.(C) 330/2023 Page 1 of 15 $~37 * IN THE HIGH COURT OF DELHI AT NEW DELHI % Date of Decision: 18.10.2024 + W.P.(C) 330/2023 HARSH VARDHAN BANSAL ..... Petitioner Through: Mr. Ruchesh Sinha and Ms. Monalisa Maity, Advs. Versus ACIT CIRCLE 43(1) NEW DELHI & ANR. ..... Respondents Through: Mr. Aseem Chawla, Adv. CORAM: HON'BLE MR. JUSTICE VIBHU BAKHRU HON'BLE MS. JUSTICE SWARANA KANTA SHARMA VIBHU BAKHRU, J. 1. The petitioner has filed t…

Nilima Kothari, Indore vs. The Income Tax Officer, National Faceless Asstt. Centre, Indore

In the result appeal of the assessee is allowed as per terms indicated above

ITA 259/IND/2024[2016-17]Status: DisposedITAT Indore20 Sept 2024AY 2016-17

Bench: Shri Manish Boradsmt. Neelima Kothari, Income Tax Officer, 601, N.R.K. Villas, Delhi Vs. 22/2 Manoramaganj, Indore (Appellant / Assessee) (Respondent/ Revenue) Pan: Adnpk7832J Assessee By Shri S.S. Deshpande, Ar Revenue By Shri Ashish Porwal, Sr.Dr Date Of Hearing 08.08.2024 Date Of Pronouncement 20.09.2024

Section 10(38)Section 147Section 148Section 151Section 68

…4 Smt. Nilima Kothari out the reassessment proceedings the notice u/s 148 of the Act issued on 16.04.2021 in compliance the assesse filed the return on 07.12.2021. In view of the judgment of Hon’ble Supreme Court in case of Union of India vs. Ashish Agrawal 444 ITR 1(SC) Ld. AO issued fresh notice u/s 148A(b) of the Act dated 24.05.2022 as per new provisions inserted by Finance Act 2021. Thereafter proceedings u/s 148A(d) of the Act were carried out, during which the assesse’s submissions challenging reopening were considered but finally Ld. AO initiated reassessment proceedings and framed the assessment u/s 14…

Bakers Spices & Ingredients Private Limited, Coimbatore vs. DCIT, Corp Ward 1, Coimbatore

ITA 882/CHNY/2024[2016-17]Status: DisposedITAT Chennai12 Sept 2024AY 2016-17

Bench: Shri Mahavir Singh & Shri Manoj Kumar Aggarwal

For Appellant: Shri S.Sridhar, AdvocateFor Respondent: Ms. R.Anita, Addl. CIT
Section 139(1)Section 143(1)Section 147Section 148Section 148A

…was digitally signed on 31.03.2021, but on portal it was dispatched on 01.04.2021. At this point, the learned counsel for the assessee drew our attention to the decision of the Hon'ble Supreme Court in the case of Union of India Vs. Ashish Agarwal (2022) 444 ITR 1(SC), wherein the Hon'ble Supreme Court has laid down procedure and relevant principles in para 8 are as under:- “8. However, at the same time, the judgments of the several High Courts would result in no reassessment proceedings at all, even if the same are permissible under the Finance Act, 2021 and as per substituted sections 147 to 151 of the I…

ACIT-15(3)(2), Mumbai vs. Surya Ferrous Alloys Pvt Ltd, Mumbai

Appeal are dismissed as having been rendered infructuous

ITA 1407/MUM/2024[2015-16]Status: DisposedITAT Mumbai11 Sept 2024AY 2015-16

Bench: SHRI PRASHANT MAHARISHI, ACCOUNTANT MEMBER SHRI RAHUL CHAUDHARY (Judicial Member)

For Appellant: Shri Ajay R. SinghFor Respondent: Shri Kishor Dhule
Section 143(1)Section 144BSection 147Section 148Section 148ASection 149Section 151ASection 40A(3)

…s and circumstances notice, dated 27/08/2022, issued under Section 148 of the Act by the assessing officer for the Assessment Year 2015-16, pursuant to the directions issued by the Hon’ble Supreme Court in the case of Union of India Vs. Ashish Agarwal: [2022] 444 ITR 1 (SC)[04- 05-2022], was held by the Hon’ble Bombay High Court to be barred by limitation in view of the first proviso to Section 149 of the Act since it was issued after 31/03/2022. 9. The Learned Departmental Representative relied upon the judgment of the Hon’ble Supreme Court in the case of Union of India Vs. Ashish Agarwal: [2022] 444 ITR 1 (SC)[…

DCIT-14.1.1, Mumbai vs. Amcor Flexibles India Pvt. Ltd, Mumbai

In the result, appeal of the Revenue is dismissed

ITA 3842/MUM/2024[2013-14]Status: DisposedITAT Mumbai06 Sept 2024AY 2013-14

Bench: SHRI AMIT SHUKLA (Judicial Member), SMT RENU JAUHRI (Accountant Member)

Section 142(1)Section 143(2)Section 143(3)Section 147Section 148Section 148ASection 250

…of assessment for AY 2013-14 expired on 31-3-2020, notice issued in June 2021 in case of assessee was barred by limitation, hence, section 148 notice dated 28-7-2022 issued pursuant to Union of India v. Ashish Agarwal [2022] 138 taxmann.com 64/286 Taxman 183/444 ITR 1 (SC) was to be quashed and set aside and was invalid, without jurisdiction and barred by limitation. 15. It was thus submitted by the Ld. AR that the Notice issued under Section 148 of the Act is after the time limit prescribed under Section 149(1)(b) of the Act and hence it is time barred. 16. Ld. DR on the other hand relied on the order of AO an…

Income Tax Officer, Ward-1, Jharsuguda, Aayakar Bhawan vs. Hirakhand Transport and Multi Purpose Co-Operative Society Ltd., Brajaraj Nagar

ITA 282/CTK/2024[2015-2016]Status: HeardITAT Cuttack04 Sept 2024AY 2015-2016

Bench: Shri George Mathan & Shri Manish Agarwalआयकर अऩीऱ सं/Ita No.282/Ctk/2024 (ननधाारण वषा / Assessment Year : 2015-2016) Ito, Ward-1, Jharsuguda Vs Hirakhand Transport & Multi Purpose Cooperative Society Pvt. Ltd., At-Chingriguda, Bijapara, R Kudopali, Brajrajnagar, Jharsuguda-768216 Pan No. :Aaaah 5874 Q & प्रत्याक्षेऩ सं/Cross Objection No.04/Ctk/2024 (Arising Out Of Ita No.282/Ctk/2024) (ननधाारण वषा / Assessment Year : 2015-2016) Hirakhand Transport & Multi Vs Ito, Ward-1, Jharsuguda Purpose Cooperative Society Pvt. Ltd., At-Chingriguda, Bijapara, R Kudopali, Brajrajnagar, Jharsuguda-768216 Pan No. :Aaaah 5874 Q (अऩीऱाथी /Appellant) (प्रत्यथी / Respondent) .. ननधााररती की ओर से /Assessee By : Shri Anil Kumar Agrawala, Ca राजस्व की ओर से /Revenue By : Shri Sanjay Kumar, Cit-Dr सुनवाई की तारीख / Date Of Hearing : 04/09/2024 घोषणा की तारीख/Date Of Pronouncement : 04/09/2024 आदेश / O R D E R Per Bench : This Is An Appeal Filed By The Assessee Against The Order Of The Ld. Cit(A), National Faceless Appeal Centre (Nfac), Delhi, Dated 15.05.2024, Passed In Din & Order No.Itba/Nfac/S/250/2024- 25/1064895008(1) For The Assessment Year 2015-2016, On The Following Grounds Of Appeal :-

For Appellant: Shri Anil Kumar Agrawala, CAFor Respondent: Shri Sanjay Kumar, CIT-DR
Section 147Section 148Section 151(1)Section 151(2)Section 250Section 251(1)(a)Section 40A(2)(b)

…ed and if a notice is issued on or after 01.04.2021 the procedure for reopening as inserted by the Finance Act, 2021 should be followed. For this, ld. AR placed reliance on the decision of the Hon’ble Supreme Court in the case of UOI Vs. Ashish Agarwal (2022) 444 ITR 1 (SC). He also submitted that the proceedings u/s.148A of the Act were 9 & CO No.04/CTK/2024 also initiated in the case of the assessee and the same were dropped by passing the order u/s.148A(d) of the Act dated 29.07.2022 by holding that it is not a fit case for issue of notice u/s.148 of the Act as the necessary order has already been passed u/s.1…

Chhering Tomdan, Spiti, Himachal Pradesh vs. Income Tax Officer, Rampur Bushahr, Himachal Pradesh

In the result, the appeal is allowed

ITA 170/CHANDI/2024[2017-18]Status: DisposedITAT Chandigarh04 Sept 2024AY 2017-18

Bench: Shri A.D. Jain & Shri Krinwant Sahayआयकर अपील सं./ Ita No. 170/Chd/2024 "नधा"रण वष" / Assessment Year : 2017-18 Chhering Tomdan, Vs. The Ito, Village Khurik, बनाम Rampur Bushahr, Po Rangreek, Himachal Pradesh Rangrik B.O. Khurik (78), Lauhaul & Spiti, H.P. 171114 "थायी लेखा सं./Pan No: Bhxpt8803P अपीलाथ"/ Appellant ""यथ"/ Repsondent ( Hybrid Mode ) "नधा"रती क" ओर से/Assessee By : Shri Nikhil Goyal, Advocate, Shri Viren Sibbal, Advocate & Shri Ashok Goyal, Ca राज"व क" ओर से/ Revenue By : Shri Ved Parkash Kalia, Jcit, Sr. Dr

For Appellant: Shri Nikhil Goyal, AdvocateFor Respondent: Shri Ved Parkash Kalia, JCIT, Sr. DR
Section 142(1)Section 144Section 147Section 148Section 149Section 156Section 250Section 69A

…r section 149 (1) (b) of the Income Tax Act, 1961. 3. That the reassessment proceedings are bad in law and non-est as the same have been concluded without following the directions of Hon'ble Supreme Court in the case of Union of India v. Ashish Agarwal (2022) 444 ITR 1 (SC). 4. That the impugned Order had been passed in gross violation of the principle of natural justice and without allowing reasonable opportunity of being heard to the Assessee. 5. That the Ld. AO has erred in passing the order under section 144 read with section 147 of the Income Tax Act, 1961 6. That the order passed by Ld. AO is void as no…

Aakruti Ketan Mehta, Mumbai vs. National Faceless Assessment Centre, Delhi

In the result, the appeal of the assessee is allowed

ITA 3477/MUM/2024[2016-17]Status: DisposedITAT Mumbai26 Aug 2024AY 2016-17

Bench: Justice (Retd.) Shri C.V. Bhadang & Shri B.R. Baskaran: A.Y : 2016-17

For Appellant: Shri Dharmesh Shah &For Respondent: Shri Manoj Kumar Sinha, Sr.DR
Section 148Section 148A

…ver, such kind of notices issued under old provisions after 31- 03-2021 came to be struck down by various High Courts and when the matter reached Hon‟ble Supreme Court, the Hon‟ble Apex Court, in the case of Union of India and others vs. Ashish Agarwal [2022] 444 ITR 1 (SC), provided remedies to the Revenue by stating that - notices issued u/s. 148 to the respective assessees shall be deemed to have been issued u/s. 148A of the Act as substituted by the Finance Act, 2021 and be treated to be show cause notices in terms of section 148A(b). The relevant portion of the order passed by the Hon‟ble Supreme Court in th…

Vardha Enterprises Private Limited, Mumbai vs. Assistant Commissioner of Income Tax, Mumbai

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

ITA 2416/MUM/2023[2013-14]Status: DisposedITAT Mumbai26 Aug 2024AY 2013-14

Bench: Shri Narender Kumar Choudhry & Shri Amarjit Singhassessment Year: 2013-14

For Appellant: Shri Rakesh Joshi, C.AFor Respondent: Shri Ankush Kapoor, CIT DR
Section 115BSection 132Section 148Section 148ASection 250Section 69C

…IN THE INCOME TAX APPELLATE TRIBUNAL, MUMBAI BENCH “F”, MUMBAI BEFORE SHRI NARENDER KUMAR CHOUDHRY, JUDICIAL MEMBER AND SHRI AMARJIT SINGH, ACCOUNTANT MEMBER Assessment Year: 2013-14 M/s. Vardha Enterprises Assistant Private Limited, Commissioner of 103, Shantivan 2A, Income Tax, Raheja Township, Vs. Central Circle-4(3), 1921, 19th Floor, Malad (E), Mumbai-400097. Air India Building, PAN: AACCV6065D Nariman Point, Mumbai-400021. (Appellant) (Respondent) Present for: Assessee by : Shri Rakesh Joshi, C.A. Shri Tapan Doshi, A.R. Revenue by : Shri Ankush Kapoor, CIT DR Date of Hearing : 11.06.2024 Date of Prono…

Applied Tek and Management Consultancy Pvt Ltd, Mumbai vs. ITO, Mum-C-(411)(1), DCIT, Circle-1(1)(1), Mumbai

In the result, the ITA Nos

ITA 4794/MUM/2023[2014-15]Status: DisposedITAT Mumbai21 Aug 2024AY 2014-15

Bench: Shriprashant Maharishi & Shri Anikesh Banerjee

For Appellant: Shri DeepakTralshawalaFor Respondent: ShriManoj Kumar Sinha (Sr. DR)
Section 144BSection 147Section 148Section 148ASection 250

…IN THE INCOME TAX APPELLATE TRIBUNAL MUMBAI BENCH “A”, MUMBAI BEFORE SHRIPRASHANT MAHARISHI, ACCOUNTANT MEMBER AND SHRI ANIKESH BANERJEE, JUDICIAL MEMBER I.T.A No.4681/Mum/2023 - A.Y. 2016-17 I.T.A No.4792/Mum/2023 - A.Y. 2013-14 I.T.A No.4794/Mum/2023 - A.Y. 2014-15 Applied Tek and Management vs Deputy Commissioner of Income- Consultancy Pvt Ltd, tax, Circle-1(1)(1), Mumbai 401E, Remi Biz Court, Veera Aayakar Bhavan, M.K. Road, Desai Road, Andheri (West), Mumbai Mumbai-400 053 PAN : AAGCS9857C APPELLANT RESPONDENT Assessee by : Shri DeepakTralshawala Respondent by : ShriManoj Kumar Sinha (Sr. DR) Date of he…

Applied Tek and Management Consultancy Pvt Ltd, Mumbai vs. ITO, Mum-C-(411)(1), DCIT, Circle-1(1)(1), Mumbai

In the result, the ITA Nos

ITA 4792/MUM/2023[2013-14]Status: DisposedITAT Mumbai21 Aug 2024AY 2013-14

Bench: Shriprashant Maharishi & Shri Anikesh Banerjee

For Appellant: Shri DeepakTralshawalaFor Respondent: ShriManoj Kumar Sinha (Sr. DR)
Section 144BSection 147Section 148Section 148ASection 250

…IN THE INCOME TAX APPELLATE TRIBUNAL MUMBAI BENCH “A”, MUMBAI BEFORE SHRIPRASHANT MAHARISHI, ACCOUNTANT MEMBER AND SHRI ANIKESH BANERJEE, JUDICIAL MEMBER I.T.A No.4681/Mum/2023 - A.Y. 2016-17 I.T.A No.4792/Mum/2023 - A.Y. 2013-14 I.T.A No.4794/Mum/2023 - A.Y. 2014-15 Applied Tek and Management vs Deputy Commissioner of Income- Consultancy Pvt Ltd, tax, Circle-1(1)(1), Mumbai 401E, Remi Biz Court, Veera Aayakar Bhavan, M.K. Road, Desai Road, Andheri (West), Mumbai Mumbai-400 053 PAN : AAGCS9857C APPELLANT RESPONDENT Assessee by : Shri DeepakTralshawala Respondent by : ShriManoj Kumar Sinha (Sr. DR) Date of he…

Applied Tek and Management Consultancy Pvt Ltd, Mumbai vs. Income Tax Officer, Mumbai

In the result, the ITA Nos

ITA 4681/MUM/2023[2016-17]Status: DisposedITAT Mumbai21 Aug 2024AY 2016-17

Bench: Shriprashant Maharishi & Shri Anikesh Banerjee

For Appellant: Shri DeepakTralshawalaFor Respondent: ShriManoj Kumar Sinha (Sr. DR)
Section 144BSection 147Section 148Section 148ASection 250

…IN THE INCOME TAX APPELLATE TRIBUNAL MUMBAI BENCH “A”, MUMBAI BEFORE SHRIPRASHANT MAHARISHI, ACCOUNTANT MEMBER AND SHRI ANIKESH BANERJEE, JUDICIAL MEMBER I.T.A No.4681/Mum/2023 - A.Y. 2016-17 I.T.A No.4792/Mum/2023 - A.Y. 2013-14 I.T.A No.4794/Mum/2023 - A.Y. 2014-15 Applied Tek and Management vs Deputy Commissioner of Income- Consultancy Pvt Ltd, tax, Circle-1(1)(1), Mumbai 401E, Remi Biz Court, Veera Aayakar Bhavan, M.K. Road, Desai Road, Andheri (West), Mumbai Mumbai-400 053 PAN : AAGCS9857C APPELLANT RESPONDENT Assessee by : Shri DeepakTralshawala Respondent by : ShriManoj Kumar Sinha (Sr. DR) Date of he…