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Section 226(3)

Section References (mined)Section 226Section 226(3)42 judgments

BHAVIK SHASHIKANT THAKKAR,MUMBAI vs. ASSISTANT COMMISSIONER OF INCOME TAX 27(1), VASHI MUMBAI

In the result, the appeal of the assessee bearing ITA No

ITA 5208/MUM/2025[2012-13]Status: DisposedITAT Mumbai03 Feb 2026AY 2012-13

Bench: Shri Anikesh Banerjee & Shri Makarand Vasant Mahadeokarbhavik Shashikant Thakkar Vs Assistant Commissioner Of Income G 601 Kukreja Palace Tax, Ward 27(1), Mumbai 4Th Floor, Tower No.6, Vashi Station Opportunity Pok, Maharashtra-400075 Complex, Vashi-400703 Pan: Acypt3095J Appellant Respondent Assessee By : Shri Nishit Gandhi, Adv Respondent By : Ms. Rajni Rani Roy (Cit Dr) Date Of Hearing : 28/01/2026 Date Of Pronouncement : 03/02/2026 O R D E R Per: Anikesh Banerjee (Jm): The Instant Appeal Of The Assessee Filed Against The Order Of The Nfac, Delhi [For Brevity ‘The Ld. Cit(A)], Order Passed Under Section 250 Of The Income Tax Act 1961 (For Brevity ‘The Act’) For Assessment Year 2012-13, Date Of Order 28.11.2022. The Impugned Order Emanated From The Order Of The Ld. Acit-27(1), Mumbai (For Brevity The “Ld. Ao”), Order Passed Under Section 143(3) Date Of Order 24.03.2015 Of The Act.

For Appellant: Shri Nishit Gandhi, AdvFor Respondent: Ms. Rajni Rani Roy (CIT DR)
Section 143(3)Section 250

also brought to our notice that recovery proceedings have been initiated against the assessee by issuance of notice under 5 Bhavik Shashikant Thakkar section 226(3) of the Act dated 23.07.2025. By way of a sworn affidavit, the assessee has further confirmed that during the COVID-19 pandemic

DCIT, CENTRAL CIRCLE - 4(4), KOLKATA, KOLKATA vs. M/S. EVERNEWCOMMODEAL PVT. LTD. , KOLKATA

In the result, ITA No.1535/Kol/2025 of the revenue is dismissed

ITA 1536/KOL/2025[2019-20]Status: DisposedITAT Kolkata10 Oct 2025AY 2019-20

Bench: Shri Rajesh Kumar & Shri Pradip Kumar Choubeyita Nos.1535 & 1536/Kol/2025 Assessment Years: 2018-19 & 2019-20 Dcit, Central Circle-4(4), Kolkata.…………………………….…….……Appellant Vs. M/S Evernewcommodeal Pvt. Ltd..……………….………...……...…..…..Respondent 11, Pollock Street, Kol- 1. [Pan: Aabce9293P] Appearances By: Shri Altaf Hossain, Addl. Cit-Dr, Appeared On Behalf Of The Appellant. Shri Manish Tiwari, Fca, Appeared On Behalf Of The Respondent. Date Of Concluding The Hearing : September 17, 2025 Date Of Pronouncing The Order : October 10, 2025 Order Per Pradip Kumar Choubey: Both The Captioned Appeals Have Been Preferred By The Assessee For The Assessment Years 2018-19 & 2019-20 Against Separate Orders Both Dated 25.04.2025 Of The Commissioner Of Income Tax (Appeals)-27, Kolkata [Hereinafter Referred To As ‘Cit(A)’] Passed U/S 250 Of The Income Tax Act (Hereinafter Referred To As The ‘Act’) Respectively. Since, The Issues Involved In Both The Appeals Are Common & Relate To The Same Assessee, Therefore, These Appeals Have Been Heard Together & Are Being Disposed Of By This Consolidated Order. Ita No.1535/Kol/2025 Is Taken As Lead Case For Narration Of Facts. Ita No.1535/Kol/2025 - Brief Facts Of The Case Are That U/S 2. 139(1) Of The Act On 10-10-2019 Declaring A Total Income At Rs. 10,02,960/-. The Same Was Processed U/S 143(1) Of The Act. Later, A Search & Seizure Operation U/S 132 Of The Act Was Conducted At "Ladhuram Toshniwal Group" On 08-03-2022 As A Part Of "Jain Group" Of Concerns/ Persons At Various Places & Simultaneously, Business

Section 127Section 132Section 133ASection 142(1)Section 143(1)Section 143(2)Section 147Section 148Section 2Section 250

आयकर अपील"य अ"धकरण, कोलकाता पीठ, कोलकाता IN THE INCOME TAX APPELLATE TRIBUNAL “A” BENCH KOLKATA Before Shri Rajesh

DCIT, CENTRAL CIRCLE - 4(4), KOLKATA, KOLKATA vs. M/S. EVERNEWCOMMODEAL PVT. LTD. , KOLKATA

In the result, ITA No.1535/Kol/2025 of the revenue is dismissed

ITA 1535/KOL/2025[2018-19]Status: DisposedITAT Kolkata10 Oct 2025AY 2018-19

Bench: Shri Rajesh Kumar & Shri Pradip Kumar Choubeyita Nos.1535 & 1536/Kol/2025 Assessment Years: 2018-19 & 2019-20 Dcit, Central Circle-4(4), Kolkata.…………………………….…….……Appellant Vs. M/S Evernewcommodeal Pvt. Ltd..……………….………...……...…..…..Respondent 11, Pollock Street, Kol- 1. [Pan: Aabce9293P] Appearances By: Shri Altaf Hossain, Addl. Cit-Dr, Appeared On Behalf Of The Appellant. Shri Manish Tiwari, Fca, Appeared On Behalf Of The Respondent. Date Of Concluding The Hearing : September 17, 2025 Date Of Pronouncing The Order : October 10, 2025 Order Per Pradip Kumar Choubey: Both The Captioned Appeals Have Been Preferred By The Assessee For The Assessment Years 2018-19 & 2019-20 Against Separate Orders Both Dated 25.04.2025 Of The Commissioner Of Income Tax (Appeals)-27, Kolkata [Hereinafter Referred To As ‘Cit(A)’] Passed U/S 250 Of The Income Tax Act (Hereinafter Referred To As The ‘Act’) Respectively. Since, The Issues Involved In Both The Appeals Are Common & Relate To The Same Assessee, Therefore, These Appeals Have Been Heard Together & Are Being Disposed Of By This Consolidated Order. Ita No.1535/Kol/2025 Is Taken As Lead Case For Narration Of Facts. Ita No.1535/Kol/2025 - Brief Facts Of The Case Are That U/S 2. 139(1) Of The Act On 10-10-2019 Declaring A Total Income At Rs. 10,02,960/-. The Same Was Processed U/S 143(1) Of The Act. Later, A Search & Seizure Operation U/S 132 Of The Act Was Conducted At "Ladhuram Toshniwal Group" On 08-03-2022 As A Part Of "Jain Group" Of Concerns/ Persons At Various Places & Simultaneously, Business

Section 127Section 132Section 133ASection 142(1)Section 143(1)Section 143(2)Section 147Section 148Section 2Section 250

आयकर अपील"य अ"धकरण, कोलकाता पीठ, कोलकाता IN THE INCOME TAX APPELLATE TRIBUNAL “A” BENCH KOLKATA Before Shri Rajesh

SHREYANSH ANILKUMAR SHAH,NA vs. ARIVS.INCOME TAX OFFICER, WARD - 5, NAVSARI

In the result, the appeal of the assessee is partly allowed

ITA 727/SRT/2023[2010-11]Status: DisposedITAT Surat26 Sept 2025AY 2010-11

Bench: Shri Dinesh Mohan Sinha & Shri Bijayananda Prusethआयकर अपील सं./Ita No.727/Srt/2023 Assessment Year: 2010-11 (Hybrid Hearing) Shreyansh Anilkumar Shah Income Tax Officer, Ward-5, बनाम/ 504, Rushabh Residency, Navsari, Income T Ax Office, Vs. Maneklal Road, Near Charpool, Awabaug, Navsari-396 Telephone Exchange, Navsari- 445 396 445 "थायीलेखासं./जीआइआरसं./Pan/Gir No: Aiqps 6441 P (अपीलाथ"/Appellant) (""थ" /Respondent) "नधा"रती क" ओर से /Appellant By Shri Rasesh Shah, Ca राज"व क" ओर से /Respondent By Shri Ajay Uke, Sr-Dr सुनवाई क" तार"ख/Date Of Hearing 22/07/2025 उ"घोषणा क" तार"ख/Date Of Pronouncement 26/09/2025 आदेश / O R D E R Per Bijayananda Pruseth, Am: This Appeal By The Assessee Emanates From The Order Passed Under Section 250 Of The Income-Tax Act, 1961 (In Short, 'The Act’) Dated 26.07.2023 By The National Faceless Appeal Centre (Nfac), Delhi/Commissioner Of Income-Tax Appeal [In Short, The ‘Cit(A)’] For The Assessment Year (Ay) 2010-11, Which In Turn Arises Out Of Assessment Order Passed By The Assessing Officer (In Short, ‘Ao’) U/S 143(3) R.W.S. 147 Of The Act On 27.10.2017. 2. Grounds Of Appeal Raised By The Assessee For The Appeal Are As Under: “1. On The Facts & Circumstances Of The Case As Well As Law On The Subject, The Ld. Ao Has Erred In Reopening Assessment U/S.147 By Issuing Notice U/S.148 Of The It Act, 1961. 2. On The Facts & Circumstances Of The Case As Well As Law On The Subject, The Ld. Cit(A) Has Erred In Confirming The Action Of Ao In Making Addition Of Rs.32,53,637/- U/S 68 Of The Act On Account Of Alleged Unexplained Cash Credits.

Section 133(6)Section 143(2)Section 143(3)Section 147Section 148Section 226(3)Section 250Section 68

IN THE INCOME-TAX APPELLATE TRIBUNAL, SURAT BENCH, SURAT BEFORE SHRI DINESH MOHAN SINHA, JUDICIAL MEMBER & SHRI BIJAYANANDA PRUSETH, ACCOUNTANT

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