“reassessment proceedings”

Manisha Anil Sharma, Vashi, Navi Mumbai vs. The Income Tax Officer (Int Tax) - 4 (2) (1), Mumbai

Accordingly, Ground No.1 raised by the Assessee is allowed while

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

confirming the action of the Ld. AO in assuming jurisdiction under Section 147 of the Act as well as upholding the validity of the reassessment Proceedings under Section 147 read with section 148 of the Act, when initiation of proceedings did not satisfy necessary requisites including monetary limit contained ... case, the Ld. AO has erred in and the DRP has further erred in confirming the action of the Ld. AO, for initiation of reassessment proceedings by the Ld. AO had relied on the statement of Mrs. Pushpa Parakh, which is factually incorrect and false, as Mrs. Pushpa Parakh

Chemox Exports Imports Pvt Ltd, Mumbai vs. Income Tax Department, Assessment Unit, Delhi

Bench: Shri Narendra Kumar Billaiya, Hon'Ble & Shri Raj Kumar Chauhan, Hon'Bleι.Τ.Α. No. 3954/Mum/2024

been alleged by the Revenue in the Office Memorandum. Further, in paragraph 3.2 of the Office Memorandum, with respect to the reassessment proceedings, the reference to 'random allocation' has correctly been made as random allocation of cases to the Assessment Units by the National Faceless Assessment Centre. When random allocation

Konark Fixtures Ltd( Successor to Kalinga Fixtures Pvt Ltd), Mumbai vs. DCIT Circle-6(1)(2), Mumbai

Appeal is allowed

Bench: Shri Pavan Kumar Gadale & Shri Girish Agrawal

IN THE INCOME TAX APPELLATE TRIBUNAL, “E” BENCH MUMBAI BEFORE SHRI PAVAN KUMAR GADALE, JUDICIAL MEMBER & SHRI GIRISH AGRAWAL, ACCOUNTANT

Leading Age Developers Private Limited, Mumbai vs. ACIT CC 2(2), Mumbai

In the result, appeal of the assessee in ITA No

Bench: Shri Pavan Kumar Gadale & Shri Girish Agrawal

such an exercise of issuing notice u/s 133(6) was undertaken prior to the invocation of impugned proceedings and not during the course of reassessment proceedings. Going by the records placed by the assessee of all the share subscribing companies, it can be safely held that the assessee has discharged ... verify the same. However, as noted above, ld. AO in this case has not made any independent enquiry in the course of impugned reassessment proceedings to verify the genuineness of the transactions. Assessee, having furnished all the details and documents before

Leading Age Developers Private Limited, Mumbai vs. Central Circle 2(2), Central Building

In the result, appeal of the assessee in ITA No

Bench: Shri Pavan Kumar Gadale & Shri Girish Agrawal

such an exercise of issuing notice u/s 133(6) was undertaken prior to the invocation of impugned proceedings and not during the course of reassessment proceedings. Going by the records placed by the assessee of all the share subscribing companies, it can be safely held that the assessee has discharged ... verify the same. However, as noted above, ld. AO in this case has not made any independent enquiry in the course of impugned reassessment proceedings to verify the genuineness of the transactions. Assessee, having furnished all the details and documents before

International Transmission Ltd, Mumbai vs. Deputy Commissioner of Income Tax Circle -15(1)(2), Mumbai

In the result, the appeal by the assessee is allowed

Bench: Shri Om Prakash Kantshri Sandeep Singh Karhailinternational Transmission Ltd. 501, 5Th Floor, Vasudeo Chambers, Mulund Goregaon Link Road, Bhandup (W), Mumbai - 400078 ……………. Appellant Pan: Aaaci0975M V/S

facts and in the circumstances of the case, and in law, the Ld. CIT(A) erred in upholding legal validity of the reassessment proceedings under section 147 of the Act. Your appellant submits that the Ld. CIT(A) failed to appreciate, and ought to have held, that the reassessment proceedings ... 03/04/2019. 4 After receiving the reasons recorded by the AO for reopening the assessment, the assessee filed detailed objections against the initiation of reassessment proceedings for the assessment year 2012-13, which were disposed of by the AO vide order dated 29/08/2019. The AO vide order dated 28/12/2019 passed under

Sonal Snehal Shah, Mumbai vs. ITO 19(3)(1), Mumbai

Bench: Shri Prashant Maharishi, Am & Shri Rahul Chaudhary, Jm

information relied upon by him at the time of issuance of notice under section 148. This was requested for several occasions during the entire reassessment proceedings. No certified copies of the statement were furnished in completion of the reassessment and no opportunity was afforded for cross examination/verification of records ... case of punk it jokes versus ITO (2019) 411 ITR 207. vii. The learned assessing officer has not carried out any enquiry before initiating reassessment proceedings. He submits that the reopening has been made on the completely borrowed satisfaction which is not permitted under the law. For this proposition

Pankaj Dhandharia, Mumbai vs. ACIT-22(1), Mumbai

Appeal is dismissed

Bench: Shri Prashant Maharishi, Am & Shrisunil Kumar Singh, Jm

buyer. Assessee does not know anything about the valuation mechanism and the factual aspect discussed with DVO by the seller. During the course of reassessment proceedings, assessee objected about the valuation as per the stamp duty authorities and also the valuation report of the DVO. Though the assessee referred ... case of Siemens financial services (P) Ltd (2023) 154 taxmann.com 159 (Bombay) and submitted that such an approval is invalid and renders the reassessment proceedings also invalid. He further relied upon the decision of the honourable Bombay High Court in case of RuthSunil Mantri dated 17 October 2023 and several

Bhavana Lalit Jain, Navi Mumbai vs. Income Tax Officer, WD-15(1)(1), Mumbai

The appeals are allowed

Bench: Shri Prashant Maharishi, Am & Shriraj Kumar Chauhan, Jm

impugned assessment has escaped assessment, Therefore, notice under section 148 of the act was issued on 6/9/2016. 6. During the course of reassessment proceedings, assessee submitted that she has purchased 4000 shares on 26/3/2012 at a total consideration of Rs. 100,0000/– at the rate of Rs. 250 per share