“reassessment proceedings”

Sky Gem, Mumbai vs. DCIT, CC-1(1), Mumbai

that the assumption of jurisdiction by the Ld. Assessing Officer is bad in law as the conditions laid down under the Act for initiating reassessment proceeding u/s 147 of the Act have not been fulfilled. 2. On the facts and circumstances of the case ... treated by the Assessing Officer as unexplained cash credit. 4.1. Being aggrieved the Appellant preferred appeal before the CIT(A) challenging the validity of reassessment proceedings as well as the additions made on merit. Vide order dated 06/02/2023, the CIT(A) dismiss the appeal preferred by the Assessee. 4.2. Therefore

Falguni Samir Mehta, Mumbai vs. ACIT-19(1), Mumbai

In the result, the appeal of the assessee is dismissed

Bench: Shri Om Prakash Kant () & Ms. Kavitha Rajagopal () Assessment Year: 2012-13 Falguni Samir Mehta, Acit-19(1), 303, Mansarovar, Mount Pleasant Room No. 203, 2Nd Floor, Vs. Road, Mumbai-400006. Matru Mandir, Tardeo Road, Mumbai-400007. Pan No. Abeps 6347 K Appellant Respondent

categories. The ‘first’ category of the grounds is category of the grounds is where the assessee h assessee has challenged validity of the reassessment proceedings. In t f the reassessment proceedings. In the ‘second second’ category of the grounds, the assessee has challenged addition on merit. Since, the assessee ... application of the mind application of the mind by the Assessing Officer by the Assessing Officer. According to the ld Counsel, the entire reassessment proceedings vitiates he entire reassessment proceedings vitiates he entire reassessment proceedings vitiates due to non application of mind by the to non application of mind

M/S. Doit Creations (India) Pvt. Ltd, Mumbai vs. Pr. Comm of Income Tax, Central Circle-3, Mumbai

In the result, the appeal of the assessee is partly allowed and additional ground of appeal filed by the assessee is dismissed

Bench: Shri Amit Shukla & Shri Amarjit Singhdoit Creations (India) Vs. Principal Commissioner Private Limited Of Income Tax, Central 307 & 308, 3Rd Floor,, Circle 3, Room No. 1901, Midas, Sahar Plaza, 19Th Floor, Air India Andheri (East) Building, Nariman Point, Mumbai – 400 069 Mumbai – 400 021 स्थायी लेखा सं./जीआइआर सं./Pan/Gir No: Aabcd8695A Appellant .. Respondent [ Appellant By : Dharan Gandhi Respondent By : Neena Jeph Date Of Hearing 27.07.2023 Date Of Pronouncement 23.07.2023 आदेश / O R D E R Per Amarjit Singh (Am): This Appeal Filed By The Assesse Is Directed Against The Order Passed By The Ld. Pcit(Central), Mumbai -3, Dated 31.03.2022 For A.Y. 2015-16. The Assessee Has Raised The Following Grounds Before Us: “1. On The Facts & Circumstances Of The Case & In Law, The Hon'Ble Pr.Cit Central - 3 (Herein After Referred As 'Pcit) Erred In Invoking Provisions Of Section 263 Of The Income Tax Act, 1961 (Hereinafter Referred As 'The Act') By Issuing The Notice Inspite Of The Fact That Assessment U/S. 143(3) & U/S 143(3) R.Ws 147 Of The Act Has Been Completed After Due Examination & Application Of Mind While Framing The Assessment Order U/S 143(3) & U/S 143(3) Rws 147 Of The Act. Further Order U/S 263 Is Also Passed Merely Setting Aside The Assessment To The File Of The Learned Assessing Officer To Conduct Proper Inquiry Which Is Unjustified. It Is Therefore Submitted That The Order Passed U/S 263 Should Be Cancelled.

alter, or amend any of the grounds of appeal on or before the date of hearing of appeal.” Additional Ground of appeal: “1. The reassessment proceeding initiated vide notice u/s 148 of the Act dated 26.03.2019 is null and void and bad in law. Consequently, the order u/s 263 dated ... submitted that your assessee has submitted all the relevant details as called during the course of reassessment proceedings and after due inquiries, verification and satisfaction the Ld. AO has passed the order U/s 143 r.w.s. 147 of the Act accepting the returned income filed your assessee in response

Balaji Universal Tradelink Pvt. Ltd., Mumbai vs. DCIT - CC- 7(1), Mumbai

In the result, appeal of the assessee is dismissed

Bench: Shri Vikas Awasthy & Shri Gagan Goyalm/S Balaji Universal Tradelink Pvt. Ltd. 118/120, 3Rd Floor, Ashoka House, Zaveri Bazar, Mumbai-400 002 Pan: Aivpb1665R ...... Appellant Vs. Dcit Cen. Cir. 7(1) Maharashtra, Mumbai ..... Respondent

assessment year. 1.2 The Appellant submits that the considering the facts and circumstances of its case and in law prevailing on the subject the reassessment proceedings 3 M/s Balaji Universal Tradelink Pvt. Ltd. were not in accordance with the law and the provisions of the Income ... appellant submits that the reassessment proceedings be held to be bad in law and struck down. 2. Because, in any view, specific mention by the A.O. in the reasons recorded for reopening the completed assessment of the failure of the assessee to disclose fully and truly all material facts necessary

Hasmukhbhai B. Patel HUF, Mumbai vs. CIT(Appeals), NFAC, Delhi

In the result, appeals for the assessment years 2014-15 and 2015-16

Bench: Shri B.R. Baskaran & Shri Sandeep Singh Karhail

stocks proceedings under section 147 of the Act were initiated and notice under section 148 of the Act was issued on 28/09/2016. During the reassessment proceedings, the assessee filed a letter intimating about the death of Mr. Hasmukhbhai B. Patel, on 15/07/2013, and the appointment of a legal heir ... Amit H. Patel, as the new Karta of the assessee HUF. During the reassessment proceedings, it was observed that the assessee has claimed an exemption of long-term capital gains of Rs.8,18,51,632, on the sale of shares of Comfort Intech Ltd and Splash Media under section

M/S. Jet Speed Realtors, Mumbai vs. ACIT Circle 32 (1), Mumbai

Bench: Shri Aby T Varkey () & Ms. Padmavathy S. ()

reason to believe that the income for any assessment year has escaped assessment, the proviso to the aforesaid section, curtails the powers to initiate reassessment proceedings beyond the period of 4 years from the end of the relevant assessment year, where the assessment has been completed under section ... page 42 to 47 of paper book). The ld AR brought to our attention that the reasons recorded for reopening in the first round reassessment proceedings (page 26 of paper book) is the non-genuine loan transactions the assessee has entered into with certain parties and in that context