JAYANTILAL SANGHVI,INDORE vs. ACIT 4(1), INDORE

Appeal is partly allowed for statistical purpose

Bench: Shri Vijay Pal Rao & Shri B.M. Biyaniassessment Year: 2012-13 Jayantilal Sanghvi, Acit, 8/10, Warehouse Road, 4(1), बनाम/ Patel Bridge, Indore. Vs. Indore. (Assessee/Appellant) (Revenue/Respondent) Pan: Agtps5825Q Assessee By Shri Venus Rawka, C.A. Revenue By Shri Ashish Porwal, Sr. Dr Date Of Hearing 12.06.2024 Date Of Pronouncement .06.2024

154 taxmann.com 506 (Delhi): We re-produce below this order in entirety to show the facts of case: “This appeal is directed against the order dated 29-6-2018 passed by the Income-tax Appellate Tribunal [in short "Tribunal"] concerning Assessment Year (AY) 2009- 2010. 2. The principal allegation levelled against the respondent/assessee, based on which the reassessment proceedings under

SANDHYA SINGH ,BHOPAL vs. ITO (2)(3), BHOPAL

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

Bench: Shri B.M. Biyani & Shri Paresh M. Joshiassessment Year:2014-15 Sandhya Singh Nfac, 121, Rohit Nagar, New Delhi बनाम/ Bawadia Kala, Vs. Bhopal (Assessee/Appellant) (Revenue/Respondent) Pan: Aycps9215K Assessee By Shri Gagan Tiwari & Ms. Priyal Jain, Ars Revenue By Shri Ashish Porwal, Sr. Dr Date Of Hearing 19.03.2026 Date Of Pronouncement 17.04.2026

3 of 35 Sandhya Singh ITA No. 585/Ind/2025 – AY 2014-15 time-limit of 6 years from end of AY 2014-15 prescribed in section 149 expired on 31.03.2021, the time-limit was extended uptill 30.06.2021 by THE TAXATION AND OTHER LAWS (RELAXATION AND AMENDMENT OF CERTAIN PROVISIONS) ACT, 2020 [“TOLA”] and saved by the decision of Hon’ble Supreme

THE ACIT- 4(1), INDORE, INDORE vs. M/S PRESTIGE FEED MILLS LTD., INDORE

In the result, the appeal of revenue is dismissed

Bench: Shri Vijay Pal Rao & Shri B.M. Biyaniacit-4(1) Prestige Feed Mills Ltd. Indore 30, Jaora Compound Vs. Indore (Appellant / Revenue) (Assessee) Pan: Aabcp0412H Assessee By Shri Ashish Goyal & N.D. Patwa, Ars Revenue By Shri Ashish Porwal, Sr. Dr Date Of Hearing 12.10.2023 Date Of Pronouncement 13.10.2023

section 154 of the Act as it is not a mistake apparent from the record but the AO has made reassessment in the garb of rectification of mistake. He has supported the impugned order of the CIT(A) and submitted that the CIT(A) rightly deleted the addition as all these issues were already examined by the AO while passing

ASSISTANT COMMISSIONER OF INCOME TAX 1 (1), INDORE vs. M/S FERRO CONCREATE CONSTRUCTION (INDIA) PVT. LTD INDORE, INDORE

Bench: Hon’Ble Rajpal Yadav & Hon’Ble Manish Boradvirtual Hearing

3) was completed vide order dated 19.12.2011 thereby making addition of Rs. 37,25,962/- on account of low net profit and deemed dividend u/s 2(22)(e) and hence assessing total income at Rs. 1,81,09,150/-. Thereafter, an order u/s 154 was passed on 26.12.2012 on the question of depreciation resulting into determination of total income

M/S. FERRO CONCRETE CON. INDIA PVT. LTD.,INDORE vs. THE PR.CIT-1, INDORE

Bench: Hon’Ble Rajpal Yadav & Hon’Ble Manish Boradvirtual Hearing

3) was completed vide order dated 19.12.2011 thereby making addition of Rs. 37,25,962/- on account of low net profit and deemed dividend u/s 2(22)(e) and hence assessing total income at Rs. 1,81,09,150/-. Thereafter, an order u/s 154 was passed on 26.12.2012 on the question of depreciation resulting into determination of total income

M/S. FERRO CONCRETE CON. INDIA PVT. LTD.,INDORE vs. THE DCIT CIRCLE-1(1), INDORE

Bench: Hon’Ble Rajpal Yadav & Hon’Ble Manish Boradvirtual Hearing

3) was completed vide order dated 19.12.2011 thereby making addition of Rs. 37,25,962/- on account of low net profit and deemed dividend u/s 2(22)(e) and hence assessing total income at Rs. 1,81,09,150/-. Thereafter, an order u/s 154 was passed on 26.12.2012 on the question of depreciation resulting into determination of total income

SARTHAK REAL BUILT PVT. LTD, ,INDORE vs. DY, CIT,CPC-TDS, GHAZIABAD

Bench: Hon’Ble Rajpal Yadav & Hon’Ble Manish Boradvirtual Hearing

3) was completed vide order dated 19.12.2011 thereby making addition of Rs. 37,25,962/- on account of low net profit and deemed dividend u/s 2(22)(e) and hence assessing total income at Rs. 1,81,09,150/-. Thereafter, an order u/s 154 was passed on 26.12.2012 on the question of depreciation resulting into determination of total income

SHRIMATI SHARDA KASLIWAL,INDORE vs. ASSISTANT COMMISSIONER OF INCOME TAX- CENTRAL (I), INDORE, INDORE

Bench: Hon’Ble Kul Bharat & Hon’Ble Manish Borad

3. Section 153 is in respect of time limit for completion of assessments and reassessments. The second proviso to sub section 4 of Section 153 as amended by the Finance Act, 2008 w.e.f. 01106/2007 is as under.- Provided further that where a proceeding before the Settlement Commission abates under section 245HA, the period of limitation available under this section

M/S PUMARTH INFRASTRUCTURE PVT.LTD.,INDORE vs. ASSISTANT COMMISSIONER OF INCOME TAX (CENTRAL)-1, INDORE, INDORE

Bench: Hon’Ble Kul Bharat & Hon’Ble Manish Borad

3. Section 153 is in respect of time limit for completion of assessments and reassessments. The second proviso to sub section 4 of Section 153 as amended by the Finance Act, 2008 w.e.f. 01106/2007 is as under.- Provided further that where a proceeding before the Settlement Commission abates under section 245HA, the period of limitation available under this section

PARTH KASLIWAL,INDORE vs. ASSISTANT COMMISSIONER OF INCOME TAX- CENTRAL (I), INDORE , INDORE

Bench: Hon’Ble Kul Bharat & Hon’Ble Manish Borad

3. Section 153 is in respect of time limit for completion of assessments and reassessments. The second proviso to sub section 4 of Section 153 as amended by the Finance Act, 2008 w.e.f. 01106/2007 is as under.- Provided further that where a proceeding before the Settlement Commission abates under section 245HA, the period of limitation available under this section

M/S NISHANT FINANCE PVT.LTD,INDORE vs. ASSISTANT COMMISSIONER OF INCOME TAX-CENTRAL (I), INDORE, INDORE

Bench: Hon’Ble Kul Bharat & Hon’Ble Manish Borad

3. Section 153 is in respect of time limit for completion of assessments and reassessments. The second proviso to sub section 4 of Section 153 as amended by the Finance Act, 2008 w.e.f. 01106/2007 is as under.- Provided further that where a proceeding before the Settlement Commission abates under section 245HA, the period of limitation available under this section

SUMATI KUMAR KASLIWAL,INDORE vs. ASSISTANT COMMISSIONER OF INCOME TAX, (CENTRAL)-1, INDORE, INDORE

Bench: Hon’Ble Kul Bharat & Hon’Ble Manish Borad

3. Section 153 is in respect of time limit for completion of assessments and reassessments. The second proviso to sub section 4 of Section 153 as amended by the Finance Act, 2008 w.e.f. 01106/2007 is as under.- Provided further that where a proceeding before the Settlement Commission abates under section 245HA, the period of limitation available under this section

MANOJ KASLIWAL,INDORE vs. ASSISTANT COMMISSIONER OF INCOME TAX- CENTRAL (1), INDORE, INDORE

Bench: Hon’Ble Kul Bharat & Hon’Ble Manish Borad

3. Section 153 is in respect of time limit for completion of assessments and reassessments. The second proviso to sub section 4 of Section 153 as amended by the Finance Act, 2008 w.e.f. 01106/2007 is as under.- Provided further that where a proceeding before the Settlement Commission abates under section 245HA, the period of limitation available under this section

DYPUTI COMMISSIONER OF INCOME TAX (CENTRAL)-1, INDORE, INDORE vs. M/S PUMARTH INFRASTRUCTURE PVT. LTD. , INDORE

Bench: Hon’Ble Kul Bharat & Hon’Ble Manish Borad

3. Section 153 is in respect of time limit for completion of assessments and reassessments. The second proviso to sub section 4 of Section 153 as amended by the Finance Act, 2008 w.e.f. 01106/2007 is as under.- Provided further that where a proceeding before the Settlement Commission abates under section 245HA, the period of limitation available under this section

M/S SHRI GURMUKHDAS CONTRACTORS P LTD,BHOPAL vs. DCIT-CENRRAL-1, BHOPAL

In the result, Revenue’s appeals in I

Bench: Ms. Madhumita Roy & Shri Bhagirath Mal Biyani

reassessment order, as the case may be, is required to be passed by the Assessing Officer with the prior approval of the [Principal Commissioner or Commissioner] under sub-section (12) of section 144BA.]" 9.1 The above provisions of section 153D of the Act were inserted by Finance Act, 2007 with effect from 01/06/2007. In our humble understanding of the said

SHRI VIKRAM SINGH PUAR SON & LR OF LATE TUKOJI ROA PUAR,DEWAS vs. THE PR. CIT-1, BHOPAL

The appeal of the assessee is hereby allowed

Bench: Shri Kul Bharat & Shri Manish Boradassessment Year: 2011-12 Vikram Singh Paur, Pr. Cit Son & Legal Heir Of Late Shri Bhopal बनाम/ Tukoji Rao Puar Vs. Dewas (Appellant) (Revenue ) P.A. No.Agdpp8186B Appellant By Shri Girish Agrawal, Ca Revenue By Shri S.B. Prasad, Cit-Dr Date Of Hearing: 27.01.2020 Date Of Pronouncement: 20 .05.2020 आदेश / O R D E R Per Kul Bharat, J.M: This Appeal By The Assessee Is Directed Against Order Of Pr. Cit, Bhopal Dated 18.03.2016 For The Assessment Year

reassessment proceedings and same cannot be made applicable for revisional proceedings as contemplated under section 263 [In favour of assessee] 6. Assessee submits that the invalidity of passing of an order in the name of deceased assessee, Late Shri Tukoji Rao Puar even when the fact of death was informed cannot be rectified under the provisions of section 154. Reliance

M/S AD-MANUM FINANCE LTD.,INDORE vs. THEDCIT 1(1) , INDORE, INDORE

Bench: Hon’Ble Kul Bharat & Hon’Ble Manish Boradassessment Year 2010-11

reassessment proceedings after an expiry of four years from the end of the relevant assessment years on the basis of certain information coming to his possession later on after obtaining approval from competent authority. Further, there is no restriction in the Income Tax Act that the case cannot be reopened u/s 14B on the basis of information collected during

THE DCIT1(1), INDORE vs. M/S. AVILABLE FINANCE LTD., INDORE

Bench: Hon’Ble Kul Bharat & Hon’Ble Manish Boradassessment Year 2010-11

reassessment proceedings after an expiry of four years from the end of the relevant assessment years on the basis of certain information coming to his possession later on after obtaining approval from competent authority. Further, there is no restriction in the Income Tax Act that the case cannot be reopened u/s 14B on the basis of information collected during