ABHISHEK JAYKETU JOSHI,MUMBAI vs. AC CIR-42(2)(1), MUMBAI

In the result, the appeal of the assessee is allowed

Bench: Shri Amit Shukla & Shri Makarand Vasant Mahadeokarabhishek Jayketu Joshi Ac Cir-42(2)(1), C-73, Venus Society, R. G. Kautilya Bhavan, Thadani Marg, Worli Sea Vs. Mumbai-400 051 Face, Mumbai-400 018 Pan/Gir No. Ackpj8583H (Applicant) (Respondent) Assessee By Shri M. M. Golvala, Ld. Ar Revenue By Shri Surendra Mohan, Ld. Dr Date Of Hearing 07.01.2026 Date Of Pronouncement 13.01.2026

148A(d), followed by issuance of notice under section 148 on 19.04.2023. In response, the assessee filed a return of income on 18.05.2023, declaring the same income as originally returned and again claiming deduction under section 80GGC of Rs. 5,00,000/-. 6. During the reassessment proceedings, the Assessing Officer raised specific queries regarding the genuineness of the donation, including

VIPENDRA RAVINDRA MANDAL,THANE vs. INCOME TAX OFFICER- WARD 22(3)(6), MUMBAI

In the result, the appeal of the assessee is allowed

Bench: Shri Om Prakash Kant () & Shri Raj Kumar Chauhan () Assessment Year: 2016-17 Vipendra Ravindra Mandal, Ito Ward 22(3)(6), 405, Orchid Wing-F Lodha Crown, Piramal Chamber, Taloja Bypass Road, Kohni B.O. Vs. Mumbai-400012. Khoni, Thane-421204. Pan No. Alepm 8472 H Appellant Respondent

TDS Statement 2015-16 71 (R) consideration on sale of consideration on sale of immovable property (Section immovable property (Section 194IA 2.1. In view of the above 2.1. In view of the above information available with this office information available with this office and verification of status of Return Of Income filed by the and verification of status of Return

MAHAVIR CO OPERATIVE HOUSING SOCIETY LIMITED ,MUMBAI vs. ITO, WARD, 19(1)(1), MUMBAI

In the result the appeal filed by the assessee stands allowed

Bench: Smt. Beena Pillai () & Shri Omkareshwar Chidara ()

section 149(1)(b) of the I.T. Act, 1961, learned CIT (A) ought to have held that assumption of jurisdiction by A.O. u/s 147 r.w.s 148 and 148A is vitiated as at the time of passing order u/s 148A(d) A.O. was not in possession of books of account or other documents or evidence which reveal that the income chargeable

DARBARI INDUSTRIES,MUMBAI vs. ASSISTANT COMMISSIONER OF INCOME TAX - 41(1)(1), MUMBAI

In the result, the appeal of the assessee is allowed on legal ground, and the reassessment order is quashed

Bench: Shri Pawan Singh & Shri Makarand Vasant Mahadeokardarbari Industries Acit - 41(1)(1) 110, Champaklal 8Th Floor, Kautilya Udyog Bhavan, Sion Vs. Bhavan, C-41-43, Koliwada Road, Sion Avenue 3, Near Videsh (West), Mumbai – Bhavan, G-Block, Bkc, 400 022. Bandra Kurla Complex, Bandra East, Mumbai- 400 051 Pan/Gir No. Aaafd3277E (Applicant) (Respondent) Assessee By Shri Bhupendra Shah, Ld. Ar Revenue By Shri Annavaram Kosuri, Ld. Dr Date Of Hearing 16.04.2026 Date Of Pronouncement 21.04.2026

148A(d), notice under section 148 was issued on 27.04.2023. In response, the assessee filed return of income on 27.06.2023 declaring the same income of Rs. 22,02,720/-. 3. During the course of reassessment proceedings conducted under the faceless regime, notices under section 142(1) were issued calling for details of unsecured loans and related evidences. The assessee furnished

AUSTRALIA AND NEW ZEALAND BANKING GROUP LTD.,MUMBAI vs. DCIT(INTERNATIONAL TAX) 1(1)(2), MUMBAI

Bench: Shri Narendra Kumar Billaiya, Hon'Ble & Shri Rahul Chaudhary, Hon'Bleι.Τ.Α. No. 2751/Mum/2024

TDS on the said remittances. Taking a leaf out of this information, the AO was of the opinion that the assessee has not shown this income in its return of income as taxable and formed a belief that income of Rs.91,08,957/-, had escaped assessment and issued notice u/s 148 of the Act on 29/06/2021. Drawing support from

DEVANG AJIT JHAVERI,MUMBAI vs. JCIT, RANGE 17(1), MUMBAI

In the result, appeal of the Revenue is dismissed on aforesaid terms

Bench: SHRI AMIT SHUKLA (Judicial Member), SHRI GIRISH AGRAWAL (Accountant Member)

TDS) v. IKEA Trading Hong Kong Ltd., [2011] 333 ITR 565 (Del) to urge that it is the date of issuance of the Show Cause Notice ('SCN') that would be the relevant starting point. Accordingly he submits that the date of issuance of the SCN by the ACIT being 28 August, 2012, limitation would expire on 28 February, 2013. Therefore

ASST.COMMISSIONER OF INCOME TAX, BANDRA KURLA COMPLEX MUMBAI vs. DEVANG AJIT JAVERI , MUMBAI

In the result, appeal of the Revenue is dismissed on aforesaid terms

Bench: SHRI AMIT SHUKLA (Judicial Member), SHRI GIRISH AGRAWAL (Accountant Member)

TDS) v. IKEA Trading Hong Kong Ltd., [2011] 333 ITR 565 (Del) to urge that it is the date of issuance of the Show Cause Notice ('SCN') that would be the relevant starting point. Accordingly he submits that the date of issuance of the SCN by the ACIT being 28 August, 2012, limitation would expire on 28 February, 2013. Therefore

DEVANG AJIT JHAVERI ,MUMBAI vs. JCIT, RANGE 17(1), MUMBAI

In the result, appeal of the Revenue is dismissed on\naforesaid terms

TDS) ν. ΙΚΕΑ Trading Hong Kong Ltd., [2011] 333 ITR\n565 (Del) to urge that it is the date of issuance of the Show Cause\nNotice ('SCN') that would be the relevant starting point. Accordingly\nhe submits that the date of issuance of the SCN by the ACIT being\n28 August, 2012, limitation would expire on 28 February, 2013.\nTherefore

ASST. COMMISSIONER OF INCOME TAX , BANDRA KURLA COMPLEX vs. DEVANG AJIT JHAVERI , MUMBAI

In the result, appeal of the Revenue is dismissed on\naforesaid terms

TDS) ν. ΙΚΕΑ Trading Hong Kong Ltd., [2011] 333 ITR\n565 (Del) to urge that it is the date of issuance of the Show Cause\nNotice ('SCN') that would be the relevant starting point. Accordingly\nhe submits that the date of issuance of the SCN by the ACIT being\n28 August, 2012, limitation would expire on 28 February, 2013.\nTherefore

SHIVALIK VENTURES PRIVATE LIMITED,MUMBAI vs. ACIT CC 8(1), MUMBAI, MUMBAI

Bench: Ms Padmavathy S, Am & Shri Sandeep Singh Karhail, Jm

148A(d). The ld. AR further submitted that the disallowance made under section 36(1)(va) could have been made only by invoking explanation and not under the main provisions of section 147. Accordingly it is argued that when the addition made under main provisions are deleted then the disallowance under section 36(1)(va) which is done under explanation

SHIVALIK VENTURES PRIVATE LIMITED,MUMBAI vs. DCIT CC 8(1) , MUMBAI, MUMBAI

148A(b) notice and order under section\n148A(d). The ld. AR further submitted that the disallowance made under section\n36(1)(va) could have been made only by invoking explanation and not under the\nmain provisions of section 147. Accordingly it is argued that when the addition\nmade under main provisions are deleted then the disallowance under section

KALPANA RAMESH JAIN,MUMBAI vs. DEPUTY COMMISSIONER OF INCOME TAX- CENTRAL CIRCLE-4(3)(1), MUMBAI

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

Bench: Shri Om Prakash Kant () & Shri Sandeep Singh Karhail ()

TDS) Statement and information uploaded by Investigation Wings/Central Circle/1 & Cl on Insight Portal. As per the information summary available in Insight Portal, the following information relating to Assessment Year 2015-16 pertains to the assessee company individual. Sr. Source of PAN Source of PAN Informatio Information Information No Name Name n F.Y. Type Value . 1 AAACC0823E Toyam 2014-15 Information

KALPANA RAMESH JAIN,MUMBAI vs. DEPUTY COMMISSIONER OF INCOME TAX- CENTRAL CIRCLE-4(3)(1), MUMBAI, MUMBAI

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

Bench: Shri Om Prakash Kant () & Shri Sandeep Singh Karhail ()

TDS) Statement and information uploaded by Investigation Wings/Central Circle/1 & Cl on Insight Portal. As per the information summary available in Insight Portal, the following information relating to Assessment Year 2015-16 pertains to the assessee company individual. Sr. Source of PAN Source of PAN Informatio Information Information No Name Name n F.Y. Type Value . 1 AAACC0823E Toyam 2014-15 Information

KALPANA RAMESH JAIN,MUMBAI vs. DEPUTY COMMISSIONER OF INCOME TAX- CENTRAL CIRCLE-4(3)(1), MUMBAI

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

TDS) Statement and information uploaded by Investigation Wings/Central Circle/1 & CI on Insight Portal. As per the information summary available in Insight Portal, the following information relating to Assessment Year 2015-16 pertains to the assessee company individual. Sr. No Source of PAN Name AAACC0823E Source of PAN Name Toyam Industries Ltd Informatio n F.Y. 2014-15 Information Type Information

SHIVALIK VENTURES PRIVATE LIMITED,MUMBAI vs. ACIT CC 8(1), MUMBAI, MUMBAI

Accordingly we direct the AO to delete the disallowance made under section\n36(1)(va) of the Act for AY 2019-20 & 2020-21 also.\n15. In result, the appeals of the assessee for AY 2018-19 to AY 2020...

148A(b) notice and order under section\n148A(d). The ld. AR further submitted that the disallowance made under section\n36(1)(va) could have been made only by invoking explanation and not under the\nmain provisions of section 147. Accordingly it is argued that when the addition\nmade under main provisions are deleted then the disallowance under section

DATTATRAY NAMDEV SURYAWANSHI,PANVEL vs. ASSESSMENT UNIT, INCOME TAX DEPARTMENT, NEW DELHI

In the result, appeal filed by assessee is allowed

Bench: Shri Amit Shukla & Shri Girish Agrawalassessment Year: 2018-19

TDS of Rs. 3,13,515/- on contract receipts of Rs. 3,13,50,154/- during the year under consideration. 3.1. On the basis of information available with the Department, ld. Jurisdictional Assessing Officer (JAO) issued notice u/s 148A(b) of Act dated 22.03.2022, under the new regime introduced by Finance Act, 2021 pursuant to the directions

ABBAS KHAN,MUMBAI vs. NATIONAL FACELESS APPEAL CENTRE (NFAC), DELHI

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

Bench: Shri Anikesh Banerjee & Miss. Padmavathy Sabbas Khan, (Through Legal Vs National Faceless Appeal Centre/ Heir Mr. Iqbal Khan) Income-Tax Officer 41(1)(1), Flat No.7, Haroon Building, 1St Mumbai Floor, A H Wadia Marg, Opp Habib Hospital, Old Agra Road, Kurla (W), Mumbai-400 070 Pan: Aahpk3046K Appellant Respondent

TDS on contractual receipts) for the AY 2012–13. Subsequently, a notice under Section 148 of the Act dated 28.03.2019 was issued in the name of the deceased assessee. Pursuant thereto, notices under Section 142(1) dated 22.07.2019 and 07.11.2019 were issued, followed by final show cause notices dated 12.11.2019 and 22.11.2019, requiring an explanation

DCIT, CENTRAL CIRCLE-8(1), MUMBAI, MUMBAI vs. SHIVALIK VENTURES PRIVATE LIMITED, MUMBAI

Bench: Ms Padmavathy S, Am & Shri Sandeep Singh Karhail, Jm

148A(d) on 27.07.2022. Thereafter notice under section 148 was issued on 29.07.2022 and in response the assessee vide letter dated 10.02.2023 submitted the computation of total income. During the assessment proceedings after verification of details from SRA and from the assessee the AO found that the receipt of Rs. 130,80,41,280/- was a consideration received from sale