EMPLOYEES RETIREMENT SYSTEM OF TEXAS ,MUMBAI vs. DY CIT (INT. TAX)-2(2)(1), MUMBAI

The appeals are partly allowed

Bench: SHRI NARENDRA KUMAR BILLAIYA, ACCOUNTANT MEMBER SHRI RAHUL CHAUDHARY (Judicial Member)

144B of the Act as per the directions issued by the DRP on 04/12/2024 under Section 144C(5) of the Act for the Assessment Year 2022-2023. 2. The Assessee has raised the following grounds of appeal: “Based on the facts and circumstances of the case and in law, the Appellant craves leave to prefer an appeal against the order

FIDELITY RUTLAND SQUARE TRUST II STRATEGIC ADVISERS FID EMG MARKETS FUND ,MUMBAI vs. DEPUTY COMMISSIONER OF INCOME TAX (INTERNATIONAL TAXATION )2(3)(1), MUMBAI

144B of the Act as per the directions\nissued by the DRP on 04/12/2024 under Section 144C(5) of the\nAct for the Assessment Year 2022-2023.\n\n2.\nThe Assessee has raised the following grounds of appeal:\n\"Based on the facts and circumstances of the case and in law, the\nAppellant craves leave to prefer an appeal against

FIDELITY RUTLAND SQUARE TRUST II STRATEGIC ADVISERS EMERGING MARKETS FUND ,MUMBAI vs. DEPUTY COMMISSIONER OF INCOME TAX (INTERNATIONAL TAXATION), MUMBAI

The appeals are partly allowed

144B of the Act as per the directions\nissued by the DRP on 04/12/2024 under Section 144C(5) of the\nAct for the Assessment Year 2022-2023.\n2. The Assessee has raised the following grounds of appeal:\n\"Based on the facts and circumstances of the case and in law, the\nAppellant craves leave to prefer an appeal against

RAJENDRA KUMAR MUNDRA (HUF),MUMBAI vs. NATIONAL FACELESS ASSESSMENT CENTRE (NFAC), DELHI

In the result the appeal filed by the assessee stands allowed

Bench: Hon’Ble Shri Sandeep Gosain& Shri Girish Agrawalrajendra Kumar Mundra Vs. Ito, Ward 24(3)(1) (Huf) Piramal Chamber C-28, Ameya Bldg, Behind Lalbaug, Mumbai – Ymca Dn Nagar Andheri (W) 400012. 400053. Pan/Gir No.Aadh6828J (Applicant) (Respondent)

capital Date of gains/ loss made therein and the AOhaving Pronouncement: considered the details, took a conclusive 12/03/2025 view, reassessment proceedings which are initiatedu/s 147 by way of reconsideration of the material already available at the time of original assessment proceedings, would amount to change of opinion. In this regard, while passing the impugned order, Learned CIT(A) relied

ADITYA BIRLA SUN LIFE AMC LIMITED,MAHARASHTRA vs. THE DEPUTY COMMISSIONER OF INCOME TAX-CIRCLE 6(1)(1), MAHARASHTRA

144B of the Act. The CIT(A) recorded that only the income as processed under section 143(1) had been adopted in the assessment order and, accordingly, dismissed the appeal. 9. In A.Y. 2023-24, the Assessing Officer made an addition of Rs. 13,46,813/- on account of short-term capital gains

SHRI RAJESH RAMCHANDRA DAKE,PANVEL vs. DY CIT CC-1, MUMBAI

gains addition, the Tribunal held that the lands sold were agricultural lands, situated beyond 8 km from the municipal limits (based on physical measurement and Google Maps evidence), and therefore not a capital asset under Section 2(14) of the Act. The Revenue's cross-objection was dismissed as infructuous.", "result": "Allowed", "sections

ADITYA BIRLA SUN LIFE AMC LIMITED,MAHARASHTRA vs. THE DEPUTY COMMISSIONER OF INCOME TAX- CIRCLE 6(1)(1), MAHARASHTRA

Bench: Shri Amit Shukla & Shri Makarand Vasant Mahadeokar1. Ita No. 6663/Mum/2025 (Assessment Year: 2017-18) 2. Ita No. 6701/Mum/2025 (Assessment Year: 2018-19) 3. Ita No. 6702/Mum/2025 (Assessment Year: 2022-23) & 4. Ita No. 6703/Mum/2025 (Assessment Year: 2023-24) Aditya Birla Sun Life Dcitcircle-6(1)(1), Amc Limited, Room No. 502, 5Th 17Th Floor, One World Vs. Floor, Aayakar Centre Tower-1, Jupiter Bhavan, M. K. Mill Compount, 841, Road, Churchgate, Senapati Bapat Marg, Mumbai-400 020 Delisle Road, S.O. Mumbai-400 013 Pan/Gir No. Aaacb6134D (Applicant) (Respondent) Assessee By Shri Ronak Doshi, Shri Shrey Agrawal & Shri Aadish Jain, Ld. Ars Revenue By Shri Surendra Mohan, Ld. Dr Date Of Hearing 27.01.2026 Date Of Pronouncement 06.02.2026

144B of the Act. The CIT(A) recorded that only the income as processed under section 143(1) had been adopted in the assessment order and, accordingly, dismissed the appeal. 9. In A.Y. 2023–24, the Assessing Officer made an addition of Rs. 13,46,813/- on account of short-term capital gains

ARHAM ANMOL PROJECTS PRIVATE LIMITED,VILLAGE VALSHIND, BHIWANDI vs. CIRCLE 1 KALYAN, KALYAN, THANE

In the result, the legal grounds challenging the validity of the assessment are dismissed

Bench: Shri Amit Shukla & Shri Makarand Vasant Mahadeokararham Anmol Projects Dcit Circle 1, Private Limited 2Nd Floor, Rani H. No. 1113, Ground Vs. Mansion, Murbad Floor, Arham Logiparc, Road, Kalyan Nh-3, Nashik Highway, (West), Thane, Village Valshind, Maharashtra – 421 Bhiwandi, Maharashtra – 301 421 302. Pan/Gir No. Aagca9644P (Applicant) (Respondent) Assessee By Shri Subhash Bains, Ld. Ar Revenue By Shri Surendra Mohan, Ld. Dr Date Of Hearing 28.01.2026 Date Of Pronouncement 26.03.2026

section 144B. The Assessing Officer made the following additions: (i) Short Term Capital Gain – Rs. 4,54,49,186/- It was observed

ANJU CHIRANIA,MUMBAI vs. THE INCOME TAX OFFICER, WARD - 4(1)(3), MUMBAI

In the result, the appeal filed by the assessee is allowed

Bench: Shri Pavan Kumar Gadale, Judicialmember & Shri Girish Agrawalanju Chirania, Vs. Ito, Ward –4(1)(3), 301, Sona Chambers, Room No. 637, 507/509, Jss Road, Aayakar Bhavan, Chira Bazar, Marine Lines, M.K.Road, Mumbai – 400 002. Mumbai-400020. Pan/Gir No. Afcpc9073Q (अपीलाथ"/Appellant) (""यथ"/Respondent)

capital gain on transfer of shares, which was based on generic findings of investigation wing, without there being any specific finding against the bonafide investment and sale by the appellant through online platform of recognized stock exchange through the SEBI registered stock broker. 5. On the facts and the circumstances of the case and in law, the Ld. Commissioner

DCIT-2(3)(1), MUMBAI vs. KOTAK MAHINDRA BANK LTD, MUMBAI

In the result, **appeal of the Revenue is dismissed

Bench: Shri Sandeep Gosain & Shri Prabhash Shankar**

144B of the Act. It is also claimed that no personal hearing was allowed by the ld.CIT(A) despite request. Thus, the proceedings are bad in law. It is further stated that the adjustment made by CPC was wrongly upheld by the ld.CIT(A).However, in the course of hearing before this Bench, the Ld. Authorised Representative of the assessee

AGARWAL HOLDINGS PRIVATE LIMITED ,MUMBAI vs. PRINCIPAL COMMISSIONER OF INCOME TAX -1, MUMBAI

In the result, the appeal by the assessee is dismissed

Bench: Shri Sandeep Singh Karhailshri Girish Agrawalagarwal Holdings Private Ltd. 211, 2Nd Floor Atlanta Arcade, Marol Church Road Marol, Andheri (East) Mumbai - 400059 ............... Appellant Pan: Aauca5094K V/S Principal Commissioner Of Income Tax, Mumbai-1 ……………… Respondent Room No.330, 3Rd Floor, Aayakar Bhavan, Maharishi Karve Road, Mumbai Assessee By : Shri Ashok Bansal Revenue By : Shri Rajesh Kumar Yadav, Cit-Dr

capital gains or business income was not examined by the AO while passing the assessment order under section 143(3) read with section 144B

ACIT-2(3)(1), MUMBAI vs. HDFC BANK LTD ( MERGED ENTITY HDFC INVESTMENTS LIMITED ), MUMBAI

Bench: Shri Anikesh Banerjee & Shri Girish Agrawal

144B 2020-21 Revenue 39 4313/Mum/2010 CIT(A)-I/IT 378/2009-10 09.03.2010 DCIT, Range 1(1), Mumbai 30.03.2009 271(1)(c) 2002-03 Assessee [Appeals against Penalty Order passed u/s. 271(1)(c)] 40 4314/Mum/2010 CIT(A)-I/IT 374/2009-10 09.03.2010 DCIT, Range 1(1), Mumbai 30.03.2009 271(1)(c) 2003-04 41 2866/Mum/2012 CIT(A)-I/IT 682/2010-11 06.02.2012 DCIT

HDFC BANK LIMITED (AS SUCCESSOR TO HOUSING DEVELOPMENT FINANCE CORPORATION LTD.),MUMBAI vs. DCIT, RANGE-1(1)(2), MUMBAI

Bench: Shri Anikesh Banerjee & Shri Girish Agrawal

144B 2020-21 Revenue 39 4313/Mum/2010 CIT(A)-I/IT 378/2009-10 09.03.2010 DCIT, Range 1(1), Mumbai 30.03.2009 271(1)(c) 2002-03 Assessee [Appeals against Penalty Order passed u/s. 271(1)(c)] 40 4314/Mum/2010 CIT(A)-I/IT 374/2009-10 09.03.2010 DCIT, Range 1(1), Mumbai 30.03.2009 271(1)(c) 2003-04 41 2866/Mum/2012 CIT(A)-I/IT 682/2010-11 06.02.2012 DCIT

ADITYA BIRLA SUN LIFE AMC LIMITED,MAHARASHTRA vs. THE DEPUTY COMMISSIONER OF INCOME TAX CIRCLE 6(1)(1), MAHARASHTRA

Accordingly, this ground is allowed

144B of the Act. The CIT(A) recorded that only the income as processed under section 143(1) had been adopted in the assessment order and, accordingly, dismissed the appeal. 9. In A.Y. 2023-24, the Assessing Officer made an addition of Rs. 13,46,813/- on account of short-term capital gains

ADITYA BIRLA SUN LIFE AMC LIMITED,MAHARASHTRA vs. THE DEPUTY COMMISSIONER OF INCOME TAX- CIRCLE 6 (1)(1), MAHARASHTRA

Accordingly, this ground is allowed

144B of the Act. The CIT(A) recorded that only the income as processed under section 143(1) had been adopted in the assessment order and, accordingly, dismissed the appeal. 9. In A.Y. 2023-24, the Assessing Officer made an addition of Rs. 13,46,813/- on account of short-term capital gains

KOTAK MAHINDRA BANK LIMITED,MUMBAI vs. DCIT-3(2)(2), ASSESSMENT UNIT, INCOME TAX DEPT, MUMBAI

In the result, appeal of the Revenue is dismissed

144B of the Act. It is also claimed\nthat no personal hearing was allowed by the ld.CIT(A) despite request. Thus, the\nproceedings are bad in law. It is further stated that the adjustment made by CPC\nwas wrongly upheld by the ld.CIT(A).However, in the course of hearing before\nthis Bench, the Ld. Authorised Representative of the assessee

ASSISTANT COMMISSIONER OF INCOME TAX-19(3), MUMBAI, MUMBAI vs. RAJEN KIRTILAL SHAH, MUMBAI

Accordingly, all the grounds raised by the Revenue are dismissed

Bench: SHRI VIKRAM SINGH YADAV, ACCOUNTANT MEMBER SHRI RAHUL CHAUDHARY (Judicial Member)

gain or short term capital loss in their books of accounts. The Assessee had also transacted in the shares of Bakra Pratishthan Ltd during the relevant previous year. On the basis of the aforesaid information reassessment proceedings were initiated in the case of the Assessee. On 29/07/2022 the fresh notice under Section 148 and under Section 148A

INDUR THANWERDAS DADLANI,MUMBAI vs. THE PRINCIPAL COMMISSIONER OF INCOME TAX PCIT, MUMBAI-42, MUMBAI

In the result, the appeal filed by the assessee stands allowed without any order as to cost

Bench: Hon’Ble Shri Sandeep Gosain & Shri Prabhash Shankarindur Thanwerdas Dadlani Vs. Pr. Cit Flat No. 4604, The Imperial Mumbai – 42 Towers, Mp Mill Compound, Room No. 741, Aayakar Bb Nakashe Marg, Mardeo, Bhavan, Mk Road, Mumbai – 400034. Mumbai Pan/Gir No. Aacpd5262D (Applicant) (Respondent)

Section 144B of the Act on 21st September 2022, wherein the returned income of ₹15,68,590/- was accepted without any variation. The impugned notice u/s 263 mentions that, "I have examined the assessment records in your case for A.Y. 2020-21 wherein the assessment was completed ws 143(3) r.w.s 144B of the Income Tax Act (hereinafter referred

ITO WARD 3(4), THANE, THANE vs. SUNIL KUMAR BAGARIA, THANE

In the result, the appeal by the Revenue is dismissed

Bench: Shri Sandeep Singh Karhailshri Girish Agrawalito, Ward-3(4), Room No.9, B-Wing, 6Th Floor, Ashar It Park, Wagle Industrial Estate, ............... Appellant Thane West - 400604

gains from transactions on which Security Transaction Tax was paid. Subsequently, on the basis of the information received from Insight Portal that the price of the scrip of Tilak Venture Ltd. was manipulated to provide accommodation entry of bogus long-term capital gains/short-term capital loss to beneficiaries, and the assessee is one such beneficiary, proceedings under section