THE ESTATE INVESTMENT COMPANY PRIVATE LIMITED ,MUMBAI vs. DEPUTY COMMISSIONER OF INCOME TAX CENTRAL CIRCLE -8(1), MUMBAI

gains, based on the same set of seized diaries and\nmaterials. The legal challenge to the reopening rests on the\ncontention that the notice under section 148 was issued by\nthe Jurisdictional Assessing Officer in contravention of the\nFaceless Assessment Scheme framed under section 151A of\nthe Act, and is therefore void ab initio. The assessee has\nfurther assailed

DCIT, CENTRAL CIRCLE-8(1), MUMBAI, MUMBAI vs. THE ESTATE INVESTMENT COMPANY PVT LTD, MUMBAI

gains, based on the same set of seized diaries and\nmaterials. The legal challenge to the reopening rests on the\ncontention that the notice under section 148 was issued by\nthe Jurisdictional Assessing Officer in contravention of the\nFaceless Assessment Scheme framed under section 151A of\nthe Act, and is therefore void ab initio. The assessee has\nfurther assailed

DCIT CENTRAL CIRCLE-8(1), MUMBAI, MUMBAI vs. THE ESTATE INVESTMENT COMPANY PRIVATE LIMITED, MUMBAI

gains, based on the same set of seized diaries and\nmaterials. The legal challenge to the reopening rests on the\ncontention that the notice under section 148 was issued by\nthe Jurisdictional Assessing Officer in contravention of the\nFaceless Assessment Scheme framed under section 151A of\nthe Act, and is therefore void ab initio. The assessee has\nfurther assailed

THE ESTATE INVESTMENT COMPANY PRIVATE LIMITED,MUMBAI vs. DEPUTY COMMISSIONER OF INCOME TAX CENTRAL CIRCLE -8(1), MUMBAI

gains, based on the same set of seized diaries and\nmaterials. The legal challenge to the reopening rests on the\ncontention that the notice under section 148 was issued by\nthe Jurisdictional Assessing Officer in contravention of the\nFaceless Assessment Scheme framed under section 151A of\nthe Act, and is therefore void ab initio. The assessee has\nfurther assailed

THE ESTATE INVESTMENT COMPANY PRIVATE LIMITED,MUMBAI vs. DCIT CENTRAL CIRCLE 8(1), MUMBAI

gains, based on the same set of seized diaries and\nmaterials. The legal challenge to the reopening rests on the\ncontention that the notice under section 148 was issued by\nthe Jurisdictional Assessing Officer in contravention of the\nFaceless Assessment Scheme framed under section 151A of\nthe Act, and is therefore void ab initio. The assessee has\nfurther assailed

DCIT, CENTRAL CIRCLE-8(1), MUMBAI, MUMBAI vs. THE ESTATE INVESTMENT COMPANY PVT LTD, MUMBAI

gains, based on the same set of seized diaries and\nmaterials. The legal challenge to the reopening rests on the\ncontention that the notice under section 148 was issued by\nthe Jurisdictional Assessing Officer in contravention of the\nFaceless Assessment Scheme framed under section 151A of\nthe Act, and is therefore void ab initio. The assessee has\nfurther assailed

THE ESTATE INVESTMENT COMPANY PRIVATE LIMITED,MUMBAI vs. DCIT CENTRAL CIRCLE 8(1), MUMBAI

capital gains and Rs.2.50 lakh\nunder section 69A, be deleted in toto, and that the assessment\nitself, founded on invalid notice and manual DIN, be declared\nvoid ab initio.\n\n30. In so far as additions made u/s.69A, without prejudice,\narguments were made by the ld. AR can be summarized in the\nfollowing manner:-\n\n27\nITA No.3012/Mum/2025 and others

THE ESTATE INVESTMENT COMPANY PRIVATE LIMITED,MUMBAI vs. DEPUTY COMMISSIONER OF INCOME TAX CENTRAL CIRCLE -8(1), MUMBAI

capital gains and Rs.2.50 lakh\nunder section 69A, be deleted in toto, and that the assessment\nitself, founded on invalid notice and manual DIN, be declared\nvoid ab initio.\n\n30. In so far as additions made u/s.69A, without prejudice,\narguments were made by the ld. AR can be summarized in the\nfollowing manner:-\n\n27\nITA No.3012/Mum/2025 and others

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

151A. The present issue concerns issuance of notice under section 143(2) and subsequent completion of assessment under section 144B. There is no finding in Hexaware that a notice validly issued by a competent Assessing Officer under section 143(2) becomes invalid merely because the assessment is completed by the Assessment Unit. 38. The Hon’ble Delhi High Court

TARUN NANDKUMAR SEKSARIA ,MUMBAI vs. DEPUTY COMMISSIONER OF INCOME TAX CENTRAL CIRCLE -8(1), MUMBAI

151A of the Act,\nread with the scheme, any notice under section 148 of the Act\nshall be issued only in terms of the said scheme and in a\nfaceless manner. Therefore, the impugned notice issued by the\nAO is invalid and liable to be quashed and set aside.\n(iv) The AR relied on the following jurisdictional

TARUN NANDKUMAR SEKSARIA,MUMBAI vs. DCIT CENTRAL CIRCLE 8(1), MUMBAI

151A of the Act,\nread with the scheme, any notice under Section 148 of the Act\nshall be issued only in terms of the said scheme and in a\nfaceless manner. Therefore, the impugned notice issued by the\nAO is invalid and liable to be quashed and set aside.\n(iv) The AR relied on the following jurisdictional

TARUN NANDKUMAR SEKSARIA ,MUMBAI vs. DEPUTY COMMISSIONER OF INCOME TAX CENTRAL CIRCLE -8(1), MUMBAI

151A of the Act,\nread with the scheme, any notice under Section 148 of the Act\nshall be issued only in terms of the said scheme and in a\nfaceless manner. Therefore, the impugned notice issued by the\nAO is invalid and liable to be quashed and set aside.\n\n(iv) The AR relied on the following jurisdictional

LIC HOUSING FINANCE LIMITED,MUMBAI vs. ACIT 2(2)(1), MUMBAI, AAYKAR BHAVAN, MUMBAI

In the result, the appeal of the assessee is allowed

Bench: Shri Om Prakash Kant () & Shri Raj Kumar Chauhan () Assessment Year: 2017-18

151A of the Act. b) Specific Query raised during earlier assessment b) Specific Query raised during earlier assessment proceedings u/s proceedings u/s 143(3) and complete disclosure made by the Appellant Assessee 143(3) and complete disclosure made by the Appellant Assessee 143(3) and complete disclosure made by the Appellant Assessee Appellant Assessee had made complete disclosure

CHINTAN HARSHAD KANAKIA,MUMBAI vs. ITO WARD 42(1)(1), MUMBAI

In the result, ground No.3 of appeal is allowed

Bench: Shri Pawan Singhsmt Renu Jauhriassessment Year: 2015-16 (Hybrid Hearing) Chintan Harshad Kanakia, Ito Ward 42 (1)(1) Room No. 103, Sacovar Apt., Sagar Complex, 703, Kautilya Bhavan, Vs. Saibaba Nagar, Borivali (W), Bkc, Mumbai -400051 Mumbai Pan – Agnpk6023E

151A of the Act which mandates that the notice u/s 148 can only be issued by the faceless Assessing Officer and not by the jurisdictional Assessing Officer and the reason assigned for doing so are wrong and contrary to the provisions of Income Tax Act and Rules made there under. ITA No. 2822 /Mum/2025 (AY 2015-16) Chintan Harshad Kanakia

RAMESH AMRATLAL BRAHMBHATT ,MUMBAI vs. ITO WARD 34(3)(2), MUMBAI

In the result, the reassessment order dated 20

Bench: Shri Saktijit Dey & Shri Makarand Vasant Mahadeokarramesh Amratlal Ito Ward 34(3)(2), Brahmbhatt Kautilya Bhavan, 43 Rajnigandha, Vs. Bandra Kurla Gulmohar Cross Road No. Complex, Mumbai – 11, J V P D Scheme, 400 051 Juhu, Mumbai-400 049 Pan/Gir No. Aabpb7235R (Applicant) (Respondent) Assessee By Shri K. Gopal & Ms. Neha Paranjpe, Ld. Ars Revenue By Shri Annavaram Kosuri, Ld. Dr Date Of Hearing 23.02.2026 Date Of Pronouncement 25.02.2026

151A of the Act. Hence, the same is illegal and bad in law. 4. The notice dated 29.07.2022 issued under section 148 of the Act is barred by limitation as per the provisions of section 149 of the Act. Hence, the notice issued under section 148 of the Act and the entire reassessment proceedings conducted pursuant to the same

FACTS TRADELINK PRIVATE LIMITED ,MUMBAI vs. ITO 12 (2) (1), MUMBAI

In the result, appeals of the assessee are allowed

Bench: Shri Pawan Singh(Physical Hearing) Facts Tradelink Private Limited Ito - 12(2)(1), Mumbai 206, Ghanshayam Tower, M.G. Road, Vs Aayakar Bhavan, M.K. Road, Borivali (East), Mumbai – 400066. Mumbai – 400020. [Pan: Aaacf7985Q] Appellant / Assessee Respondent / Revenue

section 151A of the Act and the notification issued thereunder and without appreciating the fact that the Ld. JAO has no jurisdiction to issue a notice under 148A or 148 of the Act. 3. On the facts and circumstances of the case and in law, the Ld. CIT(A)/NFAC, erred in confirming the disallowance of business loss

DCIT-2(1)(1), MUMBAI vs. BP COMTRADE PVT. LTD., MUMBAI

In the result, cross objection filed by the assessee is allowed

Bench: Shri Amit Shukla & Shri Girish Agrawal

section 151A of the Act and therefore the said notice was bad in law. Consequently, the reassessment order is liable to be quashed; 5. The CIT(A) / Assessing Officer erred in reopening the case of the assessee beyond a period of three year from the end of the relevant assessment year without there being any income in the form

DCIT-2(1)(1), MUMBAI vs. BP COMTRADE PVT. LTD., MUMBAI

In the result, cross objection filed by the assessee is allowed

Bench: Shri Amit Shukla & Shri Girish Agrawal

section 151A of the Act and therefore the said notice was bad in law. Consequently, the reassessment order is liable to be quashed; 5. The CIT(A) / Assessing Officer erred in reopening the case of the assessee beyond a period of three year from the end of the relevant assessment year without there being any income in the form