ADDL CIT R G 7(1), MUMBAI vs. NOVARTIS INDIA LTD ( FORMERLY KNOWN AS HINDUSTAN CIBA GIEGY LTD. ), MUMBAI

Bench: Shri Amit Shukla, Hon'Ble & Shri S. Rifaur Rahman, Hon'Blem/S. Novartis India Limited V. Asst. Commissioner Of Income –Tax - 7(2)(2) {Earlier Addl. Commissioner Of Income –Tax – 7(1)} 6Th& 7Th Floor 1St Floor, Aayakar Bhavan Inspire Bkc M.K. Road, Mumbai - 400020 “G” Block, Bkc Main Road Bandra Kurla Complex, Bandra (E) Mumbai – 400051 Pan: Aaach2914F (Appellant) (Respondent) Addl. Commissioner Of Income –Tax – 7(1) V. M/S. Novartis India Limited Room No. 622, Aayakar Bhavan {Earlier Known As Hindustan Ciba Giegy Ltd.,} Sandoz House, Dr. A.B. Road M.K. Road, Mumbai - 400020 Worli, Mumbai – 400018 Pan: Aaach2914F (Appellant) (Respondent) Co No.190/Mum/2011 [Arising Out Of Ita No.6772/Mum/2010 (A.Y. 2002-03)] M/S. Novartis India Limited V. Addl. Commissioner Of Income –Tax – 7(1)} Room No. 622, Aayakar Bhavan {Earlier Known As Hindustan Ciba Giegy Ltd.,} Sandoz House, Dr. A.B. Road M.K. Road, Mumbai - 400020 Worli, Mumbai – 400018 Pan: Aaach2914F (Appellant) (Respondent)

condonation of delay on merit. Hence, this decision is not applicable in the Assessee's case. The facts in the assessee's case are different. The delay in filing of an additional ground is 16 years and no cogent evidence or no explanation has been filed by the assessee to justify the substantial delay of 16 years. In fact

THE ACIT 2(3), MUMBAI vs. M/S. TATA SONS LTD, MUMBAI

In the result, the appeals filed by the assessee are allowed and that of the Revenue is dismissed

Bench: Shri P K Bansal & Shri Ram Lal Negi

Condonation of delay is required in case the appeal is not filed within the permissible time. It is a case where the assessee has raised additional ground. It can be raised by the assessee at any time and even for the first time before the appellate authority. This is a settled law. Even the Hon’ble Supreme Court

M/S. TATA SONS LTD,MUMBAI vs. THE ACIT CIR2(3), MUMBAI

In the result, the appeals filed by the assessee are allowed and that of the Revenue is dismissed

Bench: Shri P K Bansal & Shri Ram Lal Negi

Condonation of delay is required in case the appeal is not filed within the permissible time. It is a case where the assessee has raised additional ground. It can be raised by the assessee at any time and even for the first time before the appellate authority. This is a settled law. Even the Hon’ble Supreme Court

M/S. TATA SONS LTD.,MUMBAI vs. CIT CIR. 2(3), MUMBAI

In the result, the appeals filed by the assessee are allowed and that of the Revenue is dismissed

Bench: Shri P K Bansal & Shri Ram Lal Negi

Condonation of delay is required in case the appeal is not filed within the permissible time. It is a case where the assessee has raised additional ground. It can be raised by the assessee at any time and even for the first time before the appellate authority. This is a settled law. Even the Hon’ble Supreme Court

DONA BUILDERS PVT LTD,MUMBAI vs. DCIT, CIRCLE 1(3)(1), MUMBAI

Bench: Shri Om Prakash Kant () & Shri Raj Kumar Chauhan() Assessment Year: 2009-10 & Assessment Year: 2010-11 & Assessment Year: 2011-12 & Assessment Year: 2012-13 & Assessment Year: 2013-14 Dona Builders Pvt Ltd Dcit, Circle 1(3)(1), Mumbai 108, Shiv Aashish S.V. Road, Aayakar Bhavan, Mumbai- Vs. Andheri West, Mumbai- 400058 400020 Pan No. Aaacd 3116 F Appellant Respondent : Mr. Rajesh Shah Assessee By : Mr. Annavaram Kosuri, Sr-Dr A/W Revenue By Mr. Uma Shankar Prasad, Cit Dr : 06/11/2025 Date Of Hearing Date Of Pronouncement : 21/01/2026 Order Per Bench These Five Appeals By The Assessee Are Directed Against Separate Orders Passed By The Ld. Commissioner Of Income-Tax

delay of 763 days 763 days is condoned, and the appeal is admitted for adjudication on merits admitted for adjudication on merits. admitted for adjudication on merits 4. Briefly stated, the facts of the case are that the assessee is Briefly stated, the facts of the case are that the assessee is Briefly stated, the facts of the case

DONA BUILDERS PVT LTD ,MUMBAI vs. DCIT, CIRCLE 1(3)(1), MUMBAI

Bench: Shri Om Prakash Kant () & Shri Raj Kumar Chauhan() Assessment Year: 2009-10 & Assessment Year: 2010-11 & Assessment Year: 2011-12 & Assessment Year: 2012-13 & Assessment Year: 2013-14 Dona Builders Pvt Ltd Dcit, Circle 1(3)(1), Mumbai 108, Shiv Aashish S.V. Road, Aayakar Bhavan, Mumbai- Vs. Andheri West, Mumbai- 400058 400020 Pan No. Aaacd 3116 F Appellant Respondent : Mr. Rajesh Shah Assessee By : Mr. Annavaram Kosuri, Sr-Dr A/W Revenue By Mr. Uma Shankar Prasad, Cit Dr : 06/11/2025 Date Of Hearing Date Of Pronouncement : 21/01/2026 Order Per Bench These Five Appeals By The Assessee Are Directed Against Separate Orders Passed By The Ld. Commissioner Of Income-Tax

delay of 763 days 763 days is condoned, and the appeal is admitted for adjudication on merits admitted for adjudication on merits. admitted for adjudication on merits 4. Briefly stated, the facts of the case are that the assessee is Briefly stated, the facts of the case are that the assessee is Briefly stated, the facts of the case

DCIT-1(2)1, MUMBAI., MUMBAI vs. PATIL CONSTRUCTION AND INFRASTRUCTURE LTD, MUMBAI

In the result In the result, all the three appeals filed by the revenue s filed by the revenue are dismissed

Bench: Shri Sandeep Gosain, Hon’Ble & Ms. Padmavathy S., Hon’Ble

condone the delay and hence the appeals are the appeals are admitted for hearing admitted for hearing on merits. 4. All the grounds raised by the Department are inter- All the grounds raised by the Department are inter All the grounds raised by the Department are inter related and inter related and inter-connected and relates to challenging

DCIT-1(2)1, MUMBAI, MUMBAI vs. PATIL CONSTRUCTION AND INFRASTRUCTURE LTD, MUMBAI

In the result In the result, all the three appeals filed by the revenue s filed by the revenue are dismissed

Bench: Shri Sandeep Gosain, Hon’Ble & Ms. Padmavathy S., Hon’Ble

condone the delay and hence the appeals are the appeals are admitted for hearing admitted for hearing on merits. 4. All the grounds raised by the Department are inter- All the grounds raised by the Department are inter All the grounds raised by the Department are inter related and inter related and inter-connected and relates to challenging

ITO 20(2)(3), MUMBAI vs. KARAN R. SHAH, MUMBAI

Bench: Hon’Ble Shri R. C. Sharma, Am & Hon’Ble Sh. Sandeep Gosain, Jm आयकरअपीलसं./ I.T.A. No. 3652 & 4290/Mum/2015 (निर्धारणवर्ा / Assessment Year: 2010-11 & 2009-10)

condone the delay of 907 days in filing the appeal. Resultantly, 48 I.T.A. No. 3652 & 4290/Mum/2015 & 1238/Mum/2018 Karan R. Shah this application is allowed and appeal is admitted to be heard on merits. 23. The solitary ground raised by the assessee relates to challenging the order of Ld. CIT(A) in confirming the action of AO on account of addition

DCIT 3(3)(2), MUMBAI vs. WATERMARK SYSTEMS (INDIA) P. LTD, MUMBAI

In the result, all the appeals of the revenue are dismissed

condone the delay in filing the cross-objections.” 14. And the Hon’ble High Court has dealt in the aforesaid case (peter vaz) with the objection raised in the present appeals by Ld. CIT- DR that since assessee has not raised objection against jurisdiction of AO at the first instance (during assessment proceedings) as contemplated

DCIT 3(3)(2), MUMBAI vs. WATERMARK FINANCIAL CONSULTANTS LTD, MUMBAI

In the result, all the appeals of the revenue are dismissed

condone the delay in filing the cross-objections.” 14. And the Hon’ble High Court has dealt in the aforesaid case (peter vaz) with the objection raised in the present appeals by Ld. CIT- DR that since assessee has not raised objection against jurisdiction of AO at the first instance (during assessment proceedings) as contemplated

DCIT 3(3)(2), MUMBAI vs. WATERMARK SYSTEMS (INDIA) P. LTD, MUMBAI

In the result, all the appeals of the revenue are dismissed

condone the delay in filing the cross-objections.” 14. And the Hon’ble High Court has dealt in the aforesaid case (peter vaz) with the objection raised in the present appeals by Ld. CIT- DR that since assessee has not raised objection against jurisdiction of AO at the first instance (during assessment proceedings) as contemplated

DCIT 3(3)(2), MUMBAI vs. WATERMARK FINANCIAL CONSULTANTS LTD, MUMBAI

In the result, all the appeals of the revenue are dismissed

condone the delay in filing the cross-objections.” 14. And the Hon’ble High Court has dealt in the aforesaid case (peter vaz) with the objection raised in the present appeals by Ld. CIT- DR that since assessee has not raised objection against jurisdiction of AO at the first instance (during assessment proceedings) as contemplated

ITO 3(3)(4), MUMBAI vs. WATERMARK SYSTEMS (I) P. LTD., MUMBAI

In the result, all the appeals of the revenue are dismissed

condone the delay in filing the cross-objections.” 14. And the Hon’ble High Court has dealt in the aforesaid case (peter vaz) with the objection raised in the present appeals by Ld. CIT- DR that since assessee has not raised objection against jurisdiction of AO at the first instance (during assessment proceedings) as contemplated

DCIT 3(3)(2), MUMBAI vs. WATERMARK FINANCIAL CONSULTANTS LTD, MUMBAI

In the result, all the appeals of the revenue are dismissed

condone the delay in filing the cross-objections.” 14. And the Hon’ble High Court has dealt in the aforesaid case (peter vaz) with the objection raised in the present appeals by Ld. CIT- DR that since assessee has not raised objection against jurisdiction of AO at the first instance (during assessment proceedings) as contemplated

VIVEK VINOD VAID,MUMBAI vs. ITO 17(3)(5), MUMBAI

In the result, all the appeals of the revenue are dismissed

condone the delay in filing the cross-objections.” 14. And the Hon’ble High Court has dealt in the aforesaid case (peter vaz) with the objection raised in the present appeals by Ld. CIT- DR that since assessee has not raised objection against jurisdiction of AO at the first instance (during assessment proceedings) as contemplated

ITO 3(3)(4), MUMBAI vs. WATERMARK SYSTEMS (I) P. LTD., MUMBAI

In the result, all the appeals of the revenue are dismissed

condone the delay in filing the cross-objections.” 14. And the Hon’ble High Court has dealt in the aforesaid case (peter vaz) with the objection raised in the present appeals by Ld. CIT- DR that since assessee has not raised objection against jurisdiction of AO at the first instance (during assessment proceedings) as contemplated

DCIT CENTRAL CIRCLE-2(4) , MUMBAI vs. RONAK GEMS PRIVATE LIMITED, MUMBAI

In the result, appeal of the Revenue is allowed for statistical

Bench: Shri Om Prakash Kant () & Shri Rahul Chaudhary () Assessment Year: 2017-18 Dcit Central Circle- 2(4) M/S Ronak Gems Pvt Ltd Room No. 802, 8Th Floor, 311, Mehta Bhavan, Shop No. Vs. Prathishtha Bhavan, M.K. 5, Opp. Charni Road, Road Churchgate, Mumbai- 400 004 Mumbai- 400020 Pan No. Aabcr 7550 G Appellant Respondent Assessee By : Mr. Nishit Gandhi, Ms. Madhuri Tambe & Aishwarya Wanikar Revenue By : Smt. Sanyogita Nagpal, Cit-Dr : Date Of Hearing 09/11/2023 Date Of Pronouncement : 15/11/2023

132 upon a person not referred to in Section 153A of IT Act. He submitted that this person not referred to in Section 153A of IT Act. He submitted that this person not referred to in Section 153A of IT Act. He submitted that this was an issue of law and therefore, the ITAT should have permitted