RELIANCE INDUSTRIES LTD,MUMBAI vs. DEPUTY COMMISSIONER OF INCOME TAX LARGE TAXPAYER UNIT, MUMBAI

Bench: Shri B.R.Baskaran & Shri Sandeep Gosainreliance Industries Ltd. Maker Chambers, Iv, 3Rd Floor, 222,Nariman Point, ……………. Appellant Mumbai-400021 Pan-Aaacr5055K V/S

54 taxnmann.com 28 Hon'ble Bombay High Court held that if the explanation is found to be concocted or demonstrates thorough negligence in prosecuting the cause, then, it. would be a legitimate exercise of discretion not to condone the delay. On similar facts the Hon'ble Ii Al, Mumbai in the case of Prashant Project Ltd Vs DCIT 37 taxmann.com

INDIA LAND AND PROPERTIES LIMITED (SINCE MERGED WITH EQUINOX INDIA DEVELOPMENTS LTD FORMERLY KNOWN AS INDIA BULLS REAL ESTATE LIMITED),MUMBAI vs. DCIT CENTRAL CIRCLE 6(4), MUMBAI

In the result, all the appeals filed by the assessee stands partly allowed for statistical purposes

Bench: Smt. Beena Pillai () & Shri Girish Agrawal ()

54, Mumbai. Brief facts of the case are as under: 2. At the outset, the Ld.AR submitted that there is a delay of 968 days in filing present appeal before this Tribunal. In support of the application seeking condonation of delay stating as under: “Sub: Filing of Application for condonation of delay. Dear Sir, Please find enclosed two copies

LODHA DEVELOPERS LTD(FORMERLY KNOWN AS LODHA DEVELOPERS PRIVATE LIMITED),MUMBAI vs. DCIT CEN CIR 7(3), MUMBAI

In the result, appeal of the Revenue is dismissed and appeal of the assessee is allowed

Bench: Shri C.N. Prasad, Hon'Ble & Shri G. Manjunatha, Hon'Bledy. Commissioner Of Income-Tax V. M/S. Palava Dwellers Pvt. Ltd., Central Circle – 7(3) 412, 71-G, Vardhman Chamber Room No. 655, 6Th Floor C.P. Road, Horniman Circle Aayakar Bhavan, M.K. Road Fort, Mumbai Mumbai – 400 020 Pan: Aabcl1117D (Appellant) (Respondent) Lodha Developers Limited Dy. Commissioner Of Income-Tax V. {Since Merged M/S. Palava Dwellers Pvt. Ltd.,} Central Circle – 7(3) 412, 4Th Floor, 17G, Vardhman Chamber Room No. 655, 6Th Floor Cawasji Patel Road, Horniman Circle Aayakar Bhavan, M.K. Road Fort, Mumbai - 400 001 Mumbai – 400 020 Pan: Aabcl1117D (Appellant) (Respondent)

54,01,967/- which is the entire exempt income earned by the assessee and claimed as deduction. 10. On appeal the Ld.CIT(A) restricted the disallowance only to the exempt income observing as under: - “The submissions of the learned counsel have been carefully considered. It is the contention of the learned counsel that the investments made have been made

DCIT CENT. CIR. -7(3), MUMBAI vs. PALAVA DWELLERS PVT. LTD. , MUMBAI

In the result, appeal of the Revenue is dismissed and appeal of the assessee is allowed

Bench: Shri C.N. Prasad, Hon'Ble & Shri G. Manjunatha, Hon'Bledy. Commissioner Of Income-Tax V. M/S. Palava Dwellers Pvt. Ltd., Central Circle – 7(3) 412, 71-G, Vardhman Chamber Room No. 655, 6Th Floor C.P. Road, Horniman Circle Aayakar Bhavan, M.K. Road Fort, Mumbai Mumbai – 400 020 Pan: Aabcl1117D (Appellant) (Respondent) Lodha Developers Limited Dy. Commissioner Of Income-Tax V. {Since Merged M/S. Palava Dwellers Pvt. Ltd.,} Central Circle – 7(3) 412, 4Th Floor, 17G, Vardhman Chamber Room No. 655, 6Th Floor Cawasji Patel Road, Horniman Circle Aayakar Bhavan, M.K. Road Fort, Mumbai - 400 001 Mumbai – 400 020 Pan: Aabcl1117D (Appellant) (Respondent)

54,01,967/- which is the entire exempt income earned by the assessee and claimed as deduction. 10. On appeal the Ld.CIT(A) restricted the disallowance only to the exempt income observing as under: - “The submissions of the learned counsel have been carefully considered. It is the contention of the learned counsel that the investments made have been made

RAJIV KUMAR NANDLAL VARMA,MUMBAI vs. ASSTT. COMMISSIONER OF INCOME TAX -23(3),, MUMBAI

In the result, the appeal filed by the assessee is allowed for statistical purposes

Bench: Shri Prashant Maharishi, Am & Shri Rahul Chaudhary, Jm Asst. Commissioner Of Rajiv Kumar Nandlal Varma Income Tax-23(3) C/O.Mangaldas D Shah & Co 506, 5Th Floor, Lotus House 33-A, Vs. Room No.104, Matru Mandir New Marine Lines, Mumbai-400020 Mumbai-400007 (Appellant) (Respondent) Pan No. Aajpv8710G

54 of ₹4,62,89,300/- and restricted the deduction under Section 54EC of the Act of ₹1,00,00,000 to Rs 50,00,000/-. 05. The assessee preferred the appeal before the learned Commissioner of Income-tax (Appeals).The learned CIT (A) noted that there is a delay in filing of the appeal by two years

NILESH JANARDAN THAKUR,MUMBAI vs. ITO 25(1)(4), MUMBAI

In the result, appeal filed by the assessee in ITA No

Bench: Shri D.T. Garasia () & Shri G Manjunatha ()

condone the delay in filing the appeal and admit the appeal for adjudication, on merits. ITA 3738/Mum/2013 10. The assessee has raised common grounds of appeal for both the assessment years. For the sake of brevity, grounds of appeal for AY 2008-09 in ITA No.3738/Mum/2013 are reproduced below:- “1. On facts and circumstances of the case

SHASHWAT FOUNDATION TRUST ,MUMBAI vs. I.T.O EXEM WARD 2(3), MUMBAI

In the result, appeal of the assessee is partly allowed for statistical purposes

Bench: Shri Pawan Singh & Shri Girish Agrawalassessment Year: 2020-21 Shashwat Foundation Trust I.T.O. Exemption 253/C, Kelichi Chawl, Ward 2(3), Mumbai G. K. Marg, Lower Parel, Vs. Mumbai – 400013. (Pan: Aalts8825J) (Appellant) (Respondent) Present For: Assessee : Shri Shyamsunder Agrawal, Ca Revenue : Shri Pravin Salunkhe, Sr. Dr Date Of Hearing : 14.10.2025 Date Of Pronouncement : 31.10.2025 O R D E R Per Girish Agrawal: This Appeal Filed By The Assessee Is Against The Order Of Ld. Cit(A), Delhi, Vide Order No. Itba/Nfac/S/250/2024-25/1074468829(1), Dated 13.03.2025 Passed Against The Assessment Order By Assistant Director Of Income Tax, Cpc, Bengaluru, U/S. 154 Of The Income-Tax Act, 1961 (Hereinafter Referred To As The “Act”), Dated 31.08.2023 For Assessment Year 2020-21. 2. Grounds Taken By The Assessee Are Reproduced As Under: Ground No. 1 In The Facts & Circumstances Of The Case & In Law, The Learned C.I.T. (Appeal) Has Erred In Dismissing The Appeal & Not Condoning The Delay In Filing The Appeal Without Appreciating The Fact That: The Appellant Is A Charitable Trust

condone the delay. This delay is wholly unintentional and beyond the control of the appellant. The word "Sufficient Cause" has been construed quite liberal in the case of:- R.J. Pratap Singh |100 ITR 698 S.C.] S. N. Ghorpade [48 ITR 54 Mumbai] The word 'Sufficient Cause' is used in section

SUBHA HARIHARAN ,MUMBAI vs. INCOME TAX OFFICER 35(3)(4), MUMBAI

In the result, appeal of the assessee is allowed for statistical purposes

Bench: Shri Sandeep Gosain & Shri Girish Agrawalassessment Year: 2011-12 Subha Hariharan Income Tax Officer, Plot No. 4 B 503/504, Ward 35(3)(4), Dosti Elite Tower -B Mumbai Vs. Next To Sion Telephone Exchange Sion (W), Mumbai – 400022 (Pan: Acmph5705R) (Assessee) (Respondent) Present For: Assessee : Mr. Ruturaj Gurjar, Advocate Revenue : Mr. Virabhadra S. Mahajan, Sr. Dr (Virtually Appeared) Date Of Hearing : 30.09.2025 Date Of Pronouncement : 13.10.2025 O R D E R Per Girish Agrawal: This Appeal Filed By The Assessee Is Against The Order Of Ld. Cit(A), National Faceless Appeal Centre (Nfac), Delhi, Vide Order No. Itba/Nfac/S/250/2024-25/1071531320(1), Dated 24.12.2024 Passed Against The Assessment Order By Income-Tax Officer, Ward – 35(3)(4), Mumbai, U/S. 144 R.W.S.147 Of The Income-Tax Act, 1961 (Hereinafter Referred To As The “Act”), Dated 27.12.2018 For Assessment Year 2011-12. 2. Grounds Taken By The Assessee Are Reproduced As Under: “1. The Ld. Cit (A) Has Erred In Passing The Order Dated 24/12/2024 Without Giving Reasonable Opportunity To The Petitioner To Represent Its Case.

section 249(3) should receive liberal construction, so as to advance substantial justice. The true guide while deciding a condonation petition should be to see whether the uppellant acted with rea- sonable diligence in prosecution of its appeal Brij Indar Singh vs. Kanshi Ram 1917 (PC) 156). [AIR 4 Subha Hariharan AY 2011-12 We request you to condone

FANCY REHABILITATION TRUST,MUMBAI vs. ASSISTANT DIRECTOR OF INCOME TAX , MUMBAI

In the result, the appeal filed by the assessee is treated as allowed for statistical purposes

Bench: Shri Pavan Kumar Gadale & Shri Amarjit Singhfancyrehabilitationtrust, Vs. I T O (Exem), Ward 2(3), Cumballa Hill,Mtnl Te Sewri Cross Road, Near Building, Pedderroad, Bdd Chawl No. 9, Drgopalrao D Marg, Sewri (W), Mumbai–400026. Mumbai-400015. Pan/Gir No. Aaatf0598C (अपीलाथ"/Appellant) (""यथ"/Respondent)

54 Mumbai] 6 Fancy Rehabilitation Trust, Mumbai The word 'Sufficient Cause' is used in section 5 of the Limitation Act, hence equally important relevance is attached to it. The Supreme Court has interpreted this phrase which is binding on all courts and Quasi- judicial authorities that decide Condonation of delay

VISSANJI A 1 FRIENDS CO-OPERATIVE HOUSING SOCIETY LTD.,MUMBAI vs. ITO, WARD 20(3)(1), MUMBAI, MUMBAI

In the result, all the five appeals of the assessee are dismissed

Bench: Shri Sandeep Gosain & Shri Girish Agrawal

54,008/-, a demand of Rs. 60,850/- was raised. Assessee moved first appeal before the Ld. CIT(A) by filling Form No. 35 with delay of seven years and one months for which we have already narrated the facts in the above paragraphs. 5. Before us, Ld. Counsel for the assessee pointed out that there is a delay

VISSANJI A 1 FRIENDS CO-OPERATIVE HOUSING SOCIETY LTD.,MUMBAI vs. ITO, WARD 20(3)(1), MUMBAI, MUMBAI

In the result, all the five appeals of the assessee are dismissed

Bench: Shri Sandeep Gosain & Shri Girish Agrawal

54,008/-, a demand of Rs. 60,850/- was raised. Assessee moved first appeal before the Ld. CIT(A) by filling Form No. 35 with delay of seven years and one months for which we have already narrated the facts in the above paragraphs. 5. Before us, Ld. Counsel for the assessee pointed out that there is a delay

VISSANJI A 1 FRIENDS CO-OPERATIVE HOUSING SOCIETY LTD.,MUMBAI vs. ITO, WARD 20(3)(1), MUMBAI, MUMBAI

In the result, all the five appeals of the assessee are dismissed

Bench: Shri Sandeep Gosain & Shri Girish Agrawal

54,008/-, a demand of Rs. 60,850/- was raised. Assessee moved first appeal before the Ld. CIT(A) by filling Form No. 35 with delay of seven years and one months for which we have already narrated the facts in the above paragraphs. 5. Before us, Ld. Counsel for the assessee pointed out that there is a delay

VISSANJI A 1 FRIENDS CO-OPERATIVE HOUSING SOCIETY LTD.,MUMBAI vs. ITO, WARD 20(3)(1), MUMBAI, MUMBAI

In the result, all the five appeals of the assessee are dismissed

Bench: Shri Sandeep Gosain & Shri Girish Agrawal

54,008/-, a demand of Rs. 60,850/- was raised. Assessee moved first appeal before the Ld. CIT(A) by filling Form No. 35 with delay of seven years and one months for which we have already narrated the facts in the above paragraphs. 5. Before us, Ld. Counsel for the assessee pointed out that there is a delay

VISSANJI A 1 FRIENDS CO-OPERATIVE HOUSING SOCIETY LTD.,MUMBAI vs. ITO, WARD 20(3)(1), MUMBAI, MUMBAI

In the result, all the five appeals of the assessee are dismissed

condone the said delay. He thus, did not admit the\nappeal and rejected it, treating the appeal as dismissed.\n3. 1. Even though the appeal was not admitted and dismissed by the\nLd. CIT(A), he proceeded to discuss on the facts of the case and\nconfirmed the disallowance made by the Ld. AO holding his action as\ncorrect

RESHMA MOHAMMED ASIM ANSARI,BANDRA EAST vs. ITO-23(3)(1), MUMBAI, PIRAMAL CHAMBER, LALBAUG

In the result, the appeal of the assessee is allowed for esult, the appeal of the assessee is allowed for esult, the appeal of the assessee is allowed for statistical purposes

Bench: Shri Om Prakash Kant () & Shri Raj Kumar Chauhan () Assessment Year: 2018-19 Reshma Mohammed Asim Ansari, Ito-23(3)(1), Room No. 402, Mina Centre Piramal Chamber, Lalbaug, Vs. Building, Ahmed Zakaria Nagar, Mumbai-400012. Bandra East, Mumbai-400051. Pan No. Ardpa 8448 G Appellant Respondent

54 without without considering the actual investment made by considering the actual investment made by the assessee. assessee.” 2. The brief facts leading to The brief facts leading to the present appeal are that the the present appeal are that the assessee filed her return of income on 31.08.2018, declaring a total assessee filed her return of income

ASIA INVESTMENT P.LTD,MUMBAI vs. JCIT (OSD) CIR 2(1), MUMBAI

In the result, appeal filed by the assessee in ITA No

Bench: Shri Joginder Singh & Shri Ramit Kochar

54,83,065/- which culminated finally into an assessment order dated 26-12-2003 passed by the u/s 143(3). The AO also initiated penalty proceedings u/s 271(1)(c) for furnishing of inaccurate particulars of income , which finally culminated into an penalty order dated 17-03-2006 passed by the AO u/s 271(1)(c) for furnishing of inaccurate

ANIL PREMCHAND MOTIRAMANI,MUMBAI vs. ASSISTANT COMMISSIONER OF INCOME TAX, CIRCLE 2, THANE , THANE

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

Bench: Shri B.R. Baskaran & Shri Sandeep Singh Karhail

condone the delay in filing the present appeal by the assessee and we proceed to decide the appeal on merits. 5. In this appeal, the assessee has raised the following grounds:– ―1. The Commissioner of Income-tax (Appeals) at National Faceless Appeal Centre (hereinafter referred to as the CIT(A)) erred in upholding the action of the Assistant Commissioner

RAJENDRA KAMALAKANT CHODANKAR,MUMBAI vs. DCIT 15(1)(1), MUMBAI

In the result appeal filed by the assessee stands partly allowed for statistical purposes

Bench: Smt. Beena Pillai () I.T.A. No. 6629/Mum/2024 Assessment Year: 2020-21

CONDONATION OF DELAY IN FILING APPEAL 1. In the above-mentioned case, the Hon'ble CIT(A), NFAC had passed an order on 26.08.2024. The statutory due date for filing this appeal before your Honour was 25.10.2024. However, the captioned appeal has been filed by the appellant on 18.12.2024 resulting in a delay of 54 days. 2. It is respectfully