ACIT CIR. 12(1)(2), MUMBAI vs. BHARTI AXA LIFE INSURANCE COMPANY LTD., MUMBAI

In the result, the appeal of the revenue is dismissed and cross objection of the assessee is allowed

151(2) of the Act. When the appeal was taken up for hearing on the 18th January, 1971, only the report submitted by the Income-tax Officer to the Commissioner and the order of the Commissioner was produced. The order sheet recording the reasons of the Income-tax Officer as required by section 148(2) was not produced. Here

GLOBAL TRADEX LTD. (PREVIOUSLY KNOWN AS NAMCO STEEL PVT. LTD.),MUMBAI vs. ACIT CIRCLE 7(1)(1), MUMBAI

In the result, appeal filed by the assessee is allowed

Bench: Smt. Beena Pillai & Shri Girish Agrawalassessment Year: 2016-17

depreciation against the addition made u/s 41(1). That on the facts and in the circumstances of the case and in law the appellant being entitled to set off of such losses, the same may very kindly be now allowed.” 3. For the year under consideration, assessee contended on the legal issue that approval obtained by the ld. Assessing Officer

ACIT-CC-7(3), MUMBAI vs. LOTUS LOGISTICS AND DEVELOPERS PRIVATE LIMITED, MUMBAI

In the result, the appeal of the Revenue is dismissed whereas cross-objection of the assessee are partly allowed

Bench: Shri Om Prakash Kant () & Ms Kavitha Rajagopal () Assessment Year: 2017-18 Acit-Cc-7(3) Lotus Logistics & Developers Room No. 655, Floor 6Th, Private Limited Aayakar Bhavan, M.K.Road, Vs. 1301, 13Th Level, Lotus Trade Mumbai-400020 Centre, New Link Road, Near D N Nagar Metro Station, Andheri-West, Mumbai- 700013 Pan No. Aabcl 1198 G Appellant Respondent

151 of the Act and hence Lotus Logistics and Developers Private 4 Ltd. ITA No. 627/MUM/2025 & CO No. 49/MUM/2025 the reassessment order passed is against procedures laid down in the Act and thereby be quashed as invalid. (d) The Ld. CIT(A) erred in not appreciating that reopening of the case is vitiated by law being based on mere change

ASSISTANT COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE 6(4), MUMBAI, MUMBAI vs. SHANTILAL CHIMANLAL SHETH, MUMBAI

In the result, the appeals by the revenue are dismissed and the\ncross-objections by the assessee are partly allowed

section 132A of the Act in the case of\npertains or pertain to or any information contained therein, relate to you or the person in respect of\nwhich you are assessable under the Act.\n2. I therefore, propose to assess or reassess such income or recompute the loss or the depreciation\nallowance or any other allowance or deduction

ASSISTANT COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE 6(4), MUMBAI, MUMBAI vs. SHANTILAL CHIMANLAL SHETH, MUMBAI

In the result, the appeals by the revenue are dismissed and the\ncross-objections by the assessee are partly allowed

section 132A of the Act in the case of\npertains or pertain to or any information contained therein, relate to you or the person in respect of\nwhich you are assessable under the Act.\n2. I therefore, propose to assess or reassess such income or recompute the loss or the depreciation\nallowance or any other allowance or deduction

GRASIM INDUSTRIES LTD,MUMBAI vs. DCIT CENT. CIR. - 1(4), MUMBAI

In the result, the appeals of the Revenue are dismissed

Bench: Shri Om Prakash Kant () & Shri Pavan Kumar Gadale ()

section 151 of the Actand correspondingly, Assessing Officer is obliged to hand over a copy of the same, as and Assessing Officer is obliged to hand over a copy of the same, as and Assessing Officer is obliged to hand over a copy of the same, as and when, the assessee seeksfor it. when, the assessee seeksfor it. He submitted

GRASIM INDUSTRIES LTD,MUMBAI vs. DCIT CENT. CIR. - 1(4), MUMBAI

In the result, the appeals of the Revenue are dismissed

Bench: Shri Om Prakash Kant () & Shri Pavan Kumar Gadale ()

section 151 of the Actand correspondingly, Assessing Officer is obliged to hand over a copy of the same, as and Assessing Officer is obliged to hand over a copy of the same, as and Assessing Officer is obliged to hand over a copy of the same, as and when, the assessee seeksfor it. when, the assessee seeksfor it. He submitted

JCIT CENT. CIR. - 1(4), MUMBAI vs. GRASIM INDUSTRIES LTD, MUMBAI

In the result, the appeals of the Revenue are dismissed

Bench: Shri Om Prakash Kant () & Shri Pavan Kumar Gadale ()

section 151 of the Actand correspondingly, Assessing Officer is obliged to hand over a copy of the same, as and Assessing Officer is obliged to hand over a copy of the same, as and Assessing Officer is obliged to hand over a copy of the same, as and when, the assessee seeksfor it. when, the assessee seeksfor it. He submitted

SHRI AMIT MANGILAL JAIN,MUMBAI vs. ACIT, - 33(1), MUMBAI

In the result, both the above appeals are allowed

Bench: Shri Sandeep Gosain & Shri Prabhash Shankar

depreciation allowance or any other allowance or deduction for such assessment year and for which a prior notice under Section 148 would be required to be issued. Section 147 does not contemplate an eventuality which Section 153A or Section 153C contemplates, the basis of which is inter alia a search action under Section 132 being resorted as noted hereinabove. Thus

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

151 of the Act mandates\nprior approval of the specified authority before issuance of notice\nunder section 148A(b) as well as notice under section 148. For\ncases where more than three years have elapsed from the end of the\nrelevant assessment year, the statute clearly requires approval of\nthe Principal Chief Commissioner of Income Tax or the Chief\nCommissioner

DCIT CC 4(4), MUMBAI, MUMBAI vs. SANMAN TRADE IMPEX LIMITED, MUMBAI

In the result, appeals of the Revenue are dismissed dismissed whereas appeals of the assessee are partly allowed appeals of the assessee are partly allowed

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

151 is reproduced as under: “ Approving Authority Approving Authority PCIT/CIT PCIT/CIT Category Assessment Assessment Income Escaped Amount >= 1 Lakh Income Escaped Amount >= 1 Lakh Yes Income Escaping Assessment Income Escaping Assessment (Rs.) ” 12.4 On perusal of the above proforma, it is evident that already On perusal of the above proforma, it is evident that already On perusal of the above

SANMAN TRADE IMPEX LIMITED,MUMBAI vs. ASSISTANT COMMISSIONER OF INCOME TAX-CENTRAL CIRCLE 4(4), MUMBAI, MUMBAI

In the result, appeals of the Revenue are dismissed dismissed whereas appeals of the assessee are partly allowed appeals of the assessee are partly allowed

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

151 is reproduced as under: “ Approving Authority Approving Authority PCIT/CIT PCIT/CIT Category Assessment Assessment Income Escaped Amount >= 1 Lakh Income Escaped Amount >= 1 Lakh Yes Income Escaping Assessment Income Escaping Assessment (Rs.) ” 12.4 On perusal of the above proforma, it is evident that already On perusal of the above proforma, it is evident that already On perusal of the above

DCIT CC 4 (4), MUMBAI, MUMBAI vs. SANMAN TRADE IMPEX LIMITED, MUMBAI

In the result, appeals of the Revenue are dismissed dismissed whereas appeals of the assessee are partly allowed appeals of the assessee are partly allowed

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

151 is reproduced as under: “ Approving Authority Approving Authority PCIT/CIT PCIT/CIT Category Assessment Assessment Income Escaped Amount >= 1 Lakh Income Escaped Amount >= 1 Lakh Yes Income Escaping Assessment Income Escaping Assessment (Rs.) ” 12.4 On perusal of the above proforma, it is evident that already On perusal of the above proforma, it is evident that already On perusal of the above

DCIT CC 4 (4), MUMBAI, MUMBAI vs. SANMAN TRADE IMPEX LIMITED, MUMBAI

In the result, appeals of the Revenue are dismissed dismissed whereas appeals of the assessee are partly allowed appeals of the assessee are partly allowed

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

151 is reproduced as under: “ Approving Authority Approving Authority PCIT/CIT PCIT/CIT Category Assessment Assessment Income Escaped Amount >= 1 Lakh Income Escaped Amount >= 1 Lakh Yes Income Escaping Assessment Income Escaping Assessment (Rs.) ” 12.4 On perusal of the above proforma, it is evident that already On perusal of the above proforma, it is evident that already On perusal of the above

SANMAN TRADE IMPEX LIMITED,MUMBAI vs. ASSISTANT COMMISSIONER OF INCOME TAX- CENTRAL CIRCLE 4(4), MUMBAI, MUMBAI

In the result, appeals of the Revenue are dismissed dismissed whereas appeals of the assessee are partly allowed appeals of the assessee are partly allowed

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

151 is reproduced as under: “ Approving Authority Approving Authority PCIT/CIT PCIT/CIT Category Assessment Assessment Income Escaped Amount >= 1 Lakh Income Escaped Amount >= 1 Lakh Yes Income Escaping Assessment Income Escaping Assessment (Rs.) ” 12.4 On perusal of the above proforma, it is evident that already On perusal of the above proforma, it is evident that already On perusal of the above

ACIT - 14(2) (2), MUMBAI vs. PFIZER LTD, MUMBAI

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

Bench: Shri Prashant Maharishi, Am & Shri Rahul Chaudhary, Jm M/S Pfizer Limited The Capital, 1802/1901, Acit-14(2)(2) Plot No.C-70, G-Block, 461, 4T H Floor, Aaykar Bhavan Bandra Kurla Complex, Vs. Mumbai-400 020 Bandra (East), Mumbai-400 051 (Appellant) (Respondent) Pan No. Aaacp3334M

section 32 (1) of The Income Tax Act. The AO further submitted that the decision of the coordinate bench in ITA number 722/BANG/2014 [ United Breweries Limited] for assessment year 2007 – 08 held that an amalgamated company cannot claim depreciation on the assets acquired in the scheme of amalgamation including goodwill, more than that which is permitted to the amalgamating company

PFIZER LTD,MUMBAI vs. DCIT - 14(2) (2), MUMBAI

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

Bench: Shri Prashant Maharishi, Am & Shri Rahul Chaudhary, Jm M/S Pfizer Limited The Capital, 1802/1901, Acit-14(2)(2) Plot No.C-70, G-Block, 461, 4T H Floor, Aaykar Bhavan Bandra Kurla Complex, Vs. Mumbai-400 020 Bandra (East), Mumbai-400 051 (Appellant) (Respondent) Pan No. Aaacp3334M

section 32 (1) of The Income Tax Act. The AO further submitted that the decision of the coordinate bench in ITA number 722/BANG/2014 [ United Breweries Limited] for assessment year 2007 – 08 held that an amalgamated company cannot claim depreciation on the assets acquired in the scheme of amalgamation including goodwill, more than that which is permitted to the amalgamating company

DCIT CEN 5 3, MUMBAI, MUMBAI vs. ICICI LOMBARD GENERAL INSURANCE CO. LIMITED, MUMBAI

In the result, appeals of the Revenue are allowed partly

Bench: Shri Om Prakash Kant () & Shri Raj Kumar Chauhan ()

Depreciation 30,458 Employees' remuneration & welfare benefits Employees' remuneration & welfare benefits 5,71,67,541 5,71,67,541 Legal & professional charges Legal & professional charges 1,33,37,144 1,33,37,144 Printing & Stationery Printing & Stationery 60,740 Rents, Rates & Taxes Rents, Rates & Taxes 3,52,594 3,52,594 Repairs & Maintenance Repairs & Maintenance

DCIT CEN 5 3, MUMBAI, MUMBAI vs. ICICI LOMBARD GENERAL INSURANCE CO. LIMITED, MUMBAI

In the result, appeals of the Revenue are allowed partly

Bench: Shri Om Prakash Kant () & Shri Raj Kumar Chauhan ()

Depreciation 30,458 Employees' remuneration & welfare benefits Employees' remuneration & welfare benefits 5,71,67,541 5,71,67,541 Legal & professional charges Legal & professional charges 1,33,37,144 1,33,37,144 Printing & Stationery Printing & Stationery 60,740 Rents, Rates & Taxes Rents, Rates & Taxes 3,52,594 3,52,594 Repairs & Maintenance Repairs & Maintenance