DCIT, CENTRAL CIRCLE-8(1), MUMBAI, MUMBAI vs. EI RESORTS & CLUBS PVT LTD, MUMBAI

3213/Mum/2025

Bench: SHRI AMIT SHUKLA (Judicial Member), SHRI ARUN KHODPIA (Accountant Member)

151A of the Act, and is therefore void ab initio. The assessee has further assailed the consequential assessment orders on the ground that they were passed without a Document Identification Number (DIN), in breach of the mandatory directions contained in CBDT Circular No. 19 of 2019 dated 14 August 2019. 53. On merits, the assessee has contested the additions made

DCIT, CENTRAL CIRCLE-8(1), MUMBAI, MUMBAI vs. E I RESORTS AND CLUBS PVT LTD, MUMBAI

3213/Mum/2025

Bench: SHRI AMIT SHUKLA (Judicial Member), SHRI ARUN KHODPIA (Accountant Member)

151A of the Act, and is therefore void ab initio. The assessee has further assailed the consequential assessment orders on the ground that they were passed without a Document Identification Number (DIN), in breach of the mandatory directions contained in CBDT Circular No. 19 of 2019 dated 14 August 2019. 53. On merits, the assessee has contested the additions made

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

151A of\nthe Act, and is therefore void ab initio.\n59. On merits, the assessee has contested the additions made\non account of alleged unaccounted investment in land is said\nto have arisen from the statements recoded under section\n132[4]/131 which have been retracted, contending that the\nsame are purely notional and unsupported by any cogent\nmaterial

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

151A of\nthe Act, and is therefore void ab initio.\n\n59. On merits, the assessee has contested the additions made\non account of alleged unaccounted investment in land is said\nto have arisen from the statements recoded under Section\n132[4]/131 which have been retracted, contending that the\nsame are purely notional and unsupported by any cogent\nmaterial

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

151A of\nthe Act, and is therefore void ab initio.\n\n59. On merits, the assessee has contested the additions made\non account of alleged unaccounted investment in land is said\nto have arisen from the statements recoded under Section\n132[4]/131 which have been retracted, contending that the\nsame are purely notional and unsupported by any cogent\nmaterial

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

3012/Mum/2025

Bench: SHRI AMIT SHUKLA (Judicial Member), SHRI ARUN KHODPIA (Accountant Member)

151A of the Act, and is therefore void ab initio. The assessee has further assailed the consequential assessment orders on the ground that they were passed without a valid Document Identification Number (DIN), in breach of the mandatory directions contained in CBDT Circular No. 19 of 2019 dated 14 August 2019. 53. On merits, the assessee has contested the additions

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

section 147 cannot be used as a ploy for roving verification or fishing enquiry into completed matters.\n\n63\nITA No.3012/Mum/2025 and others\nThe Estate Investment Company Pvt. Ltd. and others\nThe Assessing Officer's act of extrapolating entries found in one year to reopen other years is precisely the mischief which the Court sought to prevent. On this count

EI RESORTS AND CLUBS PVT LTD ,MUMBAI vs. DEPUTY COMMISSIONER OF INCOME TAX CENTRAL CIRCLE -8(1), MUMBAI

151A and compounded by the\nfailure to generate and quote a valid DIN, stand vitiated in law. The dual\nbreaches one jurisdictional, the other procedural strike at the\nroot of the assessment's validity. The notice under Section\n148, having been issued by an officer not authorised under\nthe notified scheme, is coram non judice, and the subsequent\norder passed

EI BENEFICARY TRUST ,MUMBAI vs. DEPUTY COMMISSIONER OF INCOME TAX CENTRAL CIRCLE -8(1), MUMBAI

3230/Mum/2025 Govind

Bench: SHRI AMIT SHUKLA (Judicial Member), SHRI ARUN KHODPIA (Accountant Member)

151A and compounded by the failure to generate and quote a valid DIN, stand vitiated in law. The dual breaches one jurisdictional, the other procedural strike at the root of the assessment‟s validity. The notice under section 148, having been issued by an officer not authorised under the notified scheme, is coram non judice, and the subsequent order passed

EI BENEFICIARY TRUST ,MUMBAI vs. DEPUTY COMMISSIONER OF INCOME TAX CENTRAL CIRCLE -8(1), MUMBAI

151A and compounded by the failure to generate and quote a valid DIN, stand vitiated in law. The dual breaches one jurisdictional, the other procedural strike at the root of the assessment's validity. The notice under section 148, having been issued by an officer not authorised under the notified scheme, is coram non judice, and the subsequent order passed

GOVIND CORPORATION ,MUMBAI vs. DEPUTY COMMISSIONER OF INCOME TAX CENTRAL CIRCLE -8(1), MUMBAI

151A and compounded by the failure to generate and quote a valid DIN, stand vitiated in law. The dual breaches one jurisdictional, the other procedural strike at the root of the assessment's validity. The notice under section 148, having been issued by an officer not authorised under the notified scheme, is coram non judice, and the subsequent order passed

GOVIND CORPORATION,MUMBAI vs. DEPUTY COMMISSIONER OF INCOME TAX CENTRAL CIRCLE -8(1), MUMBAI

151A and compounded by the failure to\ngenerate and quote a valid DIN, stand vitiated in law. The dual\nbreaches one jurisdictional, the other procedural strike at the\nroot of the assessment's validity. The notice under section\n148, having been issued by an officer not authorised under\nthe notified scheme, is coram non judice, and the subsequent\norder passed

EI BENEFICIARY TRUST ,MUMBAI vs. DEPUTY COMMISSIONER OF INCOME TAX CENTRAL CIRCLE -8(1), MUMBAI

151A and compounded by the failure to\ngenerate and quote a valid DIN, stand vitiated in law. The dual\nbreaches one jurisdictional, the other procedural strike at the\nroot of the assessment's validity. The notice under section\n148, having been issued by an officer not authorised under\nthe notified scheme, is coram non judice, and the subsequent\norder passed

J KUMAR INFRAPROJECTS LIMITED,MUMBAI vs. THE DY COMMISSIONER OF INCOME TAX CENTRAL CIRCLE -5(1), MUMBAI

The Appeal of the Assessee is partly allowed and that of the department is dismissed

Bench: Hon’Ble Shri Sandeep Gosain & Shri Prabhash Shankar

Section 65B obtained at the time of taking the document, without which, the secondary evidence pertaining to that electronic record, is inadmissible. (Page 38 to 52 of Paper Book – II; Relevant para 12-17 on page 43-45) The Hon’ble Madras High Court in the case of Saravana Selvarathnam Retails

J KUMAR INFRAPROJECTS LIMITED,MUMBAI vs. THE DY COMMISSIONER OF INCOME TAX CENTRAL CIRCLE -5(1), MUMBAI

The Appeal of the Assessee is partly allowed and that of the department is dismissed

Bench: Hon’Ble Shri Sandeep Gosain & Shri Prabhash Shankar

Section 65B obtained at the time of taking the document, without which, the secondary evidence pertaining to that electronic record, is inadmissible. (Page 38 to 52 of Paper Book – II; Relevant para 12-17 on page 43-45) The Hon’ble Madras High Court in the case of Saravana Selvarathnam Retails

J KUMAR INFRAPROJECTS LIMITED,MUMBAI vs. THE DY COMMISSIONER OF INCOME TAX CENTRAL CIRCLE -5(1), MUMBAI

The Appeal of the Assessee is partly allowed and that of the department is dismissed

Bench: Hon’Ble Shri Sandeep Gosain & Shri Prabhash Shankar

Section 65B obtained at the time of taking the document, without which, the secondary evidence pertaining to that electronic record, is inadmissible. (Page 38 to 52 of Paper Book – II; Relevant para 12-17 on page 43-45) The Hon’ble Madras High Court in the case of Saravana Selvarathnam Retails

DCIT CC 5-1, MUMBAI, MUMBAI vs. J KUMAR INFRAPROJECTS LIMITED , MUMBAI

The Appeal of the Assessee is partly allowed and that of the department is dismissed

Bench: Hon’Ble Shri Sandeep Gosain & Shri Prabhash Shankar

Section 65B obtained at the time of taking the document, without which, the secondary evidence pertaining to that electronic record, is inadmissible. (Page 38 to 52 of Paper Book – II; Relevant para 12-17 on page 43-45) The Hon’ble Madras High Court in the case of Saravana Selvarathnam Retails

DCIT, MUMBAI vs. J KUMAR INFRAPROJECTS LIMITED, MUMBAI

The Appeal of the Assessee is partly allowed and that of the department is dismissed

Bench: Hon’Ble Shri Sandeep Gosain & Shri Prabhash Shankar

Section 65B obtained at the time of taking the document, without which, the secondary evidence pertaining to that electronic record, is inadmissible. (Page 38 to 52 of Paper Book – II; Relevant para 12-17 on page 43-45) The Hon’ble Madras High Court in the case of Saravana Selvarathnam Retails