DCIT-14.1.1, MUMBAI vs. AMCOR FLEXIBLES INDIA PVT. LTD, MUMBAI

In the result, appeal of the Revenue is dismissed

Bench: SHRI AMIT SHUKLA (Judicial Member), SMT RENU JAUHRI (Accountant Member)

disallowance of depreciation on goodwill. On validity of reassessment proceedings, it was submitted by the 5 Amcor Flexibles India Pvt. Ltd. assessee before the Ld. CIT (A) that the notice under Section 148 should have been issued by the Faceless Assessing Officer and not by the Jurisdiction Assessing Officer. It was also contended that reassessment cannot be initiated

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

section 151A; It is further clarified\nthat all consequential adjustments such as disallowances,\ncarry-forward of losses, and levy of interest

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

Section 151A; It is further clarified\nthat all consequential adjustments such as disallowances,\ncarry-forward of losses, and levy of interest

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

Section 151A; It is further clarified\nthat all consequential adjustments such as disallowances,\ncarry-forward of losses, and levy of interest

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; (iii) the assessment orders themselves are invalidated for non-compliance with CBDT Circular No. 19 of 2019 due to the absence of a valid pre-generated DIN and (iv) the assessment orders themselves are invalidated on account of defective notices issued under section 148. It is further clarified that all consequential adjustments such as disallowances

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; (iii) the assessment orders themselves are invalidated for non-compliance with CBDT Circular No. 19 of 2019 due to the absence of a valid pre-generated DIN and (iv) the assessment orders themselves are invalidated on account of defective notices issued under section 148. It is further clarified that all consequential adjustments such as disallowances

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)

section 251 of the Act are indeed wide, but they are not unbounded. They must operate within the framework of issues arising out of the assessment before the CIT(A) and cannot extend to introducing new sources of income that were never the subject of consideration before the Assessing Officer. The Hon’ble Supreme Court in CIT v. Shapoorji Pallonji

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

section 147 cannot be used as a ploy for\nroving verification or fishing enquiry into completed matters.\n\n63\nITA No.3012/Mum/2025 and others\nThe Estate Investment Company Pvt. Ltd. and others\n\nThe Assessing Officer's act of extrapolating entries found in\none year to reopen other years is precisely the mischief which\nthe Court sought to prevent. On this

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

section 147 cannot be used as a ploy for\nroving verification or fishing enquiry into completed matters.\n\n62\nITA No.3012/Mum/2025 and others\nThe Estate Investment Company Pvt. Ltd. and others\n\nThe Assessing Officer's act of extrapolating entries found in\none year to reopen other years is precisely the mischief which\nthe Court sought to prevent. On this

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

section 148 or 153A of the Act\nbased on the same set of seized diaries, statements, and MIS\nsheets, such assessments stand annulled for want of\njurisdiction, procedural legitimacy, and evidentiary support.\nAll consequential additions made therein are correspondingly\nset aside.\n\n62. For the sake of clarity and completeness, it is hereby\nrecorded that: (i) in all years where

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

section 147 cannot be used as a ploy for\nroving verification or fishing enquiry into completed matters.\n\n62\nITA No.3012/Mum/2025 and others\nThe Estate Investment Company Pvt. Ltd. and others\n\nThe Assessing Officer's act of extrapolating entries found in\none year to reopen other years is precisely the mischief which\nthe Court sought to prevent. On this

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

section 148 or 153A of the Act\nbased on the same set of seized diaries, statements, and MIS\nsheets, such assessments stand annulled for want of\njurisdiction, procedural legitimacy, and evidentiary support.\nAll consequential additions made therein are correspondingly\nset aside.\n\n62. For the sake of clarity and completeness, it is hereby\nrecorded that: (i) in all years where

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

section 147 cannot be used as a ploy for\nroving verification or fishing enquiry into completed matters.\n\n62\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\none year to reopen other years is precisely the mischief which\nthe Court sought to prevent. On this count

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

section 148 or 153A of the Act\nbased on the same set of seized diaries, statements, and MIS\nsheets, such assessments stand annulled for want of\njurisdiction, procedural legitimacy, and evidentiary support.\nAll consequential additions made therein are correspondingly\nset aside.\n\n62. For the sake of clarity and completeness, it is hereby\nrecorded that: (i) in all years where

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

section 148 or 153A of the Act\nbased on the same set of seized diaries, statements, and MIS\nsheets, such assessments stand annulled for want of\njurisdiction, procedural legitimacy, and evidentiary support.\nAll consequential additions made therein are correspondingly\nset aside.\n\n62. For the sake of clarity and completeness, it is hereby\nrecorded that: (i) in all years where

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

151A (ii) the assessment orders themselves are invalidated for non-compliance with CBDT Circular No. 19 of 2019 due to the absence of a valid pre- generated DIN and (iii) the assessment orders themselves are invalidated on account of defective notices issued under section 148; It is further clarified that all consequential adjustments such as disallowances

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

151A (ii) the assessment orders themselves are invalidated for non-compliance with CBDT Circular No. 19 of 2019 due to the absence of a valid pre- generated DIN and (iii) the assessment orders themselves are invalidated on account of defective notices issued under section 148; It is further clarified that all consequential adjustments such as disallowances