INCOME TAX OFFICER, KAUTALIYA BHAVAN vs. RASHESH SHIRISHKUMAR BHUTA, MUMBAI

In the result, the appeals of the learned Assessing Officer for 025

Bench: Shri Prashant Maharishi, Am & Shri Sunil Kumar Singh, Jm

u/s 271(1) (c) of the Act can be sustained on such addition. Honourable Gujarat High court in RAMESHCHANDRA A SHAH 019. VERSUS ASSTT. CIT, CIRCLE 3 OR HIS SUCCESSOR TAX APPEAL NO. 800 of 2008 dated August 10, 2016, on the question of law " Whether on the facts and circumstances of the case, the Income-tax Appellate Tribunal

PANASONIC LIFE SOLUTIONS INDIA PVT LTD,THANE vs. ASST CIT CC 7(2), MUMBAI

In the result, Appeal of assessee is partly allowed

Bench: Shri Prashant Maharishi, Am & Shri Rahul Chaudhary, Jm Panasonic Life Solutions India Asst. Commissioner Of Private Limited Income-Tax (Formerly Known As Anchor Central Circle 7(2) Electricals Private Limited) 3Rd Floor, B Wing, 655, 6Th Floor, Aaykar Bhavan Vs. I – Think Techno Campus, M.K. Road, Pokhran Road No.2, Thane Mumbai-400 020 (West) (Appellant) (Respondent) Pan No. Aaeca2190C Assessee By : Shri M.P. Lohia Shri Nikhil Tiwari, Ar Revenue By : Shri Manoj Kumar, Cit Dr Date Of Hearing: 08-12-2023 Date Of Pronouncement : 19.12.2023

u/s 80IC of the Act 02. Assessee has raised following grounds of appeal:- ““Based on the facts and circumstances of the case, Panasonic Life Solutions India Private Limited (hereinafter referred to as the 'Appellant) craves leave to prefer an appeal against the order passed by the Learned Assistant Commissioner of Income-Tax, Central Circle -7(2) (hereinafter referred

INCOME TAX OFFICER-19(2)(2), , MUMBAI vs. MUKESHKUMAR SOMATMALJI DOSHI, MUMBAI

Bench: Shri Prashant Maharishi, Am & Shri Sunil Kumar Singh, Jm Mukeshkumar Somatmalji Income Tax Officer Doshi, Ward 19(2)(2) 63/A, 1St Khumbharwada Lane, Room No.503, Bhandari Street, Vs. Piramal Chamber, Near Goel Deval, Lalgaug, Lower Parel, Mumbai-400 004 Mumbai-400 012 (Appellant) (Respondent) Pan No. Abqpd5578B

u/s 271(1)(c) of the I.T. Act @ 12.5% on alleged purchases of Rs. 61 ,77,214/- without considering the fact that the assessee, when asked to prove the genuineness and creditworthiness of the transactions and parties /suppliers, has neither produced any parties for verification nor submitted vital documents, evidences before AO, which proves that the purchases were non- genuine

HELIOS MERCANTILE LIMITED,MUMBAI vs. DY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-6(1), MUMBAI

penalty u/s 271AAB(1A) in\nthe instant case where no additions were made and, in a\nyear, where the section was non- existent.\n0. In the case of Citron Infraprojects Ltd, for AY 2012-13 to\nAY 2018-19, the approval number granted by the Addl.\nCIT has not been mentioned in the Assessment Orders.\np. In the case

HELIOS MERCANTILE LIMITED ,MUMBAI vs. DY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-6(1), MUMBAI, MUMBAI.

penalty u/s 271AAB(1A) in\nthe instant case where no additions were made and, in a\nyear, where the section was non- existent.\n0.\nIn the case of Citron Infraprojects Ltd, for AY 2012-13 to\nAY 2018-19, the approval number granted by the Addl.\nCIT has not been mentioned in the Assessment Orders.\np.\nIn the case

HELIOS MERCANTILE LIMITED ,MUMBAI vs. DY COMMISSIONER OF INCOME TAX CENTRAL CIRCLE-6(1), MUMBAI

penalty u/s 271AAB(1A) in\nthe instant case where no additions were made and, in a\nyear, where the section was non- existent.\n0. In the case of Citron Infraprojects Ltd, for AY 2012-13 to\nAY 2018-19, the approval number granted by the Addl.\nCIT has not been mentioned in the Assessment Orders.\np. In the case

SVP GLOBAL TEXTILES LTD FORMERLY SVP GLOBAL VENTURES LTD,MUMBAI vs. DY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-6(1), MUMBAI MUMBAI, MUMBAI

penalty u/s 271AAB(1A) in\nthe instant case where no additions were made and, in a\nyear, where the section was non- existent.\n0.\nIn the case of Citron Infraprojects Ltd, for AY 2012-13 to\nAY 2018-19, the approval number granted by the Addl.\nCIT has not been mentioned in the Assessment Orders.\np.\nIn the case

HELLIOS EXPORTS LIMITED,MUMBAI vs. THE COMMISSIONER OF INCOME TAX,CENTRAL CIRCLE-8(2), MUMBAI

penalty u/s 271AAB(1A) in\nthe instant case where no additions were made and, in a\nyear, where the section was non- existent.\n0.\nIn the case of Citron Infraprojects Ltd, for AY 2012-13 to\nAY 2018-19, the approval number granted by the Addl.\nCIT has not been mentioned in the Assessment Orders.\np.\nIn the case

SHRIVALLABH PITTE INDUSTRIES LTD MUMBAI,MUMBAI vs. DY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-6(1),MUMBAI, MUMBAI

penalty u/s 271AAB(1A) in\nthe instant case where no additions were made and, in a\nyear, where the section was non- existent.\n0.\nIn the case of Citron Infraprojects Ltd, for AY 2012-13 to\nAY 2018-19, the approval number granted by the Addl.\nCIT has not been mentioned in the Assessment Orders.\np.\nIn the case

THERMO FISHER SCIENTIFIC INDIA PVT LTD. ,MUMBAI vs. DCIT-15(3)(1), MUMBAI

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

Bench: Shri Om Prakash Kant () & Ms. Kavitha Rajagopal () Assessment Year: 2009-10 Thermo Fisher Scientific India Dy. Cit-15(3)(1), Pvt. Ltd., Room No. 360, Aayakar Vs. 403-404, ‘B’ Wing, Delphi, Bhavan, New Marine Lines, Hiranandani Business Park, Mumbai-400020. Mumbai-400076. Pan No. Aabct 3207 A Appellant Respondent

penalty proceedings under section 271(1)(c) of the IT Act. 271(1)(c) of the IT Act. 2. Briefly stated facts of the case are that Briefly stated facts of the case are that the assessee i.e. M/s the assessee i.e. M/s Thermo Fisher Scientific India Private Limited (previously "Thermo Thermo Fisher Scientific India Private Limited (previously "Thermo Thermo

ASSTT COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-6(1), MUMBAI vs. HELIOS MERCANTILE LIMITED, MUMBAI

penalty u/s 271AAB(1A) in\nthe instant case where no additions were made and, in a\nyear, where the section was non- existent.\n0.\nIn the case of Citron Infraprojects Ltd, for AY 2012-13 to\nAY 2018-19, the approval number granted by the Addl.\nCIT has not been mentioned in the Assessment Orders.\np.\nIn the case

ASST. COMMISSIONER OF INCOME TAX, MUMBAI vs. AADHAAR WHOLESALE TRADING AND DISTRIBUTION LTD., MUMBAI

In the result, appeals of revenue are dismissed and cross\nobjection of the assessee is allowed

150,00,00,000/-. The AO was not\nsatisfied with the submission of the assessee. He held that reliance on\na share valuation report of A.Y. 2010-11 for considering value of\nshares for A.Y. 2013-14 would give a distorted picture. Since, the\nassessee did not carry out fresh valuation of share for the year under\nconsideration

ASSTT COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-6(1), MUMBAI vs. HELIOS MERCANTILE LIMITED, MUMBAI

penalty u/s 271AAB(1A) in\nthe instant case where no additions were made and, in a\nyear, where the section was non- existent.\n\n0.\nIn the case of Citron Infraprojects Ltd, for AY 2012-13 to\nAY 2018-19, the approval number granted by the Addl.\nCIT has not been mentioned in the Assessment Orders

ACIT, MUMBAI vs. AADHAAR WHOLESALE TRADING AND DISTRIBUTION LTD., MUMBAI

In the result, appeals of revenue are dismissed and cross\nobjection of the assessee is allowed

150,00,00,000/-. The AO was not\nsatisfied with the submission of the assessee. He held that reliance on\na share valuation report of A.Y. 2010-11 for considering value of\nshares for A.Y. 2013-14 would give a distorted picture. Since, the\nassessee did not carry out fresh valuation of share for the year under\nconsideration

ASST. COMMISSIONER OF INCOME TAX, MUMBAI vs. AADHAAR WHOLESALE TRADING AND DISTRIBUTION LTD., MUMBAI

In the result, appeals of revenue are dismissed and cross\nobjection of the assessee is allowed

150,00,00,000/-. The AO was not\nsatisfied with the submission of the assessee. He held that reliance on\na share valuation report of A.Y. 2010-11 for considering value of\nshares for A.Y. 2013-14 would give a distorted picture. Since, the\nassessee did not carry out fresh valuation of share for the year under\nconsideration

ASST. COMMISSIONER OF INCOME TAX, MUMBAI vs. AADHAAR WHOLESALE TRADING AND DISTRIBUTION LTD., MUMBAI

In the result, appeals of revenue are dismissed and cross\nobjection of the assessee is allowed

150,00,00,000/-. The AO was not\nsatisfied with the submission of the assessee. He held that reliance on\na share valuation report of A.Y. 2010-11 for considering value of\nshares for A.Y. 2013-14 would give a distorted picture. Since, the\nassessee did not carry out fresh valuation of share for the year under\nconsideration

ACIT- 3(1)(1), MUMBAI vs. MM/S SANOFI INDIA LIMITED (FORMERLY KNOWN AS AVENTIS PHARMA LTD)., MUMBAI

In the result, appeal filed by the Revenue is dismissed

Bench: Shri Vikas Awasthy, Hon’Ble & Shri S. Rifaur Rahman, Hon'Ble

2 to 8). Copy of the order is placed on record. 68. On the other hand, Ld. DR has fairly accepted the submissions of the Ld.AR. 69. Considered the submissions and material placed on record, we observe from the record that identical issue is decided in favour of the assessee for the A.Y. 2002-03. While deciding the issue

M/S SANOFI INDIA LTD (FORMERLY KNOWN AS AVENTIS PHARMA LTD,MUMBAI vs. THE ACIT RG 8(1), MUMBAI

In the result, appeal filed by the Revenue is dismissed

Bench: Shri Vikas Awasthy, Hon’Ble & Shri S. Rifaur Rahman, Hon'Ble

2 to 8). Copy of the order is placed on record. 68. On the other hand, Ld. DR has fairly accepted the submissions of the Ld.AR. 69. Considered the submissions and material placed on record, we observe from the record that identical issue is decided in favour of the assessee for the A.Y. 2002-03. While deciding the issue