RAKESH JAIN AS THE LEGAL HEIR OF BHAWARLAL SHRILAL JAIN ,MUMBAI vs. ITO WARD-1 PALGHAR , MUMBAI

In the result, all four appeals of the assessee stand allowed

Bench: Shri Saktijit Dey & Shri Makarand Vasant Mahadeokar1. Ita No. 7674/Mum/2025 (Assessment Year: 2013-14) 2. Ita No. 7675/Mum/2025 (Assessment Year: 2013-14) 3. Ita No. 7676/Mum/2025 (Assessment Year: 2013-14) & 4. Ita No. 7677/Mum/2025 (Assessment Year: 2013-14) Rakesh Jain As Legal Ito Ward-1, Heir Of Bhawarlal Shrilal Bidco Road, Jain, Vs. Palghar, Shop 5, Vaibhav Complex, Maharashtra – Irani Road, Malyan, 401 404 Dahanu Road, Thane – 401602, Maharashtra. Pan/Gir No. Abjpj5270F (Applicant) (Respondent) Assessee By Shri Suchek Anchaliya, Ld. Ar Revenue By Shri Annavaram Kosuri, Ld. Dr Date Of Hearing 05.02.2026 Date Of Pronouncement 09.02.2026 आदेश / Order Per Makarand Vasant Mahadeokar, Am: These Four Appeals Are Directed Against Separate Orders Passed By The Commissioner Of Income-Tax (Appeals), National Faceless Appeal Centre, Delhi [Hereinafter Referred To As “Cit(A)”], All Dated 26.09.2025 & 18.09.2025, For Assessment Year 2013– 14. Since The Issues Involved In All The Appeals Arise Out Of The Same Set Of Facts & Relate To Proceedings Initiated In The Name Of Late Shri Bhawarlal Shrilal Jain, These Appeals Were Heard Together & Are Being Disposed Of By This Common Order For The Sake Of Convenience & Brevity.

271(1)(b) and 271F. 8. Subsequently, separate penalty orders were passed. Each of these orders proceeded on the footing that statutory notices were duly served and that there was deliberate non-compliance. 9. Appeals were filed before the CIT(A). In the appeals, the appellant, being legal heir Shri Rakesh Jain, contended that Late Shri Bhawarlal Shrilal Jain expired

RAKESH JAIN AS THE LEGAL HEIR OF BHAWARLAL SHRILAL JAIN,MUMBAI vs. ITO WARD 1 PALGHAR, THANE

In the result, all four appeals of the assessee stand allowed

Bench: Shri Saktijit Dey & Shri Makarand Vasant Mahadeokar1. Ita No. 7674/Mum/2025 (Assessment Year: 2013-14) 2. Ita No. 7675/Mum/2025 (Assessment Year: 2013-14) 3. Ita No. 7676/Mum/2025 (Assessment Year: 2013-14) & 4. Ita No. 7677/Mum/2025 (Assessment Year: 2013-14) Rakesh Jain As Legal Ito Ward-1, Heir Of Bhawarlal Shrilal Bidco Road, Jain, Vs. Palghar, Shop 5, Vaibhav Complex, Maharashtra – Irani Road, Malyan, 401 404 Dahanu Road, Thane – 401602, Maharashtra. Pan/Gir No. Abjpj5270F (Applicant) (Respondent) Assessee By Shri Suchek Anchaliya, Ld. Ar Revenue By Shri Annavaram Kosuri, Ld. Dr Date Of Hearing 05.02.2026 Date Of Pronouncement 09.02.2026 आदेश / Order Per Makarand Vasant Mahadeokar, Am: These Four Appeals Are Directed Against Separate Orders Passed By The Commissioner Of Income-Tax (Appeals), National Faceless Appeal Centre, Delhi [Hereinafter Referred To As “Cit(A)”], All Dated 26.09.2025 & 18.09.2025, For Assessment Year 2013– 14. Since The Issues Involved In All The Appeals Arise Out Of The Same Set Of Facts & Relate To Proceedings Initiated In The Name Of Late Shri Bhawarlal Shrilal Jain, These Appeals Were Heard Together & Are Being Disposed Of By This Common Order For The Sake Of Convenience & Brevity.

271(1)(b) and 271F. 8. Subsequently, separate penalty orders were passed. Each of these orders proceeded on the footing that statutory notices were duly served and that there was deliberate non-compliance. 9. Appeals were filed before the CIT(A). In the appeals, the appellant, being legal heir Shri Rakesh Jain, contended that Late Shri Bhawarlal Shrilal Jain expired

RAKESH JAIN AS THE LEGAL HEIR OF BHAWARLAL SHRILAL JAIN ,MUMBAI vs. ITO WARD -1 PALGHAR , THANE

In the result, all four appeals of the assessee stand allowed

Bench: Shri Saktijit Dey & Shri Makarand Vasant Mahadeokar1. Ita No. 7674/Mum/2025 (Assessment Year: 2013-14) 2. Ita No. 7675/Mum/2025 (Assessment Year: 2013-14) 3. Ita No. 7676/Mum/2025 (Assessment Year: 2013-14) & 4. Ita No. 7677/Mum/2025 (Assessment Year: 2013-14) Rakesh Jain As Legal Ito Ward-1, Heir Of Bhawarlal Shrilal Bidco Road, Jain, Vs. Palghar, Shop 5, Vaibhav Complex, Maharashtra – Irani Road, Malyan, 401 404 Dahanu Road, Thane – 401602, Maharashtra. Pan/Gir No. Abjpj5270F (Applicant) (Respondent) Assessee By Shri Suchek Anchaliya, Ld. Ar Revenue By Shri Annavaram Kosuri, Ld. Dr Date Of Hearing 05.02.2026 Date Of Pronouncement 09.02.2026 आदेश / Order Per Makarand Vasant Mahadeokar, Am: These Four Appeals Are Directed Against Separate Orders Passed By The Commissioner Of Income-Tax (Appeals), National Faceless Appeal Centre, Delhi [Hereinafter Referred To As “Cit(A)”], All Dated 26.09.2025 & 18.09.2025, For Assessment Year 2013– 14. Since The Issues Involved In All The Appeals Arise Out Of The Same Set Of Facts & Relate To Proceedings Initiated In The Name Of Late Shri Bhawarlal Shrilal Jain, These Appeals Were Heard Together & Are Being Disposed Of By This Common Order For The Sake Of Convenience & Brevity.

271(1)(b) and 271F. 8. Subsequently, separate penalty orders were passed. Each of these orders proceeded on the footing that statutory notices were duly served and that there was deliberate non-compliance. 9. Appeals were filed before the CIT(A). In the appeals, the appellant, being legal heir Shri Rakesh Jain, contended that Late Shri Bhawarlal Shrilal Jain expired

RAKESH JAIN AS THE LEGAL HEIR OF BHAWARLAL SHRILAL JAIN ,MUMBAI vs. ITO WARD 1, PALGHAR , THANE

In the result, all four appeals of the assessee stand allowed

Bench: Shri Saktijit Dey & Shri Makarand Vasant Mahadeokar1. Ita No. 7674/Mum/2025 (Assessment Year: 2013-14) 2. Ita No. 7675/Mum/2025 (Assessment Year: 2013-14) 3. Ita No. 7676/Mum/2025 (Assessment Year: 2013-14) & 4. Ita No. 7677/Mum/2025 (Assessment Year: 2013-14) Rakesh Jain As Legal Ito Ward-1, Heir Of Bhawarlal Shrilal Bidco Road, Jain, Vs. Palghar, Shop 5, Vaibhav Complex, Maharashtra – Irani Road, Malyan, 401 404 Dahanu Road, Thane – 401602, Maharashtra. Pan/Gir No. Abjpj5270F (Applicant) (Respondent) Assessee By Shri Suchek Anchaliya, Ld. Ar Revenue By Shri Annavaram Kosuri, Ld. Dr Date Of Hearing 05.02.2026 Date Of Pronouncement 09.02.2026 आदेश / Order Per Makarand Vasant Mahadeokar, Am: These Four Appeals Are Directed Against Separate Orders Passed By The Commissioner Of Income-Tax (Appeals), National Faceless Appeal Centre, Delhi [Hereinafter Referred To As “Cit(A)”], All Dated 26.09.2025 & 18.09.2025, For Assessment Year 2013– 14. Since The Issues Involved In All The Appeals Arise Out Of The Same Set Of Facts & Relate To Proceedings Initiated In The Name Of Late Shri Bhawarlal Shrilal Jain, These Appeals Were Heard Together & Are Being Disposed Of By This Common Order For The Sake Of Convenience & Brevity.

271(1)(b) and 271F. 8. Subsequently, separate penalty orders were passed. Each of these orders proceeded on the footing that statutory notices were duly served and that there was deliberate non-compliance. 9. Appeals were filed before the CIT(A). In the appeals, the appellant, being legal heir Shri Rakesh Jain, contended that Late Shri Bhawarlal Shrilal Jain expired

ASST.COMMISSIONER OF INCOME TAX, BANDRA KURLA COMPLEX MUMBAI vs. DEVANG AJIT JAVERI , MUMBAI

In the result, appeal of the Revenue is dismissed on aforesaid terms

Bench: SHRI AMIT SHUKLA (Judicial Member), SHRI GIRISH AGRAWAL (Accountant Member)

u/s, 271(1)(c) for concealment of income & 27l(1)(b) for non-compliance of statutory notices, & 271 D for violating the provisions of Section 269 SS as discussed above." 12. The predecessor bench of this Court in the aforesaid judgments has held that where the AO has initiated the penalty taken as the relevant date

DEVANG AJIT JHAVERI,MUMBAI vs. JCIT, RANGE 17(1), MUMBAI

In the result, appeal of the Revenue is dismissed on aforesaid terms

Bench: SHRI AMIT SHUKLA (Judicial Member), SHRI GIRISH AGRAWAL (Accountant Member)

u/s, 271(1)(c) for concealment of income & 27l(1)(b) for non-compliance of statutory notices, & 271 D for violating the provisions of Section 269 SS as discussed above." 12. The predecessor bench of this Court in the aforesaid judgments has held that where the AO has initiated the penalty taken as the relevant date

HETAL PAGARE, ACIT 16(2), MUMBAI, MUMBAI vs. HASMUKH KABABHAI RAVAT, MULUND WEST

In the result, the appeal filed by the revenue is accordingly dismissed in above terms

Bench: Shri Vikram Singh Yadav & Shri Raj Kumar Chauhanacit 16(2), Vs. Hasmukh Kababhai Ravat, Room No. 481, Aayakar Bhavan, 1901, Moksh Mahal Building, Mumbai-400 020 Maharashtra-400 080 Pan: Aabpr2061D (Appellant) (Respondent)

Penalty u/s 271(1)(b) of the income tax act is initiated for non response to notice issued u/s 142(1) of the act. Computation of income and demand notice u/s 156 of the act is attached.” 7. Aggrieved by the impugned assessment order, assessee preferred the appeal before Ld. CIT(A) and has raised before him total 5 grounds

DY.DIT., (IT)-3(1), MUMBAI vs. GLOBAL CRICKET CORPORATION PVT.LTD., MUMBAI

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

Bench: Shri Om Prakash Kant, Am & Ms. Kavitha Rajagopal, Jm & Dy. Cit(It) – 3(1) M/S. Global Cricket Corpn Pte Ltd. Scindia House, R. No. 132, 1St Floor, C/O. S. R. Batliboi & Co. Vs. 18Th Floor, Express Towers, N. M. Road, Mumbai- 38 Nariman Point, Mumbai-21 Pan/Gir No. Aabcg 7951 L (Revenue) : (Assessee) & Cross Objection No. 83/Mum/2012 (Arising Out Of Ita No.4990/Mum/2011) (Assessment Year: 2003-04) M/S. Global Cricket Corpn Pte Ltd. The Dy. Dit (It)-3(1) C/O. S R B C & Associates Mumbai- 400 038 14Th Floor, The Ruby, Vs. 29 Senapati Bapat Marg, Dadar (W), Mumbai-400 028 Pan/Gir No. Aabcg 7951 L (Assessee) : (Revenue) : Shri P J Pardiwala/Aarati Sathe Assessee By Revenue By : Shri Ajay Kumar Sharma : 16.10.2023 Date Of Hearing Date Of Pronouncement : 27.10.2023

159 47.37 574,937,222 of India) 3 Prasar Bharati All India Radio 1,10,000 47.37 5,210,700 4 LG Electronics India Private Ltd. 3,971,060 47.37 188,109,112 5 Hero Honda Motors Ltd. 2,550,150 47.37 120,800,606 6 Hutchison Max Telecom Private Ltd. 1,520,000 47.37 72,002,400 Total

THE ADIT (IT)-3(1), MUMBAI vs. M/S. GLOBAL CRICKET CORPN PTE. LTD, MUMBAI

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

Bench: Shri Om Prakash Kant, Am & Ms. Kavitha Rajagopal, Jm & Dy. Cit(It) – 3(1) M/S. Global Cricket Corpn Pte Ltd. Scindia House, R. No. 132, 1St Floor, C/O. S. R. Batliboi & Co. Vs. 18Th Floor, Express Towers, N. M. Road, Mumbai- 38 Nariman Point, Mumbai-21 Pan/Gir No. Aabcg 7951 L (Revenue) : (Assessee) & Cross Objection No. 83/Mum/2012 (Arising Out Of Ita No.4990/Mum/2011) (Assessment Year: 2003-04) M/S. Global Cricket Corpn Pte Ltd. The Dy. Dit (It)-3(1) C/O. S R B C & Associates Mumbai- 400 038 14Th Floor, The Ruby, Vs. 29 Senapati Bapat Marg, Dadar (W), Mumbai-400 028 Pan/Gir No. Aabcg 7951 L (Assessee) : (Revenue) : Shri P J Pardiwala/Aarati Sathe Assessee By Revenue By : Shri Ajay Kumar Sharma : 16.10.2023 Date Of Hearing Date Of Pronouncement : 27.10.2023

159 47.37 574,937,222 of India) 3 Prasar Bharati All India Radio 1,10,000 47.37 5,210,700 4 LG Electronics India Private Ltd. 3,971,060 47.37 188,109,112 5 Hero Honda Motors Ltd. 2,550,150 47.37 120,800,606 6 Hutchison Max Telecom Private Ltd. 1,520,000 47.37 72,002,400 Total

SPICE OF LIFE HOTELS AND ESTATES PRIVATE LIMITED,MUMBAI vs. DCIT-2(3)(1), MUMBAI

Bench: Smt. Beeba Pillai, Jm & Shri Arun Khodpia, Am

271(1)(c) for allegedly furnishing inaccurate particulars of income whereas the levy of penalty by the Id. AO was on account of alleged concealment of income alone. 1.4. The Appellant prays that the penalty levied be deleted. 2. GROUND NO. 2: GENERAL: The Appellant craves leave to add, amend, modify, rescind, supplement or alter any of the Grounds stated

SPICE OF LIFE HOTELS AND ESTATES PRIVATE LIMITED,MUMBAI vs. DCIT- 2(3)(1), MUMBAI

Bench: Smt. Beeba Pillai, Jm & Shri Arun Khodpia, Am

271(1)(c) for allegedly furnishing inaccurate particulars of income whereas the levy of penalty by the Id. AO was on account of alleged concealment of income alone. 1.4. The Appellant prays that the penalty levied be deleted. 2. GROUND NO. 2: GENERAL: The Appellant craves leave to add, amend, modify, rescind, supplement or alter any of the Grounds stated

ZODIAC VENTURES LTD ,MUMBAI vs. INCOME TAX OFFICER WARD 1(3)(4), MUMBAI

In the result, appeal filed by the assessee is allowed in the above terms

Bench: Ms. Padmavathy S & Shri. Raj Kumar Chauhanzodiac Ventures Ltd. Vs. Income Tax Officer Ward 404, Dev Plaza, 68, S.V. Road, 11(3)(4) Andheri West, Mumbai – Aayakar Bhawan, Maharshi 400058. Karve Road, Mumbai- Pan: Aafps7328J 400020. (Appellant) (Respondent)

159/- is disallowed u/s. 14A and added to the total income of the assessee. This is the fit case for initiated of penalty u/s. 271(1)(c) of the Income Tax Act, 1961, as the assessee has furnished inaccurate particulars of its income. Therefore, penalty notice u/s. 271 (1)(c) of the I.T. Act, 1961 is issued for furnishing inaccurate

THE DY. COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-5(1), MUMBAI vs. M/S SKYWAY INFRA PROJECTS PRIVATE LIMITED, MUMBAI

In the result, cross objections of the assessee are dismissed, cross objections of the assessee are dismissed, cross objections of the assessee are dismissed, whereas appeals of the revenue are par...

Bench: Shri Aby T Varkey () & Shri Om Prakash Kant () Assessment Year: 2013-14 & Assessment Year: 2014-15 & Assessment Year: 2015-16 & Assessment Year: 2016-17 & Assessment Year: 2017-18 & Assessment Year: 2018-19 & Assessment Year: 2019-20 & Assessment Year: 2020-21

Penalty U/S 271(1) © rws 274 of the rws 274 of the Act, is initiate for concealment of Income concealment of Income.” 7.5 On further appeal before the Ld. CIT(A), the assessee On further appeal before the Ld. CIT(A), the assessee On further appeal before the Ld. CIT(A), the assessee submitted that it had filed copy

UDAYAN GROVER,MUMBAI vs. NATIONAL FACELESS APPEAL CENTRE(NFAC), DELHI

In the result, appeal filed by the assessee is allowed

Bench: Shri Aby T Varkey, Hon'Ble & Shri S. Rifaur Rahman, Hon'Bleudayan Grover V. National Faceless Appeal Centre Panch Mahal Delhi Panch Sristhi Complex {Acit – 26(3), Bkc, Mumbai} Powai, Mumbai - 400072 Pan: Aclpg0572G (Appellant) (Respondent) Assessee Represented By : Shri Vimal Punmiya Department Represented By : Ms. Kavitha Kaushik

Section 10(38), in a pre-planned manner to evade taxes. The AO extensively relied upon the search and survey operations conducted by the Investigation Wing of the Income Tax Department in Kolkata, Delhi, Mumbai and Ahmedabad on penny stocks, which sets out the modus operandi adopted in the business of providing entries of bogus LTCG. However, the reliance placed

THOMAS COOK (INDIA) LTD.,MUMBAI vs. ADDL/ JT/ DY/CIT/ASSTT/ITO, NATIONAL E-ASSESSMENT CENTRE, DELHI

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

Bench: Shri S. Rifaur Rahman, Hon'Ble & Ms. Kavitha Rajagopal, Hon'Ble

section under which ESOP expenditure is allowable under the Income Tax Act 1961 ('Act). The only provision where a company can claim the expenditure is section 37 of the ActHence, it is pertinent to test the conditions mentioned in section 37 in order to conclude whether the expenditure is allowable? Section 37 of the Act Page

LEADING AGE DEVELOPERS PRIVATE LIMITED,MUMBAI vs. ACIT CC 2(2), MUMBAI

In the result, appeal of the assessee in ITA No

Bench: Shri Pavan Kumar Gadale & Shri Girish Agrawal

penalty proceedings u/s 271(1)(c) of the I.T.Act. Leading Age Developers Pvt. Ltd., AY 2011-12 3. We first take up appeal in ITA No.1113/Mum/2024. Brief facts of the case are that assessee is a company engaged in the business of real estate. Assessee filed its return of income on 20.09.2011 reporting a total income as loss

LEADING AGE DEVELOPERS PRIVATE LIMITED,MUMBAI vs. CENTRAL CIRCLE 2(2), CENTRAL BUILDING

In the result, appeal of the assessee in ITA No

Bench: Shri Pavan Kumar Gadale & Shri Girish Agrawal

penalty proceedings u/s 271(1)(c) of the I.T.Act. Leading Age Developers Pvt. Ltd., AY 2011-12 3. We first take up appeal in ITA No.1113/Mum/2024. Brief facts of the case are that assessee is a company engaged in the business of real estate. Assessee filed its return of income on 20.09.2011 reporting a total income as loss

ACIT CIRCLE-2(1)(1), MUMBAI vs. M/S BOMBAY DYEING & MANUFACTURING CO. LTD. , MUMBAI

Bench: Shri Aby T Varkey () & Shri Om Prakash Kant () - A.Y 2014-15 - A.Y 2015-16 Asst. Commissioner Of M/S Bombay Dyeing & Income-Tax 2(1)(1), Mumbai, Manufacturing Co. Ltd Room No.561, 5Th Floor, Vs. Neville House, Jn Herdia Aayakar Bhavan, M.K. Road, Marg, Ballard Estate, Mumbai-400 020 Mumbai-400 001 Pan No. Aaact 2328 K Appellant Respondent - A.Y 2014-15 - A.Y 2015-16 M/S Bombay Dyeing & Dy. Commissioner Of Income- Manufacturing Co. Ltd Tax 2(1), Mumbai, Room Neville House, Jn Herdia No.561, 5Th Floor, Aayakar Vs Marg, Ballard Estate, Bhavan, M.K. Road, Mumbai- Mumbai-400 001 400 020 Pan No. Aaact 2328 K Appellant Respondent

section 45(2) of the Act. The second issue is regarding issue is regarding computation of quantum of long computation of quantum of long-term capital gain, which has been term capital gain, which has been agitated by the assessee in ground no. 1 of its appeal. ated by the assessee in ground no. 1 of its appeal. While ated