M/S SANJEEV CHIRANIA HUF,MUMBAI vs. INCOME TAX OFFICER, WARD-28(3)(1) , MUMBAI

In the result, the appeal of the assessee is allowed

Bench: Shri Om Prakash Kant () & Shri Sandeep Singh Karhail () Assessment Year: 2015-16 M/S Sanjeev Chirania Huf, Ito-28(3)(1), 301, Sona Chambers, 507/509 Tower No. 6, Vashi Railway Vs. Jss Road, Chira Bazar, Station Commercial Marine Lines – East, Complex, Vashi, Mumbai-400 002. Navi Mumbai-400703 Pan No. Aarhs 4527 D Appellant Respondent Assessee By : Ms. Ritu Kamalkishor, Ar Revenue By : Mr. Milind S. Chavan, Cit-Dr : Date Of Hearing 23/03/2023 : Date Of Pronouncement 31/03/2023 Order

271 , section section 271A, 22 [ section 271A section 271AA,] section 271AA 271B 23[, section 271BA section 271BA], 24 [ section 271BB section 271BB,] section 271C , 25[ section 271CA , ] section section 271D, section 271D section 271F, 27 271E, 26 [ 27 [ section 271FA,] 28 [ section 271FB,] 29 [ section 271G section 271G,]] clause (c) or clause (d) of sub (c) or clause (d

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.

272A(1)(d) 271(1)(b) Original Order Passed Date of 28.09.2021 28.01.2022 27.01.2022 31.01.2022 Original Order Income Income assessed at Penalty of Penalty of Rs. Penalty of Rs. Assessed / Rs. 1,67,77,000/- Rs. 5,000/- 30,000/- 50,000/- Penalty Levied Date of 18.09.2025 26.09.2025 26.09.2025 26.09.2025 CIT(A) Order Result before Appeal dismissed Appeal Appeal Appeal

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.

272A(1)(d) 271(1)(b) Original Order Passed Date of 28.09.2021 28.01.2022 27.01.2022 31.01.2022 Original Order Income Income assessed at Penalty of Penalty of Rs. Penalty of Rs. Assessed / Rs. 1,67,77,000/- Rs. 5,000/- 30,000/- 50,000/- Penalty Levied Date of 18.09.2025 26.09.2025 26.09.2025 26.09.2025 CIT(A) Order Result before Appeal dismissed Appeal Appeal Appeal

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.

272A(1)(d) 271(1)(b) Original Order Passed Date of 28.09.2021 28.01.2022 27.01.2022 31.01.2022 Original Order Income Income assessed at Penalty of Penalty of Rs. Penalty of Rs. Assessed / Rs. 1,67,77,000/- Rs. 5,000/- 30,000/- 50,000/- Penalty Levied Date of 18.09.2025 26.09.2025 26.09.2025 26.09.2025 CIT(A) Order Result before Appeal dismissed Appeal Appeal Appeal

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.

272A(1)(d) 271(1)(b) Original Order Passed Date of 28.09.2021 28.01.2022 27.01.2022 31.01.2022 Original Order Income Income assessed at Penalty of Penalty of Rs. Penalty of Rs. Assessed / Rs. 1,67,77,000/- Rs. 5,000/- 30,000/- 50,000/- Penalty Levied Date of 18.09.2025 26.09.2025 26.09.2025 26.09.2025 CIT(A) Order Result before Appeal dismissed Appeal Appeal Appeal

ANAND RATHI SHARE AND STOCK BROKERS LIMITED ,MUMBAI vs. DEPUTY COMMISSIONER OF INCOME TAX CENTRAL CIRCLE 5(1), MUMBAI

In the result, all the appeals of the assessee are allowed

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

u/s 271FA of the Act for delay in filing the A of the Act for delay in filing the statement of foreign accounts transaction. For ready reference, statement of foreign accounts transaction. For ready reference, statement of foreign accounts transaction. For ready reference, section 271FA of the Act is reproduced as under: e Act is reproduced as under: “[Penalty

ANAND RATHI SHARE AND STOCK BROKERS LIMITED ,MUMBAI vs. DY. COMMISSIONER OF INCOME TAX CENTRAL CIRCLE 5(1), MUMBAI

In the result, all the appeals of the assessee are allowed

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

u/s 271FA of the Act for delay in filing the A of the Act for delay in filing the statement of foreign accounts transaction. For ready reference, statement of foreign accounts transaction. For ready reference, statement of foreign accounts transaction. For ready reference, section 271FA of the Act is reproduced as under: e Act is reproduced as under: “[Penalty

ANAND RATHI SHARE AND STOCK BROKERS LIMITED ,MUMBAI vs. DEPUTY COMMISSIONER OF INCOME TAX CENTRAL CIRCLE 5(1), MUMBAI

In the result, all the appeals of the assessee are allowed

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

u/s 271FA of the Act for delay in filing the A of the Act for delay in filing the statement of foreign accounts transaction. For ready reference, statement of foreign accounts transaction. For ready reference, statement of foreign accounts transaction. For ready reference, section 271FA of the Act is reproduced as under: e Act is reproduced as under: “[Penalty

ANAND RATHI SHARE AND STOCK BROKERS LIMITED,MUMBAI vs. DEPUTY COMMISSIONER OF INCOME TAX CENTRAL CIRCLE 5(1), MUMBAI

In the result, all the appeals of the assessee are allowed

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

u/s 271FA of the Act for delay in filing the A of the Act for delay in filing the statement of foreign accounts transaction. For ready reference, statement of foreign accounts transaction. For ready reference, statement of foreign accounts transaction. For ready reference, section 271FA of the Act is reproduced as under: e Act is reproduced as under: “[Penalty

WEST COAST FINE FOODS (INDIA) PRIVATE LIMITED ,ANDHERI, MUMBAI vs. DEPUTY COMMISSIONER OF INCOME TAX 13(3)(2), AAYKAR BHAWAN, MUMBAI

Appeal of the assessee is allowed

Bench: Justice (Retd.) C V Bhadang & Ms Padmavathy S, Am

u/s 44AB of the Act, by the specified date for the A.Y. 2017-18, despite the appellant having gross receipts of Rs. 212,51,06,142/-. Consequently, the imposition of the penalty of Rs. 1,50,000/- under section 271B is in order, and I find no infirmity in the same.” 4. The ld. AR submitted that

KOTAK MAHINDRA BANK LIMITED,MUMBAI vs. ADDL. DIRECTOR OF INCOME TAX (INV), UNIT 7 , MUMBAI

The appeal of the assessee is allowed

Bench: Vikas Awasthy () & Ms. Padmavathy S. ()

u/s 131 of the ACT and the provisions of section 272A(l)(c) are not attracted and AO be further directed to delete the penalty of Rs. 10,0007-. 5. Without prejudice to the above, since the Appellant has not acted deliberately in defiance of law nor was guilty of conduct contumacious or dishonest, or acted in conscious disregard

JIGNESH SURESH SHAH,MUMBAI vs. INCOME TAX DEPARTMENT INCOME TAX OFFICER WARD,1,, THANE

Bench: Shri Narender Kumar Choudhry, Jm & Ms Padmavathy S, Am

u/s 271B of the income tax act, 1961 as there was reasonable cause and circumstances beyond applicant's control for the said failure as explained above considering section 2738 of the act.” 7. We heard the ld DR and perused the material on record. The AO reopened the assessment for the reason that the turnover of the assessee as declared

VISEN INDUSTRIES LIMITED ,MUMBAI vs. DEPUTY COMMISSIONER OF INCOME TAX (TRANSFER PRICING )-4(3)(1), MUMBAI

Appeal of the assessee is allowed

Bench: Shri Anikesh Banerjee, Jm & Ms Padmavathy S, Am

u/s 271 G of the IT Act levied by the TPO is confirmed. Accordingly, the grounds of appeal are Dismissed.” 3. The ld. AR submitted that the assessee though did not respond to the first two notices issued by the TPO subsequently responded to the notices and filed all the relevant details before the TPO. The ld. AR further submitted

KRISHNA FASHION WORLD,CHEMBUR, MUMBAI vs. ITO, MUMBAI

In the result, all the four appeals are hereby dismissed

Bench: Shri Anikesh Banerjee & Smt. Renu Jauhriआयकर अपील सुं./Ita No. 3270 To 3273/Mum/2024 (नििाारण वर्ा / Assessment Year: 2010-11 To 2013-14) M/S. Krishna Fashion V/S. Income Tax Officer World बिाम Income Tax Officer, Ward 803/804, T-6, Godrej 22(2)(1), Room No. 312, Prime Colony, Sahakar Piramal Chambers, Lalbaug Nagar No.2, Shell Colony, 400012 Chembur, Mumbai 400071 स्थायी लेखा सं./जीआइआर सं./Pan/Gir No: Aajfk2799R Appellant/अपीलार्थी .. Respondent/प्रनिवादी निर्ााररती की ओर से /Assessee By: None राजस्व की ओर से /Revenue By: Shri Ritesh Misra, Cit Dr A/W Shri Hemanshu Joshi, Sr Dr स िवाई की िारीख / Date Of Hearing 10.07.2025 घोर्णा की िारीख/Date Of Pronouncement 22.07.2025

272A(1)(c), while framing assessment and passing order dated 15.03.2016 under section 143(3) read with section 147 of the I.T. Act, 1961. The Appellant craves leave to add, amend, alter, modify and delete any of the above ground.” Ground No 1: Illegal Assumption Of Jurisdiction a) In the facts and circumstances of the case, National Faceless Appeal Centre

MS. KRISHNA FASHION WORLD,CHEMBUR vs. INCOME TAX OFFICER, MUMBAI

In the result, all the four appeals are hereby dismissed

Bench: Shri Anikesh Banerjee & Smt. Renu Jauhriआयकर अपील सुं./Ita No. 3270 To 3273/Mum/2024 (नििाारण वर्ा / Assessment Year: 2010-11 To 2013-14) M/S. Krishna Fashion V/S. Income Tax Officer World बिाम Income Tax Officer, Ward 803/804, T-6, Godrej 22(2)(1), Room No. 312, Prime Colony, Sahakar Piramal Chambers, Lalbaug Nagar No.2, Shell Colony, 400012 Chembur, Mumbai 400071 स्थायी लेखा सं./जीआइआर सं./Pan/Gir No: Aajfk2799R Appellant/अपीलार्थी .. Respondent/प्रनिवादी निर्ााररती की ओर से /Assessee By: None राजस्व की ओर से /Revenue By: Shri Ritesh Misra, Cit Dr A/W Shri Hemanshu Joshi, Sr Dr स िवाई की िारीख / Date Of Hearing 10.07.2025 घोर्णा की िारीख/Date Of Pronouncement 22.07.2025

272A(1)(c), while framing assessment and passing order dated 15.03.2016 under section 143(3) read with section 147 of the I.T. Act, 1961. The Appellant craves leave to add, amend, alter, modify and delete any of the above ground.” Ground No 1: Illegal Assumption Of Jurisdiction a) In the facts and circumstances of the case, National Faceless Appeal Centre

KRISHNA FASHION WORLD,CHEMBUR, MUMBAI vs. ITO, MUMBAI

In the result, all the four appeals are hereby dismissed

Bench: Shri Anikesh Banerjee & Smt. Renu Jauhriआयकर अपील सुं./Ita No. 3270 To 3273/Mum/2024 (नििाारण वर्ा / Assessment Year: 2010-11 To 2013-14) M/S. Krishna Fashion V/S. Income Tax Officer World बिाम Income Tax Officer, Ward 803/804, T-6, Godrej 22(2)(1), Room No. 312, Prime Colony, Sahakar Piramal Chambers, Lalbaug Nagar No.2, Shell Colony, 400012 Chembur, Mumbai 400071 स्थायी लेखा सं./जीआइआर सं./Pan/Gir No: Aajfk2799R Appellant/अपीलार्थी .. Respondent/प्रनिवादी निर्ााररती की ओर से /Assessee By: None राजस्व की ओर से /Revenue By: Shri Ritesh Misra, Cit Dr A/W Shri Hemanshu Joshi, Sr Dr स िवाई की िारीख / Date Of Hearing 10.07.2025 घोर्णा की िारीख/Date Of Pronouncement 22.07.2025

272A(1)(c), while framing assessment and passing order dated 15.03.2016 under section 143(3) read with section 147 of the I.T. Act, 1961. The Appellant craves leave to add, amend, alter, modify and delete any of the above ground.” Ground No 1: Illegal Assumption Of Jurisdiction a) In the facts and circumstances of the case, National Faceless Appeal Centre

SHAMJI KANJI ZARU,ANJAR vs. DCIT, CENTRAL CIRCLE-6(4), MUMBAI, MUMBAI

In the result, all the appeals filed by the assessee are stands allowed

Bench: Shri Sandeep Gosain & Shri Arun Khodpia

271(1)(b) of the Act is totally unjustified on facts as also in law may kindly be deleted. 3 Your Honour's appellant craves leave to add, to amend, alter, or withdraw any or more grounds of appeal on or before the hearing of appeal. 3. The only effective ground raised by the assessee in the present appeal

SHAMJI KANJI ZARU,ANJAR vs. DCIT, CENTRAL CIRCLE-6(4), MUMBAI, MUMBAI

In the result, all the appeals filed by the assessee are stands allowed

Bench: Shri Sandeep Gosain & Shri Arun Khodpia

271(1)(b) of the Act is totally unjustified on facts as also in law may kindly be deleted. 3 Your Honour's appellant craves leave to add, to amend, alter, or withdraw any or more grounds of appeal on or before the hearing of appeal. 3. The only effective ground raised by the assessee in the present appeal

SHAMJI KANJI ZARU,ANJAR vs. DCIT, CENTRAL CIRCLE-6(4), MUMBAI, MUMBAI

In the result, all the appeals filed by the assessee are stands allowed

Bench: Shri Sandeep Gosain & Shri Arun Khodpia

271(1)(b) of the Act is totally unjustified on facts as also in law may kindly be deleted. 3 Your Honour's appellant craves leave to add, to amend, alter, or withdraw any or more grounds of appeal on or before the hearing of appeal. 3. The only effective ground raised by the assessee in the present appeal