SWARAN NADHAN SALARIA,MUMBAI vs. DCIT CENTRAL CIRCLE 1(2), MUMBAI

In the result all In the result all appeals of the assesses from AY 2014

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

56,660/ income varied as compared to income declared in original return of as compared to income declared in original return of as compared to income declared in original return of income filed on 28/11/2014) income filed on 28/11/2014) . u/s 153A of the 4.1 During the course of course of assessment proceedings u/s 153A of the Act, the Assessing Officer

SWARAN NADHAN SALARIA,MUMBAI vs. DICT CENTRAL CIRCLE 1(2), MUMBAI

In the result all In the result all appeals of the assesses from AY 2014

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

56,660/ income varied as compared to income declared in original return of as compared to income declared in original return of as compared to income declared in original return of income filed on 28/11/2014) income filed on 28/11/2014) . u/s 153A of the 4.1 During the course of course of assessment proceedings u/s 153A of the Act, the Assessing Officer

SWARAN NADHAN SALARIA,MUMBAI vs. DCIT, CENTRAL CIRCLE 1(2), MUMBAI

In the result all appeals of the assesses from AY 2014-15 to AY\n2020-21 are partly allowed

56,660/-(i.e. total\nincome varied as compared to income declared in original return of\nincome filed on 28/11/2014) .\n4.1 During the course of assessment proceedings u/s 153A of the\nAct, the Assessing Officer observed discrepancies/variation in the\nprofit and loss account and balance sheet filed with the return\nunder section 153A vis-à-vis the original return. Notably, variations

SWARAN NADHAN SALARIA,MUMBAI vs. DCIT, CENTRAL CIRCLE 1(2), MUMBAI

In the result all appeals of the assesses from AY 2014-15 to AY\n2020-21 are partly allowed

56,660/-(i.e. total\nincome varied as compared to income declared in original return of\nincome filed on 28/11/2014) .\n4.1 During the course of assessment proceedings u/s 153A of the\nAct, the Assessing Officer observed discrepancies/variation in the\nprofit and loss account and balance sheet filed with the return\nunder section 153A vis-à-vis the original return. Notably, variations

CORNERSTONE ONDEMAND LIMITED ,MUMBAI vs. ACIT(IT)-2(1)(1), MUMBAI

Bench: Shri Amit Shukla, Jm & Ms Padmavathy S, Am

271(1)(c) on the same ground. Therefore our decision in AY 2015- 11 ITA 3747, 3751, 3753, 3752 and 5677/Mum/2024 Cornerstone Ondemand Limited 16 is mutatis mutandis applicable to AY 2016-17 also. Accordingly we direct the AO to delete the penalty for AY 2016-17. ITA No.3753/Mum/2024 – AY 2017-18 12. For AY 2017-18 the assessee filed

CORNERSTONE ONDEMAND LIMITED ,MUMBAI vs. ASSISTANT COMMISSIONER OF INCOME TAX (INTERNATIONAL TAXATION )-2(1)(1), MUMBAI

Bench: Shri Amit Shukla, Jm & Ms Padmavathy S, Am

271(1)(c) on the same ground. Therefore our decision in AY 2015- 11 ITA 3747, 3751, 3753, 3752 and 5677/Mum/2024 Cornerstone Ondemand Limited 16 is mutatis mutandis applicable to AY 2016-17 also. Accordingly we direct the AO to delete the penalty for AY 2016-17. ITA No.3753/Mum/2024 – AY 2017-18 12. For AY 2017-18 the assessee filed

CONNERSTONE ONDEMAND LIMITED,MUMBAI vs. ASSISTANT COMMISSIONER OF INCOME TAX (INTERNATIONAL TAXATION )-2(1)(1), MUMBAI

Bench: Shri Amit Shukla, Jm & Ms Padmavathy S, Am

271(1)(c) on the same ground. Therefore our decision in AY 2015- 11 ITA 3747, 3751, 3753, 3752 and 5677/Mum/2024 Cornerstone Ondemand Limited 16 is mutatis mutandis applicable to AY 2016-17 also. Accordingly we direct the AO to delete the penalty for AY 2016-17. ITA No.3753/Mum/2024 – AY 2017-18 12. For AY 2017-18 the assessee filed

CORNERSTONE ONDEMAND LIMITED ,MUMBAI vs. ASSISTANT COMMISSIONER OF INCOME TAX (INTERNATIONAL TAXATION )-2(1)(1), MUMBAI

Bench: Shri Amit Shukla, Jm & Ms Padmavathy S, Am

271(1)(c) on the same ground. Therefore our decision in AY 2015- 11 ITA 3747, 3751, 3753, 3752 and 5677/Mum/2024 Cornerstone Ondemand Limited 16 is mutatis mutandis applicable to AY 2016-17 also. Accordingly we direct the AO to delete the penalty for AY 2016-17. ITA No.3753/Mum/2024 – AY 2017-18 12. For AY 2017-18 the assessee filed

CORNERSTONE ONDEMAND LIMITED ,MUMBAI vs. ASSISTANT COMMISSIONER OF INCOME TAX (INTERNATIONAL TAXATION )-291)(1), MUMBAI

Bench: Shri Amit Shukla, Jm & Ms Padmavathy S, Am

271(1)(c) on the same ground. Therefore our decision in AY 2015- 11 ITA 3747, 3751, 3753, 3752 and 5677/Mum/2024 Cornerstone Ondemand Limited 16 is mutatis mutandis applicable to AY 2016-17 also. Accordingly we direct the AO to delete the penalty for AY 2016-17. ITA No.3753/Mum/2024 – AY 2017-18 12. For AY 2017-18 the assessee filed

SWARAN NADHAN SALARIA,MUMBAI vs. DCIT CENTRAL CIRCLE 1(2), MUMBAI

56,660/-(i.e. total\nincome varied as compared to income declared in original return of\nincome filed on 28/11/2014) .\n4.1 During the course of assessment proceedings u/s 153A of the\nAct, the Assessing Officer observed discrepancies/variation in the\nprofit and loss account and balance sheet filed with the return\nunder section 153A vis-à-vis the original return. Notably, variations

SMT SURUCHI SATISH SARMALKAR ,MUMBAI vs. ITO WARD-32(1)(1), MUMBAI

In the result, the appeal filed by the assessee stands allowed

Bench: Shri Sandeep Gosain& Shri Om Prakash Kant

271(1)(c) of the Act which are not found relevant to decide the issue before us. Only the decision of Co-ordinate Bench of Bombay Tribunal in the case of Alrameez Construction (P.) Ltd. v. CIT/NFAC [2023] 152 taxmann.com 382/202 ITD 379 (Mumbai - Trib.) is found to be in the context of penalty under Section 270A

DINESH SUNDERJI SHAH,MUMBAI vs. ASSESSING OFFICER, NFAC, DELHI

In the result both the appeals are allowed

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

56(2)(X)(b) of the Act also do not apply. 015. Accordingly, solitary ground raised in this appeal is allowed and the learned Assessing Officer is directed to allow carry forward of capital loss of ₹3,39,60,946/- to the assessee. 016. In the result, ITA No.275/Mum/2024 is allowed. 017. ITA No. 274/Mum/2024, is filed by the assessee

DINESH SUNDERJI SHAH,MUMBAI vs. ASSESSING OFFICER, WARD-15(1)(1), MUMBAI

In the result both the appeals are allowed

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

56(2)(X)(b) of the Act also do not apply. 015. Accordingly, solitary ground raised in this appeal is allowed and the learned Assessing Officer is directed to allow carry forward of capital loss of ₹3,39,60,946/- to the assessee. 016. In the result, ITA No.275/Mum/2024 is allowed. 017. ITA No. 274/Mum/2024, is filed by the assessee

CIDCO EMPLOYEES CO-OP. CREDIT SOCIETY LTD,NAVI MUMBAI vs. WARD 28(1)(3), NAVI MUMBAI

In the result, the assessee‟s appeal ITA NO

Bench: SHRI GAGAN GOYAL (Accountant Member), SHRI SUNIL KUMAR SINGH (Judicial Member)

Penalty proceedings u/s. 271(1)(C) of the Act were separately initiated for furnishing inaccurate particulars of income. 2. (ii) Aggrieved by the assessment order, assessee preferred an appeal before learned CIT(A), who confirmed assessment order, holding that the assessee is neither a primary agricultural credit society nor primary agricultural development bank but is a co–operative bank

CIDCO EMPLOYEES CO-OP. CREDIT SOCIETY LTD,NAVI MUMBAI vs. WARD 28(1)(3), NAVI MUMBAI

In the result, the assessee‟s appeal ITA NO

Bench: SHRI GAGAN GOYAL (Accountant Member), SHRI SUNIL KUMAR SINGH (Judicial Member)

Penalty proceedings u/s. 271(1)(C) of the Act were separately initiated for furnishing inaccurate particulars of income. 2. (ii) Aggrieved by the assessment order, assessee preferred an appeal before learned CIT(A), who confirmed assessment order, holding that the assessee is neither a primary agricultural credit society nor primary agricultural development bank but is a co–operative bank

CIDCO EMPLOYEES CO-OP. CREDIT SOCIETY LTD,NAVI MUMBAI vs. WARD 28(1)(3), NAVI MUMBAI

In the result, the assessee‟s appeal ITA NO

Bench: SHRI GAGAN GOYAL (Accountant Member), SHRI SUNIL KUMAR SINGH (Judicial Member)

Penalty proceedings u/s. 271(1)(C) of the Act were separately initiated for furnishing inaccurate particulars of income. 2. (ii) Aggrieved by the assessment order, assessee preferred an appeal before learned CIT(A), who confirmed assessment order, holding that the assessee is neither a primary agricultural credit society nor primary agricultural development bank but is a co–operative bank

SHRI NARENDRA S SHAH,MUM vs. DCIT, CC-2(2),, MUM

Bench: Shri Vikas Awasthy () & Shri Om Prakash Kant ()

x Act, 1961 (in short ‘the Act’) dated 25.03.2014. In the reasons recorded, the Assessing Officer dated 25.03.2014. In the reasons recorded, the Assessing Officer dated 25.03.2014. In the reasons recorded, the Assessing Officer noted that tax was not deducted by the assessee on the interest noted that tax was not deducted by the assessee on the interest noted that

DCIT, CC-2(2),, MUM vs. SHRI NARENDRA S SHAH, MUMBAI

Bench: Shri Vikas Awasthy () & Shri Om Prakash Kant ()

x Act, 1961 (in short ‘the Act’) dated 25.03.2014. In the reasons recorded, the Assessing Officer dated 25.03.2014. In the reasons recorded, the Assessing Officer dated 25.03.2014. In the reasons recorded, the Assessing Officer noted that tax was not deducted by the assessee on the interest noted that tax was not deducted by the assessee on the interest noted that