DCIT, CENTRAL CIRCLE 7(1), MUMBAI vs. BALAJI BULLIONS AND COMMODITIES INDIA PRIVATE LIMITED, MUMBAI

The appeal of the assessee is dismissed whereas the\nappeal of the Revenue is allowed for statistical purposes

reassessment proceedings based on information from the Investigation Wing, alleging the assessee engaged in bogus purchases and accommodation entries during the demonetization

MANISHA ANIL SHARMA,VASHI, NAVI MUMBAI vs. THE INCOME TAX OFFICER (INT TAX) - 4 (2) (1), MUMBAI

Accordingly, Ground No.1 raised by the Assessee is allowed while

Bench: SHRI PRASHANT MAHARISHI, ACCOUNTANT MEMBER SHRI RAHUL CHAUDHARY (Judicial Member)

reassessment proceedings were initiated in the case of the Appellant for the reason that cash deposits of INR 9,30,000/- were made in the bank account maintained by the Appellant with Saraswat Cooperative Bank Ltd during the demonetization

ARYAN NAZIM JIVANI (LEAGAL HEIR OF NAZIM NOORDIN JIVANI) PROP.JIVANI WINE MART,MUMBAI vs. INCOME TAX OFFICER, PIRAMAL CHAMBER

In the result, the appeal by the assessee is allowed

Bench: Shri Vikram Singh Yadavshri Sandeep Singh Karhailaryan Nazim Jivani (Legal Heir Of Nazim Noordin Jivani), B-8, Ferreira Mansion, Sitladevi Temple Road, Mahim, Mumbai - 400016 ............... Appellant Pan: Aacpj1522G V/S Income Tax Officer, Ward – 20(2)(1), Piramal Chamber, Dr. S.S. Rao Marg, ……………… Respondent Parel, Mumbai - 400021

demonetization period. 4. We have considered the submissions of both sides and perused the material available on record. Pursuant to the information available that the assessee had made a cash deposit of Rs. 60,02,000/- during the year under consideration, notice under section 148 of the Act was issued on 24.12.2019, and reassessment

INCOME TAX OFFICER-28(3)(1), MUMBAI, NAVI MUMBAI vs. VINOD BHANJI SHAH, VASHI, NAVI MUMBAI

In the result, the Cross Objection by the assessee is allowed, while the Revenue’s appeal is dismissed

Bench: Shri Sandeep Singh Karhailshri Bijayananda Pruseth

demonetization period, and that the failed to submit any cogent evidence or satisfactory explanation regarding the availability and source of cash in hand? (iv) Whether on the facts and in the circumstances of the case and in law, the Ld. CIT (A), NFAC has erred in holding that the Assessing Officer exceeded the scope of reassessment

MAHAVIR SAMPATRAJ JAIN ,MUMBAI vs. INCOME TAX OFFICER WARD 20(2)(2), MUMBAI

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

Bench: Shri Aby T Varkey & Shri Amarjit Singhmahavir Sampatraj Jain Vs. Ito, Ward 20(2)(2) M/S Makker & Co. Piramal Chamber Shop No. 7B Shamji Lalbaug, Morarji Bldg Champsi Mumbai - 400012 Bhimji Road, Mazgaon Mumbai – 400010 स्थायी लेखा सं./जीआइआर सं./Pan/Gir No: Aadpj0382R Appellant .. Respondent Appellant By : Amit Lad Respondent By : Bharat Andhale Date Of Hearing 13.03.2023 Date Of Pronouncement 17.03.2023 आदेश / O R D E R Per Amarjit Singh (Am):

Demonetization. The assessee had not filed return of income u/s 139(1) of the Act, therefore notice u/s 142(1) of the Act was issued on 04.12.2017 and 10.03.2018. However, the assesse has not filed any return of income in response to the notice issued by the assessing officer. Therefore, case of the assessee was reopened

BALAJI BULLIONS AND COMMODITIES INDIA PRIVATE LIMITED,MUMBAI vs. DCIT CENTRAL CIRCLE 7(1), MUMBAI

The appeal of the Revenue is allowed for statistical purposes

Bench: Shri Om Prakash Kant () & Ms. Kavitha Rajagopal () Assessment Year: 2017-18

reassessment proceedings, the Assessing Officer called for and examined the details of the assessee’s Assessing Officer called for and examined the details of the assessee’s Assessing Officer called for and examined the details of the assessee’s purchases and sales as reflected in the books of account. Upon such purchases and sales as reflected in the books

DCIT, CC - 2(4), MUMBAI vs. MISHAL NICKUNJ SHAH SHRI. L/H. OF LATE NICKUNJ GUNVANTRAI SHAH , MUMBAI

Accordingly, grounds raised by the revenue are dismissed

Bench: Shri Amit Shukla, Hon'Ble & Shri S. Rifaur Rahman, Hon'Ble

reassessment of concluded assessment in garb of invoking provisions of section 153A. Gurinder Singh Bawa vs DCIT [2012]28 Where in search assessment u/s 153A, all taxmann.com328 (Mumbai Tribunal) assessments pertaining to six immediately preceeding assessment years were complete, assessing officer cannot make any addition there under unless there is any incriminating material recovered during search ACIT vs RPD Earth

DCIT, CC - 2(4), MUMBAI vs. MISHAL NICKUNJ SHAH SHRI. L/H. OF LATE NICKUNJ GUNVANTRAI SHAH , MUMBAI

Accordingly, grounds raised by the revenue are dismissed

Bench: Shri Amit Shukla, Hon'Ble & Shri S. Rifaur Rahman, Hon'Ble

reassessment of concluded assessment in garb of invoking provisions of section 153A. Gurinder Singh Bawa vs DCIT [2012]28 Where in search assessment u/s 153A, all taxmann.com328 (Mumbai Tribunal) assessments pertaining to six immediately preceeding assessment years were complete, assessing officer cannot make any addition there under unless there is any incriminating material recovered during search ACIT vs RPD Earth

ITO-23(3)(6).MUMBAI, MUMBAI vs. RAJESHWAR BULLION TRADING , MUMBAI

In the result, the appeal is dismissed

Bench: Shri Saktijit Dey & Shri Makarand Vasant Mahadeokarm/S. Rajeshwar Bullion Trading Income Tax Officer 2Nd Floor, 61/63, Ward 23(3)(6) Har Narayan Building, Vs. Mumbai Zaveri Bazar, Mumbai-400 002 Pan/Gir No. Aasfr 7707 D (Assessee) : (Revenue) & Income Tax Officer M/S. Rajeshwar Bullion Trading Ward 23(3)(6) 2Nd Floor, 61/63, Mumbai Vs. Har Narayan Building, Zaveri Bazar, Mumbai-400 002 Pan/Gir No. Aasfr 7707 D (Revenue) : (Assessee) Appellant By : Shri Dhran Gandhi Respondent By : Shri Annavaram Kosuri (Sr. Ar) Date Of Hearing : 16.02.2026 Date Of Pronouncement : 20.02.2026 O R D E R Per Saktijit Dey: The Captioned Appeals, One By The Assessee & The Other By The Revenue Arise Out Of Two Separate Orders Passed By National Faceless Appeal Centre (‘Nfac’ For Short), Delhi, Pertaining To The Very Same Assessment Year (A.Y. For Short) 2017-18. However, While Assessee’S Appeal Arises Out Of Original Assessment Proceeding, The Revenue’S Appeal Arises Out Of Reassessment Proceeding U/S. 147 Of The Act. M/S. Rajeshwar Bullion Trading 2. At The Outset, We Will Deal With Assessee’S Appeal, Being Ita No.5754/Mum/2025. In Ground Nos. 1 & 2, The Assessee Has Challenged The Decision Of Ld. First Appellate Authority In Remanding The Issue Back To The Assessing Officer (A.O. For Short) For De Novo Adjudication. Whereas, In Ground No. 3, The Assessee Has Challenged The Non-Adjudication Of The Ground Relating To The Applicability Of Section 115Bbe Of The Act. Since, The Issues Are Overlapping, We Will Deal With Them Concurrently.

reassessment proceeding u/s. 147 of the Act. M/s. Rajeshwar Bullion Trading 2. At the outset, we will deal with assessee’s appeal, being ITA No.5754/Mum/2025. In ground nos. 1 & 2, the assessee has challenged the decision of ld. First appellate authority in remanding the issue back to the Assessing Officer (A.O. for short) for de novo adjudication. Whereas, in ground

M/S. RAJESHWAR BULLION TRADING ,MUMBAI vs. ASST. CIT, CIRCLE 23(3), MUMBAI

In the result, the appeal is dismissed

Bench: Shri Saktijit Dey & Shri Makarand Vasant Mahadeokarm/S. Rajeshwar Bullion Trading Income Tax Officer 2Nd Floor, 61/63, Ward 23(3)(6) Har Narayan Building, Vs. Mumbai Zaveri Bazar, Mumbai-400 002 Pan/Gir No. Aasfr 7707 D (Assessee) : (Revenue) & Income Tax Officer M/S. Rajeshwar Bullion Trading Ward 23(3)(6) 2Nd Floor, 61/63, Mumbai Vs. Har Narayan Building, Zaveri Bazar, Mumbai-400 002 Pan/Gir No. Aasfr 7707 D (Revenue) : (Assessee) Appellant By : Shri Dhran Gandhi Respondent By : Shri Annavaram Kosuri (Sr. Ar) Date Of Hearing : 16.02.2026 Date Of Pronouncement : 20.02.2026 O R D E R Per Saktijit Dey: The Captioned Appeals, One By The Assessee & The Other By The Revenue Arise Out Of Two Separate Orders Passed By National Faceless Appeal Centre (‘Nfac’ For Short), Delhi, Pertaining To The Very Same Assessment Year (A.Y. For Short) 2017-18. However, While Assessee’S Appeal Arises Out Of Original Assessment Proceeding, The Revenue’S Appeal Arises Out Of Reassessment Proceeding U/S. 147 Of The Act. M/S. Rajeshwar Bullion Trading 2. At The Outset, We Will Deal With Assessee’S Appeal, Being Ita No.5754/Mum/2025. In Ground Nos. 1 & 2, The Assessee Has Challenged The Decision Of Ld. First Appellate Authority In Remanding The Issue Back To The Assessing Officer (A.O. For Short) For De Novo Adjudication. Whereas, In Ground No. 3, The Assessee Has Challenged The Non-Adjudication Of The Ground Relating To The Applicability Of Section 115Bbe Of The Act. Since, The Issues Are Overlapping, We Will Deal With Them Concurrently.

reassessment proceeding u/s. 147 of the Act. M/s. Rajeshwar Bullion Trading 2. At the outset, we will deal with assessee’s appeal, being ITA No.5754/Mum/2025. In ground nos. 1 & 2, the assessee has challenged the decision of ld. First appellate authority in remanding the issue back to the Assessing Officer (A.O. for short) for de novo adjudication. Whereas, in ground

ASST. COMMISSIONER OF INCOME TAX CENTRAL CIRCLE 2(3),, MUMBAI vs. FA CONSTRUCTION , MUMBAI

In the result, all the three appeals of the Revenue are In the result, all the three appeals of the Revenue are In the result, all the three appeals of the Revenue are dismissed

Bench: Shri Sandeep Gosain () & Shri Om Prakash Kant ()

reassessment proceedings based on information regarding high based on information regarding high-value cash wit value cash withdrawals received via the INSIGHT Portal. The assessment was completed received via the INSIGHT Portal. The assessment was completed received via the INSIGHT Portal. The assessment was completed ex-parte under Section 144, treating the cash withdrawals as parte under Section 144, treating

DCIT, CENTRAL CIRCLE 7(1), MUMBAI vs. JORSS BULLION PRIVATE LIMITED, MUMBAI

Reassessment limitation effect of Section 149(1)(b) - period\nextended where alleged escaped income exceeds prescribed\nlimit Section 149 does not override provisions of section 147-\nnotice after four years failure to disclose material facts\nnecessary for assessment must exist.\"\n(ii) Novo Nordisk India P. Ltd. V/s. DCIT[2018] 95 taxmann.com\n225 Karnataka. The catch-note is reproduced

JORSS BULLION PVT LTD,MUMBAI vs. DY COMMISSIONER OF INCOME TAX -CENTRAL CIRCLE 7(1), MUMBAI

Reassessment limitation effect of Section 149(1)(b) - period\nextended where alleged escaped income exceeds prescribed\nlimit Section 149 does not override provisions of section 147-\nnotice after four years failure to disclose material facts\nnecessary for assessment must exist.\"\n(ii) Novo Nordisk India P. Ltd. V/s. DCIT[2018] 95 taxmann.com\n225 Karnataka. The catch-note is reproduced

GARIMA MRITYUNJAY SINGH,MUMBAI vs. ITO WD-19(1)(1), MUMBAI

In the result, appeal filed by assessee stands allowed

demonetized cash during the period\n09/11/2016 to 31/12/2016. The Ld.AO thus, treated\nRs.1,35,28,860/- as unexplained money u/s 69A of the Act.\nAggrieved by the order of the Ld.AO, assessee preferred appeal\nbefore Ld.CIT(A).\n2. 1. Before Ld.CIT(A), assessee submitted that, he is running a\npetrol pump and his main sales are against cash

K M TEXTILES EXPORT PRIVATE LIMITED ,MUMBAI vs. INCOME TAX OFFICER WARD 10(1)(1), MUMBAI

In the result, appeal of the assessee is allowed and appeal filed by the Revenue is dismissed

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

reassessment proceedings, the Assessing Officer noticed that cash aggregating to ₹16,10,995/- had been deposited in Kotak Mahindra Bank during the demonetisation period between 09.11.2016 and 30.12.2016. However, instead of confining the enquiry to the said period or to the said quantum, the Assessing Officer proceeded to examine cash deposits in all bank accounts maintained by the assessee throughout

INCOME TAX OFFICER - 10(1)(1), MUMBAI, MUMBAI vs. K M TEXTILES EXPORTS PVT. LTD., MUMBAI

In the result, appeal of the assessee is allowed and appeal filed by the Revenue is dismissed

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

reassessment proceedings, the Assessing Officer noticed that cash aggregating to ₹16,10,995/- had been deposited in Kotak Mahindra Bank during the demonetisation period between 09.11.2016 and 30.12.2016. However, instead of confining the enquiry to the said period or to the said quantum, the Assessing Officer proceeded to examine cash deposits in all bank accounts maintained by the assessee throughout

WINES 2000 AND COMPANY,MUMBAI vs. DCIT CIRCLE 27(3), NAVI MUMBAI

In the result, the appeal is allowed for statistical\npurposes

demonetization period. The contention of the\nappellant remained unjustified and unsubstantiated. Hence, the Assessment\nOrder is upheld the ground is noted as disallowed. In view of the above\ndiscussion, it is held that the source of cash deposit done by the appellant\nremain unexplained and needs to be taxed in the hands of appellant.\nTherefore, the undersigned sees no reason

HASU EXPORTERS,MUMBAI vs. PR. COMM OF INCOME TAX-17, MUMBAI

In the result, it is held that the initiation of proceedings under section 263 on the issue of LTCG is bad and uncalled for

Bench: Shri Prashant Maharishi & Shri Pavan Kumar Gadalehasu Exporters Vs. Pr. Cit-17 Room No. 39, 1St Floor Room No. 120, 1St 94, Kansara Chawl, Floor, Kautilya Kalbadevi Road, Bhavan, C-41 To 43, G Mumbai – 400002. Block, Bkc, Bandra (E), Mumbai – 400051. "थायी लेखा सं./जीआइआर सं./Pan/Gir No. : Aabfh7119J Appellant .. Respondent Appellant By : Shri. Himanshu Gandhi.Ar Respondent By : Smt.Madhumalti Ghosh.Cit Dr Date Of Hearing 14.11.2022 Date Of Pronouncement 24.11.2022 आदेश / O R D E R Per Pavan Kumar Gadale Jm: The Assessee Has Filed The Appeal Against The Order Passed By The Pr. Commissioner Of Income Tax(Pr.Cit) -17, Mumbai Passed U/S 263 Of The Act.

demonetization and pass the assessment order de-novo after due verifications. Needless to say that the Assessing Officer shall give the assessee reasonable opportunity of being heard and pass a speaking order after taking into consideration the explanation and supporting evidence submitted by the assessee. 5. Aggrieved by order of the Pr.CIT, the assessee has filed an appeal with