JAYSHREE CHANDRASINGH KABALI,MUMBAI vs. DCIT CIRCLE 27 (1), MUMBAI

In the result, both the stay petitions of the assessee are dismissed and both the appeals are allowed for statistical purposes

Bench: Shri Saktijit Dey, Hon'Ble & Shri Girish Agrawal

penalty imposed thereafter, in respect of reassessment order passed u/s.147 r.w.s. 144 and penalty order u/s. 271AAC(1). Demand raised

RAVI NIRMAN NIGAM LIMITED,MUMBAI vs. CIRCLE -13(3)(1), MUMBAI

In the result, appeal of the assessee is allowed

reassessment, the penalty proceedings should not survive.", "held": "The Tribunal held that the reassessment proceedings were quashed as void ab initio

DCIT CENTRAL CIRCLE-2(4), MUMBAI vs. M/S PATAN SOLAR PVT LTD, MUMBAI

In the result, the appeal filed by the revenue is dismissed

Bench: Shri Baskaran Br & Shir Pavan Kumar Gadaledcit, Vs. M/Spatansolarpvtltd., Central Circle – 2(4) 602, 6Th Floor, Western Room No. 802, 8Th Floor, Edge-I,Western Prathishtha Bhavan, Express Highway, Mk Road, Churchgate, Borivali (E), Mumbai-400020. Mumbai-400066. Pan/Gir No. : Aafcp6744A Appellant .. Respondent Appellant By : Mr. V.K. Chaturvedi.Dr Respondent By : Mr. Rushabh Mehta.Ar Date Of Hearing 09.02.2023 Date Of Pronouncement 15.02.2023 आदेश / O R D E R Per Pavan Kumar Gadale Jm: The Revenue Has Filed The Appeal Against The Order Of The Commissioner Of Income Tax (Appeals)-48, Mumbai Passed U/S 250 Of The Act.The Revenue Has Raised The Following Grounds Of Appeal:

reassessment in pursuance of which penalty is levied, cannot be the subject matter of penalty proceedings. The assessment or reassessment

NATH CAPITAL & FINANCIAL SERVICES LTD.,MUMBAI vs. ITO WARD 1 (2)(3), MUMBAI

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

reassessment in pursuance of which penalty\nis levied, cannot be the subject matter of penalty proceedings.\nThe assessment or reassessment

SUGRABAHEN UMER BHORANIA,MUMBAI vs. WARD 20(3)(1), MUMBAI, PIRAMAL CHAMBERS

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

Bench: Smt. Beena Pillai & Shri Girish Agrawalassessment Year: 2016-17 Sugrabahen Umer Bhorania Vs Income Tax Officer, Ward 6Th Floor, Flat 602, Murga Giran 20(3)(1), Mumbai Chs, Grant Road (E), Mumbai Piramal Chambers, Mumbai 400008 400012 Pan: (Cddpb8620D) Appellant Respondent Present For: Appellant By : Ms. Shruti Kalyanikar-Advocate Respondent By : Shri Arun Kanti Datta, Cit-Dr Date Of Hearing : 24.11.2025 Date Of Pronouncement : 26.11.2025 O R D E R Per Girish Agrawal: This Appeal Filed By The Assessee Is Against The Order Of National Faceless Appeal Centre (Nfac), Delhi Vide Order No. Itba/Nfac/S/250/2025-26/1078510218(1) Dated 15.07.2025 Passed Against The Assessment Order By Income Tax Officer Ward 20(3)(1), Mumbai U/S. 147 R.W.S 144 Of The Income-Tax Act, 1961 (Hereinafter Referred To As The “Act”), Dated 23.09.2024 For Ay 2016-17. 2. Grounds Taken By The Assessee Are Reproduced As Under: “1. On The Facts & In The Circumstances Of The Case & In Law The Hon'Ble Cit(A) Erred In Upholding Penalty Of Rs. 45,10,345/- U/S 271(1)(C) Of The Act & The 2

penalty proceedings so initiated while completing the reassessment proceeding. He levied penalty of Rs. 45,10,345/- being minimum penalty

RAVI NIRMAN NIGAM LIMITED,MUMBAI vs. CIRCLE 13(3)(1), MUMBAI

In the result, appeal of the assessee is allowed

Bench: Shri Satbeer Singh Godara (Jm) & Shri Girish Agrawal (Am)

penalty by submitting that the reassessment proceedings which had been quashed by the Hon’ble ITAT and therefore the penalty

RAVI NIRMAN NIGAM LIMITED,MUMBAI vs. CIRCLE 13(3)(1), MUMBAI

In the result, appeal of the assessee is allowed

Bench: Ms. Kavitha Rajagopal & Shri Girish Agrawal

penalty by submitting that the reassessment proceedings which had been quashed by the Hon’ble ITAT and therefore the penalty

RAVI NIRMAN NIGAM LIMITED,MUMBAI vs. CIRCLE -13(3)(1), MUMBAI

In the result, appeal of the assessee is allowed

Bench: Ms. Kavitha Rajagopal & Shri Girish Agrawal

penalty by submitting that the reassessment proceedings which had been quashed by the Hon’ble ITAT and therefore the penalty

DINESH SOMATMAL DHOKAR,MUMBAI vs. INCOME TAX OFFICER - 19(1)(1), MUMBAI

In the result, both the appeals are partly allowed

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

reassessment order penalty proceedings 04. was initiated and at the time of passing of penalty order the order of the learned

DINESH SOMATMAL DHOKAR,MUMBAI vs. INCOME TAX OFFICER - 19(1)(1), MUMBAI

In the result, both the appeals are partly allowed

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

reassessment order penalty proceedings 04. was initiated and at the time of passing of penalty order the order of the learned

SHYAM KUMAR SADASHIVAN PILLAI,MUMBAI vs. INCOME TAX OFFICER, CIRCLE 27(3)(1), NAVI MUMBAI

In the result, the appeal is allowed

Bench: Ms Padmavathy S, Am & Shri Raj Kumar Chauhan, Jm

penalty by holding that “5. The above explanation of the assessee is considered carefully and found to be not acceptable for the reasons that 1. it becomes apparent that there was no reasonable cause on the part of the assessee for non-compliance to the various notices and letters issued during the reassessment

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.

reassessment and penalty proceedings were initiated and completed in the name of the deceased person without taking steps to bring

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.

reassessment and penalty proceedings were initiated and completed in the name of the deceased person without taking steps to bring

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.

reassessment and penalty proceedings were initiated and completed in the name of the deceased person without taking steps to bring

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.

reassessment and penalty proceedings were initiated and completed in the name of the deceased person without taking steps to bring

M/S MUMBADEVI VEYHICLES,MUMBAI vs. ITO WARD 41(4)(2), MUMBAI

In the result the appeal of the assessee is allowed

Bench: Shri Saktijit Dey & Shri Makarand Vasant Mahadeokarm/S. Mumbadevi Ito Ward 41(4)(2), Veyhicles Room No. 854B, 8Th Shop No. 18, Suyash Vs. Floor, Kautilya Shopping Centre, Nnp, A. Bhavan, Bkc, K. Vaidya Marg, Goregaon Bandra (East), (E), Mumbai-400 065 Mumbai-400 051 Pan/Gir No. Aaofm0851F (Applicant) (Respondent) Assessee By Ms. Dinkle Hariya & Ms. Sruti Kalyanikar, Ld. Ars Revenue By Shri Annavaram Kosuri, Ld. Dr Date Of Hearing 19.02.2026 Date Of Pronouncement 24.02.2026

reassessment, the Assessing Officer initiated penalty proceedings under section 271(1)(c) of the Act for alleged concealment of income

M/S. JAGRUTI COMPUTECH PVT LTD,MUMBAI vs. I.T.O, WARD, 1(2)(1), MUMBAI

In the result, the appeal filed by the Assessee is allowed for statistical purposes

Bench: Shri Narender Kumar Choudhry & Ms. Padmavathy Sassessment Year: 2013-14

penalty levied by dismissing the appeal and holding as under: “6.18 In the present case, the appellant failed to offer any explanation for short admission of receipts to the extent of Rs 16,12,014/-, details of c/f business loss claimed before AO both during reassessment

RELIANCE INDUSTRIES LIMITED ,MUMBAI vs. DEPUTY COMMISSIONER OF INCOME TAX -CIRCLE 3(4) , MUMBAI

In the result, the appeal of the Revenue is dismissed whereas\nthe appeal of the assessee is allowed

penalty cannot stand if\nthe assessment itself is set aside. Where an order of\nassessment or reassessment on the basis

ACIT-3(4), MUMBAI vs. RELIANCE INDUSTRIES LIMITED, MUMBAI

In the result, the appeal of the Revenue is dismissed whereas the appeal of the assessee is allowed

Bench: Shri Om Prakash Kant () & Ms. Kavitha Rajagopal () Assessment Year: 2016-17 Reliance Industries Ltd., Dy. Cit Circle 3(4), 3Rd Floor, Maker Chamber Iv 222 Room No. 559, Aayakar Bhavan, Nariman Point, Vs. Maharshi Karve Road, Mumbai-400021. Mumbai-400020. Pan No. Aaacr 5055 K Appellant Respondent Assessment Year: 2016-17 Acit-3(4), Reliance Industries Ltd., Room No. 481(2), 4Th Floor, 3Rd Floor, Maker Chamber Iv Aayakar Bhavan, N.M. Road, Vs. Nariman Point, New Marine Lines, Mumbai-400021. Mumbai-400020. Pan No. Aaacr 5055 K Appellant Respondent

penalty cannot stand if the assessment itself is set aside. Where an order of assessment or reassessment on the basis