M/S. PANTIME FINANCE CO. P. LTD.,MUMBAI vs. ITO WARD-13(1)(1), MUMBAI

In the result, the appeal of the assessee is allowed

reassessment proceedings itself. Hence the same cannot be the subject matter of revision proceedings u/s 263 of the Act by the ld. PCIT

DCIT 5 3 1 MUMBAI, MUMBAI vs. ALTR INTERNATIONAL PVT LTD, MUMBAI

In the result, both the appe

Bench: Shri Om Prakash Kant () & Ms. Kavitha Rajagopal ()

reassessment order passed by him by way of revision order dated 23/03/2018 and of revision order dated 23/03/2018 and directed the Assessing directed the Assessing Officer to pass a fresh assessment order. The impugned assessment ss a fresh assessment order. The impugned assessment ss a fresh assessment order. The impugned assessment order has been passed in consequent to the said

DCIT 5 3 1 , MUMBAI vs. ALTR INTERNATIONAL PVT LTD, MUMBAI

In the result, both the appe

Bench: Shri Om Prakash Kant () & Ms. Kavitha Rajagopal ()

reassessment order passed by him by way of revision order dated 23/03/2018 and of revision order dated 23/03/2018 and directed the Assessing directed the Assessing Officer to pass a fresh assessment order. The impugned assessment ss a fresh assessment order. The impugned assessment ss a fresh assessment order. The impugned assessment order has been passed in consequent to the said

RAJ IMPEX,THANE vs. PCIT CENTRAL MUMBAI 1, MUMBAI

Accordingly, are rendered as dismissed

Bench: SHRI BEENNA PILLAI (Judicial Member), SHRI ARUN KHODPIA (Accountant Member)

revising the said approval granted u/s 153D of the Act. 22. Since the assessment was initiated after Search & Seizure operation 132(1) of the Act for the year under consideration which is an unabated assessment year, can the addition or disallowance be made without any incriminating material found or unearthed during the course of search. Ld. AR placed his reliance

RAJ IMPEX,THANE vs. PCIT CENTRAL MUMBAI 1, MUMBAI

Accordingly, are rendered as dismissed

Bench: SHRI BEENNA PILLAI (Judicial Member), SHRI ARUN KHODPIA (Accountant Member)

revising the said approval granted u/s 153D of the Act. 22. Since the assessment was initiated after Search & Seizure operation 132(1) of the Act for the year under consideration which is an unabated assessment year, can the addition or disallowance be made without any incriminating material found or unearthed during the course of search. Ld. AR placed his reliance

RAJ IMPEX,THANE vs. PCIT CENTRAL MUMBAI 1, MUMBAI

Accordingly, are rendered as dismissed

Bench: SHRI BEENNA PILLAI (Judicial Member), SHRI ARUN KHODPIA (Accountant Member)

revising the said approval granted u/s 153D of the Act. 22. Since the assessment was initiated after Search & Seizure operation 132(1) of the Act for the year under consideration which is an unabated assessment year, can the addition or disallowance be made without any incriminating material found or unearthed during the course of search. Ld. AR placed his reliance

RAJ IMPEX,THANE vs. PCIT CENTRAL MUMBAI 1, MUMBAI

Accordingly, are rendered as dismissed

Bench: SHRI BEENAPPILLAI (Judicial Member), SHRI ARUN KHODPIA (Accountant Member)

revising the said approval granted u/s 153D of the Act. 22. Since the assessment was initiated after Search & Seizure operation 132(1) of the Act for the year under consideration which is an unabated assessment year, can the addition or disallowance be made without any incriminating material found or unearthed during the course of search. Ld. AR placed his reliance

RAJ IMPEX,THANE vs. PCIT CENTRAL MUMBAI 1, MUMBAI

Accordingly, are rendered as dismissed

Bench: SHRI BEENAPPILLAI (Judicial Member), SHRI ARUN KHODPIA (Accountant Member)

revising the said approval granted u/s 153D of the Act. 22. Since the assessment was initiated after Search & Seizure operation 132(1) of the Act for the year under consideration which is an unabated assessment year, can the addition or disallowance be made without any incriminating material found or unearthed during the course of search. Ld. AR placed his reliance

RAJ IMPEX,THANE vs. PCIT CENTRAL MUMBAI 1, MUMBAI

Accordingly, are rendered as dismissed

Bench: SHRI BEENA PILLAI (Judicial Member), SHRI ARUN KHODPIA (Accountant Member)

revising the said approval granted u/s 153D of the Act. 22. Since the assessment was initiated after Search & Seizure operation 132(1) of the Act for the year under consideration which is an unabated assessment year, can the addition or disallowance be made without any incriminating material found or unearthed during the course of search. Ld. AR placed his reliance

HSBC SECURITIES AND CAPITAL MARKETS (INDIA) PRIVATE LIMITED,MUMBAI vs. PRINCIPAL COMMISSIONER OF INCOME-TAX, MUMBAI-4, MUMBAI

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

Bench: Shri Narender Kumar Choudhry & Shri Girish Agrawalassessment Year: 2014-15

u/s 263(2) applies to the Original Order which time limit has expired. Therefore, the revision proceedings are time barred.” (Highlighted by us for clarity) 5. The Ld. PCIT though considered the contentions raised by the Assessee, however, not being convinced by the same, ultimately held the reassessment

ANUMITA INFRASTRUCTURE PRIVATE LIMITED,MUMBAI vs. PCIT-4, MUMBAI

u/s 263 it has been alleged that source of purchase and sale of transactions remained to be verified.\n9. That the appellant craves leave to add, alter, modify, or delete any grounds of appeal during the course of appellate proceedings.”\n11. During the course of hearing before us the learned Authorised Representative (AR) submitted that the reassessment proceedings

DCIT 14.1.1, MUMBAI vs. AADI INDUSTRIES LTD, MUMBAI

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

Bench: Shri Pavan Kumar Gadale & Shri Girish Agrawaldcit – 14(1)(1), Vs. M/S.Aadi Industries Ltd 320/7, Siddhivinayak Room No. 432, 4Th Floor Housing Society, Aayakar Bhavan, Hingwals Lane, M.K.Road, Ghatkopar (East), Mumbai -400020. Mumbai – 400075. Pan/Gir No. Aaacj8256G (अपीलाथ"/Appellant) (""यथ"/Respondent) Appellant By Shri Manoj Kumar Sinha, Sr. Dr Respondent By None सुनवाई क" तार"ख/Date Of Hearing 07.08.2024 घोषणा क" तार"ख/Date Of Pronouncement 12.08.2024 Order Per Pavan Kumar Gadale, Jm: “ The Appeal Is Filed By The Revenue Against The Order Of National Faceless Appeal Centre(Nfac), Delhi / Cit(A) Passed U/Sec143(3) R.W.S263 U/Sec 250 Of The Act. The Revenue Has Raised The Following Grounds Of Appeal:

reassess the completed assessment. Accordingly, we are also set-aside the order passed u/s. 263 of the Act and annul the initiation of revision

M/S TRICITY REALTY LLP ,MUMBAI vs. PCIT(CENTRAL)-2 , MUMBAI

In the result, appeal of the assessee is allowed

Bench: Shri Vikas Awasthy & Shri M Balaganeshvk-Vk-La- 750@Eaqcbz@2022 ¼Fu-Oa- 2017&18½ M/S Tricity Realty Llp 1001/1002, Bhumiraj Costarica, Plot No.1-2, Sector 18 Off Palm Beach Road, Sanpada (E) Navi Mumbai-400 705 ..... Vihykfkhz/Appellant Pan No. Aakft6601L Cuke Vs. Principal Commissioner Of Income Tax (Cen.)-2 Room No.1920, 19Th Floor, Air India Building Nariman Point, ..... Izfroknh/Respondent Mumbai-400 021

reassess the earlier assessment in terms of section 147 or carry out rectification u/s 154 of the Act. He can’t usurp the power of the CIT and recommend a revision. No overlapping of powers of the authorities under the Act can be permitted. As the revision proceedings in this case have triggered with the AO sending a proposal

BIRLA CARBON INDIA PRIVATE LIMITED,MUMBAI vs. THE PRINCIPAL COMMISSIONER OF INCOME TAX, MUMBAI - 5, MUMBAI

In the result, the appeal is allowed as indicated above

Bench: Shri Saktijit Dey & Shri Narendra Kumar Billaiyabirla Carbon India Private Limited The Principal Commissioner Of Ground Floor, Aditya Birla Centre, Income Tax Room No. 515, 5Th Floor, Aaykar S. K. Ahire Marg, Worli, Vs. Mumbai-400 030 Bhavan, M. K. Road, Mumbai-400 020 Pan/Gir No. Aascs 9916 L (Appellant) : (Respondent) Appellant By : Shri Madhur Agarwal Respondent By : Shri Satyaprakash R. Singh Date Of Hearing : 16.09.2025 Date Of Pronouncement : 22.09.2025 O R D E R Per Saktijit Dey: In The Present Appeal, The Assessee Has Called Into Question The Validity Of The Order Dated 25.03.2025, Passed U/S. 263 Of The Income Tax Act, 1961 (‘The Act’ For Short) By Learned Principal Commissioner Of Income Tax (‘Ld.Pcit’ For Short), Pertaining To The Assessment Year (A.Y.) 2018-19. 2. Thought Multiple Grounds Have Been Raised In The Memorandum Of Appeal, However, The Assessee Has Raised A Pertinent Preliminary Issue, Challenging The Competence & Jurisdiction Of Ld. Pcit To Invoke Powers U/S. 263 Of The Act To Revise An Assessment Order Passed U/S. 144C(13) Of The Act, In Pursuance To The Directions Of Learned Dispute Resolution Panel (Ld. Drp).

u/s. 144(3) is being revised by Ld.CIT. Ld. Counsel of the assessee in this regard submits that from 6 Birla Carbon India Private Limited vs. Pr. CIT the Finance Act, 2009, memorandum explaining the rationale behind the insertion of section 144C of the Act by the Finance Bill, 2009 as also the CBDT Circular No. 5 of 2010 dated

JAYANTILAL RAJMAL SETH,MUMBAI vs. DCIT-CC-4(3), MUMBAI, MUMBAI

Bench: Shri Om Prakash Kant () & Shri Raj Kumar Chauhan () Assessment Year: 2018-19 Jayantilal Rajmal Seth, Dcit-Cc-4(3), A-3, Saibaba Shopping Centre, Bkc, Mumbai-400051. Mumbai Central, Vs. Mumbai-400008. Pan No. Agepj 0499 E Appellant Respondent

revised return filed earlier on 03.06.2019 under section 139(5) of the Act. return filed earlier on 03.06.2019 under section 139(5) of the Act. return filed earlier on 03.06.2019 under section 139(5) of the Act. The reassessment was thereafter completed on 25.02.2022, wherein The reassessment was thereafter completed on 25.02.2022, wherein The reassessment was thereafter completed

AQUA TECH SOLUTIONS PRIVATE LIMITED,PUNE vs. PCIT (CENTRAL)-3, MUMBAI, MUMBAI

In the result, the appeal of the assessee is allowed

Bench: Shri Saktijit Dey & Ms Padmavathy S, Acccountant Member

reassessment order passed on 31.03.2023 u/s 143(3) r.w.s 147 as order sought to be revised', whereas the impugned deduction u/s 801A(4) was already examined and allowed in the previous assessment order passed u/s 143(3) of the Act on 17.05.2021 after complete scrutiny under CASS, with reference to which, the limitation for revision u/s 263

RAJ IMPEX,THANE vs. PCIT CENTRAL MUMBAI 1, MUMBAI

Accordingly, are rendered as dismissed

revising the said\napproval granted u/s 153D of the Act.\n22. Since the assessment was initiated after Search & Seizure operation 132(1) of\nthe Act for the year under consideration which is an unabated assessment year, can\nthe addition or disallowance be made without any incriminating material found or\nunearthed during the course of search. Ld. AR placed his reliance

JAYSHREE RAVI SANCHETI,MUMBAI vs. PCIT-20, MUMBAI

In the result, the appeal of the assessee is allowed

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

263 is bad in law since the re-assessment order passed u/s 147 itself was invalid and non-est; 2.0 On facts and circumstances of the case and in law, the Pr. CIT erred in passing the revision order u/s.263 though the re-assessment order passed u/s 147 is not erroneous and in so far is not prejudicial to interest