DY. COMMISSIONER OF INCOME TAX CIRCLE - 3(3)(1), MUMBAI, MUMBAI vs. SMALL INDUSTRIES DEVELOPMENT BANK OF INDIA, MUMBAI

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

1) (vii) of the Act. The fact that this sum has been omitted to be claimed in the return of income has been amply demonstrated by the Assessee. Even in the reassessment proceedings the AO has no answer to the claim of the Assessee in this regard and has merely observed in his order that there is no evidence produced

SMALL INDUSTRIES DEVELOPMENT BANK OF INDIA,MUMBAI vs. DEPUTY COMMISSIONER OF INCOME TAX CIRCLE 3(3)(1),MUMBAI, MUMBAI

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

1) (vii) of the Act. The fact that this sum has been omitted to be claimed in the return of income has been amply demonstrated by the Assessee. Even in the reassessment proceedings the AO has no answer to the claim of the Assessee in this regard and has merely observed in his order that there is no evidence produced

INCOME TAX OFFICER (IT)-3(2)(1), KAUTILYA BHAWAN vs. SHAPOORJI PALLONJI MISTRY, MUMBAI

In the result, appeal filed by the Revenue is dismissed

Bench: Shri Amit Shukla & Shri Girish Agrawal

reassess under unamended section 147, (b) issuance of notice under unamended section 148, (c) in accordance with time limit in terms of unamended section 149 and (d) sanction under unamended section 151 of the Act. 3 ITA Nos. 3674/Mum/2025 and ors. Shapoorji Pallonji Mistry AYs 2015-16 and 2016-17 5. Whether section 3(1

KUDOS FINANCE AND INVESTMENT PVT LTD,MUMBAI vs. PRINCIPLE COMMISSIONER OF INCOME TAX-6, MUMBAI

Bench: SHRI OM PRAKASH KANT, ACCOUNTANT MEMBER SHRI RAHUL CHAUDHARY (Judicial Member)

Section 36(1)(viia) of the Act and to reassess the income after granting the Assessee a reasonable opportunity of being

INCOME TAX OFFICER (INTERNATIONAL TAXATION) 3(2)(1), KAUTILYA BHAWAN MUMBAI vs. SHAPOORJI PALLONJI MISTRY, MUMBAI

In the result, both appeals by the Revenue are dismissed and the\ntwo Cross Objections of the assessee are allowed

Section 149(1)(b) of the Act. Consequently, the reassessment proceedings and orders were quashed.", "result": "Dismissed", "sections": [ "147", "148", "148A

KUDOS FINANCE AND INVESTMENTS PVT. LTD.,PUNE vs. ITO, WARD-14 (2)(1), MUMBAI

Section\n36(1)(viia) of the Act and to reassess the income after granting the\nAssessee a reasonable opportunity of being

JEEVANDEEP EDUMEDIA PRIVATE LIMITED,MUMBAI vs. PRINCIPLE CIT-6, MUMBAI

In the result, the a In the result, the appeal of the assessee is stands allowed

Bench: Shri Om Prakash Kant () & Ms. Kavitha Rajagopal () Assessment Year: 2020-21 Jeevandeep Edumedia Pvt. Ltd., Pr. Cit-6, 1St Floor, Sun Paradise Business 501,5Th Floor, Aayakar Bhavan, Plaza, Senapati Bapat Marg, Vs. Maharishi Karve Road, Lower Parel (West), Mumbai-400020. Mumbai-400013. Pan No. Aabcj 0180 G Appellant Respondent

section 142(1) of the Income-tax Act, 1961: tax Act, 1961: Jeevandeep Edumedia Pvt. Ltd. Jeevandeep Edumedia Pvt. Ltd. 1. You have claimed donations given on a/c of CSR 1. You have claimed donations given on a/c of CSR 1. You have claimed donations given on a/c of CSR expenditure of Rs.24,98,000/ expenditure of Rs.24

ITO(IT)-3(2)(1), MUMBAI vs. SHAPOORJI PALLONJI MISTRY, MUMBAI

In the result, both appeals by the Revenue are dismissed and the\ntwo Cross Objections of the assessee are allowed

1), Delhi and Ors. (cited supra) has upheld the validity of Instruction\nNo.1/2022 of CBDT and that this judgement has been subsequently endorsed by\nthe Hon'ble Apex Court.\n\n2.1 Grounds taken by the assessee in the cross objections are\nreproduced as under:\n\nCO. No. 152/MUM/2025\n\n1. erred in issuing notices for reassessment proceedings under Section

VIDHI ENTERPRISES,MUMBAI vs. DEPUTY COMMISSIONER OF INCOME TAX, MUMBAI

In the result, the appeal of the assessee is partly allowed for In the result, the appeal of the assessee is partly allowed for statistical purposes whereas appeal of the Revenue is dismissed

Bench: Shri Om Prakash Kant () Before Shri Om Prakash Kant () Before Shri Om Prakash Kant () & Shri Sandeep Singh Karhail () Shri Sandeep Singh Karhail () Shri Sandeep Singh Karhail ()

section 147 are bad in law. 1.2 The appellant craves leave to add amend alter or modify the The appellant craves leave to add amend alter or modify the The appellant craves leave to add amend alter or modify the ground or grounds of appeal before the hearing. ground or grounds of appeal before the hearing. GROUND 2: UPHOLDING

ACIT 32 1, MUMBAI vs. VIDHI ENTERPRISES, MUMBAI

In the result, the appeal of the assessee is partly allowed for In the result, the appeal of the assessee is partly allowed for statistical purposes whereas appeal of the Revenue is dismissed

Bench: Shri Om Prakash Kant () Before Shri Om Prakash Kant () Before Shri Om Prakash Kant () & Shri Sandeep Singh Karhail () Shri Sandeep Singh Karhail () Shri Sandeep Singh Karhail ()

section 147 are bad in law. 1.2 The appellant craves leave to add amend alter or modify the The appellant craves leave to add amend alter or modify the The appellant craves leave to add amend alter or modify the ground or grounds of appeal before the hearing. ground or grounds of appeal before the hearing. GROUND 2: UPHOLDING

SHAILESH ASALRAJ JAIN,MUMBAI vs. PRINCIPAL COMMISSIONER OF INCOME TAX, MUMBAI 20, MUMBAI

In the result, the appeal of the assessee is allowed

Bench: Shri Om Prakash Kant () & Shri Rahul Chaudhary () Assessment Year: 2018-19

reassessment proceedings, inter alia, contending that: alia, contending that: 1. On the facts and circumstances of the case of the Appellant 1. On the facts and circumstances of the case of the Appellant 1. On the facts and circumstances of the case of the Appellant and in law, the Principal Commissioner of Income Tax the Principal Commissioner of Income

M/S THE MAHARASHTRA STATE CO. OP BANK LTD.,MUMBAI vs. ITO-1(3)(3), MUMBAI

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

Bench: Shri Om Prakash Kant () & Shri Sandeep Singh Karhail () Assessment Year: 2013-14

reassessment and recomputation. and recomputation. 153. (1) No order of assessment12 shall be made under 153. (1) No order of assessment12 shall be made under 153. (1) No order of assessment12 shall be made under section

DY CIT-1(3)(2), MUMBAI vs. MAHARASHTRA STATE CO-OPERATIVE BANK LIMITED, MUMBAI

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

Bench: Shri Om Prakash Kant () & Shri Sandeep Singh Karhail () Assessment Year: 2013-14

reassessment and recomputation. and recomputation. 153. (1) No order of assessment12 shall be made under 153. (1) No order of assessment12 shall be made under 153. (1) No order of assessment12 shall be made under section

DEVANAND AMARNATH PARKAR,JOGESHWARI EAST, MUMBAI vs. INCOME TAX OFFICER 41(4)(1), KAUTILYA BHAWAN, BKC, BANDRA EAST

In the result, appeal by the assessee is allowed

1), a\nnotice under section 148 shall be issued for every such assessment year for\nassessment, reassessment or recomputation, as the case

SHREE SAI BABA SANTHAN TRUST MUMBAI ,MUMBAI vs. DCIT(EXEMPTION), MUMBAI

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

1, 1989,\nas also sections 148 to 152 are substantially different from the provisions as they\nstood prior to such substitution. Under the old provisions of section 147, separate\nclauses (a) and (b) laid down the circumstances under which income escaping\nassessment for the past assessment years could be assessed or reassessed

DY COMMISSIONER OF INCOME TAX (EXEMPTION)-2(1), MUMBAI vs. SHREE SAI BABA SANSTHAN TRUST (SHIRDI), MUMBAI

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

1, 1989,\nas also sections 148 to 152 are substantially different from the provisions as they\nstood prior to such substitution. Under the old provisions of section 147, separate\nclauses (a) and (b) laid down the circumstances under which income escaping\nassessment for the past assessment years could be assessed or reassessed

SURENDRA GARG HUF ,MUMBAI vs. ITO- 19(3)(4), MUMBAI

1)\nof section 142 has been issued to him, or\n\n(b)\na return of income has been furnished by such\nother person but no notice under sub-section (2)\nof section 143 has been served and limitation of\nserving the notice under sub-section (2) of section\n143 has expired, or\n\n(c)\nassessment or reassessment

LIC HOUSING FINANCE LIMITED,MUMBAI vs. ACIT 2(2)(1), MUMBAI, AAYKAR BHAVAN, MUMBAI

In the result, the appeal of the assessee is allowed

Bench: Shri Om Prakash Kant () & Shri Raj Kumar Chauhan () Assessment Year: 2017-18

1: Reopening of Assessment Proceedings The appellant has challenged the order passed under section The appellant has challenged the order passed under section The appellant has challenged the order passed under section 148A(d) on the ground that the reasses 148A(d) on the ground that the reassessment