DCIT CEN 5 3, MUMBAI vs. ICICI LOMBARD GENERAL INSURANCE CO. LIMITED, MUMBAI

In the result, appeals of the Revenue are allowed partly

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

10(38) in respect of interest income, dividend and LTCG, respectively is respect of interest income, dividend and LTCG, respectively is respect of interest income, dividend and LTCG, respectively is deleted. Accordingly, ground no. 2 of the appeal Accordingly, ground no. 2 of the appeal is allowed.” 3.8 Similarly, with regard to the disallowance under section 14A, Similarly, with regard

DCIT CEN 5 3, MUMBAI, MUMBAI vs. ICICI LOMBARD GENERAL INSURANCE CO. LIMITED, MUMBAI

In the result, appeals of the Revenue are allowed partly

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

10(38) in respect of interest income, dividend and LTCG, respectively is respect of interest income, dividend and LTCG, respectively is respect of interest income, dividend and LTCG, respectively is deleted. Accordingly, ground no. 2 of the appeal Accordingly, ground no. 2 of the appeal is allowed.” 3.8 Similarly, with regard to the disallowance under section 14A, Similarly, with regard

JM FINANCIAL PROPERTY FUND I,MUMBAI vs. INCOME TAX OFFICER, WARD - 25(1)(1), MUMBAI, MUMBAI

In the result, the appeal of the assessee for assessment year

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

reassessment proceeding be held as without jurisdiction, bad in law and void jurisdiction, bad in law and void-ab-initio. Ground Nos. 4 to 10 are without prejudice to Ground Nos. 1 to 3 Ground Nos. 4 to 10 are without prejudice to Ground Nos. 1 to 3 Ground Nos. 4 to 10 are without prejudice to Ground

JM FINANCIAL PROPERTY FUND I,MUMBAI vs. INCOME TAX OFFICER, WARD - 25(1)(1), MUMBAI, MUMBAI

In the result, the appeal of the assessee for assessment year

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

reassessment proceeding be held as without jurisdiction, bad in law and void jurisdiction, bad in law and void-ab-initio. Ground Nos. 4 to 10 are without prejudice to Ground Nos. 1 to 3 Ground Nos. 4 to 10 are without prejudice to Ground Nos. 1 to 3 Ground Nos. 4 to 10 are without prejudice to Ground

ACIT, PIRAMAL CHAMBERS vs. MILESTONE REAL ESTATE FUND, MUMBAI

3. The relevant facts in brief are that the Assessee, a Venture Capital Fund, filed Return of Income for the Assessment Year 2015-16 on 30/11/2015 declaring total income of INR 10,85,28,560/-. The aforesaid return was processed under Section 143(1) of the Act. Subsequently, reassessment

ACIT 23-1, MUMBAI vs. MILESTONE REAL ESTATE FUND, MUMBAI

Accordingly, Ground No. 6 raised by the Revenue is dismissed

Bench: SHRI AMARJIT SINGH, ACCOUNTANT MEMBER SHRI RAHUL CHAUDHARY (Judicial Member)

3. The relevant facts in brief are that the Assessee, a Venture Capital Fund, filed Return of Income for the Assessment Year 2015-16 on 30/11/2015 declaring total income of INR 10,85,28,560/-. The aforesaid return was processed under Section 143(1) of the Act. Subsequently, reassessment

ACIT-231, MUMBAI vs. MILESTONE REAL ESTATE FUND, MUMBAI

Accordingly, Ground No. 6 raised by the Revenue is dismissed

Bench: SHRI AMARJIT SINGH, ACCOUNTANT MEMBER SHRI RAHUL CHAUDHARY (Judicial Member)

3. The relevant facts in brief are that the Assessee, a Venture Capital Fund, filed Return of Income for the Assessment Year 2015-16 on 30/11/2015 declaring total income of INR 10,85,28,560/-. The aforesaid return was processed under Section 143(1) of the Act. Subsequently, reassessment

DCIT 3.2.1, MUMBAI vs. THE NEW INDIA ASSURANCE CO LIMITED, MUMBAI

3)\nof section 143 or this section has been made for the\nrelevant assessment year, no action shall be taken under\nthis section after the expiry of four years from the end of\nthe relevant assessment year, unless any income\nchargeable to tax has escaped assessment for such\n assessment year by reason of the failure on the part

DCIT 3.2.1, MUMBAI vs. THE NEW INDIA ASSURANCE CO LIMITED, MUMBAI

reassessment proceedings\nwere initiated within a period of four years from the end of the\nrelevant assessment year and therefore, First Proviso to Section\n147 of the Act was not applicable. Placing reliance upon\nParagraph 6.1.1 and 6.1.2 of the order impugned, the Learned\nDepartmental Representative submitted that the reasons\nITA No. 2616-2623 /Mum /2024

THE NEW INDIA ASSURANCE CO. LTD,MUMBAI vs. ASSISTANT COMMISSIONER OF INCOME TAX , INCOME TAX OFFICER, NFAC, MUMBAI

Accordingly, in terms of the aforesaid, Ground No. 3 to\n7 raised by the Assessee pertaining to merits of such\nadditions/disallowances are dismissed as having been rendered\ninfructuous

Bench: "CLEAN_TEXT": "IN THE INCOME TAX APPELLATE TRIBUNAL\n\"I\" BENCH, MUMBAI\n\nSHRI VIKRAM SINGH YADAV , ACCOUNTANT MEMBER\nSHRI RAHUL CHAUDHARY (Judicial Member)

reassessment proceedings\nwere initiated within a period of four years from the end of the\nrelevant assessment year and therefore, First Proviso to Section\n147 of the Act was not applicable. Placing reliance upon\nParagraph 6.1.1 and 6.1.2 of the order impugned, the Learned\nDepartmental Representative submitted that the reasons\n\nITA No. 2616-2623 /Mum /2024

THE NEW INDIA ASSURANCE CO. LTD ,MUMBAI vs. DEPUTY COMMISSIONER OF INCOME TAX, CIRCLE -3(2)(2), MUMBAI

reassessment proceedings\nwere initiated within a period of four years from the end of the\nrelevant assessment year and therefore, First Proviso to Section\n147 of the Act was not applicable. Placing reliance upon\nParagraph 6.1.1 and 6.1.2 of the order impugned, the Learned\nDepartmental Representative submitted that the reasons\n\nITA No. 2616-2623 /Mum /2024

KONARK STRUCTURAL ENGG PRIVATE LIMITED,MUMBAI vs. PRINCIPAL COMMISSIONER OF INCOME TAX-12, MUMBAI

In the result, the appeal of assessee is allowed

Bench: Sri Mahavir Singh, Jm & Sri Manoj Kumar Aggarwal, Am

10 March 1999 cannot stand merged with the orders of reassessment in respect of those issues which did not form the subject matter of the reassessment. Consequently Explanation 3 to Section

DCIT 3.2.1, MUMBAI vs. THE NEW INDIA ASSURANCE CO LIMITED, MUMBAI

reassessment order passed under section \n143(3) read with section 147 of the Income Tax Act (‘the \nAct’) as valid. \n2. The CIT(A) failed to appreciate the fact that in the reasons \nrecorded, the AO has not disclosed any specific non- \nITA No. 2616-2623 /Mum /2024, ITA No. 2845, 2841, 2836, 2834, \n2827

DCIT 3.2.1, MUMBAI vs. THE NEW INDIA ASSURANCE CO LIMITED, MUMBAI

Accordingly, in terms of the aforesaid, Ground No. 3 to\n7 raised by the Assessee pertaining to merits of such\nadditions/disallowances are dismissed as having been rendered\ninfructuous

reassessment proceedings\nwere initiated within a period of four years from the end of the\nrelevant assessment year and therefore, First Proviso to Section\n147 of the Act was not applicable. Placing reliance upon\nParagraph 6.1.1 and 6.1.2 of the order impugned, the Learned\nDepartmental Representative submitted that the reasons\n\nITA No. 2616-2623 /Mum /2024

THE NEW INDIA ASSURANCE CO. LTD ,MUMBAI vs. DEPUTY COMMISSIONER OF INCOME TAX, CIRCLE-3(2)(2), MUMBAI

reassessment proceedings \nwere initiated within a period of four years from the end of the \nrelevant assessment year and therefore, First Proviso to Section \n147 of the Act was not applicable. Placing reliance upon \nParagraph 6.1.1 and 6.1.2 of the order impugned, the Learned \nDepartmental Representative submitted that the reasons \nITA No. 2616-2623 /Mum /2024

MANOHAR MANAK ALLOYS P.LTD,MUMBAI vs. ACIT 4(2), MUMBAI

Appeal is allowed

3 is to empower the Assessing Officer to assess or reassess the income in respect of any issue which comes to the notice in the course of the proceedings under the section, though the reasons which were recorded in the notice under section 148(2) did not contain reference to that issue. 10

METROPOLITAN STOCK EXCHANGE OF INDIA PRIVATE LIMITED,MUMBAI vs. PRINCIPAL COMMISSIONER OF INCOME TAX - 14, MUMBAI

In the result, this appeal by the assessee stands partly allowed

Bench: Shri Shamim Yahya, Am & Shri Ram Lal Negi, Jm

reassessment. Insertion of explanation 3 to section 147 of the Act does not alter the bar of limitation under section 263(2) of the Act. This view is supported by following judicial decision: CIT vs ICICI Bank Ltd. [2012] 19 taxmann.com 142 (Bom] ".....The order under section 143(3) passed on 10

MAHARASHTRA STATE ELECTRICITY TRANSMISSION COMPANY LTD.,,MUMBAI vs. THE INCOME TAX OFFICER, WARD-14(2)(3), MUMBAI

In the result, the appeal of the assessee is al

Bench: Shri Vikas Awasthy () & Shri Om Prakash Kant () Assessment Year: 2011-12 Maharashtra State Electricity Income-Tax Officer, Ward Transmission Company Ltd., 14(2)(3), Plot No. C-19 E Block, Vs. Aayakar Bhavan, Maharshi Prakashganga, Bandra-Kurla Karve Road, Complex, Bandra (East), Mumbai-400020. Mumbai-400051. Pan No. Aaecm 2936 N Appellant Respondent Assessee By : Mr. Ketan Ved, Ar Revenue By : Mr. Harishankar Lal, Dr : Date Of Hearing 15/11/2022 Date Of Pronouncement : 29/12/2022

3 Company Ltd. reasons that income escaped assessment and issued notice under reasons that income escaped assessment and issued notice under reasons that income escaped assessment and issued notice under section 148 of the Income 8 of the Income-tax Act, 1961 (in short in short ‘the Act’) on 30/03/2018. In response In response, the assessee filed the return