LARSEN & TOUBRO INFOTECH LTD.,MUMBAI vs. DCIT-2(2)(1), MUMBAI

In the result, appeal of the assessee for A

Section 147, ergo, the limitation and the condition provided therein has to be satisfied, whether AO has assumed valid jurisdiction or not. The case of the AO is that, the issue of escapement is established in the A.Y 2009-10 when the fact came to light that the assessee is not eligible for deduction u/s 10A to the extent

LARSEN & TOURBRO INFOTECH LTD,MUMBAI vs. ASST CIT 2(2)(1), MUMBAI

In the result, appeal of the assessee for A

Section 147, ergo, the limitation and the condition provided therein has to be satisfied, whether AO has assumed valid jurisdiction or not. The case of the AO is that, the issue of escapement is established in the A.Y 2009-10 when the fact came to light that the assessee is not eligible for deduction u/s 10A to the extent

DCIT(CC)-8(3), MUMBAI vs. 63 MOONS TECHNOLOGIES LIMITED, MUMBAI

In the result, appeal of the Revenue is dismissed

Bench: Shri Sandeep Gosain & Shri Girish Agrawal

reassessment proceedings have been initiated after a period of four years from the end of the relevant assessment years and thus, conditions prescribed under the first proviso to section 147 squarely applies in this case. There are two conditions which are to be met as per the first proviso to section 147, first, the original assessment u/s. 143(3) ought

DCIT(CC)-8(3), MUMBAI vs. 63 MOONS TECHNOLOGIES LIMITED, MUMBAI

In the result, appeal of the Revenue is dismissed

Bench: Shri Sandeep Gosain & Shri Girish Agrawal

reassessment proceedings have been initiated after a period of four years from the end of the relevant assessment years and thus, conditions prescribed under the first proviso to section 147 squarely applies in this case. There are two conditions which are to be met as per the first proviso to section 147, first, the original assessment u/s. 143(3) ought

DCIT(CC)-8(3), MUMBAI vs. 63 MOONS TECHNOLOGIES LIMITED, MUMBAI

In the result, appeal of the Revenue is dismissed

Bench: Shri Sandeep Gosain & Shri Girish Agrawal

reassessment proceedings have been initiated after a period of four years from the end of the relevant assessment years and thus, conditions prescribed under the first proviso to section 147 squarely applies in this case. There are two conditions which are to be met as per the first proviso to section 147, first, the original assessment u/s. 143(3) ought

LAXMAN GORE SHRESHTHA,MUMBAI vs. DEPUTY COMMISSIONER OF INCOME TAX, CIRCLE 22(1), MUMBAI

In the result, both the appeals of the assessee bearing ITA Nos

reassessment order.\n2.\nThe Ld. CIT(A) has not considered the grounds that assessment was\nreopened after four years without the sanction from PCIT-22 u/s 151 of Income\nTax Act. 1961 as no such sanction was provided inspite of reminders.\n3.\nThe Ld. CIT(A) further erred in confirming the addition on account of\nsurrender of ULIP Market Plus

DCIT(LTU) - 1, MUMBAI vs. ACC LTD., MUMBAI

In the result, appeal filed by assessee is partly allowed

Bench: Shri S. Rifaur Rahman, Hon'Ble & Shri Sandeep Singh Karhail, Hon'Ble

reassessment proceedings are void and bad in law. The relevant para of the said decision is reproduced as under: “………The language of Section 147 makes it clear that the assessing officer certainly has the power to re-assess any income which escaped assessment for any assessment year subject to the provisions of Sections 148 to 153. However

ACC LTD.,MUMBAI vs. ADDL CIT(LTU) , MUMBAI

In the result, appeal filed by assessee is partly allowed

Bench: Shri S. Rifaur Rahman, Hon'Ble & Shri Sandeep Singh Karhail, Hon'Ble

reassessment proceedings are void and bad in law. The relevant para of the said decision is reproduced as under: “………The language of Section 147 makes it clear that the assessing officer certainly has the power to re-assess any income which escaped assessment for any assessment year subject to the provisions of Sections 148 to 153. However

LAXMAN GORE SHRESHTHA,MUMBAI vs. DY COMMISSIONER OF INCOME TAX, CIRCLE-22(1), MUMBAI

In the result, both the appeals of the assessee bearing ITA Nos

Bench: Shri Prashant Maharishi & Shri Anikesh Banerjee

reassessment order. 2. The Ld. CIT(A) has not considered the grounds that assessment was reopened after four years without the sanction from PCIT-22 u/s 151 of Income Tax Act. 1961 as no such sanction was provided inspite of reminders. 3. The Ld. CIT(A) further erred in confirming the addition on account of surrender of ULIP Market Plus

ASST. COMMISSIONER OF INCOME-TAX 6(1)(2), MUMBAI, MUMBAI vs. JAYANT AGRO ORGANICS LTD, MUMBAI

In the result, both appeals by the Revenue are allowed for statistical purposes

Bench: Shri Amarjit Singhshri Sandeep Singh Karhail

Section 10A of the IT Act which was allegedly allowed in excess. The show cause notice dated 10.02.2005 reflects the ground for reassessment

ASST. COMMISSIONER OF INCOME-TAX 6(1)(2), MUMBAI, MUMBAI vs. JAYANT AGRO ORGANICS LTD., MUMBAI

In the result, both appeals by the Revenue are allowed for statistical purposes

Bench: Shri Amarjit Singhshri Sandeep Singh Karhail

Section 10A of the IT Act which was allegedly allowed in excess. The show cause notice dated 10.02.2005 reflects the ground for reassessment

ACC LTD.,MUMBAI vs. DCIT(LTU) - 1, MUMBAI

In the result, appeal filed by assessee is partly allowed

Bench: Shri S. Rifaur Rahman, Hon'Ble & Shri Sandeep Singh Karhail, Hon'Ble

reassessment order of the AO be set aside as bad in law.” 22. Similar issue was considered by us in the Assessee’s Appeal in Ground No 6 for the A.Y. 2007-08 and held as under: - “58. Considered the rival submissions and material placed on record. It is observed that during the year under consideration assessee has sold

ACC LTD.,MUMBAI vs. DCIT(LTU) - 1, MUMBAI

In the result, appeal filed by assessee is partly allowed

Bench: Shri S. Rifaur Rahman, Hon'Ble & Shri Sandeep Singh Karhail, Hon'Ble

reassessment order of the AO be set aside as bad in law.” 22. Similar issue was considered by us in the Assessee’s Appeal in Ground No 6 for the A.Y. 2007-08 and held as under: - “58. Considered the rival submissions and material placed on record. It is observed that during the year under consideration assessee has sold

DCIT(LTU) - 1, MUMBAI vs. ACC LTD., MUMBAI

In the result, appeal filed by assessee is partly allowed

Bench: Shri S. Rifaur Rahman, Hon'Ble & Shri Sandeep Singh Karhail, Hon'Ble

reassessment order of the AO be set aside as bad in law.” 22. Similar issue was considered by us in the Assessee’s Appeal in Ground No 6 for the A.Y. 2007-08 and held as under: - “58. Considered the rival submissions and material placed on record. It is observed that during the year under consideration assessee has sold

AAACORP EXIM INDIA PRIVATE LIMITED,MUMBAI vs. D.C.I.T.-CIRCLE-14(1)(1), MUMBAI

In the result the appeal of the assessee is allowed

Bench: Shri Amit Shukla & Shri Gagan Goyal & Aaa Corp Exim India Pvt. Ltd. C-206, Ghatkopar Industrial Estate, Off Lbs Marg, Ghatkopar (W), Mumbai-400 086 Pan: Aacca8815C ...... Appellant Vs. Dcit-14(1)(1) Income Tax Offices, Aayakar Bhavan, M. K. Road, Mumbai-400 020 ..... Respondent

reassess under section 147 or pass an order enhancing the assessment or reducing a refund already made or otherwise increasing the liability of the assessee under section 154 for any assessment year the proceedings of which have been completed before the 1st day of October, 2009.] (3) Where during the course of any proceeding for the assessment of income

SANMAN TRADE IMPEX LIMITED,MUMBAI vs. ASSISTANT COMMISSIONER OF INCOME TAX-CENTRAL CIRCLE 4(4), MUMBAI, MUMBAI

In the result, appeals of the Revenue are dismissed dismissed whereas appeals of the assessee are partly allowed appeals of the assessee are partly allowed

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

reassessment proceedings on the ground of invalid invalid sanction M/s Sanman Trade Impex Ltd. M/s Sanman Trade Impex Ltd. ITA Nos. 3491, 3474, 3473, 3472 3471, 3470/MUM/2023 3471, 3470/MUM/2023 3606, 3605, 3603, 3602, 3614 & 3610, 3606, 3605, 3603, 3602, 3614 & 3610, 3601/MUM/2023 obtained u/s 151 of the Act tained u/s 151 of the Act , which is issued

SANMAN TRADE IMPEX LIMITED,MUMBAI vs. ASSISTANT COMMISSIONER OF INCOME TAX- CENTRAL CIRCLE 4(4), MUMBAI, MUMBAI

In the result, appeals of the Revenue are dismissed dismissed whereas appeals of the assessee are partly allowed appeals of the assessee are partly allowed

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

reassessment proceedings on the ground of invalid invalid sanction M/s Sanman Trade Impex Ltd. M/s Sanman Trade Impex Ltd. ITA Nos. 3491, 3474, 3473, 3472 3471, 3470/MUM/2023 3471, 3470/MUM/2023 3606, 3605, 3603, 3602, 3614 & 3610, 3606, 3605, 3603, 3602, 3614 & 3610, 3601/MUM/2023 obtained u/s 151 of the Act tained u/s 151 of the Act , which is issued

DCIT CC 4(4), MUMBAI, MUMBAI vs. SANMAN TRADE IMPEX LIMITED, MUMBAI

In the result, appeals of the Revenue are dismissed dismissed whereas appeals of the assessee are partly allowed appeals of the assessee are partly allowed

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

reassessment proceedings on the ground of invalid invalid sanction M/s Sanman Trade Impex Ltd. M/s Sanman Trade Impex Ltd. ITA Nos. 3491, 3474, 3473, 3472 3471, 3470/MUM/2023 3471, 3470/MUM/2023 3606, 3605, 3603, 3602, 3614 & 3610, 3606, 3605, 3603, 3602, 3614 & 3610, 3601/MUM/2023 obtained u/s 151 of the Act tained u/s 151 of the Act , which is issued

DCIT CC 4 (4), MUMBAI, MUMBAI vs. SANMAN TRADE IMPEX LIMITED, MUMBAI

In the result, appeals of the Revenue are dismissed dismissed whereas appeals of the assessee are partly allowed appeals of the assessee are partly allowed

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

reassessment proceedings on the ground of invalid invalid sanction M/s Sanman Trade Impex Ltd. M/s Sanman Trade Impex Ltd. ITA Nos. 3491, 3474, 3473, 3472 3471, 3470/MUM/2023 3471, 3470/MUM/2023 3606, 3605, 3603, 3602, 3614 & 3610, 3606, 3605, 3603, 3602, 3614 & 3610, 3601/MUM/2023 obtained u/s 151 of the Act tained u/s 151 of the Act , which is issued