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-\ndisclosure of material facts by the appellant.\"\n8. We have heard the both the sides in relation

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-\ndisclosure of material facts by the appellant.\"\n8. We have heard the both the sides in relation

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

reassessment order passed under section\n143(3) read with section 147 of the Income Tax Act (‘the\nAct’) as valid.\n\n2. The CIT(A) failed to appreciate the fact that in the reasons\nrecorded, the AO has not disclosed any specific non-\ndisclosure of material facts by the appellant.”\n\n8. We have heard the both the sides

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 order passed under section\n143(3) read with section 147 of the Income Tax Act (‘the\nAct’) as valid.\n\n2.\nThe CIT(A) failed to appreciate the fact that in the reasons\nrecorded, the AO has not disclosed any specific non-\ndisclosure of material facts by the appellant.”\n\n8.\nWe have heard the both the sides

NAVAJBAI RATAN TATA TRUST ,MUMBAI vs. PR CIT 17, MUMBAI

Bench: Us, Are As Follows: Page 2 Of 47 1 A) The Impugned Order Dated 31.10.2019 Passed By The Learned Principal Commissioner Of Income-Tax-17 ('Pcit') Under Section 12Aa(3)/(4) Of The Income-Tax Act, 1961 ('Ita') Cancelling The Registration Of The Appellant Is Without Jurisdiction And, Hence, Void Ab Initio.

3. The use of the word 'notice' in Section 12AA(4) relates to the aspect of the events coming to his/her knowledge. Mere notice of breach, it is respectfully, submitted would never suffice for the purposes of ordering a cancellation. If it is held so, it would mean that the Commissioner upon noticing a breach, without arriving at any satisfaction

THE NEW INDIA ASSURANCE CO. LTD ,MUMBAI vs. DEPUTY COMMISSIONER OF INCOME TAX, CIRCLE-3(2)(2), 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 \ndisclosure of material facts by the appellant.” \n8. We have heard the both the sides in relation

JAMSETJI TATA TRUST ,MUMBAI vs. PR CIT 17, MUMBAI

Bench: Us, Are As Follows: Assessment Year: 2019-20

3. The use of the word 'notice' in Section 12AA(4) relates to the aspect of the events coming to his/her knowledge. Mere notice of breach, it is respectfully, submitted would never suffice for the purposes of ordering a cancellation. If it is held so, it would mean that the Commissioner upon noticing a breach, without arriving at any satisfaction

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 order passed under section\n143(3) read with section 147 of the Income Tax Act (‘the\nAct’) as valid.\n\n2. The CIT(A) failed to appreciate the fact that in the reasons\nrecorded, the AO has not disclosed any specific non-\ndisclosure of material facts by the appellant.”\n\n8. We have heard the both the sides

TATA SOCIAL WELFARE TRUST,MUMBAI vs. PR CIT 17, MUMBAI

Bench: Us, Are As Follows: Assessment Year: 2019-20

3. The use of the word 'notice' in Section 12AA(4) relates to the aspect of the events coming to his/her knowledge. Mere notice of breach, it is respectfully, submitted would never suffice for the purposes of ordering a cancellation. If it is held so, it would mean that the Commissioner upon noticing a breach, without arriving at any satisfaction

SARVAJANIK SEVA TRUST ,MUMBAI vs. PR CIT 17, MUMBAI

Bench: Us, Are As Follows: Assessment Year: 2019-20

3. The use of the word 'notice' in Section 12AA(4) relates to the aspect of the events coming to his/her knowledge. Mere notice of breach, it is respectfully, submitted would never suffice for the purposes of ordering a cancellation. If it is held so, it would mean that the Commissioner upon noticing a breach, without arriving at any satisfaction

R D TATA TRUST,MUMBAI vs. PR CIT 17, MUMBAI

Bench: Us, Are As Follows: Assessment Year: 2019-20

3. The use of the word 'notice' in Section 12AA(4) relates to the aspect of the events coming to his/her knowledge. Mere notice of breach, it is respectfully, submitted would never suffice for the purposes of ordering a cancellation. If it is held so, it would mean that the Commissioner upon noticing a breach, without arriving at any satisfaction

TATA EDUCATION TRUST,MUMBAI vs. PR CIT 17, MUMBAI

3. The use of the word 'notice' in Section 12AA(4) relates to the aspect of the events coming to his/her knowledge. Mere notice of breach, it is respectfully, submitted would never suffice for the purposes of ordering a cancellation. If it is held so, it would mean that the Commissioner upon noticing a breach, without arriving at any satisfaction

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

11. On the other hand, the learned CIT DR, Shri B Shrinivasan argued that revision order passed by CIT under section 263 of the Act dated 30- 03-2017 has revised reassessment order framed by the AO under section 143(3

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- \ndisclosure of material facts by the appellant.” \n8. We have heard the both the sides in relation

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

Appeal is allowed

11. Per contra, Learned Departmental Representative vehemently contended that what was sought to be revised by the PCIT was the order, dated 30.12.2019, passed under 143(3) read with Section 147 of the Act and not the intimation issued under Section 143(1) of the Act. Taking the date of passing of the order under Section 143(3) read with

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

3) of the\nIncome tax Act and hence, such donations were taxable u/s 115BBC(1) of\nthe IT Act, unless exempted under sub-section (2) of sec. 115BC of the Act.\nThe other reason recorded by the assessing officer was to the effect that\nthe income received by the assessee in the form of ornaments and jewellery\nhas not been

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

3) of the\nIncome tax Act and hence, such donations were taxable u/s 115BBC(1) of\nthe IT Act, unless exempted under sub-section (2) of sec. 115BC of the Act.\nThe other reason recorded by the assessing officer was to the effect that\nthe income received by the assessee in the form of ornaments and jewellery\nhas not been

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

Accordingly, Ground No.1 to 4 raised by the Assessee are allowed

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

reassessment proceedings were initiated in the case of the Assessee which culminated into passing of Assessment Order, dated 29/06/2016 under Section 143(3) read with Section 147 of the Act. Thereafter, the case was again reopened under Section 147 of the Act after recording the reason and after obtaining the approval from the competent authority. The notice under Section

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

Accordingly, Ground No.1 to 4 raised by the Assessee are allowed

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

reassessment proceedings were initiated in the case of the Assessee which culminated into passing of Assessment Order, dated 29/06/2016 under Section 143(3) read with Section 147 of the Act. Thereafter, the case was again reopened under Section 147 of the Act after recording the reason and after obtaining the approval from the competent authority. The notice under Section