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

Section 37(1) of the Act.We have perused the aforesaid decision of the Tribunal in that case it was stated, during the assessment proceeding, the assessing officer noted that as per material available on record, the Director General of Central Excise Intelligence, Chennai Zone (DGCEI) had carried out investigation in respect of certain auto dealers and intermediaries. In course

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)

Section 37(1) of the Act.We have perused the aforesaid decision of the Tribunal in that case it was stated, during the assessment proceeding, the assessing officer noted that as per material available on record, the Director General of Central Excise Intelligence, Chennai Zone (DGCEI) had carried out investigation in respect of certain auto dealers and intermediaries. In course

SHANTILAL NAROTTAMDAS PANCHAL,MALAD EAST vs. ITO-41(3)(4), MUMBAI, BANDRA KURLA COMPLEX

Appeal is allowed

Bench: Him.

reassessment notices under Section 148 of the new regime. The surviving or balance time limit can be calculated by computing the number of days between the date of issuance of the deemed notice and 30 June 2021." 6.4.7. Further in para 110- "The effect of the creation of the legal fiction in Ashish Agarwal (supra) was that it stopped

DCIT-CC(5), MUMBAI vs. LARSEN & TOUBRO LIMITED, MUMBAI

In the result, for A.Y. 2015-16, appeal by the revenue is dismissed and cross objection by the assessee is allowed

Bench: Shri Amit Shukla & Shri Girish Agrawal

reassessment notices under section 148 of the new regime. 112. Let us take the instance of a notice issued on 1 May 2021 under

DCIT-CC- 5(4), MUMBAI vs. LARSEN & TOUBRO LIMITED, MUMBAI

In the result, for A.Y. 2015-16, appeal by the revenue is dismissed and cross objection by the assessee is allowed

Bench: Shri Amit Shukla & Shri Girish Agrawal

reassessment notices under section 148 of the new regime. 112. Let us take the instance of a notice issued on 1 May 2021 under

INCOME TAX OFFICER-12(3)(1), MUMBAI, MUMBAI vs. MANJU DIAMONDS PVT. LTD., MUMBAI

In the result, the appeal of the Revenue is allowed for statistical purposes whereas the application under Rule 27 of statistical purposes whereas the application under Rule 27

Bench: Shri Om Prakash Kant () & Shri Raj Kumar Chauhan () Assessment Year: 2017-18 Ito-12(3)(1), Manju Diamonds Pvt. Ltd., R.No. 145, 1St Floor, Aayakar 57/59, 1St Floor, Nagdevi Street, Vs. Bhavan, M.K. Road, Maszid Bunder, Mumbai-400020. Mumbai-400 003. Pan No. Aaecm 6609 G Appellant Respondent

Section 68 of the Act. 4.6 Aggrieved thereby, the assessee preferred an a Aggrieved thereby, the assessee preferred an appeal before the ppeal before the ld CIT(A), challenging both the validity of the reassessment ld CIT(A), challenging both the validity of the reassessment ld CIT(A), challenging both the validity of the reassessment proceedings as well

IMPRESSIVE TRADING PRIVATE LIMITED,MUMBAI vs. INCOME TAX OFFICER 10(1)(1), MUMBAI

In the result, all the above appeals in ITA Nos

Bench: Shri Narendra Kumar Choudhry & Shri Prabhash Shankar

reassessment notices under Section 148 of the new regime. 112. Let us take the instance of a notice issued on 1 May 2021 under

IMPRESSIVE TRADING PRIVATE LIMITED,MUMBAI vs. INCOME TAX OFFICER 10(1)(1), MUMBAI

In the result, all the above appeals in ITA Nos

Bench: Shri Narendra Kumar Choudhry & Shri Prabhash Shankar

reassessment notices under Section 148 of the new regime. 112. Let us take the instance of a notice issued on 1 May 2021 under

APCOTEX INDUSTRIES LIMITED,RAOGARH vs. INCOME TAX OFFICER - CIRCLE 15(1)(1), MUMBAI

section 148 were beyond the permissible time limit and, therefore, the entire reassessment proceedings are void ab initio and liable to be quashed.\n12. The learned AR placed reliance on the judgment of the Hon'ble Supreme Court in the case of Union of India v. Rajeev Bansal reported in 167 taxmann.com 70 (SC), and drew our attention to para

RAMESH AMRATLAL BRAHMBHATT ,MUMBAI vs. ITO WARD 34(3)(2), MUMBAI

In the result, the reassessment order dated 20

Bench: Shri Saktijit Dey & Shri Makarand Vasant Mahadeokarramesh Amratlal Ito Ward 34(3)(2), Brahmbhatt Kautilya Bhavan, 43 Rajnigandha, Vs. Bandra Kurla Gulmohar Cross Road No. Complex, Mumbai – 11, J V P D Scheme, 400 051 Juhu, Mumbai-400 049 Pan/Gir No. Aabpb7235R (Applicant) (Respondent) Assessee By Shri K. Gopal & Ms. Neha Paranjpe, Ld. Ars Revenue By Shri Annavaram Kosuri, Ld. Dr Date Of Hearing 23.02.2026 Date Of Pronouncement 25.02.2026

reassessment proceedings and confirmed the addition under section 68. Aggrieved, the assessee is in appeal before us. 6. The learned Authorised Representative (AR) submitted that the notice issued under section 148 dated 29.07.2022 is barred by limitation in view of the decision of the Hon’ble Supreme Court in UOI v. Rajeev Bansal [2024] 469 ITR 46 (SC). A comparative

LESHARK GLOBAL LLP ,MUMBAI vs. DCIT CC 4(1), MUMBAI

In the result, all the appeals for A

Bench: SHRI AMIT SHUKLA (Judicial Member), SHRI GIRISH AGRAWAL (Accountant Member)

reassess taking into consideration the other material in respect of completed assessments/unabated assessments. Meaning thereby, in respect of completed/unabated assessments, no addition can be made by the AO in absence of any incriminating material found during the course of search under Section 132 or requisition under Section 132-A of the 1961 Act. However, the completed/unabated assessments

LESHARK GLOBAL LLP ,MUMBAI vs. DCIT CC 4(1), MUMBAI

In the result, all the appeals for A

Bench: SHRI AMIT SHUKLA (Judicial Member), SHRI GIRISH AGRAWAL (Accountant Member)

reassess taking into consideration the other material in respect of completed assessments/unabated assessments. Meaning thereby, in respect of completed/unabated assessments, no addition can be made by the AO in absence of any incriminating material found during the course of search under Section 132 or requisition under Section 132-A of the 1961 Act. However, the completed/unabated assessments

LESHARK GLOBAL LLP ,MUMBAI vs. DCIT CC 4(1), MUMBAI

In the result, all the appeals for A

reassess taking into consideration the other material in respect of completed assessments/unabated assessments. Meaning thereby, in respect of completed/unabated assessments, no addition can be made by the AO in absence of any incriminating material found during the course of search under Section 132 or requisition under Section 132-A of the 1961 Act. However, the completed/unabated assessments

ASST.COMMISSIONER OF INCOME TAX, BANDRA KURLA COMPLEX MUMBAI vs. DEVANG AJIT JAVERI , MUMBAI

In the result, appeal of the Revenue is dismissed on aforesaid terms

Bench: SHRI AMIT SHUKLA (Judicial Member), SHRI GIRISH AGRAWAL (Accountant Member)

reassessment notices under Section 148 of prescribed under the Income Tax Act read with TOLA, was available to the assessing new officers the regime. 112

DEVANG AJIT JHAVERI,MUMBAI vs. JCIT, RANGE 17(1), MUMBAI

In the result, appeal of the Revenue is dismissed on aforesaid terms

Bench: SHRI AMIT SHUKLA (Judicial Member), SHRI GIRISH AGRAWAL (Accountant Member)

reassessment notices under Section 148 of prescribed under the Income Tax Act read with TOLA, was available to the assessing new officers the regime. 112

ITO WD 11(3)(1), MUMBAI, AAYAKAR BHAVAN MUMBAI vs. VALEE DEVELOPERS PRIVATE LIMITED, PLOT NO. , PARK ESTATE,

In the result, appeal of the Revenue is dismissed

Bench: SHRI AMIT SHUKLA (Judicial Member), SHRI PRABHASH SHANKAR (Accountant Member)

reassessment notices under section 148 of the new regime. 112. Let us take the instance of a notice issued on 1 May 2021 under

RAJ INTERNATIONAL LIMITED,MUMBAI vs. DEPUTY COMMISSIONER OF INCOME TAX, CIRCLE-4(3)(1), MUMBAI

Bench: Shri Pawan Singh, Jm & Ms Padmavathy S, Am

reassessment notices under section 148 of the new regime. 112. Let us take the instance of a notice issued on 1 May 2021 under

RAJ INTERNATIONAL LIMITED,MUMBAI vs. DEPUTY COMMISSIONER OF INCOME TAX, CIRCLE-4(3)(1), MUMBAI

Bench: Shri Pawan Singh, Jm & Ms Padmavathy S, Am

reassessment notices under section 148 of the new regime. 112. Let us take the instance of a notice issued on 1 May 2021 under