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

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

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

ABHUBHAI HIRABHAI DESAI,MUMBAI vs. DCIT CIRCLE 19(1), MUMBAI

In the result, the appeal of the assessee is allowed

119 of Annexure A-1\ncontained financial transaction in cash and cheque which belonged to\none Shri Kumar Mordani, who was partner in Paramvir Developers LLP.\nThe statement of Shri Jaikishin Rohra was recorded u/s.131 of the Act in\nwhich he stated that the said documents and transactions belonged to\nShri Mordani whose name appeared in the said seized page

ITO-28(3)(1), MUMBAI, MUMBAI vs. SATYA PRAKASH SINGH, MUMBAI

In the result, the ground so taken by the assessee so far as it relates to challenging the order of the AO as passed beyond the period of limitation is hereby allowed

Bench: Justice (Retd.) Shri C.V. Bhadang & Shri Vikram Singh Yadav

119, an order of assessment under section 143 or section 144 may be made at any time before the expiry of twelve months from the end of the financial year in which such return was furnished.] (2) No order of assessment, reassessment

MR. SATYA PRAKASH SINGH,MUMBAI vs. ITO, WARD-28(3)(1), VASHI

In the result, the ground so taken by the assessee so far as it relates to challenging the order of the AO as passed beyond the period of limitation is hereby allowed

Bench: Justice (Retd.) Shri C.V. Bhadang & Shri Vikram Singh Yadav

119, an order of assessment under section 143 or section 144 may be made at any time before the expiry of twelve months from the end of the financial year in which such return was furnished.] (2) No order of assessment, reassessment

SHRIVALLABH PITTE INDUSTRIES LTD ,MUMBAI vs. DY COMMISSIONER OF INCOME TAX,CENTRAL CIRLE -6(1) , MUMBAI

reassessment\npassed under clause (b) of section 153A in respect\nof each assessment year falling within six\n assessment years immediately preceding the\n assessment year relevant to the previous year in\nwhich search is conducted under section 132 or\nrequisition is made under section 132A. The\nprovision has also been made applicable to orders of\nassessment passed under clause

MR NILESH BHARANI,MUMBAI vs. DCIT CC 4(1), MUMBAI

Bench: Shri Amit Shukla, Jm & Shri Amarjit Singh, Am आयकरअपीलसं./ I.T.A. No. 612/Mum/2020 (निर्धारणवर्ा / Assessment Year: 2011-12)

reassessment, then he makes an assessment / reassessment of such income u/s 153A of the Act. 65. Now, the entire procedure is the same except under different sections having two separate contingencies. In our opinion, the Legislature has not left any discretion on the revenue officers to make the assessment /reassessment under any of the said set of provisions

HELIOS MERCANTILE LIMITED ,MUMBAI vs. DY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-6(1), MUMBAI, MUMBAI.

reassessment\npassed under clause (b) of section 153A in respect\nof each assessment year falling within six\n assessment years immediately preceding the\n assessment year relevant to the previous year in\nwhich search is conducted under section 132 or\nrequisition is made under section 132A. The\nprovision has also been made applicable to orders of\nassessment passed under clause

VINAY ARUN JOSHI,THANE vs. PCIT CENTRAL MUMBAI-1, MUMBAI

In the result, the appeal of the assessee is allowed

119; or\n(d) the order has not been passed in accordance with any decision which is\nprejudicial to the assessee, rendered by the jurisdictional High Court or\nSupreme Court in the case of the assessee or any other person.\"\n\n8.1 The above clauses of Explanation 2 to section 263 are quite lucid and\nclear and the present case

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

section 263 and set aside the reassessment proceedings for fresh consideration and set aside the reassessment proceedings for fresh consideration and set aside the reassessment proceedings for fresh consideration observing as under: “7. The above explanation at clause (c) clearly provides that the 7. The above explanation at clause (c) clearly provides that the 7. The above explanation at clause

DCIT, CENTRAL CIRCLE-8(1), MUMBAI, MUMBAI vs. E I RESORTS AND CLUBS PVT LTD, MUMBAI

3213/Mum/2025

Bench: SHRI AMIT SHUKLA (Judicial Member), SHRI ARUN KHODPIA (Accountant Member)

section 119 of the Act, has statutory force and is binding upon all officers of the Department. 44. The Circular admits of only limited exceptions in cases involving system outages, emergencies, or other exceptional circumstances and even then, mandates the recording of reasons in writing, prior approval of the Chief Commissioner or Director General, and contemporaneous documentation of such approval

DCIT, CENTRAL CIRCLE-8(1), MUMBAI, MUMBAI vs. EI RESORTS & CLUBS PVT LTD, MUMBAI

3213/Mum/2025

Bench: SHRI AMIT SHUKLA (Judicial Member), SHRI ARUN KHODPIA (Accountant Member)

section 119 of the Act, has statutory force and is binding upon all officers of the Department. 44. The Circular admits of only limited exceptions in cases involving system outages, emergencies, or other exceptional circumstances and even then, mandates the recording of reasons in writing, prior approval of the Chief Commissioner or Director General, and contemporaneous documentation of such approval

M/S MUMBADEVI VEYHICLES,MUMBAI vs. ITO WARD 41(4)(2), MUMBAI

In the result the appeal of the assessee is allowed

Bench: Shri Saktijit Dey & Shri Makarand Vasant Mahadeokarm/S. Mumbadevi Ito Ward 41(4)(2), Veyhicles Room No. 854B, 8Th Shop No. 18, Suyash Vs. Floor, Kautilya Shopping Centre, Nnp, A. Bhavan, Bkc, K. Vaidya Marg, Goregaon Bandra (East), (E), Mumbai-400 065 Mumbai-400 051 Pan/Gir No. Aaofm0851F (Applicant) (Respondent) Assessee By Ms. Dinkle Hariya & Ms. Sruti Kalyanikar, Ld. Ars Revenue By Shri Annavaram Kosuri, Ld. Dr Date Of Hearing 19.02.2026 Date Of Pronouncement 24.02.2026

reassessment proceedings. 13. The learned AR further invited our attention to the notice issued under section 148 of the Act dated 30.03.2021 placed on record. It was submitted that immediately upon receipt of the said notice, the assessee responded vide letter dated 25.04.2021, much prior to filing of the return of income in response to the said notice. Drawing

SVP SOUTH WEST INDUSTRIES LTD. (FORMERLY, PLATINUM TEXTILE LTD.),MUMBAI-400005 vs. COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-8(2), MUMBAI

Bench: Shri Prashant Maharishi, Am & Shri Sandeep Singh Karhail, Jm

reassessment passed under clause (b) of section 153A in respect of each assessment year falling within six assessment years immediately preceding the assessment year relevant to the previous year in which search is conducted under section 132 or requisition is made under section 132A. The provision has also been made applicable to orders of assessment passed under clause

ACIT (CC)-8(2) , MUMBAI vs. HELIOS EXPORTS LTD, MUMBAI

Bench: Shri Prashant Maharishi, Am & Shri Sandeep Singh Karhail, Jm

reassessment passed under clause (b) of section 153A in respect of each assessment year falling within six assessment years immediately preceding the assessment year relevant to the previous year in which search is conducted under section 132 or requisition is made under section 132A. The provision has also been made applicable to orders of assessment passed under clause

SVP GLOBAL TEXTILES LTD FORMERLY SVP GLOBAL VENTURES LTD MUMBAI ,MUMBAI vs. DY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-6(1), MUMBAI , MUMBAI

Bench: Shri Prashant Maharishi, Am & Shri Sandeep Singh Karhail, Jm

reassessment passed under clause (b) of section 153A in respect of each assessment year falling within six assessment years immediately preceding the assessment year relevant to the previous year in which search is conducted under section 132 or requisition is made under section 132A. The provision has also been made applicable to orders of assessment passed under clause