KASHYAP KANIYALAL MEHTA,MUMBAI vs. DCIT CC-4(1), MUMBAI

In the result, appeals of the assessee are allowed

reassessment proceedings initiated by notice u/s 148 has to be reckoned as pending in terms of 2nd proviso to section 153A, therefore, such an assessment for the AY 2011-12 which was sought to be reopened gets abated. Once the assessment is abated, the entire assessment is open and AO should have frame the assessment /re-assessment taking into consideration

KASHYAP KANIYALAL MEHTA,MUMBAI vs. DCIT CC-4(1), MUMBAI

In the result, appeals of the assessee are allowed

reassessment proceedings initiated by notice u/s 148 has to be reckoned as pending in terms of 2nd proviso to section 153A, therefore, such an assessment for the AY 2011-12 which was sought to be reopened gets abated. Once the assessment is abated, the entire assessment is open and AO should have frame the assessment /re-assessment taking into consideration

KASHYAP KANIYALAL MEHTA,MUMBAI vs. DCIT CC-4(1), MUMBAI

In the result, appeals of the assessee are allowed

reassessment proceedings initiated by notice u/s 148 has to be reckoned as pending in terms of 2nd proviso to section 153A, therefore, such an assessment for the AY 2011-12 which was sought to be reopened gets abated. Once the assessment is abated, the entire assessment is open and AO should have frame the assessment /re-assessment taking into consideration

KASHYAP KANIYALAL MEHTA,MUMBAI vs. DCIT, CC-4(1), MUMBAI

In the result, appeals of the assessee are allowed

reassessment proceedings initiated by notice u/s 148 has to be reckoned as pending in terms of 2nd proviso to section 153A, therefore, such an assessment for the AY 2011-12 which was sought to be reopened gets abated. Once the assessment is abated, the entire assessment is open and AO should have frame the assessment /re-assessment taking into consideration

KASHYAP KANIYALAL MEHTA,MUMBAI vs. DCIT CC-4(1), MUMBAI

In the result, appeals of the assessee are allowed

reassessment proceedings initiated by notice u/s 148 has to be reckoned as pending in terms of 2nd proviso to section 153A, therefore, such an assessment for the AY 2011-12 which was sought to be reopened gets abated. Once the assessment is abated, the entire assessment is open and AO should have frame the assessment /re-assessment taking into consideration

KASHYAP KANIYALAL MEHTA,MUMBAI vs. DCIT CC-4(1), MUMBAI

In the result, appeals of the assessee are allowed

reassessment proceedings initiated by notice u/s 148 has to be reckoned as pending in terms of 2nd proviso to section 153A, therefore, such an assessment for the AY 2011-12 which was sought to be reopened gets abated. Once the assessment is abated, the entire assessment is open and AO should have frame the assessment /re-assessment taking into consideration

KASHYAP KANIYALAL MEHTA,MUMBAI vs. DCIT CC-4(1), MUMBAI

In the result, appeals of the assessee are allowed

reassessment proceedings initiated by notice u/s 148 has to be reckoned as pending in terms of 2nd proviso to section 153A, therefore, such an assessment for the AY 2011-12 which was sought to be reopened gets abated. Once the assessment is abated, the entire assessment is open and AO should have frame the assessment /re-assessment taking into consideration

ADDL CIT R G 7(1), MUMBAI vs. NOVARTIS INDIA LTD ( FORMERLY KNOWN AS HINDUSTAN CIBA GIEGY LTD. ), MUMBAI

Bench: Shri Amit Shukla, Hon'Ble & Shri S. Rifaur Rahman, Hon'Blem/S. Novartis India Limited V. Asst. Commissioner Of Income –Tax - 7(2)(2) {Earlier Addl. Commissioner Of Income –Tax – 7(1)} 6Th& 7Th Floor 1St Floor, Aayakar Bhavan Inspire Bkc M.K. Road, Mumbai - 400020 “G” Block, Bkc Main Road Bandra Kurla Complex, Bandra (E) Mumbai – 400051 Pan: Aaach2914F (Appellant) (Respondent) Addl. Commissioner Of Income –Tax – 7(1) V. M/S. Novartis India Limited Room No. 622, Aayakar Bhavan {Earlier Known As Hindustan Ciba Giegy Ltd.,} Sandoz House, Dr. A.B. Road M.K. Road, Mumbai - 400020 Worli, Mumbai – 400018 Pan: Aaach2914F (Appellant) (Respondent) Co No.190/Mum/2011 [Arising Out Of Ita No.6772/Mum/2010 (A.Y. 2002-03)] M/S. Novartis India Limited V. Addl. Commissioner Of Income –Tax – 7(1)} Room No. 622, Aayakar Bhavan {Earlier Known As Hindustan Ciba Giegy Ltd.,} Sandoz House, Dr. A.B. Road M.K. Road, Mumbai - 400020 Worli, Mumbai – 400018 Pan: Aaach2914F (Appellant) (Respondent)

section 143(2) proceeding and was treated as such by the assessee preclude it from urging lack of jurisdiction." (emphasis supplied) (3) There is no interplay of section 127 as held in para 8, in the following words- "8. As far as the section 127 goes, we are of the opinion that having regard to the findings rendered, that question

CHEMOX EXPORTS IMPORTS PVT LTD,MUMBAI vs. INCOME TAX DEPARTMENT, ASSESSMENT UNIT, DELHI

reassessment proceedings under the\namended provision of law, more particularly, as amended by the Finance Act, 2021.\n17\nआयकर अपीलीय अधिकरण\nINCOME TAX APPELLATE TRIBUNAL\nI.T.A. No. 3954/Mum/2024\nIt never intended the authorities concerned to continue with the proceedings from\nthe stage of the issuance of notices under section 148, nor is the directions to that\neffect. And there cannot

HEMENDRA RAMJI VIRA ,MUMBAI vs. DCIT CC 4(1), MUMBAI

In the result, appeals of the assessee are allowed

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

reassessment proceedings. Once the competent authority namely, the PCIT– 27, Mumbai had transferred jurisdiction over the assessee to the DCIT, Central Circle 4(1), Mumbai by a valid and subsisting order under section 127

HEMENDRA RAMJI VIRA,MUMBAI vs. DCIT CC 4(1), MUMBAI

In the result, appeals of the assessee are allowed

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

reassessment proceedings. Once the competent authority namely, the PCIT– 27, Mumbai had transferred jurisdiction over the assessee to the DCIT, Central Circle 4(1), Mumbai by a valid and subsisting order under section 127

HEMENDRA RAMJI VIRA ,MUMBAI vs. DCIT CC 4(1), MUMBAI

In the result, appeals of the assessee are allowed

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

reassessment proceedings. Once the competent authority namely, the PCIT– 27, Mumbai had transferred jurisdiction over the assessee to the DCIT, Central Circle 4(1), Mumbai by a valid and subsisting order under section 127

HEMENDRA RAMJI VIRA ,MUMBAI vs. DCIT CC 4(1), MUMBAI

In the result, appeals of the assessee are allowed

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

reassessment proceedings. Once the competent authority namely, the PCIT– 27, Mumbai had transferred jurisdiction over the assessee to the DCIT, Central Circle 4(1), Mumbai by a valid and subsisting order under section 127

HEMENDRA RAMJI VIRA ,MUMBAI vs. DCIT CC-4(1), MUMBAI

In the result, appeals of the assessee are allowed

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

reassessment proceedings. Once the competent authority namely, the PCIT– 27, Mumbai had transferred jurisdiction over the assessee to the DCIT, Central Circle 4(1), Mumbai by a valid and subsisting order under section 127

HEMENDRA RAMJI VIRA ,MUMBAI vs. DCIT CC 4(1), MUMBAI

In the result, appeals of the assessee are allowed

reassessment proceedings. Once the competent authority namely, the PCIT– 27, Mumbai had transferred jurisdiction over the assessee to the DCIT, Central Circle 4(1), Mumbai by a valid and subsisting order under section 127

HEMENDRA RAMJI VIRA,MUMBAI vs. DCIT CC 4(1), MUMBAI

In the result, appeals of the assessee are allowed

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

reassessment proceedings. Once the competent authority namely, the PCIT– 27, Mumbai had transferred jurisdiction over the assessee to the DCIT, Central Circle 4(1), Mumbai by a valid and subsisting order under section 127

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