SURENDRA GARG HUF ,MUMBAI vs. ITO- 19(3)(4), MUMBAI

reassessment proceedings initiated under Section\n147 of the Act. In that case also the judgment of the Hon'ble\nSupreme Court in the case of Abhisar Buildwell Private Ltd. (Supra)\ndealing with the interpretation of provisions contained in Section\n153A of the Act and the judgment of Hon'ble High Court of\nRajasthan in the case of Shyam Sunder Khandelwal

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

reassessment\nproceedings under Section 147 of the Act and the Assessment\nOrder, dated 29/12/2017, passed under Section 143(3) read\nwith Section 147 of Act are also quashed. Thus Ground No.1\nraised by the Assessee is allowed and Ground No.2 is dismissed\nas having been rendered infructuous.\nGround No.3 to 7:\n19. Ground No. 3 to 7 raised

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

reassessment\nproceedings under Section 147 of the Act and the Assessment\nOrder, dated 29/12/2017, passed under Section 143(3) read\nwith Section 147 of Act are also quashed. Thus Ground No.1\nraised by the Assessee is allowed and Ground No.2 is dismissed\nas having been rendered infructuous.\nGround No.3 to 7:\n19. Ground No. 3 to 7 raised

SURENDRA GARG HUF,MUMBAI vs. ITO - 19(3)(4), MUMBAI

reassessment proceedings initiated under Section\n147 of the Act. In that case also the judgment of the Hon'ble\nSupreme Court in the case of Abhisar Buildwell Private Ltd. (Supra)\ndealing with the interpretation of provisions contained in Section\n153A of the Act and the judgment of Hon'ble High Court of\nRajasthan in the case of Shyam Sunder Khandelwal

ESTATE OF VANDRAVAN P SHAH,MUMBAI vs. ASSISTANT COMISSIONER OF INCOME TAX, CIRCLE 19(3), MUMBAI

In the result all the three captioned appeals are dismissed

Bench: Sandeep Gosain () & Shri Om Prakash Kant ()

13, which relate to periods prior to the date of death. prior to the date of death. 9.2 Under the provisions of section 159 of the Act, the legal Under the provisions of section 159 of the Act, the legal Under the provisions of section 159 of the Act, the legal representative is deemed to be liable to di representative

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\nproceedings under Section 147 of the Act and the Assessment\nOrder, dated 29/12/2017, passed under Section 143(3) read\nwith Section 147 of Act are also quashed. Thus Ground No.1\nraised by the Assessee is allowed and Ground No.2 is dismissed\nas having been rendered infructuous.\n\nGround No.3 to 7:\n\n19.\nGround No. 3 to 7 raised

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

reassessment\nproceedings under Section 147 of the Act and the Assessment\nOrder, dated 29/12/2017, passed under Section 143(3) read\nwith Section 147 of Act are also quashed. Thus Ground No.1\nraised by the Assessee is allowed and Ground No.2 is dismissed\nas having been rendered infructuous.\n\nGround No.3 to 7:\n\n19. Ground No. 3 to 7 raised

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

reassessment \nproceedings under Section 147 of the Act and the Assessment \nOrder, dated 29/12/2017, passed under Section 143(3) read \nwith Section 147 of Act are also quashed. Thus Ground No.1 \nraised by the Assessee is allowed and Ground No.2 is dismissed \nas having been rendered infructuous. \nGround No.3 to 7: \n19. Ground No. 3 to 7 raised

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\nproceedings under Section 147 of the Act and the Assessment\nOrder, dated 29/12/2017, passed under Section 143(3) read\nwith Section 147 of Act are also quashed. Thus Ground No.1\nraised by the Assessee is allowed and Ground No.2 is dismissed\nas having been rendered infructuous.\n\nGround No.3 to 7:\n\n19. Ground No. 3 to 7 raised

JAYANTILAL RAJMAL SETH,MUMBAI vs. DCIT-CC-4(3), MUMBAI, MUMBAI

Bench: Shri Om Prakash Kant () & Shri Raj Kumar Chauhan () Assessment Year: 2018-19 Jayantilal Rajmal Seth, Dcit-Cc-4(3), A-3, Saibaba Shopping Centre, Bkc, Mumbai-400051. Mumbai Central, Vs. Mumbai-400008. Pan No. Agepj 0499 E Appellant Respondent

reassessment is valid if there is prima facie reason to believe that income has escaped assessment. AO is not required to believe that income has escaped assessment. AO is not required to believe that income has escaped assessment. AO is not required to conclusively prove escapement of income at the stage of to conclusively prove escapement of income

LIC HOUSING FINANCE LIMITED,MUMBAI vs. ACIT 2(2)(1), MUMBAI, AAYKAR BHAVAN, MUMBAI

In the result, the appeal of the assessee is allowed

Bench: Shri Om Prakash Kant () & Shri Raj Kumar Chauhan () Assessment Year: 2017-18

section 37(1) redundant. The statutory distinction between business 37(1) redundant. The statutory distinction between business 37(1) redundant. The statutory distinction between business deductions and Chapter VI deductions and Chapter VI-A incentives must be respected, and A incentives must be respected, and their misuse avoided in letter and spirit. their misuse avoided in letter and spirit. Accordingly

JCIT CENT. CIR. - 1(4), MUMBAI vs. GRASIM INDUSTRIES LTD, MUMBAI

The appeal of the Revenue is dismissed whereas appeal of the assessee is partly allowed for statistical purposes

Bench: Shri Om Prakash Kant () & Ms. Kavitha Rajagopal () Assessment Year: 2010-11 Grasim Industries Limited, The Dcit Cc-1(4), Corporate Finance Division, Room No. 902, 9Th Floor, Old Vs. A-2, Aditya Birla Centre, S.K. Cgo Building, M.K. Road, Ahire Marg, Worli, Mumbai-400020. Mumbai-400030. Pan No. Aaacg 4464 B Appellant Respondent Assessment Year: 2010-11 Jcit (Osd), Central Circle- Grasim Industries Limited, 1(4), A-Wing, 2Nd Floor, Aditya Room No. 902, Pratishtha Vs. Birla Centre, S.K. Ahire Bhavan, 9Th Floor, Old Cgo Marg, Worli, Building Annexe, Mumbai-400030. Mumbai-400020. Pan No. Aaacg 4464 B Appellant Respondent Assessee By : Mr. Yogesh Thar & Mr. Chaitanya Joshi Revenue By : Dr. Kishor Dhule, Cit-Dr Date Of Hearing : 03/04/2024 : Date Of Pronouncement 29/04/2024

reassessment under the provisions of section 153A/153C of the Act for the assessments/reassessments which have abated and those which the assessments/reassessments which have abated and those which the assessments/reassessments which have abated and those which have attained finality. have attained finality. 16.13 The use of the phrase 'so far as may be' in section 153(1)(a) implies 13

JAIN MACHINE TOOLS ,MUMBAI vs. INCOME TAX OFFICER, WARD 26(1)(7), MUMBAI

In the result, the appeal of the assessee is allowed

Bench: Shri Om Prakash Kant () & Shri Sunil Kumar Singh () Assessment Year: 2012-13 Jain Machine Tools, Ito, Ward 26(1)(7), 16, Meghal Industrial Estate, Room 625, 6Th Floor, Kautilya Vs. Devidayal Road, Mulund (West) Bhavan, C-41 To C-43, G Block, Mumbai-400080. Bandra Kurla Complex, Bandra (East), Mumbai-400051. Pan No. Aacfj 6163 H Appellant Respondent

13 , which was already scrutinized under section 143(3) of the Act but notice u/s 148 of the Act has been section 143(3) of the Act but notice u/s 148 of the Act has bee section 143(3) of the Act but notice u/s 148 of the Act has bee issued on 31/03/2019, which is beyond the period

SKF INDIA LIMITED ,MUMBAI vs. DCIT, 4(3)(1), , MUMBAI

In the result, the appeal by the assessee is allowed

Bench: Shri Sandeep Singh Karhailshri Bijayananda Prusethskf India Limited., 4Th Floor, Mahatma Gandhi Memorial Building, Mumbai Maharashtra - 400002 ............... Appellant Pan : Aaacs0684H

reassessment with a new regime. The first proviso to section 149 does not expressly bar the application of Taxation and other Laws (Relaxation and Amendment of Certain Provisions) Act, 2020, Section 3 of the Taxation and other Laws (Relaxation and Amendment of Certain Provisions) Act, 2020 applies to the entire Income-tax Act, including sections

SHRI AMIT MANGILAL JAIN,MUMBAI vs. ACIT, - 33(1), MUMBAI

In the result, both the above appeals are allowed

Bench: Shri Sandeep Gosain & Shri Prabhash Shankar

reassess income of such other persons in accordance with the provisions of section 153A of the Act. Therefore, it is mandatory for the AO to P a g e | 13

BIRLA CARBON INDIA PRIVATE LIMITED,MUMBAI vs. THE PRINCIPAL COMMISSIONER OF INCOME TAX, MUMBAI - 5, MUMBAI

In the result, the appeal is allowed as indicated above

Bench: Shri Saktijit Dey & Shri Narendra Kumar Billaiyabirla Carbon India Private Limited The Principal Commissioner Of Ground Floor, Aditya Birla Centre, Income Tax Room No. 515, 5Th Floor, Aaykar S. K. Ahire Marg, Worli, Vs. Mumbai-400 030 Bhavan, M. K. Road, Mumbai-400 020 Pan/Gir No. Aascs 9916 L (Appellant) : (Respondent) Appellant By : Shri Madhur Agarwal Respondent By : Shri Satyaprakash R. Singh Date Of Hearing : 16.09.2025 Date Of Pronouncement : 22.09.2025 O R D E R Per Saktijit Dey: In The Present Appeal, The Assessee Has Called Into Question The Validity Of The Order Dated 25.03.2025, Passed U/S. 263 Of The Income Tax Act, 1961 (‘The Act’ For Short) By Learned Principal Commissioner Of Income Tax (‘Ld.Pcit’ For Short), Pertaining To The Assessment Year (A.Y.) 2018-19. 2. Thought Multiple Grounds Have Been Raised In The Memorandum Of Appeal, However, The Assessee Has Raised A Pertinent Preliminary Issue, Challenging The Competence & Jurisdiction Of Ld. Pcit To Invoke Powers U/S. 263 Of The Act To Revise An Assessment Order Passed U/S. 144C(13) Of The Act, In Pursuance To The Directions Of Learned Dispute Resolution Panel (Ld. Drp).

13) Upon receipt of the directions issued under sub-section (5), the Assessing Officer shall, in conformity with the directions, complete, notwithstanding anything to the contrary contained in section 153 [or section 153B], the assessment without providing any further opportunity of being heard to the assessee, within one month from the end of the month in which such direction

ACCENTURE SOLUTIONS PRIVATE LIMITED,MUMBAI vs. DY. COMMISSIONER OF INCOME TAX, MUMBAI

In the result, the appeal is allowed as indicated above

Bench: Shri Saktijit Dey, Vp & Shri Girish Agrawal, Am Accenture Solutions Private Limited Pr. Cit, 501, 5Th Floor, Plat 3, Godrej & Boycee Compound, Vikhroli (W), Vikhroli S.O., Vs. Aayakar Bhavan, M. K. Road, Mumbai-400 079 Mumbai-400 020 Pan/Gir No. (Appellant) : (Respondent) Appellant By : Shri Nishant Thakkar Respondent By : Shri Satya Pal Kumar Date Of Hearing : 18.08.2025 Date Of Pronouncement : 28.08.2025 O R D E R Per Saktijit Dey, Vp: The Captioned Appeal Has Been Filed By The Assessee, Assailing The Order Dated 20.03.2025, Passed U/S. 263 Of Income Tax Act, 1961 (‘The Act’ For Short) By Learned Principal Commissioner Of Income Tax, Mumbai-6 (‘Ld. Pcit’ For Short), Pertaining To The Assessment Year (A.Y.) 2017-18. 2. We Have Heard The Parties & Perused The Materials Available On Record. The Short Issue Arising For Consideration Is Whether The Final Assessment Order Passed U/S. 144C(13) Of The Act, Can Be Subjected To Revisionary Jurisdiction U/S. 263 Of The Act. For Deciding This Issue, Few Necessary Facts Are Required To Be Considered. The Assessee Is A Resident Corporate Entity Engaged In The Business Of Providing Information Technology (It)/Information Technology Enabled Service (Ites) To Its Group Companies As Well As Consulting Services To Its Clients. For The Assessment Year Under Dispute, The Assessee Filed

13) Upon receipt of the directions issued under sub-section (5), the Assessing Officer shall, in conformity with the directions, complete, notwithstanding anything to the contrary contained in section 153 [or section 153B], the assessment without providing any further opportunity of being heard to the assessee, within one month from the end of the month in which such direction

MONDELEZ INDIA FOODS PRIVATE LIMITED ,MUMBAI vs. PRINCIPAL COMMISSIONER OF INCOME TAX -8 , MUMBAI

In the result, the appeal by the assessee stands partly allowed

Bench: Hon’Ble Shri Sandeep Gosain& Hon’Ble Shri Prabhash Shankarmondelez India Foods Vs. Principal Commissioner Private Limited Of Income-Tax, Mumbai- Unit No. 2001, 20Th Floor, 8 Tower-3 (Wing C), One 611, 6Th Floor, Aayakar International Cente Bhavan, Maharshi (Formerly Indiabulls Finance Karve Road, Mumbai- Centre) Parel, Mumbai- 400020 400013 Pan/Gir No. Aaacc0460H (Applicant) (Respondent) Assessee By Shri Nishant Thakker & Hiten Thakkar Revenue By Shri Krishna Kumar (Sr. Dr.) Date Of Hearing 19.02.2026 Date Of Pronouncement 27.03.2026 आदेश / Order Per Sandeep Gosain, Jm: The Present Appeal Has Been Filed By The Assessee Challenging The Impugned Order Dated 20.03.2025 Passed U/S 263 Of The Income Tax Act, 1961 (‘The Act’), By The Principal Commissioner Of Income Tax – Pcit, Mumbai-8 (‘The Ld. Pcit’) For The Assessment Year 2018-19. The Following Grounds Are Reproduced Below:

13) Upon receipt of the directions issued under sub-section (5), the Assessing Officer shall, in conformity with the directions, complete, notwithstanding anything to the contrary contained in section 153 [or section 153B], the assessment without providing any further opportunity of being heard to the assessee, within one month from the end of the month in which such direction