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

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

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

8 & 11 of F&U guidelines dated\n28/09/2006 and circular no:048/IRDA/De-tariff/Dec-07\ndated 18th Dec, 2007.\nb) Circular ref.no.IRDA/CIR/011/2003 dated 27-03-2003.\nc) Commission circular ref.no.011/IRDA/Brok-comm/Aug-08,\ndated 25-08-2008 and para 30 of F&U guidelines dated\n28/09/2006.\nd) Regulation 3 of IRDA (Licensing of Corporate Agent)\nRegulation, 2002 and clause 21 of IRDA circular\nref.017/IRDA/Circular/CA

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

8 & 11 of F&U guidelines dated\n28/09/2006 and circular no:048/IRDA/De-tariff/Dec-07\ndated 18th Dec, 2007.\nb) Circular ref.no.IRDA/CIR/011/2003 dated 27-03-2003.\nc) Commission circular ref.no.011/IRDA/Brok-comm/Aug-08,\ndated 25-08-2008 and para 30 of F&U guidelines dated\n28/09/2006.\nd) Regulation 3 of IRDA (Licensing of Corporate Agent)\nRegulation, 2002 and clause 21 of IRDA circular\nref.017/IRDA/Circular/CA

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 ()

8. At the outset, the assessee addressed Ground No. 2 of the At the outset, the assessee addressed Ground No. 2 of the At the outset, the assessee addressed Ground No. 2 of the appeal and contended that the assessment had been invalidly appeal and contended that the assessment had b appeal and contended that the assessment had b completed

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

8 & 11 of F&U guidelines dated\n28/09/2006 and circular no:048/IRDA/De-tariff/Dec-07\ndated 18th Dec, 2007.\n\nb) Circular ref.no.IRDA/CIR/011/2003 dated 27-03-2003.\n\nc) Commission circular ref.no.011/IRDA/Brok-comm/Aug-08,\ndated 25-08-2008 and para 30 of F&U guidelines dated\n28/09/2006.\n\nd) Regulation 3 of IRDA (Licensing of Corporate Agent)\nRegulation, 2002 and clause

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)

8 & 11 of F&U guidelines dated\n28/09/2006 and circular no:048/IRDA/De-tariff/Dec-07\ndated 18th Dec, 2007.\n\nb) Circular ref.no.IRDA/CIR/011/2003 dated 27-03-2003.\n\nc) Commission circular ref.no.011/IRDA/Brok-comm/Aug-08,\ndated 25-08-2008 and para 30 of F&U guidelines dated\n28/09/2006.\n\nd) Regulation 3 of IRDA (Licensing of Corporate Agent)\nRegulation, 2002 and clause

SALTWATER STUDIO LLP,MUM vs. NATIONAL FACELESS ASSESSMENT CENTRE, DELHI

In the result, the appeal of the assessee is allowed

Bench: Shri Aby T. Varkey, Jm & Shri Om Prakash Kant, Am आयकरअपीलसं/ I.T.A. No.13/Mum/2023 (निर्धारणवर्ा / Assessment Year: 2017-18) बिधम / Saltwater Studio Llp Nfac, Delhi 103, Corporate Corner, F Block, Northe Block, Vs. Sunder Nagar, Near Dalmia New Delhi-110001 College, Malad (West) Mumbai-400 064 स्थधयीलेखधसं/.जीआइआरसं/.Pan/Gir No. : Ackfs1653D (अपीलार्थी / Appellant) .. (प्रत्यर्थी / Respondent)

reassessed or recomputed in a preceding order. (11) No addition or disallowance of an amount shall form the basis for imposition of penalty, if such addition or disallowance has formed the basis of imposition penalty in the case of the person for the same or any other assessment year. (12) The penalty referred to in sub-section (1) shall

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

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

8 & 11 of F&U guidelines dated \n28/09/2006 and circular no:048/IRDA/De-tariff/Dec-07 \ndated 18th Dec, 2007. \nb) Circular ref.no.IRDA/CIR/011/2003 dated 27-03-2003. \nc) Commission circular ref.no.011/IRDA/Brok-comm/Aug-08, \ndated 25-08-2008 and para 30 of F&U guidelines dated \n28/09/2006. \nd) Regulation 3 of IRDA (Licensing of Corporate Agent) \nRegulation, 2002 and clause 21 of IRDA circular \nref.017/IRDA/Circular/CA

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

8 & 11 of F&U guidelines dated\n28/09/2006 and circular no:048/IRDA/De-tariff/Dec-07\ndated 18th Dec, 2007.\nb) Circular ref.no.IRDA/CIR/011/2003 dated 27-03-2003.\nc) Commission circular ref.no.011/IRDA/Brok-comm/Aug-08,\ndated 25-08-2008 and para 30 of F&U guidelines dated\n28/09/2006.\nd) Regulation 3 of IRDA (Licensing of Corporate Agent)\nRegulation, 2002 and clause 21 of IRDA circular\nref.017/IRDA/Circular/CA

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

8 of Hon'ble Supreme Court order). 9.2 The assessee submits that the impugned notice u/s. 148A(b) 9.2 The assessee submits that the impugned notice u/s. 148A(b) 9.2 The assessee submits that the impugned notice u/s. 148A(b) had been issued merely relying on the information received from had been issued merely relying on the information received from

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

13 The use of the phrase 'so far as may be' in section 153(1)(a) implies that all the provisions of the IT Act as contained under Chapter AV that all the provisions of the IT Act as contained under Chapter AV that all the provisions of the IT Act as contained under Chapter AV prescribing the procedure

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

8. In the facts and circumstances of the case and in law, the Learned CIT(A) has erred in upholding the reassessment proceedings which was CIT(A) has erred in upholding the reassessment proceedings which was CIT(A) has erred in upholding the reassessment proceedings which was initiated with a mechanical and invalid sanction granted initiated with a mechanical

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

8. We have considered the submissions of both sides and perused the material available on record. We, at the outset, find that similar issue pertaining to the challenge against notices issued under section 148 of the Act for the assessment year 2015-16 on the basis that same are beyond the limitation period prescribed under section

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

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

reassessment cannot be examined in proceedings arising from section 263 is devoid of merit. It is well- proceedings arising from section 263 is devoid of merit. proceedings arising from section 263 is devoid of merit. settled that a jurisdictional defect strikes at the foundation of settled that a jurisdictional defect strikes at the foundation of settled that a jurisdictional defect