INCOME TAX OFFICER (IT)-3(2)(1), KAUTILYA BHAWAN vs. SHAPOORJI PALLONJI MISTRY, MUMBAI

In the result, appeal filed by the Revenue is dismissed

Bench: Shri Amit Shukla & Shri Girish Agrawal

132 for which the last of authorisations is executed; or (c) a requisition made under section 132A, after the 15th day of March of such financial year, a period of fifteen days shall be excluded for the purpose of computing the period of limitation as per this section and the notice issued under clause (b) of section 148A in such

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

132", "Section 132A", "Section 131" ], "issues": "1. Whether the reassessment proceedings initiated under Section 147 of the Act were valid

ASSISTANT COMMISSIONER OF INCOME TAX, KAUTILYA BHAWAN vs. JAJ INTERNATIONAL, MUMBAI

In the result, the grounds relating to merit the file of the Ld

Bench: Shri Om Prakash Kant () & Shri Sunil Kumar Singh ()

132 or making of requisition under section 132A in the second proviso to sub section 132A in the second proviso to sub-section (1) of section 153A shall section (1) of section 153A shall be construed as reference to the date of receiving the books of account or rued as reference to the date of receiving the books of account

ASSISTANT COMMISSIONER OF INCOME TAX CIRCLE- 41(1)(1), MUMBAI, KAUTILYA BHAWAN, BKC vs. JAJ INTERNATIONAL, MUMBAI

In the result, the grounds relating to merit the file of the Ld

Bench: Shri Om Prakash Kant () & Shri Sunil Kumar Singh ()

132 or making of requisition under section 132A in the second proviso to sub section 132A in the second proviso to sub-section (1) of section 153A shall section (1) of section 153A shall be construed as reference to the date of receiving the books of account or rued as reference to the date of receiving the books of account

INCOME TAX OFFICER (INTERNATIONAL TAXATION) 3(2)(1), KAUTILYA BHAWAN MUMBAI vs. SHAPOORJI PALLONJI MISTRY, MUMBAI

In the result, both appeals by the Revenue are dismissed and the\ntwo Cross Objections of the assessee are allowed

132 for which the last of authorisations is executed;\nor\n(c) a requisition made under section 132A,\nafter the 15th day of March of such financial year, a period of fifteen days\nshall be excluded for the purpose of computing the period of limitation as per\nthis section and the notice issued under clause (b) of section 148A

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

sections": [ "143(1)", "147", "10(38)", "68", "148", "153C", "132", "132A", "153A", "131", "10(38)" ], "issues": "1. Whether reassessment proceedings

ITO(IT)-3(2)(1), MUMBAI vs. SHAPOORJI PALLONJI MISTRY, MUMBAI

In the result, both appeals by the Revenue are dismissed and the\ntwo Cross Objections of the assessee are allowed

132 for which the last of authorisations is executed;\nor\n(c) a requisition made under section 132A,\nafter the 15th day of March of such financial year, a period of fifteen days\nshall be excluded for the purpose of computing the period of limitation as per\nthis section and the notice issued under clause (b) of section 148A

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

In the result, appeals of the assessee are allowed

1) of the Act w.e.f. 01/04/2017 which envisages, ―Provided further that assessment or reassessment, if any, relating to any assessment year falling within the period of six assessment years and for the relevant assessment year or years referred to in this sub-section pending on the date of initiation of the search under section 132

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

In the result, appeals of the assessee are allowed

1) of the Act w.e.f. 01/04/2017 which envisages, ―Provided further that assessment or reassessment, if any, relating to any assessment year falling within the period of six assessment years and for the relevant assessment year or years referred to in this sub-section pending on the date of initiation of the search under section 132

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

In the result, appeals of the assessee are allowed

1) of the Act w.e.f. 01/04/2017 which envisages, ―Provided further that assessment or reassessment, if any, relating to any assessment year falling within the period of six assessment years and for the relevant assessment year or years referred to in this sub-section pending on the date of initiation of the search under section 132

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

In the result, appeals of the assessee are allowed

1) of the Act w.e.f. 01/04/2017 which envisages, ―Provided further that assessment or reassessment, if any, relating to any assessment year falling within the period of six assessment years and for the relevant assessment year or years referred to in this sub-section pending on the date of initiation of the search under section 132

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

In the result, appeals of the assessee are allowed

1) of the Act w.e.f. 01/04/2017 which envisages, ―Provided further that assessment or reassessment, if any, relating to any assessment year falling within the period of six assessment years and for the relevant assessment year or years referred to in this sub-section pending on the date of initiation of the search under section 132

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

In the result, appeals of the assessee are allowed

1) of the Act w.e.f. 01/04/2017 which envisages, ―Provided further that assessment or reassessment, if any, relating to any assessment year falling within the period of six assessment years and for the relevant assessment year or years referred to in this sub-section pending on the date of initiation of the search under section 132

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

In the result, appeals of the assessee are allowed

1) of the Act w.e.f. 01/04/2017 which envisages, ―Provided further that assessment or reassessment, if any, relating to any assessment year falling within the period of six assessment years and for the relevant assessment year or years referred to in this sub-section pending on the date of initiation of the search under section 132

DEVANAND AMARNATH PARKAR,JOGESHWARI EAST, MUMBAI vs. INCOME TAX OFFICER 41(4)(1), KAUTILYA BHAWAN, BKC, BANDRA EAST

In the result, appeal by the assessee is allowed

132 for which the last of authorisations is executed; or\n(c) a requisition made under section 132A,\nafter the 15th day of March of such financial year, a period of fifteen days shall be\nexcluded for the purpose of computing the period of limitation as per this section and\nthe notice issued under clause (b) of section 148A

PRAFUL ARJUN RANE ,MUMBAI vs. ITO INT TAX WARD-4(1)(1), MUMBAI

In the result, appeal of the assessee is allowed

Bench: SHRI SAKTIJIT DEY, HON’BLE (Vice President), SHRI GIRISH AGRAWAL (Accountant Member)

132 for which the last of authorisations is executed; or (c) a requisition made under section 132A, after the 15th day of March of such financial year, a period of fifteen days shall be excluded for the purpose of computing the period of limitation as per this section and the notice issued under clause (b) of section 148A in such

SUDESH DHANRAJ MURPANA (HUF),MUMBAI vs. THE INCOME TAX OFFICER, WARD 23(3)(1, MUMBAI

In the result, appeal of the assessee is allowed

Bench: Shri Amit Shukla & Shri Girish Agrawalassessment Year: 2013-14 Sudesh Dhanraj Murpana Income Tax Officer – 23(3) (1) (Huf) Matru Mandir, Tardeo, Grant 401 Somdhan Bldg, Perry Road, Cross Road Bandra (West), Vs. Mumbai - 400007 Mumbai 400050

reassessment proceedings, notice under section 148A(b) was issued on 18.06.2022, for which order under section 148A(d) was passed on 20.07.2022. Subsequently, notice under section 148 was issued on 20.07.2022. Computation of limitation as per decision of, Hon’ble Supreme Court in the case of, UOI vs. Rajeev Bansal [2024] 167 taxmann.com

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)

section 153A (1)(a) of the Act, it is clear that it was mandatory for the AO of the person searched u/s 132 of the Act to issue a notice of assessment / reassessment

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)

132 or making of requisition under section 132A in the second proviso tosub-section (1) of section 153A shall be construed as reference to the date of receiving the books of account or documents or assets seized or requisitioned by the Assessing Officer having jurisdiction over such other person: Provided further that the Central Government may by rules made