DCIT-1(2)1, MUMBAI., MUMBAI vs. PATIL CONSTRUCTION AND INFRASTRUCTURE LTD, MUMBAI

In the result In the result, all the three appeals filed by the revenue s filed by the revenue are dismissed

Bench: Shri Sandeep Gosain, Hon’Ble & Ms. Padmavathy S., Hon’Ble

139 of the Act. Similarly, the A.O. is also entitled to reexamine the issues and make a entitled to reexamine the issues and make a reassessment in respect of such return. However, the reassessment in respect of such return. However, the reassessment in respect of such return. However, the assessee assessee assessee is is is required required required

DCIT-1(2)1, MUMBAI, MUMBAI vs. PATIL CONSTRUCTION AND INFRASTRUCTURE LTD, MUMBAI

In the result In the result, all the three appeals filed by the revenue s filed by the revenue are dismissed

Bench: Shri Sandeep Gosain, Hon’Ble & Ms. Padmavathy S., Hon’Ble

139 of the Act. Similarly, the A.O. is also entitled to reexamine the issues and make a entitled to reexamine the issues and make a reassessment in respect of such return. However, the reassessment in respect of such return. However, the reassessment in respect of such return. However, the assessee assessee assessee is is is required required required

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

139, 147, 148, 149, 151 & 153. 28. The language of explanation 2 to new Section 148 is akin to Section 153A and Section 153C. Corollary being that after seizing of operational period of Section 153A to 153D, the P a g e | 18 ITA No. 3331, 3332/Mum/2019 A.Y. 2009-10, 2010-11 Shri Amit Mangilal Jain cases being dealt thereunder

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

section 139(5) of the Act. The reassessment was thereafter completed on 25.02.2022, wherein The reassessment was thereafter completed on 25.02.2022, wherein

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)

139, section 147, section 148, section 149, section 151 and section 153, where the Assessing Officer is satisfied that,— (a) any money, bullion, jewellery or other valuable article or 60 I.T.A. No. 612/Mum/2020 Mr. Nilesh Bharani thing, seized or requisitioned, belongs to; or (b) any books of account or documents, seized or requisitioned, pertains or pertain to, or any information

ANUMITA INFRASTRUCTURE PRIVATE LIMITED,MUMBAI vs. PCIT-4, MUMBAI

139(4) declaring total income of Rs. 19,370/-. The return was processed under section 143(1) and thereafter a regular assessment was completed under section 143(3) on 22.10.2019 by Central Circle- 2(2), Mumbai, determining income at Rs. 19,370/-.\n3. Subsequently, reassessment proceedings were initiated and notice under section 148 was issued on 29.07.2022. In response

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

139 is furnished, an order of assessment under section 143 or section 144 may be made at any time before the expiry of 8[twelve] months from the end of the financial year in which such return was furnished. 9[(1B) Notwithstanding anything in sub-section (1), where a return is furnished in consequence of an order under clause

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

139 is furnished, an order of assessment under section 143 or section 144 may be made at any time before the expiry of 8[twelve] months from the end of the financial year in which such return was furnished. 9[(1B) Notwithstanding anything in sub-section (1), where a return is furnished in consequence of an order under clause

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

In the result, the appeal of the assessee is allowed

5\nITA No. 4684/Mum/2025\nΑ.Υ. 2014-15\nAbhubhai Hirabhai Desai\non 24.11.2017.However,as claimed by the ld.AR, the AO withdrew the\nsaid notice and proceeding u/s 153C of the Act was dropped and instead\nproceeding u/s 148 of the Act was initiated vide notice u/s 148 of the Act\ndated 22.12.2017 for the relevant assessment year, as evident from

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

5. While completing the reassessment, the Assessing Officer initiated penalty proceedings under section 271(1)(c) of the Act for alleged concealment of income / furnishing of inaccurate particulars of income. Separate penalty proceedings under section 271F were also initiated for failure to file return under section 139

DCIT, CC-7(2), MUMBAI vs. M/S. PATANJALI FOODS LTD.,( FORMERLY KNOWN AS RUCHI SOYA INDUSTRIES LTD,, MUMBAI

In the result, the appeal and cross objections of the assessee are partly allowed and the appeals of the revenue are dismissed

Bench: Shri Aby T. Varkey, Jm & Shri S Rifaur Rahman, Am आयकर अपील सं/ I.T. A. No. 1172/Mum/2023 (निर्धारण वर्ा / Assessment Year: 2010-11) & आयकर अपील सं/ I.T. A. No. 1175/Mum/2023 (निर्धारण वर्ा / Assessment Year: 2012-13) & आयकर अपील सं/ I.T. A. No. 1176/Mum/2023 (निर्धारण वर्ा / Assessment Year: 2012-13)

reassessment, if any, relating to any assessment year falling within the period of six assessment years referred to in sub-section (1) is pending on the date of initiation of the search u/s. 132 of the Act shall abate. In the present case before us, however, though the second proviso to sub-section (1) of section 153A would not apply

M/S. PATANJALI FOODS LTD (FORMERLY KNOWN AS RUCHI SOYA INDUSTRIES LTD),MUMBAI vs. DY COMM OF INCOME TAX- CENTRAL CIRCLE-7(2), MUMBAI

In the result, the appeal and cross objections of the assessee are partly allowed and the appeals of the revenue are dismissed

Bench: Shri Aby T. Varkey, Jm & Shri S Rifaur Rahman, Am आयकर अपील सं/ I.T. A. No. 1172/Mum/2023 (निर्धारण वर्ा / Assessment Year: 2010-11) & आयकर अपील सं/ I.T. A. No. 1175/Mum/2023 (निर्धारण वर्ा / Assessment Year: 2012-13) & आयकर अपील सं/ I.T. A. No. 1176/Mum/2023 (निर्धारण वर्ा / Assessment Year: 2012-13)

reassessment, if any, relating to any assessment year falling within the period of six assessment years referred to in sub-section (1) is pending on the date of initiation of the search u/s. 132 of the Act shall abate. In the present case before us, however, though the second proviso to sub-section (1) of section 153A would not apply

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

In the result, appeals of the assessee are allowed

139; (b) assess or reassess the total income of six assessment years immediately preceding the assessment year relevant to the previous year in which such search is conducted or requisition is made [and for the relevant assessment year or years: 10 ITA No.6197-6203/Mum/2024 Kashyap Kaniyalal Mehta Provided that the Assessing Officer shall assess or reassess the total income in respect

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

In the result, appeals of the assessee are allowed

139; (b) assess or reassess the total income of six assessment years immediately preceding the assessment year relevant to the previous year in which such search is conducted or requisition is made [and for the relevant assessment year or years: 10 ITA No.6197-6203/Mum/2024 Kashyap Kaniyalal Mehta Provided that the Assessing Officer shall assess or reassess the total income in respect

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

In the result, appeals of the assessee are allowed

139; (b) assess or reassess the total income of six assessment years immediately preceding the assessment year relevant to the previous year in which such search is conducted or requisition is made [and for the relevant assessment year or years: 10 ITA No.6197-6203/Mum/2024 Kashyap Kaniyalal Mehta Provided that the Assessing Officer shall assess or reassess the total income in respect

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

In the result, appeals of the assessee are allowed

139; (b) assess or reassess the total income of six assessment years immediately preceding the assessment year relevant to the previous year in which such search is conducted or requisition is made [and for the relevant assessment year or years: 10 ITA No.6197-6203/Mum/2024 Kashyap Kaniyalal Mehta Provided that the Assessing Officer shall assess or reassess the total income in respect

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

In the result, appeals of the assessee are allowed

139; (b) assess or reassess the total income of six assessment years immediately preceding the assessment year relevant to the previous year in which such search is conducted or requisition is made [and for the relevant assessment year or years: 10 ITA No.6197-6203/Mum/2024 Kashyap Kaniyalal Mehta Provided that the Assessing Officer shall assess or reassess the total income in respect

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

In the result, appeals of the assessee are allowed

139; (b) assess or reassess the total income of six assessment years immediately preceding the assessment year relevant to the previous year in which such search is conducted or requisition is made [and for the relevant assessment year or years: 10 ITA No.6197-6203/Mum/2024 Kashyap Kaniyalal Mehta Provided that the Assessing Officer shall assess or reassess the total income in respect