NAVNIDHI STEEL AND ENGG CO. P.LTD,MUMBAI vs. DCIT 5(2)(1), MUMBAI

The appeal of the assessee is dismissed

Bench: Shri Joginder Singh, Assessment Year: 2007-08

reassessment proceedings even when intimation under section 143(1) had been issued. 19. Inevitable conclusion is that High Court has wrongly applied Adani Exports case (supra) which has no application to the case on the facts in view of the conceptual difference between section 143(1) and section 143(3) of the Act. 24 Navnidhi Steel & Engg

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

reassess under unamended section 147, (b) issuance of notice under unamended section 148, (c) in accordance with time limit in terms of unamended section 149 and (d) sanction under unamended section 151 of the Act. 3 ITA Nos. 3674/Mum/2025 and ors. Shapoorji Pallonji Mistry AYs 2015-16 and 2016-17 5. Whether section 3(1) of TOLA creates a legal

MAHARASHTRA STATE ELECTRICITY TRANSMISSION COMPANY LTD.,,MUMBAI vs. THE INCOME TAX OFFICER, WARD-14(2)(3), MUMBAI

In the result, the appeal of the assessee is al

Bench: Shri Vikas Awasthy () & Shri Om Prakash Kant () Assessment Year: 2011-12 Maharashtra State Electricity Income-Tax Officer, Ward Transmission Company Ltd., 14(2)(3), Plot No. C-19 E Block, Vs. Aayakar Bhavan, Maharshi Prakashganga, Bandra-Kurla Karve Road, Complex, Bandra (East), Mumbai-400020. Mumbai-400051. Pan No. Aaecm 2936 N Appellant Respondent Assessee By : Mr. Ketan Ved, Ar Revenue By : Mr. Harishankar Lal, Dr : Date Of Hearing 15/11/2022 Date Of Pronouncement : 29/12/2022

142(1) r/w 143(2), which finally culminated in the assessment order dated 30th December culminated in the assessment order dated 30th December culminated in the assessment order dated 30th December 2008 under section 143(3). It is therefore e 2008 under section 143(3). It is therefore evident that vident that Respondent No. 1 after passing the original assessment

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

1)(b) of the Act. Consequently, the reassessment proceedings and orders were quashed.", "result": "Dismissed", "sections": [ "147", "148", "148A", "149", "151", "143(3)", "68", "142

SHYAM KUMAR SADASHIVAN PILLAI,MUMBAI vs. INCOME TAX OFFICER, CIRCLE 27(3)(1), NAVI MUMBAI

In the result, the appeal is allowed

Bench: Ms Padmavathy S, Am & Shri Raj Kumar Chauhan, Jm

reassessment proceedings. Sec. 142(1) of the Act contemplates enquiry before assessment in order to determine the true and correct income of the assessee and it is the duty of every assessee to cooperate with and join the proceedings to ascertain the truth regarding cases. The purpose of the penal provision contained in Section

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

142(1) issued wherein Approval of 156-157\nTax.\nPrincipal Chief Commissioner of Income\nInternational Taxation. New Delhi dated\n27th July 2022 for order u/s 148A(d) and issued\nof notice u/s 148 was provided\n18. 30th May 2023\nDraft assessment order u/s 144C(1) r.w.s 147 158-169\nwas passed proposing addition of\nRs.28,50,30,661/- while computing

BALAJI UNIVERSAL TRADELINK P.LTD,MUMBAI vs. DCIT CEN CIR 40, MUMBAI

The appeals of the assessee are allowed and that of the Revenue are dismissed

Bench: Shri Joginder Singh & Shri Sanjay Arora

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. 2.11. From the aforesaid provision, it is clear that the first requirement is valid initiation of search. The Revenue has executed warrant of authorization in the name of the assessee company

ASST CIT CIR 2, THANE vs. SALASAR DEVELOPERS, THANE

The appeals of the Revenue are dismissed

Bench: Shri Joginder Singh & Shri N.K. Pradhan

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. 2.11. From the aforesaid provision, it is clear that the first requirement is valid initiation of search. The Revenue has executed warrant of authorization in the name of the assessee company

ASST CIT CIR 2, THANE vs. SALASAR DEVELOPERS, THANE

The appeals of the Revenue are dismissed

Bench: Shri Joginder Singh & Shri N.K. Pradhan

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. 2.11. From the aforesaid provision, it is clear that the first requirement is valid initiation of search. The Revenue has executed warrant of authorization in the name of the assessee company

ASST CIT CIR 2, THANE vs. SALASAR DEVELOPERS, THANE

The appeals of the Revenue are dismissed

Bench: Shri Joginder Singh & Shri N.K. Pradhan

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. 2.11. From the aforesaid provision, it is clear that the first requirement is valid initiation of search. The Revenue has executed warrant of authorization in the name of the assessee company

M/S.BALAJI BULLION & COMMODITIES (INDIA) PRIVATE LIMITED,MUMBAI vs. DCIT CENTRAL CIRCLE-40, MUMBAI

In the result, both the appeals are allowed

Bench: Shri Prashant Maharishi, Am & Shri Amarjit Singh, Jm Balaji Bullion & Commodities The Dy. Commissioner Of (India) Private Limited Income–Tax, 118/120, 3Rd Floor, Ashoka Central Circle–40, Vs. House Zavri Baazar, Mumbai Mumbai-400 002 (Appellant) (Respondent) Pan No. Aadcbo236F Balaji Universal Tradelinks P. The Dy. Commissioner Of Ltd. Income–Tax, 118/120, 3Rd Floor, Ashoka Central Circle–40, Vs. House Zavri Baazar, Mumbai Mumbai-400 002

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. 2.11. From the aforesaid provision, it is clear that the first requirement is valid initiation of search. The Revenue has executed warrant of authorization in the name of the assessee company

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

section 263 and set aside the reassessment proceedings for fresh consideration and set aside the reassessment proceedings for fresh consideration and set aside the reassessment proceedings for fresh consideration observing as under: “7. The above explanation at clause (c) clearly provides that the 7. The above explanation at clause (c) clearly provides that the 7. The above explanation at clause

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 ()

reassessment has abated. (2) Where books of account or documents or assets seized or requisitioned 2) Where books of account or documents or assets seized or requisitioned 2) Where books of account or documents or assets seized or requisitioned as referred to in sub as referred to in sub-section (1) has or have been received by the section (1

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 ()

reassessment has abated. (2) Where books of account or documents or assets seized or requisitioned 2) Where books of account or documents or assets seized or requisitioned 2) Where books of account or documents or assets seized or requisitioned as referred to in sub as referred to in sub-section (1) has or have been received by the section (1

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

1)\nof section 142 or section 148 or to disclose fully and truly\nall material facts necessary for his assessment, for that\n assessment year”\n12. As per First Proviso to Section 147 of the Act, no action under\nITA No. 2616-2623 /Mum /2024, ITA No. 2845, 2841, 2836, 2834,\n2827

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

1)\nof section 142 or section 148 or to disclose fully and truly\nall material facts necessary for his assessment, for that\n assessment year”\n12. As per First Proviso to Section 147 of the Act, no action under\nITA No. 2616-2623 /Mum /2024, ITA No. 2845, 2841, 2836, 2834,\n2827

DY CIT CC 6(4) , MUMBAI vs. SMT. DEVAL D THAKKAR [NOW KNOWN AS SMT DEVAL E ANTHONY], MUMBAI

In the result, both the appeals filed by the revenue are 11

Bench: Shri Aby T. Varkey, Jm & Shri Gagan Goyal, Am आयकर अपील सं/ I.T.A. No. 968/Mum/2020 (निर्धारण वर्ा / Assessment Year: 2004-05) & आयकर अपील सं/ I.T.A. No. 974/Mum/2020 (निर्धारण वर्ा / Assessment Year: 1999-2000) Dcit, Central Circle-6(4) बिधम/ Smt. Deval D. Thakkar (Now Room No. 1925, 19Th Floor, Known As Smt. Deval E Vs. Air India Building, Nariman Anthony) Point, Mumbai-400021. 12/22B, Acropolis, Malabar Hills, Mumbai-400006. स्थायी लेखा सं./जीआइआर सं./Pan/Gir No. : Aacpt8999F (अपीलाथी /Appellant) (प्रत्यथी / Respondent) .. Revenue By: Smt. Mahita Nair (Sr. Ar) Assessee By: Shri Dilip Thakkar सुनवाई की तारीख / Date Of Hearing: 09/11/2022 घोषणा की तारीख /Date Of Pronouncement: 23/11/2022 आदेश / O R D E R Per Aby T. Varkey, Jm: These Are Appeals Preferred By The Revenue Against The Action Of The Ld. Cit(A)-54, Mumbai Dated 26.11.2019 For A.Y.1999-2000 & For Ay. 2004-05. 2. Both The Parties Agree That The Issue Involved In Both The Appeals Are Identical, Therefore, We Take The Appeal Of The Assessee For Ay. 1999-2000 As The Lead Case & The Decision Of Which Will Be Followed For Ay. 2004-05. 3. The Grounds Of Appeal Of The Revenue For Ay. 1999-2000 Is As Under: -

142(1) of the Act and the AO taking note that pursuant to a search action which was carried out in the case of assessee’s father Shri Dilip J. Thakkar on 10.08.2011, certain incriminating documents were unearthed from his residential premises. As per the AO, from perusal of the seized material revealed that the certain payments amounting Sterling

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)

1)\nof section 142 or section 148 or to disclose fully and truly\nall material facts necessary for his assessment, for that\n assessment year”\n\n12.\nAs per First Proviso to Section 147 of the Act, no action under\n\nITA No. 2616-2623 /Mum /2024, ITA No. 2845, 2841, 2836, 2834,\n2827