CHEMOX EXPORTS IMPORTS PVT LTD,MUMBAI vs. INCOME TAX DEPARTMENT, ASSESSMENT UNIT, DELHI

Bench: Shri Narendra Kumar Billaiya, Hon'Ble & Shri Raj Kumar Chauhan, Hon'Bleι.Τ.Α. No. 3954/Mum/2024

reassessment or recomputation under section 147 of the Act, (b) issuance of notice under section 148 of the Act, Shall be through automated allocation, in accordance with risk management strategy formulated by the Board as referred to in section 148 of the Act for issuance of notice, and in a faceless manner, to the extent provided in section 144B

DCIT, CIR-3(3)(1), MUMBAI vs. EAST WEST PIPELINE PVT LTD., MUMBAI

Accordingly, without any adjudication upon the merits, Ground No. 5 to 8 to raised by the Revenue are dismissed as being infructuous

Bench: SHRI B.R. BASKARAN, ACCOUNTANT MEMBER SHRI RAHUL CHAUDHARY (Judicial Member)

reassessment proceedings contending that the same have been initiated in violation of the provisions contained in Section 147 of the Act. The CIT(A) agreed with the Assessee and vide order, 30/03/2023, quashed the Assessment Order dated 29/03/2022, passed under Section 147 read with Section 144B

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

Bench: Shri Amit Shukla& Shri Makarand Vasant Mahadeokar

reassessment proceedings were completed by the Assessing Officer vide order dated 28.02.2023, passed under section 147 read with section 143(3) and section 144B

GAMNARAM OKHAJI PRAJAPATI ,MUMBAI vs. DCIT. CIRCLE 1(2)(1), MUMBAI

Appeal is allowed

Bench: SHRI RAHUL CHAUDHARY, JUDICIAL MEMBER SHRI PRABHASH SHANKAR (Accountant Member)

reassessment made under section 147 rws 144 read with section 144B be cancelled. 2. The reassessment notice under section 148A

DCIT-14.1.1, MUMBAI vs. AMCOR FLEXIBLES INDIA PVT. LTD, MUMBAI

In the result, appeal of the Revenue is dismissed

Bench: SHRI AMIT SHUKLA (Judicial Member), SMT RENU JAUHRI (Accountant Member)

reassessment order under section 147 read with section 144B of the Act on 26.05.2023 disallowing depreciation on goodwill of Rs. 2,37,83,195/-. 8. The assessee

SKA SALES PVT LTD,MUMBAI vs. INCOME TAX OFFICSR, WARD 13(2)(1), MUMBAI

reassessment proceedings were initiated in the case of the Assessee. The aforesaid proceedings culminated to passing of the Assessment Order under Section 147 of the Act read with Section 144B

ITO 13(2)(1), MUMBAI vs. SKA SALES PRIVATE LIMITED, MUMBAI

Bench: SHRI RAHUL CHAUDHARY, JUDICIAL MEMBER SHRI BIJAYANANDA PRUSETH (Accountant Member)

reassessment proceedings were initiated in the case of the Assessee. The aforesaid proceedings culminated to passing of the Assessment Order under Section 147 of the Act read with Section 144B

SATISH HARNAMDAS SETHI,MUMBAI vs. NATIONAL FACELESS ASSESSMENT CENTRE DELHI, DELHI

In the result, appeal of the assessee is allowed

Bench: Ms Kavitha Rajagopal & Shri Girish Agrawalassessment Year: 2017-18

reassessment order passed under section 147 r.w.s. 144B in pursuance of the said notice are bad in law and the same

CARRIER TECHNOLOGIES INDIA LIMITED,MUMBAI vs. DEPUTY COMMISSIONER OF INCOME TAX-3(1)(1), MUMBAI

In the result, the appeal filed by the assessee is allowed

Bench: Shri Prashant Maharishi, Am & Ms. Kavitha Rajagopal, Jm Carrier Technologies India Limited Dy. Cit-3(1)(1), Office No. 8, The Centrium, Level-1, Mumbai Phoenix Market City, Kamani Junction, Vs. Lal Bahadur Shastri Marg, Kurla (W), Mumbao-400 070 Pan/Gir No. Aaacv 2873 P (Appellant) (Respondent) :

section 144B(vii) of the Act for ease of reference : Faceless Assessment. 144B. (1) Notwithstanding anything to the contrary contained in any other provision of this Act, the assessment, reassessment

SHRIKANT FINCONSERY PRIVATE LIMITED ,MUMBAI vs. PCIT-4, MUMBAI

In the result, all three appeals preferred by the Appellant are allowed

Bench: SHRI PRASHANT MAHARISHI, ACCOUNTANT MEMBER SHRI RAHUL CHAUDHARY (Judicial Member)

Reassessment Order for the Assessment Year 2012-13 was pending adjudication before the CIT(A). The Appellant had also filed a copy of Re-assessment Order for the Assessment Year 2012-13 as well as the appeal preferred before the CIT(A) with the Assessing Officer. The Assessing Officer, thereafter, passed Order under Section 147 read with Section 144B

SHRIKANT FINCONSERV PRIVATE LIMITED,MUMBAI vs. PCIT-4, MUMBAI

In the result, all three appeals preferred by the Appellant are allowed

Bench: SHRI PRASHANT MAHARISHI, ACCOUNTANT MEMBER SHRI RAHUL CHAUDHARY (Judicial Member)

Reassessment Order for the Assessment Year 2012-13 was pending adjudication before the CIT(A). The Appellant had also filed a copy of Re-assessment Order for the Assessment Year 2012-13 as well as the appeal preferred before the CIT(A) with the Assessing Officer. The Assessing Officer, thereafter, passed Order under Section 147 read with Section 144B

DARBARI INDUSTRIES,MUMBAI vs. ASSISTANT COMMISSIONER OF INCOME TAX - 41(1)(1), MUMBAI

In the result, the appeal of the assessee is allowed on legal ground, and the reassessment order is quashed

Bench: Shri Pawan Singh & Shri Makarand Vasant Mahadeokardarbari Industries Acit - 41(1)(1) 110, Champaklal 8Th Floor, Kautilya Udyog Bhavan, Sion Vs. Bhavan, C-41-43, Koliwada Road, Sion Avenue 3, Near Videsh (West), Mumbai – Bhavan, G-Block, Bkc, 400 022. Bandra Kurla Complex, Bandra East, Mumbai- 400 051 Pan/Gir No. Aaafd3277E (Applicant) (Respondent) Assessee By Shri Bhupendra Shah, Ld. Ar Revenue By Shri Annavaram Kosuri, Ld. Dr Date Of Hearing 16.04.2026 Date Of Pronouncement 21.04.2026

reassessment proceedings deserve to be annulled at the threshold. 10. Per contra, the learned Departmental Representative did not raise any specific objection to the admission of the additional legal ground so raised by the assessee. On merits, the learned Departmental Representative relied upon the assessment order passed under section 147 read with section 144B

MAHENDER SINGH ARORA,MUMBAI vs. DY CIT CIRCLE 42(2)(1), MUMBAI

Bench: the expiry of 6 years from the end of Assessment Year 2014-2015). Subsequently, in compliance with the judgment of the Hon'ble Supreme Court in the case of Union of India vs. Ashish Agarwal 444 ITR 1 (SC) [04/05/2022], communication, dated 31/05/2022, was sent to the Assessee intimating that the aforesaid notice issued under Section 148 of the Act (under old regime) would be treated as the show-cause notice issued in terms of Section 148A(b) of the Act (under new regime introduced by the Fi

reassessment proceedings culminated into passing of the Assessment Order, dated 30/05/2023, passed under section 147 read with Section 144B of the Act. The Assessing

RAMESH AMRATLAL BRAHMBHATT ,MUMBAI vs. ITO WARD 34(3)(2), MUMBAI

In the result, the reassessment order dated 20

Bench: Shri Saktijit Dey & Shri Makarand Vasant Mahadeokarramesh Amratlal Ito Ward 34(3)(2), Brahmbhatt Kautilya Bhavan, 43 Rajnigandha, Vs. Bandra Kurla Gulmohar Cross Road No. Complex, Mumbai – 11, J V P D Scheme, 400 051 Juhu, Mumbai-400 049 Pan/Gir No. Aabpb7235R (Applicant) (Respondent) Assessee By Shri K. Gopal & Ms. Neha Paranjpe, Ld. Ars Revenue By Shri Annavaram Kosuri, Ld. Dr Date Of Hearing 23.02.2026 Date Of Pronouncement 25.02.2026

reassessment was completed under section 147 read with section 144B vide order dated 20.05.2023 determining total income at Rs. 3,86,90,692/- by making

SAI PRERNA CO-OP. CREDIT SOCIETY LTD,MUMBAI vs. ITO WD 17(3) (2) , MUMBAI

In the result, the appeal of the assessee is partly allowed

Bench: Shri Kuldip Singh () & Shri Om Prakash Kant () Assessment Year: 2012-13 Sai Prerana Co-Op Society Ltd., Ito-7(3)(2), 317, Puran Aasha Bldg. Gr. Fl. Room No. 126, 1St Floor, Narashi Natha Street, Katha Vs. Kautilya Bhavan, C-41 To C- Bazar Musjid Bunder (W), 43 Block, Bandra Kurla Mumbai-400 009. Complex, Bandra (East) Mumbai-400051. Pan No. Aadts 5638 M Appellant Respondent Assessee By : Ms. Ruby Srivastava & Mr. Bharat Kumar, Ca Revenue By : Mr. Milind S. Chavan, Dr Date Of Hearing : 27/04/2023 : Date Of Pronouncement 28/04/2023 Order

Section 144B of the Act are set aside.” 6.2 Similar finding has been given by the Hon’ble Bombay Similar finding has been given by the Hon’ble Bombay Similar finding has been given by the Hon’ble Bombay High Court while deciding the writpetition no. 1809 of 2022 in High Court while deciding the writpetition

SHANTILAL NAROTTAMDAS PANCHAL,MALAD EAST vs. ITO-41(3)(4), MUMBAI, BANDRA KURLA COMPLEX

Appeal is allowed

Bench: Him.

reassessment proceedings for the Assessment Year 2017-2018 since the notice, dated 29/07/2022, was issued under Section 148 of the Act after taking approval from the Principal Commissioner of Income Tax instead of Principal Chief Commissioner of Income Tax as mandated by Section 151 of the Act. 12. Respectfully following the above judicial precedents, we hold that notice, dated 21/07/2022

NILANJANA ARVINDER SINGH,MUMBAI vs. DCIT, MUMBAI

In the result, the appeal by the assessee for the assessment year 2014-

Bench: Shri Amarjit Singhshri Sandeep Singh Karhail

reassessment proceedings, which began on 01.06.2021, to issue a notice under Section 148 of the Act. The said notice was required to be accompanied by an order under Section 148A(d) of the Act. Thus, the AO was required to pass an order under Section 148A(d) of the Act within the said twenty-nine days notwithstanding the time stipulated

SAI PRERNA CO-OP. CREDIT SOCIETY LTD,MUMBAI vs. ITO WD 17(3) (2) , MUMBAI

In the result, appeals of the assessee and the Revenue are In the result, appeals of the assessee and the Revenue are In the result, appeals of the assessee and the Revenue are decided as under:

Bench: Shri Kuldip Singh () & Shri Om Prakash Kant () Ita Nos. 217, 220 & 221, 218 & 219, 215, 214/Mum/2023 Assessment Years: 2013-14, 2016-17, 2017-18, 2018-19, 2020-21 Sai Prerana Co-Op Credit Ito-17(3)(2), Society Ltd., Room No. 126, 1St Floor, Vs. 317, Puran Aasha Bldg, Gr. Fl. Kautilya Bhavan, C-41 To C- Narashi Natha Street, Katha 43, G Block Bandra Kurla Bazar Masjid Bunder (W), Complex, Bandra (East), Mumbai-400 009. Mumbai-400051. Pan No. Aadts 5638 M Appellant Respondent

Section 144B of the Act are set aside.” 6.2 Similar finding has been given by the Ho Similar finding has been given by the Hon’ble Bombay High n’ble Bombay High Court while deciding the writpetition no. 1809 of 2022 in the writpetition no. 1809 of 2022 in the Court while deciding the case of Tahnee Heights

INCOME TAX OFFICER-26(2)(1), MUMBAI vs. SAI PRERANA CO-OP CREDIT SOCIETY LTD., MUMBAI

In the result, appeals of the assessee and the Revenue are In the result, appeals of the assessee and the Revenue are In the result, appeals of the assessee and the Revenue are decided as under:

Bench: Shri Kuldip Singh () & Shri Om Prakash Kant () Ita Nos. 217, 220 & 221, 218 & 219, 215, 214/Mum/2023 Assessment Years: 2013-14, 2016-17, 2017-18, 2018-19, 2020-21 Sai Prerana Co-Op Credit Ito-17(3)(2), Society Ltd., Room No. 126, 1St Floor, Vs. 317, Puran Aasha Bldg, Gr. Fl. Kautilya Bhavan, C-41 To C- Narashi Natha Street, Katha 43, G Block Bandra Kurla Bazar Masjid Bunder (W), Complex, Bandra (East), Mumbai-400 009. Mumbai-400051. Pan No. Aadts 5638 M Appellant Respondent

Section 144B of the Act are set aside.” 6.2 Similar finding has been given by the Ho Similar finding has been given by the Hon’ble Bombay High n’ble Bombay High Court while deciding the writpetition no. 1809 of 2022 in the writpetition no. 1809 of 2022 in the Court while deciding the case of Tahnee Heights