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)

Section 147 of the Act\nwas disposed off as dismissed. The Assessee has raised 6\ngrounds of appeal which are taken up hereinafter in seriatim.\n\nGround No.1 & 2\n\n26.\nGround No. 1 & 2 raised by the Assessee challenged the validity\nof the reassessment

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

Section 147 of the Act\nwas disposed off as dismissed. The Assessee has raised 6\ngrounds of appeal which are taken up hereinafter in seriatim.\n\nGround No.1 & 2\n\n26. Ground No. 1 & 2 raised by the Assessee challenged the validity\nof the reassessment

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

Section 147 of the Act\nwas disposed off as dismissed. The Assessee has raised 6\ngrounds of appeal which are taken up hereinafter in seriatim.\n\nGround No.1 & 2\n\n26. Ground No. 1 & 2 raised by the Assessee challenged the validity\nof the reassessment

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

Accordingly, Ground No.1 to 4 raised by the Assessee are allowed

Bench: SHRI VIKRAM SINGH YADAV , ACCOUNTANT MEMBER SHRI RAHUL CHAUDHARY (Judicial Member)

6 grounds of appeal which are taken up hereinafter in seriatim. Ground No.1 & 2 26. Ground No. 1 & 2 raised by the Assessee challenged the validity of the reassessment proceedings read as under: “1. The CIT(A) erred in confirming the action of the AO by treating the reassessment order passed under section 143(3) read with section 147

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

Accordingly, Ground No.1 to 4 raised by the Assessee are allowed

Bench: SHRI VIKRAM SINGH YADAV, ACCOUNTANT MEMBER SHRI RAHUL CHAUDHARY (Judicial Member)

6 grounds of appeal which are taken up hereinafter in seriatim. Ground No.1 & 2 26. Ground No. 1 & 2 raised by the Assessee challenged the validity of the reassessment proceedings read as under: “1. The CIT(A) erred in confirming the action of the AO by treating the reassessment order passed under section 143(3) read with section 147

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

Accordingly, Ground No.1 to 4 raised by the Assessee are allowed

Bench: SHRI VIKRAM SINGH YADAV, ACCOUNTANT MEMBER SHRI RAHUL CHAUDHARY (Judicial Member)

6 grounds of appeal which are taken up hereinafter in seriatim. Ground No.1 & 2 26. Ground No. 1 & 2 raised by the Assessee challenged the validity of the reassessment proceedings read as under: “1. The CIT(A) erred in confirming the action of the AO by treating the reassessment order passed under section 143(3) read with section 147

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

Accordingly, Ground No.1 to 4 raised by the Assessee are allowed

Bench: SHRI VIKRAM SINGH YADAV , ACCOUNTANT MEMBER SHRI RAHUL CHAUDHARY (Judicial Member)

6 grounds of appeal which are taken up hereinafter in seriatim. Ground No.1 & 2 26. Ground No. 1 & 2 raised by the Assessee challenged the validity of the reassessment proceedings read as under: “1. The CIT(A) erred in confirming the action of the AO by treating the reassessment order passed under section 143(3) read with section 147

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

6 \ngrounds of appeal which are taken up hereinafter in seriatim. \nGround No.1 & 2 \n26. Ground No. 1 & 2 raised by the Assessee challenged the validity \nof the reassessment proceedings read as under: \n“1. The CIT(A) erred in confirming the action of the AO by \ntreating the reassessment order passed under section \n143(3) read with section 147

INCOME TAX OFFICER-12(3)(1), MUMBAI, MUMBAI vs. MANJU DIAMONDS PVT. LTD., MUMBAI

In the result, the appeal of the Revenue is allowed for statistical purposes whereas the application under Rule 27 of statistical purposes whereas the application under Rule 27

Bench: Shri Om Prakash Kant () & Shri Raj Kumar Chauhan () Assessment Year: 2017-18 Ito-12(3)(1), Manju Diamonds Pvt. Ltd., R.No. 145, 1St Floor, Aayakar 57/59, 1St Floor, Nagdevi Street, Vs. Bhavan, M.K. Road, Maszid Bunder, Mumbai-400020. Mumbai-400 003. Pan No. Aaecm 6609 G Appellant Respondent

reassessment completed u/s 147 of the Act is concerned, before the Ld. CIT(A), the assessee Ld. CIT(A), the assessee referred to the provisions of section 153C of referred to the provisions of section 153C of the Act and submitted that information was obtained from the the Act and submitted that information was obtained from

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

147 of the\nAct. In our view accepting the aforesaid contention advanced in\nbehalf of the Assessee would amount to substitution of opinion of\nappellate authority in place of opinion of the Assessing Officer of the\nAssessee but also the opinion of Assessing Officer of the searched\npersons (to not prepare the aforesaid satisfaction note) and that too\nwithout examining

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 ()

6 ITA Nos. 2147 & 2146 & CO No. 107 & 2147 & 2146 & CO No. 107 & 108/MUM/2024 4.3.1 The Appellant has through the Grounds of Appeal has contended The Appellant has through the Grounds of Appeal has contended The Appellant has through the Grounds of Appeal has contended that the Assessment Orders passed for AY 2014 that the Assessment Orders passed

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 ()

6 ITA Nos. 2147 & 2146 & CO No. 107 & 2147 & 2146 & CO No. 107 & 108/MUM/2024 4.3.1 The Appellant has through the Grounds of Appeal has contended The Appellant has through the Grounds of Appeal has contended The Appellant has through the Grounds of Appeal has contended that the Assessment Orders passed for AY 2014 that the Assessment Orders passed

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

147 of the\nAct. In our view accepting the aforesaid contention advanced in\nbehalf of the Assessee would amount to substitution of opinion of\nappellate authority in place of opinion of the Assessing Officer of the\nAssessee but also the opinion of Assessing Officer of the searched\npersons (to not prepare the aforesaid satisfaction note) and that too\nwithout examining

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

6 \ngrounds of appeal which are taken up hereinafter in seriatim.\nGround No.1 & 2 \n26. Ground No. 1 & 2 raised by the Assessee challenged the validity \nof the reassessment proceedings read as under:\n“1. The CIT(A) erred in confirming the action of the AO by \ntreating the reassessment order passed under section \n143(3) read with section 147

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

Section 147 of the Act\nwas disposed off as dismissed. The Assessee has raised 6\ngrounds of appeal which are taken up hereinafter in seriatim.\n\nGround No.1 & 2\n\n26. Ground No. 1 & 2 raised by the Assessee challenged the validity\nof the reassessment

M/S. BIOBUILD DEVELOPERS ,MUMBAI vs. INCOME TAX OFFICER WARD 24(1)(3), MUMBAI

Bench: SHRI VIKRAM SINGH YADAV, ACCOUNTANT MEMBER SHRI RAHUL CHAUDHARY (Judicial Member)

reassessment proceedings in cases there no return of income has been filed even without identifying any income that has escaped assessment. Clause (a) of Explanation 2 to Section 147 of the Act provides that for the purpose of Section 147 of the Act income shall be deemed to have escaped assessment where no return of income had been furnished

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

section 147 of the Act, an assessment completed u/s 143(3) of the Act could be reopened beyond the completed u/s 143(3) of the Act could be reopened beyond the completed u/s 143(3) of the Act could be reopened beyond the period of four years from the end of the relevant assessment year iod of four years from

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

6 \ngrounds of appeal which are taken up hereinafter in seriatim. \nGround No.1 & 2 \n26. Ground No. 1 & 2 raised by the Assessee challenged the validity \nof the reassessment proceedings read as under: \n“1. The CIT(A) erred in confirming the action of the AO by \ntreating the reassessment order passed under section \n143(3) read with section 147