ACIT, CIRCLE 24(1) MUMBAI, MUMBAI vs. NILKAMAL CRATES & CONTAINERS, MUMBAI

Bench: Hon’Ble Justice (Retd.) C.V. Bhadang & Shri Arun Khodpia, Am

reassessment proceedings have been continued under new provisions only. Hence the AO has issued notice u/s 148A(b) and also passed order u/s. 148A(d) of the Act. The provisions of section

AJAY MULTI PROJECTS PRIVATE LIMITED,MUMBAI vs. DCIT, CIRCLE 4(1)(1), MUMBAI, AAYKAR BHAWAN, MUMBAI

In the result, the appeal of the assessee is allowed

Bench: Shri Om Prakash Kant () & Ms. Kavitha Rajagopal () Assessment Year: 2016-17 Ajay Multi Projects Pvt. Ltd., Dcit, Circle-4(1)(1), 2Nd Floor, C.J. House, 285 Aayakar Bhavan, Vs. Princess Street, Marine Lines, Mumbai-400020. Mumbai-400002. Pan No. Aadca 0338 H Appellant Respondent

148A(d) of the Act, the of the Act, the consequential reassessment proceedings and the order, dated consequential reassessment proceedings and the order, dated consequential reassessment proceedings and the order, dated 25/05/2023, passed under 25/05/2023, passed under Section

LIC HOUSING FINANCE LIMITED,MUMBAI vs. ACIT 2(2)(1), MUMBAI, AAYKAR BHAVAN, MUMBAI

In the result, the appeal of the assessee is allowed

Bench: Shri Om Prakash Kant () & Shri Raj Kumar Chauhan () Assessment Year: 2017-18

reassessment proceedings initiated under section 148A and reassessment proceedings initiated under section 148A and reassessment proceedings initiated under section 148A

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 148A(b) of the Act and also after initiation of reassessment proceedings under Section 147 of after initiation of reassessment

RA FASHIONS PVT. LTD.,MUMBAI vs. ASSESSMENT UNIT, INCOME TAX DEPARTMENT, MUMBAI

Bench: SHRI RAHUL CHAUDHARY, JUDICIAL MEMBER SMT RENU JAUHRI (Accountant Member)

reassessment proceedings and the order, dated 02/05/2023, passed under Section 147 read with Section 144B of the Act are quashed as violative of the provisions contained in Section 148A

ACIT(IT)-1(2)(1), MUMBAI vs. BARCLAYS EXECUTION SERVICES LIMITED, LONDON

In the result, the appeal filed by the Revenue is dismissed and the cross-objection filed by the assessee is dismissed as infructuous

Bench: SHRI AMIT SHUKLA (Judicial Member), SHRI PRABHASH SHANKAR (Accountant Member)

148A(d) - to pass an order deciding whether or not it is a fit case for issuing a notice under section 148; and d. Section 148 - to issue a reassessment

INCOME TAX OFFICER 23 3 6, PIRAMAL CHAMBERS vs. RAHUL HARIPRASAD TIBREWAL, MUMBAI

Bench: SHRI RAHUL CHAUDHARY, JUDICIAL MEMBER SMT RENU JAUHRI (Accountant Member)

148A(d) - to pass an order deciding whether or not it is a fit case for issuing a notice under section 148; and d. Section 148 - to issue a reassessment

ACIT-19(3), MUMBAI vs. RAMCHAND THAKURDAS JHAMTANI, THANE

Accordingly, all the grounds raised by the Revenue in the departmental appeal in relation to the relief granted by the CIT(A) on merits are dismissed as having been rendered infructuous

Bench: SHRI RAHUL CHAUDHARY, JUDICIAL MEMBER SMT RENU JAUHRI (Accountant Member)

reassessment proceedings and the order, dated 25/05/2023, passed under Section 147 read with Section 144B of the Act are quashed as bad in law being violative of the provisions contained in Section 148A

DEVANSHI SHARMA ,MUMBAI vs. ITO WARD 34(1)(1), MUMBAI

In the result, the appeal is allowed as indicated above

Bench: Shri Saktijit Dey & Shri Makarand Vasant Mahadeokardevanshi Sharma Ito, Ward 34(1)(1) 216, 2Nd Floor, Kautaliya Bhawan, Sagar Jyoti, Plot No. 18, Vs. 6Th Road, Jvpd Scheme, G-Block, Bandra Kurla Complex, Vile Parle (W), Mumbai-400 056 Bandra (E), Mumbai-400 051 Pan/Gir No. Cmvpk 6007 Q (Appellant) : (Respondent) Appellant By : Shri Shashank Mehta Respondent By : Shri Annavaram Kosuri Date Of Hearing : 05.02.2026 Date Of Pronouncement : 10.02.2026 O R D E R Per Saktijit Dey: This Is An Appeal By The Assessee Against Order Dated 27.10.2025, Passed By National Faceless Appeal Centre (‘Nfac’ For Short), Delhi For The Assessment Year (A.Y. For Short) 2017-18. 2. In Ground No. 1, The Assessee Has Raised A Pertinent Legal Issue, Challenging The Validity Of The Order Passed U/S. 148A(D) Of The Income Tax Act, 1961 (‘The Act’ For Short) As Also The Notice Issued U/S. 148 Of The Act. Since, The Aforesaid Issue Raised By The Assessee Is A Purely Legal & Jurisdictional Issue Going To The Root Of The Matter & Affecting The Validity Of The Proceedings Initiated U/S. 147 Of The Act, We Are Inclined To Address The Issue At The Very Outset.

148A(d) - to pass an order deciding whether or not it is a fit case for issuing a notice under section 148; and (d) Section 148 - to issue a reassessment

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

reassessment proceedings under Section 148A, conducting the reassessment under Sections 148A and 148, and/or in passing the impugned orders dated

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

Bench: Shri Amit Shukla & Shri Girish Agrawal

reassessment proceedings under Section 148A, conducting the reassessment under Sections 148A and 148, and/or in passing the impugned orders dated

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 148A(b). In consequence thereof, the Assessing Officer the Assessing Officer appears to have regarded the earlier reassessment order

ALBERT JOSEPH ROZARIO,MUMBAI vs. ITO, INT. TAX, CIRCLE 4(1)(1), MUMBAI, MUMBAI

In the result, the appeal of the assessee is partly allowed for statistical purposes

Bench: Shri Vikram Singh Yadav & Shri Rahul Chaudharyassessment Year : 2018-19 Albert Joseph Rozario, Ito, (Int. Tax), Circle-4(1)(1), B-311, 5Th Wing, Room No. 629, 6Th Floor, Inlaks Park, Vs. Kautilya Bhavan, Yari Road, Versova, C-41 To C-43, G Block, Andheri West, Bandra Kurla Complex, Mumbai-400058 Bandra East, Pan : Afvpr6139P Mumbai-400051 (Appellant) (Respondent) For Assessee : Shri Dharan Gandhi For Revenue : Shri Sridhar G. Menon, Sr.Dr Date Of Hearing : 01-05-2025 Date Of Pronouncement : 22-07-2025 O R D E R Per Vikram Singh Yadav, A.M : This Is An Appeal Filed By The Assessee Against The Final Assessment Order Passed By The Assessing Officer U/S 147 R/W 144C(13) Of The Act Dt. 30-12-2024, Consequent To The Directions Given By The Ld. Drp-1, Mumbai-3, U/S 144C(5) Of The Act, Dated 30-11-2024 Pertaining To Assessment Year (Ay.) 2018-19. 2. Briefly The Facts Of The Case Are That Basis Information Available Through The Insight Portal That The Assessee Had Purchased Immoveable Properties Amounting To Rs. 8,31,45,549/- & Has Received Interest

reassess the income in respect of any issue, which has escaped assessment, and such issue comes to his notice subsequently in the course of the proceedings under this section, irrespective of the fact that the provisions of section 148A

AJAY MULTI PROJECTS PRIVATE LIMITED,MUMBAI vs. DCIT, CIRCLE 4(1)(1), MUMBAI, MUMBAI

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

Bench: Shri Sandeep Gosain, () & Shri Prabhash Shankar, ()

reassessment proceedings and the order, dated 25/05/2023, passed under Section 147 read with Section 144B of the Act are quashed as bad in law being violative of the provisions contained in Section 148A

ACIT-19(3), MUMBAI, MUMBAI vs. RISHABH AVNISH MODY, MUMBAI

In the result, cross objection filed by the assessee is allowed and appeal filed by the revenue is dismissed

148A(d)- to pass an order deciding whether or not it is a fit case for issuing a notice under section 148; and 12 ITA No. 8101/Mum/2025 & CO No. 35/Mum/2026 (A.Y. 2016-17) Rishabh Avnish Mody d. Section 148-to issue a reassessment

CYRUS PATEL ,MUMBAI vs. INCOME TAX OFFICER WARD 23(2)(1), MUMBAI

In the result, the appeal is allowed

Bench: SHRI SANDEEP GOSAIN (Judicial Member), SHRI PRABHASH SHANKAR (Accountant Member)

reassessment are issued beyond the period of three years from the end of the assessment year, the appropriate authority for the purpose of section 148 and section 148A

VIPENDRA RAVINDRA MANDAL,THANE vs. INCOME TAX OFFICER- WARD 22(3)(6), MUMBAI

In the result, the appeal of the assessee is allowed

Bench: Shri Om Prakash Kant () & Shri Raj Kumar Chauhan () Assessment Year: 2016-17 Vipendra Ravindra Mandal, Ito Ward 22(3)(6), 405, Orchid Wing-F Lodha Crown, Piramal Chamber, Taloja Bypass Road, Kohni B.O. Vs. Mumbai-400012. Khoni, Thane-421204. Pan No. Alepm 8472 H Appellant Respondent

section 148A. 148A. During During During the the reassessment the reassessment reassessment proceedings, the assessee categorically explained that the net proceedings

SHIVI MUKESH KUMAR ,MUMBAI vs. ACIT, CIRCLE 22(1), MUMBAI

In the result, the appeal is partly allowed as indicated above

Bench: Shri Saktijit Dey & Shri Jagadishshivi Mukesh Kumar Acit, Circle 22(1) D-1402, Hubtown Seasons, Mumbai Next To Fine Arts Society, Vs. Ramakrishna Chemburkar Marg, Chembur, Mumbai-400 071 Pan/Gir No. Aqapk 9881 H (Appellant) : (Respondent) Appellant By : Shri Dharan V. Gandhi – Advocate & Ms. Vinita A. Nara – Advocate Respondent By : Shri Arun Kanti Datta – Cit Dr Date Of Hearing : 11.12.2025 Date Of Pronouncement : 17.12.2025 O R D E R Per Saktijit Dey: This Is An Appeal By The Assessee Against The Order Dated 01.07.2025, Passed By National Faceless Appeal Centre (‘Nfac’ For Short), Delhi, Pertaining To The Assessment Year (A.Y.) 2016-17. 2. Though, The Assessee Has Raised Multiple Grounds, However, At The Time Of Hearing, Ld. Counsel Appearing For The Assessee Specifically Drew Our Attention To Ground No. 6, Which Reads As Under: 6. The Sanction U/S. 151 Is Bad In Law & As A Result, The Reassessment Proceeding Is Bad In Law. 3. Referring To This Ground, Ld. Counsel Submitted, At The Very Outset, This Issue May Be Considered And, If Warranted The Other Issues Can Be Taken Up Thereafter. As Could Be Seen

148A(d)- to pass an order deciding whether or not it is a fit case for issuing a notice under section 148; and 7 Shivi Mukesh Kumar vs. ACIT d. Section 148-to issue a reassessment