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 ()

reassess the income of the other person in ess the income of the other person in accordance with the provisions of section 153A, if, that Assessing Officer is accordance with the provisions of section 153A, if, that Assessing Officer is accordance with the provisions of section 153A, if, that Assessing Officer is satisfied that the books of account or documents

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 ()

reassess the income of the other person in ess the income of the other person in accordance with the provisions of section 153A, if, that Assessing Officer is accordance with the provisions of section 153A, if, that Assessing Officer is accordance with the provisions of section 153A, if, that Assessing Officer is satisfied that the books of account or documents

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

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

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

reassessment\norder as bad in law. Relevant extracts from the said order are\nreproduced for the sake of ready reference:\n\n11\nITA Nos.3674/Mum/2025 and ors.\nShapoorji Pallonji Mistry\nAYs 2015-16 and 2016-17\n\n\"7.\nTo delve on the issue in hand before us, let us take note of the provisions\ncontained in section 149

NARESH AMRATLAL SHAH,MUMBAI vs. ITO WARD-27(2)(1), MUMBAI

In the result, the appeal of the In the result, the appeal of the Assessee is allowed allowed

Bench: Shri Om Prakash Kant () & Shri Raj Kumar Chauhan ()

reassessment proceedings initiated under the old or un under the old or un-amended provisions of section 148, read amended provisions of section 148, read with the extensions granted under the Taxation and Other Laws with the extensions granted under the Taxation and Other Laws with the extensions granted under the Taxation and Other Laws (Relaxation and Amendment of Certain

PRAFUL ARJUN RANE ,MUMBAI vs. ITO INT TAX WARD-4(1)(1), MUMBAI

In the result, appeal of the assessee is allowed

Bench: SHRI SAKTIJIT DEY, HON’BLE (Vice President), SHRI GIRISH AGRAWAL (Accountant Member)

Section 149(1)(b) of the new regime stipulates that the Revenue can issue reassessment notices for past assessment years

SUDESH DHANRAJ MURPANA (HUF),MUMBAI vs. THE INCOME TAX OFFICER, WARD 23(3)(1, MUMBAI

In the result, appeal of the assessee is allowed

Bench: Shri Amit Shukla & Shri Girish Agrawalassessment Year: 2013-14 Sudesh Dhanraj Murpana Income Tax Officer – 23(3) (1) (Huf) Matru Mandir, Tardeo, Grant 401 Somdhan Bldg, Perry Road, Cross Road Bandra (West), Vs. Mumbai - 400007 Mumbai 400050

Section 149(1)(b) of the new regime stipulates that the Revenue can issue reassessment notices for past assessment years

PANKAJ CHANDRAKANT PIMPLE,BORIVALI (WEST), MUMBAI vs. INT TAX WARD 3(3)(1), MUMBAI

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

reassessment notices are to be dealt with\nas under:\n(i) AY 2013-14, AY 2014-15 and AY 2015-16: Fresh notice under section\n148 of the Act can be issued in these cases, with the approval of the\nspecified authority, only if the case falls under clause.\n(b) of sub-section (1) of section 149

MOHAMEDALI SHABANALI BADAMI,MUMBAI vs. ITO 25(2)(1), MUMBAI

In the result, appeal of the assessee is allowed

Bench: Shri Amit Shukla & Shri Girish Agrawalassessment Year: 2015-16

Section 149(1)(b) of the new regime stipulates that the Revenue can issue reassessment notices for past assessment years

NISHA THOMAS,MUMBAI vs. COMMISSIONER OF INCOME TAX (A)-DRP-2 , MUMBAI

In the result, the appeal is allowed

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

reassessment or recomputation, as the case may be.] (2) The provisions of sub-section (1) as to the issue of notice shall be subject to the provisions of section 151.] The first proviso to Section 149

DEVANAND AMARNATH PARKAR,JOGESHWARI EAST, MUMBAI vs. INCOME TAX OFFICER 41(4)(1), KAUTILYA BHAWAN, BKC, BANDRA EAST

In the result, appeal by the assessee is allowed

reassessment\norder as bad in law. Relevant extracts from the said order are\nreproduced for the sake of ready reference:\n"7. To delve on the issue in hand before us, let us take note of the provisions\ncontained in section 149

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

149, section 151 and section 153, in the case of a person where a search is section 153, in the case of a person where a search is section 153, in the case of a person where a search is initiated under section 132 or books of account, other initiated under section 132 or books of account, other initiated under

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

149, section 151 and section 153, in the case of a person where a search is section 153, in the case of a person where a search is section 153, in the case of a person where a search is initiated under section 132 or books of account, other initiated under section 132 or books of account, other initiated under

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

reassessment. Section 149 requires assessing officers to issue a notice of reassessment under section 5 148 within the prescribed time

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: -

reassessment proceedings, if he has reason to believe that any income chargeable to tax has escaped assessment for any assessment year. Such power is, however, subject to the provision of sections 148 to 153 of the Act. Section 149

BHUSHAN VASANT PARELKAR,MUMBAI vs. WARD 41(2)(1), MUMBAI, MUMBAI

In the result, appeal of the assessee is allowed

Bench: Smt Beena Pillai & Shri Girish Agrawalassessment Year: 2013-14 Bhushan Vasant Parelkar Income Tax Officer, A-204 Saikripa, Navghar Ward 41(2)(1), Road, Mulund East S.O, Vs Mumbai Mumbai - 400081 (Pan: Akdpp6556D) Appellant Respondent Present For: Appellant By : Shri Dharan Gandhi, Advocate Respondent By : Shri Bhagirath Ramawat, Sr. Dr Date Of Hearing : 21.01.2026 Date Of Pronouncement : 30.01.2026 O R D E R Per Girish Agrawal: This Appeal Filed By The Assessee Is Against The Order Of Ld. Cit(A), National Faceless Appeal Centre (Nfac), Delhi, Vide Order No. Itba/Nfac/S/250/2025-26/1079866363(1), Dated 22.08.2025, Passed Against The Assessment Order By Ito, Ward-41(2)(1),, U/S. 147 Of The Income-Tax Act (Hereinafter Referred To As The “Act”), Dated 31.05.2023 For Assessment Year 2013-14. 2. Grounds Taken By The Assessee Are Reproduced As Under: “The Ld. Cit(A) Erred In Confirming The Action Of Ld. Ao Of Reopening The Assessment U/S 147 Although The Reopening Is Time Barred & Hence Bad In Law. Bhushan Vasant Parelkar Ay 2013-14

Section 149(1)(b) of the new regime stipulates that the Revenue can issue reassessment notices for past assessment years

AUSTRALIA AND NEW ZEALAND BANKING GROUP LTD.,MUMBAI vs. DCIT(INTERNATIONAL TAX) 1(1)(2), MUMBAI

In the result, appeal of the assessee is allowed

149 as\nextended under sub-section (1) of Section 3 of TOLA\". Therefore, the provisions of\nTOLA cannot apply. Also the Notifications thereunder do not apply to the case at\nhand for AY 2013-14.\n28. It is required to be noted that the Apex Court, while enabling the Revenue to\nrestart the reassessment

ACIT-15(3)(2), MUMBAI, MUMBAI vs. SURYA FERROUS ALLOYS PVT LTD, MUMBAI

Appeal are dismissed as having been rendered infructuous

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

reassessment or recomputation, as the case may be. (2) The provisions of sub-section (1) as to the issue of notice shall be subject to the provisions of section 151. The first proviso to Section 149