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

b) of sub-section (1), a\nnotice under section 148 shall be issued for every such assessment year for\nassessment, reassessment or recomputation, as the case may be.]\n(2) The provisions of sub-section (1) as to the issue of notice shall be subject to the\nprovisions of section 151.)\n7.1. Finance Act, 2021 amended re-assessment related provisions

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

b) of sub-section (1), a notice under section 148 shall be issued for every such assessment year for assessment, 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.) 8.1 Finance Act, 2021 amended re-assessment related provisions w.e.f

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

b) of sub-section (1), a notice under section 148 shall be issued for every such assessment year for assessment, 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.) 13 ITA Nos. 3674/Mum/2025 and ors. Shapoorji Pallonji Mistry

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

b) of sub-section (1), a notice under section 148 shall be issued for\nevery such assessment year for assessment, reassessment or recomputation,\nas the case may be.]\n(2) The provisions of sub-section (1) as to the issue of notice shall be subject to\nthe provisions of section 151.)\n\n13\nITA Nos.3674/Mum/2025 and ors.\nShapoorji Pallonji Mistry

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

b) of sub-section (1), a notice under section 148 shall be issued for\nevery such assessment year for assessment, reassessment or recomputation,\nas the case may be.]\n\n(2) The provisions of sub-section (1) as to the issue of notice shall be subject to\nthe provisions of section 151.)\n\n13\nITA Nos.3674/Mum/2025 and ors.\nShapoorji Pallonji

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)

b) of sub-section (1), a notice under section 148 shall be issued for every such assessment year for assessment, 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.) 7.1. Finance Act, 2021 amended re-assessment related provisions w.e.f

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

b) of sub-section (1), a notice under section 148 shall be issued for every such assessment year for assessment, 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.) 5.1. Finance Act, 2021 amended re-assessment related provisions w.e.f

JCIT CENT. CIR. - 1(4), MUMBAI vs. GRASIM INDUSTRIES LTD, MUMBAI

The appeal of the Revenue is dismissed whereas appeal of the assessee is partly allowed for statistical purposes

Bench: Shri Om Prakash Kant () & Ms. Kavitha Rajagopal () Assessment Year: 2010-11 Grasim Industries Limited, The Dcit Cc-1(4), Corporate Finance Division, Room No. 902, 9Th Floor, Old Vs. A-2, Aditya Birla Centre, S.K. Cgo Building, M.K. Road, Ahire Marg, Worli, Mumbai-400020. Mumbai-400030. Pan No. Aaacg 4464 B Appellant Respondent Assessment Year: 2010-11 Jcit (Osd), Central Circle- Grasim Industries Limited, 1(4), A-Wing, 2Nd Floor, Aditya Room No. 902, Pratishtha Vs. Birla Centre, S.K. Ahire Bhavan, 9Th Floor, Old Cgo Marg, Worli, Building Annexe, Mumbai-400030. Mumbai-400020. Pan No. Aaacg 4464 B Appellant Respondent Assessee By : Mr. Yogesh Thar & Mr. Chaitanya Joshi Revenue By : Dr. Kishor Dhule, Cit-Dr Date Of Hearing : 03/04/2024 : Date Of Pronouncement 29/04/2024

1 pertaining to the assessee were forwarded forwarded to the Assessing Officer of the assessee Assessing Officer of the assessee following due procedure of law rocedure of law. Consequently, notice u/s 153C of the Act r.w.s. 153A was issued Consequently, notice u/s 153C of the Act r.w.s. 153A was issued Consequently, notice u/s 153C of the Act r.w.s. 153A

ESSEL MINING & INDUSTRIES LIMITED,MUMBAI vs. DEPUTY COMMISSIONER OF INCOME TAX - CENTRAL CIRCLE 1(4), MUMBAI

In the result, the appeal of the Revenue for assessment year the result, the appeal of the Revenue for assessment year the result, the appeal of the Revenue for assessment year

Bench: Shri Aby T Varkey () & Shri Om Prakash Kant () Assessment Year: 2011-12 & Assessment Year: 2012-13 Essel Mining & Industries Ltd., Dy. Cit, Central Circle-1(4), Industry House, 18Th Floor, 10, 9Th Floor, Old Cgo Building, Camac Street, Vs. Mk Road, Kolkata-700017. Mumbai-400020. Pan No. Aaace 6607 L Appellant Respondent Assessment Year: 2011-12 & Assessment Year: 2012-13 Jcit, Central Circle-1(4), M/S Essel Mining & Industries Room No. 902, Pratishtha Ltd., Bhavan, 9Th Floor, Old Cgo Vs. Industry House, 18Th Floor, 10, Building Annexe, Camac Street, Mumbai-400020. Kolkata-700017. Pan No. Aaace 6607 L Appellant Respondent Assessment Year: 2011-12 M/S Essel Mining & Industries Dy. Cit, Central Circle-1(4), Ltd., 9Th Floor, Old Cgo Building, Vs. Industry House, 18Th Floor, 10, Mk Road

reassessments finalized for finalized for the the the assessment years covered under Section 153A of the assessment years covered under Section 153A of the assessment years covered under Section 153A of the Essel Mining & Industries Ltd. ITA Nos. 1020, 1019, 1550 & 1548/M/2018 & 1970/M/2022 Income Income-tax Act stand abated cannot be accepted. tax Act stand abated cannot be accepted. Similarly

ESSEL MINING & INDUSTRIES LIMITED,MUMBAI vs. DY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-1(4), MUMBAI

In the result, the appeal of the Revenue for assessment year the result, the appeal of the Revenue for assessment year the result, the appeal of the Revenue for assessment year

Bench: Shri Aby T Varkey () & Shri Om Prakash Kant () Assessment Year: 2011-12 & Assessment Year: 2012-13 Essel Mining & Industries Ltd., Dy. Cit, Central Circle-1(4), Industry House, 18Th Floor, 10, 9Th Floor, Old Cgo Building, Camac Street, Vs. Mk Road, Kolkata-700017. Mumbai-400020. Pan No. Aaace 6607 L Appellant Respondent Assessment Year: 2011-12 & Assessment Year: 2012-13 Jcit, Central Circle-1(4), M/S Essel Mining & Industries Room No. 902, Pratishtha Ltd., Bhavan, 9Th Floor, Old Cgo Vs. Industry House, 18Th Floor, 10, Building Annexe, Camac Street, Mumbai-400020. Kolkata-700017. Pan No. Aaace 6607 L Appellant Respondent Assessment Year: 2011-12 M/S Essel Mining & Industries Dy. Cit, Central Circle-1(4), Ltd., 9Th Floor, Old Cgo Building, Vs. Industry House, 18Th Floor, 10, Mk Road

reassessments finalized for finalized for the the the assessment years covered under Section 153A of the assessment years covered under Section 153A of the assessment years covered under Section 153A of the Essel Mining & Industries Ltd. ITA Nos. 1020, 1019, 1550 & 1548/M/2018 & 1970/M/2022 Income Income-tax Act stand abated cannot be accepted. tax Act stand abated cannot be accepted. Similarly

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

b) of sub- section (1) of this Section or Section 153A or Section 153C, as the case may be, as they stood immediately before the commencement of the Finance Act, 2021". 28. Section has to be interpreted so as to give meaning to all the words/phrases used in the Section and it should not be interpreted in such

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

1) Notwithstanding anything contained in section\n139, section 147, section 148, section 149, section\n151 and section 153, where the Assessing Officer is\nsatisfied that:\n\n(a) any money, bullion, jewellery or other valuable\narticle or thing, seized or requisitioned, belongs\nto; or\n\n(b) any books of account or documents, seized or\nrequisitioned, pertains or pertain

SHRI SHIV SHANKAR SHARMA,MUMBAI vs. ASSISTANT COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE 4(3), MUMBAI, MUMBAI

In the result, all the appeals filed by the revenue are dismissed and the assessee’s appeals are partly allowed

Bench: SHRI AMIT SHUKLA (Judicial Member), SHRI GIRISH AGRAWAL (Accountant Member)

reassessment made in respect of an assessment year under this section, the tax shall be chargeable at the rate or rates (i) in as applicable to such assessment year.” 11. A careful and purposive reading of section 153A(1)(b

DCIT CENTRAL CIRCLE-8(1), MUMBAI, MUMBAI vs. SHIVSHANKAR RAMSWAROOP SHARMA, MUMBAI

In the result, all the appeals filed by the revenue are dismissed and the assessee’s appeals are partly allowed

Bench: SHRI AMIT SHUKLA (Judicial Member), SHRI GIRISH AGRAWAL (Accountant Member)

reassessment made in respect of an assessment year under this section, the tax shall be chargeable at the rate or rates (i) in as applicable to such assessment year.” 11. A careful and purposive reading of section 153A(1)(b

SHIV SHANKAR SHARMA,MUMBAI vs. ASSISTANT COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE 4(3), MUMBAI, MUMBAI

In the result, all the appeals filed by the revenue are dismissed and the assessee’s appeals are partly allowed

Bench: SHRI AMIT SHUKLA (Judicial Member), SHRI GIRISH AGRAWAL (Accountant Member)

reassessment made in respect of an assessment year under this section, the tax shall be chargeable at the rate or rates (i) in as applicable to such assessment year.” 11. A careful and purposive reading of section 153A(1)(b

DCIT, CENTRAL CIRCLE - 8 (1), MUMBAI, MUMBAI vs. SHIV SHANKAR SHARMA, MUMBAI

In the result, all the appeals filed by the revenue are dismissed and the assessee’s appeals are partly allowed

Bench: SHRI AMIT SHUKLA (Judicial Member), SHRI GIRISH AGRAWAL (Accountant Member)

reassessment made in respect of an assessment year under this section, the tax shall be chargeable at the rate or rates (i) in as applicable to such assessment year.” 11. A careful and purposive reading of section 153A(1)(b

DCIT, CENTRAL CIRCLE-8(1), MUMBAI, MUMBAI vs. SHIV SHANKAR SHARMA, MUMBAI

In the result, all the appeals filed by the revenue are dismissed and the assessee’s appeals are partly allowed

Bench: SHRI AMIT SHUKLA (Judicial Member), SHRI GIRISH AGRAWAL (Accountant Member)

reassessment made in respect of an assessment year under this section, the tax shall be chargeable at the rate or rates (i) in as applicable to such assessment year.” 11. A careful and purposive reading of section 153A(1)(b

SHIV SHANKAR SHARMA,MUMBAI vs. ASSISTANT COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE 4(3), MUMBAI, MUMBAI

In the result, all the appeals filed by the revenue are dismissed and the assessee’s appeals are partly allowed

Bench: SHRI AMIT SHUKLA (Judicial Member), SHRI GIRISH AGRAWAL (Accountant Member)

reassessment made in respect of an assessment year under this section, the tax shall be chargeable at the rate or rates (i) in as applicable to such assessment year.” 11. A careful and purposive reading of section 153A(1)(b

ACIT (CC)-8(2) , MUMBAI vs. HELIOS EXPORTS LTD, MUMBAI

Bench: Shri Prashant Maharishi, Am & Shri Sandeep Singh Karhail, Jm

153A or the assessment year referred to in clause (b) of sub-section (1) of section 153B, except with the prior approval of the Joint Commissioner:] 48[Provided that nothing contained in this section shall apply where the assessment or reassessment