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)

Section 37 of the Act (read with Explanation 1 thereto) in respect of payments made by the Assessee to auto dealers during the previous year relevant to Assessment Year 2014-2015. Thereafter, the Assessing Officer proceeded to initiate reassessment proceedings ITA No. 2616-2623 /Mum /2024

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)

Section 37 of the Act (read with Explanation 1 thereto) in respect of payments made by the Assessee to auto dealers during the previous year relevant to Assessment Year 2014-2015. Thereafter, the Assessing Officer proceeded to initiate reassessment proceedings ITA No. 2616-2623 /Mum /2024

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)

Section 37 of the Act (read with Explanation 1 thereto) in respect of payments made by the Assessee to auto dealers during the previous year relevant to Assessment Year 2014-2015. Thereafter, the Assessing Officer proceeded to initiate reassessment proceedings ITA No. 2616-2623 /Mum /2024

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 notice; 80. In Ashish Agarwal (supra), this Court directed that Section 148 notices which were challenged before various High Courts "shall be deemed to have been issued under section 148-A of the Income-tax Act as substituted by the Finance Act, 2021 and construed or treated to be show-cause notices in terms of Section

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

Appeal is allowed

Bench: Him.

reassessment notice; 80. In Ashish Agarwal (supra), this Court directed that Section 148 notices which were challenged before various High Courts "shall be deemed to have been issued under section 148-A of the Income-tax Act as substituted by the Finance Act, 2021 and construed or treated to be show-cause notices in terms of Section

TATA EDUCATION TRUST ,MUMBAI vs. DEPUTY COMMISSIONER OF INCOME TAX , MUMBAI

In the result, the appeal is allowed

reassessment or re computation under section 147;\nc. an order being an intimation under sub-section (1) of section 200A;\nd. an order under section 201;\ne. an order being an intimation under sub-section (6A) of section 206C;\nf. an order under sub-section (1) of section 206CB;\ng. an order imposing a penalty under Chapter

ACIT-3(2)(1), MUMBAI vs. MAHARASHTRA AIRPORT DEVELOPMENT COMPANY LTD., MUMBAI

reassessment [or fresh order under section 92CA, as\nthe case may be,], such effect shall be given within a period of three\nmonths from the end of the month in which order under section 250\nor section 254 or section 260 or section 262 is received by the\nPrincipal Chief Commissioner or Chief Commissioner or Principal\nCommissioner or Commissioner

SHIVRAM S SHETTY,MUMBAI vs. INCOME TAX OFFICER WARD 2(1), THANE

In the result, the appeals filed by the assessee are hereby allowed

Reassessment proceedings were well\nwithin the statutory time limit and were not time-barred in view of the first proviso\nto Section 149(1) of the IT Act, which was made applicable from 01/04/2021.\n(vi) That the time limit to re-open the proceedings in the present case within the\nmeaning of Section 147 had been extended to 30/06/2021

LESHARK GLOBAL LLP ,MUMBAI vs. DCIT CC 4(1), MUMBAI

In the result, all the appeals for A

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

section 2(24)(xviii) of the Act. In respect of the FPS, the ld. Counsel relied on the decision of the ITAT Chennai Bench in the case of Eastman Exports Global Clothing Pvt. Ltd. in ITA No. 47/MDS/2016(AYs 2011-12 and 2012-13) dated 17.05.2016 and the ITAT Delhi in the case of Bharat Rasayan

LESHARK GLOBAL LLP ,MUMBAI vs. DCIT CC 4(1), MUMBAI

In the result, all the appeals for A

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

section 2(24)(xviii) of the Act. In respect of the FPS, the ld. Counsel relied on the decision of the ITAT Chennai Bench in the case of Eastman Exports Global Clothing Pvt. Ltd. in ITA No. 47/MDS/2016(AYs 2011-12 and 2012-13) dated 17.05.2016 and the ITAT Delhi in the case of Bharat Rasayan

LESHARK GLOBAL LLP ,MUMBAI vs. DCIT CC 4(1), MUMBAI

In the result, all the appeals for A

section 2(24)(xviii) of the Act. In respect of the FPS, the ld. Counsel relied on the decision of the ITAT Chennai Bench in the case of Eastman Exports Global Clothing Pvt. Ltd. in ITA No. 47/MDS/2016(AYs 2011-12 and 2012-13) dated 17.05.2016 and the ITAT Delhi in the case of Bharat Rasayan

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

Section 37 of the Act \n(read with Explanation 1 thereto) in respect of payments made \nby the Assessee to auto dealers during the previous year \nrelevant to Assessment Year 2014-2015. Thereafter, the \nAssessing Officer proceeded to initiate reassessment proceedings \nafter recording/concluding as under:\n“For the A.Y.2010-11, the nature of expenses in the form of \npayments made

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

Section 37 of the Act\n(read with Explanation 1 thereto) in respect of payments made\nby the Assessee to auto dealers during the previous year\nrelevant to Assessment Year 2014-2015. Thereafter, the\nAssessing Officer proceeded to initiate reassessment proceedings\nITA No. 2616-2623 /Mum /2024, ITA No. 2845, 2841, 2836, 2834,\n2827

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

Section 37 of the Act\n(read with Explanation 1 thereto) in respect of payments made\nby the Assessee to auto dealers during the previous year\nrelevant to Assessment Year 2014-2015. Thereafter, the\nAssessing Officer proceeded to initiate reassessment proceedings\n\n==End of OCR for page 43==\n\nafter recording/concluding as under:\n\n“For the A.Y.2010-11

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

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

reassessment notice; 80. In Ashish Agarwal (supra), this Court directed that Section 148 notices which were challenged before various High 5 Assessment Year 2016-17 Courts "shall be deemed to have been issued under section 148-A of the Income-tax Act as substituted by the Finance Act, 2021 and construed or treated to be show-cause notices in terms

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 notice; 80. In Ashish Agarwal (supra), this Court directed that Section 148 notices which were challenged before various High Courts "shall be deemed to have been issued under section 148-A of the Income-tax Act as substituted by the Finance Act, 2021 and construed or treated to be show-cause notices in terms of Section

ESTATE OF VANDRAVAN P SHAH,MUMBAI vs. ASSISTANT COMMISSIONER OF INCOME TAX, CIRCLE 19(3), MUMBAI

In the result all the three captioned appeals are dismissed

section 160(iii) specifically\nprovided that in respect of income which the court of wards, the\nAdministrator -General, the official trustee or any receiver or\nmanager (including any person, whatever his designation, who in\nfact manages property on behalf of another) appointed by or under\nany order of a court, receives or is entitled to receive on behalf

ESTATE OF VANDRAVAN P SHAH,MUMBAI vs. ASSISTANT COMMISSIONER OF INCOME TAX, CIRCLE 19(3), MUMBAI

In the result all the three captioned appeals are dismissed

section 160(iii) specifically\nprovided that in respect of income which the court of wards, the\nAdministrator -General, the official trustee or any receiver or\nmanager (including any person, whatever his designation, who in\nfact manages property on behalf of another) appointed by or under\nany order of a court, receives or is entitled to receive on behalf