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(1) of the Act.We have perused the aforesaid decision of the Tribunal in that case it was stated, during the assessment proceeding, the assessing officer noted that as per material available on record, the Director General of Central Excise Intelligence, Chennai Zone (DGCEI) had carried out investigation in respect of certain auto dealers and intermediaries. In course

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(1) of the Act.We have perused the aforesaid decision of the Tribunal in that case it was stated, during the assessment proceeding, the assessing officer noted that as per material available on record, the Director General of Central Excise Intelligence, Chennai Zone (DGCEI) had carried out investigation in respect of certain auto dealers and intermediaries. In course

IMPRESSIVE TRADING PRIVATE LIMITED,MUMBAI vs. INCOME TAX OFFICER 10(1)(1), MUMBAI

In the result, all the above appeals in ITA Nos

Bench: Shri Narendra Kumar Choudhry & Shri Prabhash Shankar

reassessment notices would have to be issued within the time limit surviving. To understand how the law laid down by the Hon’ble Supreme Court in Rajeev Bansal would apply to the present case, it would be apposite to set out in the following table the notices etc issued in the present case. 1. 30-06-2021 Notice under

IMPRESSIVE TRADING PRIVATE LIMITED,MUMBAI vs. INCOME TAX OFFICER 10(1)(1), MUMBAI

In the result, all the above appeals in ITA Nos

Bench: Shri Narendra Kumar Choudhry & Shri Prabhash Shankar

reassessment notices would have to be issued within the time limit surviving. To understand how the law laid down by the Hon’ble Supreme Court in Rajeev Bansal would apply to the present case, it would be apposite to set out in the following table the notices etc issued in the present case. 1. 30-06-2021 Notice under

ANNAPURNA INFRATECH,MUMBAI vs. DCIT, CENTRAL CIRCLE 1, THANE, THANE

In the result, both the appeals of the assessee are allowed

194/- in AY 2015-16 and Rs.1,43,05,438/- in AY 2016-17. It is pertinent to note that both these years fall under the category of ‘unabated assessment years'. It is well settled proposition of law that the AO is entitled to make addition in the assessment completed u/s 153A of the Act in the unabated assessment years

SHIVALIK VENTURES PRIVATE LIMITED,MUMBAI vs. DCIT CC 8(1) , MUMBAI, MUMBAI

reassessment proceedings were initiated based upon\ntangible, credible, and previously undisclosed information resulting from the\nsurvey action u/s 133A conducted on 07.10.2021. This survey clearly revealed\ncritical facts regarding the appellant's non-deduction of TDS under Section 194

SHIVALIK VENTURES PRIVATE LIMITED,MUMBAI vs. ACIT CC 8(1), MUMBAI, MUMBAI

Bench: Ms Padmavathy S, Am & Shri Sandeep Singh Karhail, Jm

reassessment proceedings were initiated based upon tangible, credible, and previously undisclosed information resulting from the survey action u/s 133A conducted on 07.10.2021. This survey clearly revealed critical facts regarding the appellant's non-deduction of TDS under Section 194

SHIVALIK VENTURES PRIVATE LIMITED,MUMBAI vs. ACIT CC 8(1), MUMBAI, MUMBAI

Accordingly we direct the AO to delete the disallowance made under section\n36(1)(va) of the Act for AY 2019-20 & 2020-21 also.\n15. In result, the appeals of the assessee for AY 2018-19 to AY 2020...

reassessment proceedings were initiated based upon\ntangible, credible, and previously undisclosed information resulting from the\nsurvey action u/s 133A conducted on 07.10.2021. This survey clearly revealed\ncritical facts regarding the appellant's non-deduction of TDS under Section 194

IMPRESSIVE TRADING PVT. LTD.,MUMBAI vs. INCOME TAX OFFICER 10(1)(1), MUMBAI

In the result, all the above appeals in ITA Nos

reassessment notices would have to be issued within the time\nlimit surviving. To understand how the law laid down by the Hon'ble Supreme\nCourt in Rajeev Bansal would apply to the present case, it would be apposite to\nset out in the following table the notices etc issued in the present case.\n1. 30-06-2021 Notice under

ABDUL SALAM MOHAMED YASIN,MUMBAI vs. DCIT CIRCLE 17(1), MUMBAI

In the result, the appeal of the assessee is allowed on legal grounds

Bench: SHRI AMIT SHUKLA (Judicial Member), SHRI MAKARAND VASANT MAHADEOKAR (Accountant Member)

reassessment proceedings. The present case squarely falls within this interdicted zone, where the notice is not only ex facie time-barred but is also vitiated by non-compliance with the mandatory sanctional regime under section 151(ii) of the Act. 10. Section 151(ii) of the Act unambiguously provides that where more than three years have elapsed from

ANNAPURNA INFRATECH,MUMBAI vs. DCIT, CENTRAL CIRCLE 1, THANE, THANE

In the result, both the appeals of the assessee are allowed

194/- in AY\n2015-16 and Rs.1,43,05,438/- in AY 2016-17. It is pertinent to note that\nboth these years fall under the category of ‘unabated assessment years'. It\nis well settled proposition of law that the AO is entitled to make addition in\nthe assessment completed u/s 153A of the Act in the unabated\n assessment

SAI PRERNA CO-OP. CREDIT SOCIETY LTD,MUMBAI vs. ITO WD 17(3) (2) , MUMBAI

In the result, appeals of the assessee and the Revenue are In the result, appeals of the assessee and the Revenue are In the result, appeals of the assessee and the Revenue are decided as under:

Bench: Shri Kuldip Singh () & Shri Om Prakash Kant () Ita Nos. 217, 220 & 221, 218 & 219, 215, 214/Mum/2023 Assessment Years: 2013-14, 2016-17, 2017-18, 2018-19, 2020-21 Sai Prerana Co-Op Credit Ito-17(3)(2), Society Ltd., Room No. 126, 1St Floor, Vs. 317, Puran Aasha Bldg, Gr. Fl. Kautilya Bhavan, C-41 To C- Narashi Natha Street, Katha 43, G Block Bandra Kurla Bazar Masjid Bunder (W), Complex, Bandra (East), Mumbai-400 009. Mumbai-400051. Pan No. Aadts 5638 M Appellant Respondent

194 & 195/MUM/2023 Assessment Year: 2016-17, 2017-18, 2018-19 & 2020-21 ITO-26(2)(1), Sai Prerana Co-op Credit Society Room No. 127, 1st floor, G- Ltd., Vs. Block, Kautilya Bhavan, 317, Puran Aasha Bldg, Gr. Fl. Bandra Kurla Complex, NarashiNatha Street, Katha Mumbai-400051. Bazar Masjid Bunder (W), Mumbai-400 009. PAN No. AADTS 5638 M Appellant

ITO-26(2)(1) , MUMBAI vs. SAI PRERANA CO-OP CREDIT SOCIETY LTD, MUMBAI

In the result, appeals of the assessee and the Revenue are In the result, appeals of the assessee and the Revenue are In the result, appeals of the assessee and the Revenue are decided as under:

Bench: Shri Kuldip Singh () & Shri Om Prakash Kant () Ita Nos. 217, 220 & 221, 218 & 219, 215, 214/Mum/2023 Assessment Years: 2013-14, 2016-17, 2017-18, 2018-19, 2020-21 Sai Prerana Co-Op Credit Ito-17(3)(2), Society Ltd., Room No. 126, 1St Floor, Vs. 317, Puran Aasha Bldg, Gr. Fl. Kautilya Bhavan, C-41 To C- Narashi Natha Street, Katha 43, G Block Bandra Kurla Bazar Masjid Bunder (W), Complex, Bandra (East), Mumbai-400 009. Mumbai-400051. Pan No. Aadts 5638 M Appellant Respondent

194 & 195/MUM/2023 Assessment Year: 2016-17, 2017-18, 2018-19 & 2020-21 ITO-26(2)(1), Sai Prerana Co-op Credit Society Room No. 127, 1st floor, G- Ltd., Vs. Block, Kautilya Bhavan, 317, Puran Aasha Bldg, Gr. Fl. Bandra Kurla Complex, NarashiNatha Street, Katha Mumbai-400051. Bazar Masjid Bunder (W), Mumbai-400 009. PAN No. AADTS 5638 M Appellant

INCOME TAX OFFICER-26(2)(1), MUMBAI vs. SAI PRERANA CO-OP CREDIT SOCIETY LTD., MUMBAI

In the result, appeals of the assessee and the Revenue are In the result, appeals of the assessee and the Revenue are In the result, appeals of the assessee and the Revenue are decided as under:

Bench: Shri Kuldip Singh () & Shri Om Prakash Kant () Ita Nos. 217, 220 & 221, 218 & 219, 215, 214/Mum/2023 Assessment Years: 2013-14, 2016-17, 2017-18, 2018-19, 2020-21 Sai Prerana Co-Op Credit Ito-17(3)(2), Society Ltd., Room No. 126, 1St Floor, Vs. 317, Puran Aasha Bldg, Gr. Fl. Kautilya Bhavan, C-41 To C- Narashi Natha Street, Katha 43, G Block Bandra Kurla Bazar Masjid Bunder (W), Complex, Bandra (East), Mumbai-400 009. Mumbai-400051. Pan No. Aadts 5638 M Appellant Respondent

194 & 195/MUM/2023 Assessment Year: 2016-17, 2017-18, 2018-19 & 2020-21 ITO-26(2)(1), Sai Prerana Co-op Credit Society Room No. 127, 1st floor, G- Ltd., Vs. Block, Kautilya Bhavan, 317, Puran Aasha Bldg, Gr. Fl. Bandra Kurla Complex, NarashiNatha Street, Katha Mumbai-400051. Bazar Masjid Bunder (W), Mumbai-400 009. PAN No. AADTS 5638 M Appellant

ITO-26(2)(1), MUMBAI vs. SAI PRERANA CO-OP CREDIT SOCIETY LTD, MUMBAI

In the result, appeals of the assessee and the Revenue are In the result, appeals of the assessee and the Revenue are In the result, appeals of the assessee and the Revenue are decided as under:

Bench: Shri Kuldip Singh () & Shri Om Prakash Kant () Ita Nos. 217, 220 & 221, 218 & 219, 215, 214/Mum/2023 Assessment Years: 2013-14, 2016-17, 2017-18, 2018-19, 2020-21 Sai Prerana Co-Op Credit Ito-17(3)(2), Society Ltd., Room No. 126, 1St Floor, Vs. 317, Puran Aasha Bldg, Gr. Fl. Kautilya Bhavan, C-41 To C- Narashi Natha Street, Katha 43, G Block Bandra Kurla Bazar Masjid Bunder (W), Complex, Bandra (East), Mumbai-400 009. Mumbai-400051. Pan No. Aadts 5638 M Appellant Respondent

194 & 195/MUM/2023 Assessment Year: 2016-17, 2017-18, 2018-19 & 2020-21 ITO-26(2)(1), Sai Prerana Co-op Credit Society Room No. 127, 1st floor, G- Ltd., Vs. Block, Kautilya Bhavan, 317, Puran Aasha Bldg, Gr. Fl. Bandra Kurla Complex, NarashiNatha Street, Katha Mumbai-400051. Bazar Masjid Bunder (W), Mumbai-400 009. PAN No. AADTS 5638 M Appellant

SAI PRERNA CO-OP. CREDIT SOCIETY LTD,MUMBAI vs. ITO WD 17(3) (2) , MUMBAI

In the result, appeals of the assessee and the Revenue are In the result, appeals of the assessee and the Revenue are In the result, appeals of the assessee and the Revenue are decided as under:

Bench: Shri Kuldip Singh () & Shri Om Prakash Kant () Ita Nos. 217, 220 & 221, 218 & 219, 215, 214/Mum/2023 Assessment Years: 2013-14, 2016-17, 2017-18, 2018-19, 2020-21 Sai Prerana Co-Op Credit Ito-17(3)(2), Society Ltd., Room No. 126, 1St Floor, Vs. 317, Puran Aasha Bldg, Gr. Fl. Kautilya Bhavan, C-41 To C- Narashi Natha Street, Katha 43, G Block Bandra Kurla Bazar Masjid Bunder (W), Complex, Bandra (East), Mumbai-400 009. Mumbai-400051. Pan No. Aadts 5638 M Appellant Respondent

194 & 195/MUM/2023 Assessment Year: 2016-17, 2017-18, 2018-19 & 2020-21 ITO-26(2)(1), Sai Prerana Co-op Credit Society Room No. 127, 1st floor, G- Ltd., Vs. Block, Kautilya Bhavan, 317, Puran Aasha Bldg, Gr. Fl. Bandra Kurla Complex, NarashiNatha Street, Katha Mumbai-400051. Bazar Masjid Bunder (W), Mumbai-400 009. PAN No. AADTS 5638 M Appellant

INCOME TAX OFFICER-26(2)(1), MUMBAI vs. SAI PRERANA CO-OP CREDIT SOCIETY LTD., MUMBAI

In the result, appeals of the assessee and the Revenue are In the result, appeals of the assessee and the Revenue are In the result, appeals of the assessee and the Revenue are decided as under:

Bench: Shri Kuldip Singh () & Shri Om Prakash Kant () Ita Nos. 217, 220 & 221, 218 & 219, 215, 214/Mum/2023 Assessment Years: 2013-14, 2016-17, 2017-18, 2018-19, 2020-21 Sai Prerana Co-Op Credit Ito-17(3)(2), Society Ltd., Room No. 126, 1St Floor, Vs. 317, Puran Aasha Bldg, Gr. Fl. Kautilya Bhavan, C-41 To C- Narashi Natha Street, Katha 43, G Block Bandra Kurla Bazar Masjid Bunder (W), Complex, Bandra (East), Mumbai-400 009. Mumbai-400051. Pan No. Aadts 5638 M Appellant Respondent

194 & 195/MUM/2023 Assessment Year: 2016-17, 2017-18, 2018-19 & 2020-21 ITO-26(2)(1), Sai Prerana Co-op Credit Society Room No. 127, 1st floor, G- Ltd., Vs. Block, Kautilya Bhavan, 317, Puran Aasha Bldg, Gr. Fl. Bandra Kurla Complex, NarashiNatha Street, Katha Mumbai-400051. Bazar Masjid Bunder (W), Mumbai-400 009. PAN No. AADTS 5638 M Appellant

SAI PRERNA CO-OP. CREDIT SOCIETY LTD,MUMBAI vs. ITO WD 17(3) (2) , MUMBAI

In the result, appeals of the assessee and the Revenue are In the result, appeals of the assessee and the Revenue are In the result, appeals of the assessee and the Revenue are decided as under:

Bench: Shri Kuldip Singh () & Shri Om Prakash Kant () Ita Nos. 217, 220 & 221, 218 & 219, 215, 214/Mum/2023 Assessment Years: 2013-14, 2016-17, 2017-18, 2018-19, 2020-21 Sai Prerana Co-Op Credit Ito-17(3)(2), Society Ltd., Room No. 126, 1St Floor, Vs. 317, Puran Aasha Bldg, Gr. Fl. Kautilya Bhavan, C-41 To C- Narashi Natha Street, Katha 43, G Block Bandra Kurla Bazar Masjid Bunder (W), Complex, Bandra (East), Mumbai-400 009. Mumbai-400051. Pan No. Aadts 5638 M Appellant Respondent

194 & 195/MUM/2023 Assessment Year: 2016-17, 2017-18, 2018-19 & 2020-21 ITO-26(2)(1), Sai Prerana Co-op Credit Society Room No. 127, 1st floor, G- Ltd., Vs. Block, Kautilya Bhavan, 317, Puran Aasha Bldg, Gr. Fl. Bandra Kurla Complex, NarashiNatha Street, Katha Mumbai-400051. Bazar Masjid Bunder (W), Mumbai-400 009. PAN No. AADTS 5638 M Appellant