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

14 to AY 2020-21 except AY 2014-15 15 , 2015-16 and 2019-20. These appeals being connecte These appeals being connected with same same assessee and involving common issue, same involving common issue, same were heard together and disposed off were heard together and disposed off by way of this consolidated order for convenience and avoid

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

14 to AY 2020-21 except AY 2014-15 15 , 2015-16 and 2019-20. These appeals being connecte These appeals being connected with same same assessee and involving common issue, same involving common issue, same were heard together and disposed off were heard together and disposed off by way of this consolidated order for convenience and avoid

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

14 to AY 2020-21 except AY 2014-15 15 , 2015-16 and 2019-20. These appeals being connecte These appeals being connected with same same assessee and involving common issue, same involving common issue, same were heard together and disposed off were heard together and disposed off by way of this consolidated order for convenience and avoid

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

14 to AY 2020-21 except AY 2014-15 15 , 2015-16 and 2019-20. These appeals being connecte These appeals being connected with same same assessee and involving common issue, same involving common issue, same were heard together and disposed off were heard together and disposed off by way of this consolidated order for convenience and avoid

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

14 to AY 2020-21 except AY 2014-15 15 , 2015-16 and 2019-20. These appeals being connecte These appeals being connected with same same assessee and involving common issue, same involving common issue, same were heard together and disposed off were heard together and disposed off by way of this consolidated order for convenience and avoid

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

14 to AY 2020-21 except AY 2014-15 15 , 2015-16 and 2019-20. These appeals being connecte These appeals being connected with same same assessee and involving common issue, same involving common issue, same were heard together and disposed off were heard together and disposed off by way of this consolidated order for convenience and avoid

JEEVANDEEP EDUMEDIA PRIVATE LIMITED,MUMBAI vs. PRINCIPLE CIT-6, MUMBAI

In the result, the a In the result, the appeal of the assessee is stands allowed

Bench: Shri Om Prakash Kant () & Ms. Kavitha Rajagopal () Assessment Year: 2020-21 Jeevandeep Edumedia Pvt. Ltd., Pr. Cit-6, 1St Floor, Sun Paradise Business 501,5Th Floor, Aayakar Bhavan, Plaza, Senapati Bapat Marg, Vs. Maharishi Karve Road, Lower Parel (West), Mumbai-400020. Mumbai-400013. Pan No. Aabcj 0180 G Appellant Respondent

Reassessment proceedings for the assessment year 2020-21 With reference to the above With reference to the above subject and under the instructions subject and under the instructions of our above named client, we would like to submit as under; of our above named client, we would like to submit as under; of our above named client, we would like

DCIT CC-8(2),MUMBAI, MUMBAI vs. RAKESH S KATHOTIA, MUMBAI

In the result appeal filed by the revenue stands dismissed

Bench: Shri Sandeep Gosain & Shri Prabhash Shankar

reassessment has to be based on fulfilment of certain pre-condition and if the concept of "change of opinion" as an in- built test to check abuse of power by the Assessing Officer". 1. In the aforesaid backdrop, without prejudice, it is also relevant to mention here the decision of Hon'ble Supreme Court in the case

GLOBAL BUSINESS CONEXXTIONS PVT.LTD.,MADHYA PRADESH vs. ACIT/DCIT-5(3), MUMBAI

reassessment proceedings were initiated against the Appellant 11. on the ground that income liable to tax in the hands of the Appellant as deemed dividend under Section 2(22)(e) of the Act had escaped assessment. The Assessing Officer made addition of INR 11,83,73,433/- under Section 2(22)(e) of the Act which was confirmed

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

In the result all the three captioned appeals are dismissed

Bench: Sandeep Gosain () & Shri Om Prakash Kant ()

reassessment proceedings had been initiated in the name of a deceas been initiated in the name of a deceased person. Estate of Vandravan P Shah Estate of Vandravan P Shah ITA No. 5401, 5402 & 5403/MUM/2024 5.1 It was submitted that the notices issued under sections 143(2) It was submitted that the notices issued under sections 143(2

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

In the result, the appeal of the assessee is partly allowed

Bench: Shri Kuldip Singh () & Shri Om Prakash Kant () Assessment Year: 2012-13 Sai Prerana Co-Op Society Ltd., Ito-7(3)(2), 317, Puran Aasha Bldg. Gr. Fl. Room No. 126, 1St Floor, Narashi Natha Street, Katha Vs. Kautilya Bhavan, C-41 To C- Bazar Musjid Bunder (W), 43 Block, Bandra Kurla Mumbai-400 009. Complex, Bandra (East) Mumbai-400051. Pan No. Aadts 5638 M Appellant Respondent Assessee By : Ms. Ruby Srivastava & Mr. Bharat Kumar, Ca Revenue By : Mr. Milind S. Chavan, Dr Date Of Hearing : 27/04/2023 : Date Of Pronouncement 28/04/2023 Order

14 case was reopened u/s 147 of the Act on the ground that the assessee had claimed deduction u/s the Act on the ground that the assessee had claimed deduction u/s the Act on the ground that the assessee had claimed deduction u/s 80P of the Act. The Act. The reasons to believe that income escaped to believe that income

MEHLI MEHTA MUSIC FOUNDATION,MUMBAI vs. INCOME TAX OFFICER, EXEMPTION WARD-2(4), MUMBAI

14\nITA No.4260, 4261, 4306, 4307 & 4545/MUM/2023\nMehli Mehta Music Foundation\nthat do not violate any central or state regulation, doesn't in general\nrepresent a profit making activity. For the sake of convenience the\nrelevant extract from the CBDT circular is reproduced as under:\n\"Section 2(15) of the Income Tax Act, 1961 (\"Act') defines \"charitable\npurpose

MEHLI MEHTA MUSIC FOUNDATION,MUMBAI vs. ITO, EXEMPTION WARD-2(4), MUMBAI

reassessment proceedings even after expiry of four\nyears from end of relevant assessment year was justified.\nSohar Siraj Lokhandwala V/s ACIT (1994) 77 Taxman 302 (Bombay\nHC)- Mere production of evidence before Assessing Officer is not\nenough and there may be an omission or failure on part of assessee\nto make a 'full' and 'true' disclosure if some material

SHRI RAJESH RAMCHANDRA DAKE,PANVEL vs. DY CIT CC-1, MUMBAI

14, 2010 under Section 143(3) of the Act assessing the total income of the Assessee at Rs.37,81,900/-. The AO in the assessment order dated March 31, 2016 under Section 143(3) read with Section 153A of the Act has also made two additions of Rs.6,81,11,103/- on account of brokerage income and Rs.10

MEHLI MEHTA MUSIC FOUNDATION,MUMBAI vs. INCOME TAX OFFICER, EXEMPTION WARD-2(4), MUMBAI

14\nITA No.4260, 4261, 4306, 4307 & 4545/MUM/2023\nMehli Mehta Music Foundation\nthat do not violate any central or state regulation, doesn't in general\nrepresent a profit making activity. For the sake of convenience the\nrelevant extract from the CBDT circular is reproduced as under:\n"Section 2(15) of the Income Tax Act, 1961 (\"Act') defines \"charitable\npurpose

JAIPRAKASH L. SINGH,MUMBAI vs. ACIT 31(2)(1), MUMBAI

In the result, the appeal filed by the assessee stands\nallowed

reassessment as\nprescribed in sub-section (2) of section\n150 of the Act limitation provided\nunder section 149 of the Act has to be\ncounted from the end of relevant\n assessment year till date of order which\nis subject matter of appeal wherein\ndirections were passed.\"\n21. The Hon'ble Jurisdictional Mumbai Tribunal under\nsomewhat similar facts

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

section 37(1) redundant. The statutory distinction between business 37(1) redundant. The statutory distinction between business 37(1) redundant. The statutory distinction between business deductions and Chapter VI deductions and Chapter VI-A incentives must be respected, and A incentives must be respected, and their misuse avoided in letter and spirit. their misuse avoided in letter and spirit. Accordingly

ACIT CIRCLE-4(3)(1), MUMBAI, MUMBAI vs. KHADAMAT INTEGRATED SOLUTIONS PVT LTD, MUMBAI

In the result, Cross Objection filed by the Assessee is allowed,\nwhereas the appeal filed by the Revenue Department stands\ndismissed as infructuous

14. We shall now deal with the objection raised by the Ld. DR that as\nthe assessee had not called in question the jurisdiction of the Income-Тах\nOfficer, Ward-2(2), Bhilai within the stipulated time period of one month\nfrom the date on which he was served with the notice(s) u/ss.143(2) and\n142(I), dated