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

reassessment proceedings initiated under Section 147 of the Act cannot be sustained. Accordingly, the addition of INR 11,83,73,433/- as deemed dividend under the provisions of Section 2(22)(e) of the Act is deleted and the order dated 28/12/2018, passed under Section 143(3) read with Section 147 of the Act is quashed. The Revenue would

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

2) of the Act issued by\nthe Income Tax Officer, who had no authority and / or power to\nassess the income of the assessee and / or to make the assessment\nin the case of the assessee being beyond pecuniary\njurisdiction/limit, as prescribed by the CBDT vide Instruction no.\n01/2011.\n22. We further observe that Hon'ble Apex Court

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

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

2)(1), Mumbai.\n3. For the year under consideration, the appellant filed a return of\nincome declaring an income of Rs.1,86,429/- on 31/03/2004.\nThe return of income was processed u/s 143(1) of the on 21-04-\n2004.\n4. Thereafter, nothing was heard till 31-03-2019, on which day, the\nLearned A.O. issued a notice

DY COMMISSIONER OF INCOME TAX (EXEMPTION)-2(1), MUMBAI vs. SHREE SAI BABA SANSTHAN TRUST (SHIRDI), MUMBAI

In the result, the appeal filed by the assessee is allowed and the\nappeal of the Revenue is dismissed

2) The provisions of sub-section (1) shall not apply to any anonymous\ndonations received by-\n(a)any trust or institution created or established wholly for religious\npurposes;\n(b)any trust or institution created or established wholly for religious\nand charitable purposes other than any anonymous donation made\nwith a specific direction that such donation

SHREE SAI BABA SANTHAN TRUST MUMBAI ,MUMBAI vs. DCIT(EXEMPTION), MUMBAI

In the result, the appeal filed by the assessee is allowed and the\nappeal of the Revenue is dismissed

2) The provisions of sub-section (1) shall not apply to any anonymous\ndonation received by-\n(a)any trust or institution created or established wholly for religious\npurposes;\n(b)any trust or institution created or established wholly for religious\nand charitable purposes other than any anonymous donation made\nwith a specific direction that such donation

JT.COMMISSIONER OF INCOME TAX 15(3)2, (OSD), MUMBAI vs. M/S.U.S.ROOFS LIMITED, MUMBAI

In the result, the appeal by the assessee is allowed, while the appeal by the Revenue is dismissed

Bench: Shri G.S. Pannu & Shri Sandeep Singh Karhail

reassessment proceedings, the AO issued a notice under section 143(2) of the Act on 20/02/2011, and thereafter, upon transfer of the case, fresh notice under section 143(2) of the Act was issued on 17/10/2011. Since the issue in dispute is pertaining to the validity of notice issued under section 143(2) of the Act, therefore, before proceeding further

M/S.U.S.ROOFS LIMITED,MUMBAI vs. ACIT-10(3), MUMBAI

In the result, the appeal by the assessee is allowed, while the appeal by the Revenue is dismissed

Bench: Shri G.S. Pannu & Shri Sandeep Singh Karhail

reassessment proceedings, the AO issued a notice under section 143(2) of the Act on 20/02/2011, and thereafter, upon transfer of the case, fresh notice under section 143(2) of the Act was issued on 17/10/2011. Since the issue in dispute is pertaining to the validity of notice issued under section 143(2) of the Act, therefore, before proceeding further

ARHAM ANMOL PROJECTS PRIVATE LIMITED,VILLAGE VALSHIND, BHIWANDI vs. CIRCLE 1 KALYAN, KALYAN, THANE

In the result, the legal grounds challenging the validity of the assessment are dismissed

Bench: Shri Amit Shukla & Shri Makarand Vasant Mahadeokararham Anmol Projects Dcit Circle 1, Private Limited 2Nd Floor, Rani H. No. 1113, Ground Vs. Mansion, Murbad Floor, Arham Logiparc, Road, Kalyan Nh-3, Nashik Highway, (West), Thane, Village Valshind, Maharashtra – 421 Bhiwandi, Maharashtra – 301 421 302. Pan/Gir No. Aagca9644P (Applicant) (Respondent) Assessee By Shri Subhash Bains, Ld. Ar Revenue By Shri Surendra Mohan, Ld. Dr Date Of Hearing 28.01.2026 Date Of Pronouncement 26.03.2026

2) by the Jurisdictional Assessing Officer, followed by completion of reassessment by the Assessment Unit under section 147 read with section 144B, does not suffer from any jurisdictional infirmity. The legal ground raised by the assessee on this issue is therefore rejected. The assessment cannot be held to be invalid completion of assessment under the faceless regime. 28. The learned

HEMENDRA RAMJI VIRA ,MUMBAI vs. DCIT CC-4(1), MUMBAI

In the result, appeals of the assessee are allowed

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

2) of section 143 has expired, or (c) assessment or reassessment, if any, has been made, before the date of receiving the books of account or documents or assets seized or requisitioned by the Assessing Officer having jurisdiction over such other person, such Assessing Officer shall issue the notice and assess or reassess total income of such other person

HEMENDRA RAMJI VIRA ,MUMBAI vs. DCIT CC 4(1), MUMBAI

In the result, appeals of the assessee are allowed

2) of section 143 has expired, or (c) assessment or reassessment, if any, has been made, before the date of receiving the books of account or documents or assets seized or requisitioned by the Assessing Officer having jurisdiction over such other person, such Assessing Officer shall issue the notice and assess or reassess total income of such other person

HEMENDRA RAMJI VIRA ,MUMBAI vs. DCIT CC 4(1), MUMBAI

In the result, appeals of the assessee are allowed

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

2) of section 143 has expired, or (c) assessment or reassessment, if any, has been made, before the date of receiving the books of account or documents or assets seized or requisitioned by the Assessing Officer having jurisdiction over such other person, such Assessing Officer shall issue the notice and assess or reassess total income of such other person

HEMENDRA RAMJI VIRA ,MUMBAI vs. DCIT CC 4(1), MUMBAI

In the result, appeals of the assessee are allowed

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

2) of section 143 has expired, or (c) assessment or reassessment, if any, has been made, before the date of receiving the books of account or documents or assets seized or requisitioned by the Assessing Officer having jurisdiction over such other person, such Assessing Officer shall issue the notice and assess or reassess total income of such other person

HEMENDRA RAMJI VIRA,MUMBAI vs. DCIT CC 4(1), MUMBAI

In the result, appeals of the assessee are allowed

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

2) of section 143 has expired, or (c) assessment or reassessment, if any, has been made, before the date of receiving the books of account or documents or assets seized or requisitioned by the Assessing Officer having jurisdiction over such other person, such Assessing Officer shall issue the notice and assess or reassess total income of such other person

HEMENDRA RAMJI VIRA,MUMBAI vs. DCIT CC 4(1), MUMBAI

In the result, appeals of the assessee are allowed

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

2) of section 143 has expired, or (c) assessment or reassessment, if any, has been made, before the date of receiving the books of account or documents or assets seized or requisitioned by the Assessing Officer having jurisdiction over such other person, such Assessing Officer shall issue the notice and assess or reassess total income of such other person

HEMENDRA RAMJI VIRA ,MUMBAI vs. DCIT CC 4(1), MUMBAI

In the result, appeals of the assessee are allowed

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

2) of section 143 has expired, or (c) assessment or reassessment, if any, has been made, before the date of receiving the books of account or documents or assets seized or requisitioned by the Assessing Officer having jurisdiction over such other person, such Assessing Officer shall issue the notice and assess or reassess total income of such other person

MR. SATYA PRAKASH SINGH,MUMBAI vs. ITO, WARD-28(3)(1), VASHI

In the result, the ground so taken by the assessee so far as it relates to challenging the order of the AO as passed beyond the period of limitation is hereby allowed

Bench: Justice (Retd.) Shri C.V. Bhadang & Shri Vikram Singh Yadav

reassessment or recomputation, as the case may be, ends before the end of the month, such period shall be extended to the end of such month.] Explanation 2.—For the purposes of this section, where, by an order referred to in clause (i) of sub-section (6),— (a) any income is excluded from the total income of the assessee

ITO-28(3)(1), MUMBAI, MUMBAI vs. SATYA PRAKASH SINGH, MUMBAI

In the result, the ground so taken by the assessee so far as it relates to challenging the order of the AO as passed beyond the period of limitation is hereby allowed

Bench: Justice (Retd.) Shri C.V. Bhadang & Shri Vikram Singh Yadav

reassessment or recomputation, as the case may be, ends before the end of the month, such period shall be extended to the end of such month.] Explanation 2.—For the purposes of this section, where, by an order referred to in clause (i) of sub-section (6),— (a) any income is excluded from the total income of the assessee

ADDL CIT R G 7(1), MUMBAI vs. NOVARTIS INDIA LTD ( FORMERLY KNOWN AS HINDUSTAN CIBA GIEGY LTD. ), MUMBAI

Bench: Shri Amit Shukla, Hon'Ble & Shri S. Rifaur Rahman, Hon'Blem/S. Novartis India Limited V. Asst. Commissioner Of Income –Tax - 7(2)(2) {Earlier Addl. Commissioner Of Income –Tax – 7(1)} 6Th& 7Th Floor 1St Floor, Aayakar Bhavan Inspire Bkc M.K. Road, Mumbai - 400020 “G” Block, Bkc Main Road Bandra Kurla Complex, Bandra (E) Mumbai – 400051 Pan: Aaach2914F (Appellant) (Respondent) Addl. Commissioner Of Income –Tax – 7(1) V. M/S. Novartis India Limited Room No. 622, Aayakar Bhavan {Earlier Known As Hindustan Ciba Giegy Ltd.,} Sandoz House, Dr. A.B. Road M.K. Road, Mumbai - 400020 Worli, Mumbai – 400018 Pan: Aaach2914F (Appellant) (Respondent) Co No.190/Mum/2011 [Arising Out Of Ita No.6772/Mum/2010 (A.Y. 2002-03)] M/S. Novartis India Limited V. Addl. Commissioner Of Income –Tax – 7(1)} Room No. 622, Aayakar Bhavan {Earlier Known As Hindustan Ciba Giegy Ltd.,} Sandoz House, Dr. A.B. Road M.K. Road, Mumbai - 400020 Worli, Mumbai – 400018 Pan: Aaach2914F (Appellant) (Respondent)

section 143(2) proceeding and was treated as such by the assessee preclude it from urging lack of jurisdiction." (emphasis supplied) (3) There is no interplay of section 127 as held in para 8, in the following words- "8. As far as the section 127 goes, we are of the opinion that having regard to the findings rendered, that question