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

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

2-3 million\ncontributed by assessee for settling a trust\nin foreign country Whether assessment for\nsubject assessment year could not have been\nreopened beyond 31-3-2005 in terms of\nprovisions of section 149 as applicable at\nrelevant time\nHeld, yes\nWhether\nsubsequent amendment to section 149, by\nFinance Act, 2012, which extended limitation\nfor initiation of reassessment

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

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

31* January, 2011 issued by the\nCentral Board of Direct Taxes, where income declared/returned by\nany Non-Corporate assessee is up to Rs.20 lakhs, then the\njurisdiction will be of ITO and where the income declared returned\nby & Non Corporate assessee is above Rs.20 lakhs, the\njurisdiction will be of DO/AC.\n3. Petitioner has filed return of income of about

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

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

31. In T.K.S. Builders (P.) Ltd., the Hon’ble Delhi High Court undertook an elaborate analysis of sections 144B and 151A of the Act and the Faceless Reassessment Scheme, 2022. The Court categorically held that section 144B is fundamentally procedural and cannot be construed as the exclusive repository of the power to assess or reassess. In paragraph

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)

reassessment proceedings are the result of the only notice u/s 148 dated 29/03/2018 7. The ld. counsel also submitted that the assessee was under a bonafide belief, in absence of service of the said order u/s 127(2) on him that the assessment jurisdiction over the assessee must have been transferred after issuing the notice u/s 148 as the assessee

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)

reassessment proceedings are the result of the only notice u/s 148 dated 29/03/2018 7. The ld. counsel also submitted that the assessee was under a bonafide belief, in absence of service of the said order u/s 127(2) on him that the assessment jurisdiction over the assessee must have been transferred after issuing the notice u/s 148 as the assessee

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)

reassessment proceedings are the result of the only notice u/s 148 dated 29/03/2018 7. The ld. counsel also submitted that the assessee was under a bonafide belief, in absence of service of the said order u/s 127(2) on him that the assessment jurisdiction over the assessee must have been transferred after issuing the notice u/s 148 as the assessee

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

In the result, appeals of the assessee are allowed

reassessment proceedings are the result of the only notice u/s 148 dated 29/03/2018 7. The ld. counsel also submitted that the assessee was under a bonafide belief, in absence of service of the said order u/s 127(2) on him that the assessment jurisdiction over the assessee must have been transferred after issuing the notice u/s 148 as the assessee

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)

reassessment proceedings are the result of the only notice u/s 148 dated 29/03/2018 7. The ld. counsel also submitted that the assessee was under a bonafide belief, in absence of service of the said order u/s 127(2) on him that the assessment jurisdiction over the assessee must have been transferred after issuing the notice u/s 148 as the assessee

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)

reassessment proceedings are the result of the only notice u/s 148 dated 29/03/2018 7. The ld. counsel also submitted that the assessee was under a bonafide belief, in absence of service of the said order u/s 127(2) on him that the assessment jurisdiction over the assessee must have been transferred after issuing the notice u/s 148 as the assessee

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)

reassessment proceedings are the result of the only notice u/s 148 dated 29/03/2018 7. The ld. counsel also submitted that the assessee was under a bonafide belief, in absence of service of the said order u/s 127(2) on him that the assessment jurisdiction over the assessee must have been transferred after issuing the notice u/s 148 as the assessee

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

A.C.I.T. CIRCLE-41(4)(1), MUMBAI vs. SHRI AWADHNARAYAN LAXMINARAYAN SINGH, MUMBAI

In the result, appeal filed by the\nRevenue is dismissed

31 st\nMarch, 2010 in terms of provision of section 149 of the Income Tax Act, 1961\nas limitation for reassessment for AY 2003-04 had expired on 31.03.2010 and\ntherefore, reassessement was barred by limitation.\nAs per the proviso of section 149 of Income Tax Act, 1961 notice u/s 148 could\nnot have been issued after 6 years lapsed

A.C..I.T. CIRCLE-41(4)(1), MUMBAI vs. SHRI AWADHNARAYAN LAXMINARAYAN SINGH, MUMBAI

31 st\nMarch, 2010 in terms of provision of section 149 of the Income Tax Act, 1961\nas limitation for reassessment for AY 2003-04 had expired on 31.03.2010 and\ntherefore, reassessement was barred by limitation.\nAs per the proviso of section 149 of Income Tax Act, 1961 notice u/s 148 could\nnot have been issued after 6 years lapsed

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