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

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

v.\nITO\n[2018] 89\ntaxmann.com\n71(Legal PB\nPg. No. 35-38)\nHeld that \"for the purpose of Computation\nof period limitation for 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

DAMJI J GALA,KHANDILKAR ROAD vs. ITO 19(1)(4), TARDEO ROAD

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

v. Atlas Cycle Industries [1989] 180 ITR 3191. The\ndecision in Atlas Cycle Industries' case (supra) held that the Assessing Officer did\nnot have jurisdiction to proceed with the reassessment, once he found that the\ntwo grounds mentioned in the notice under section 148 were incorrect or non-\existent. The decisions of the Punjab & Haryana High Court in Atlas Cycle

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

In the result, appeals of the assessee are allowed

reassess the income of the other person in accordance with the provisions of section 153A, if that Assessing Officer is satisfied that the books of account or documents or assets, seized or requisitioned, have a bearing on the determination of the total income of such other person for the relevant assessment year or years referred to in sub-section

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)

reassess the income of the other person in accordance with the provisions of section 153A, if that Assessing Officer is satisfied that the books of account or documents or assets, seized or requisitioned, have a bearing on the determination of the total income of such other person for the relevant assessment year or years referred to in sub-section

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)

reassess the income of the other person in accordance with the provisions of section 153A, if that Assessing Officer is satisfied that the books of account or documents or assets, seized or requisitioned, have a bearing on the determination of the total income of such other person for the relevant assessment year or years referred to in sub-section

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)

reassess the income of the other person in accordance with the provisions of section 153A, if that Assessing Officer is satisfied that the books of account or documents or assets, seized or requisitioned, have a bearing on the determination of the total income of such other person for the relevant assessment year or years referred to in sub-section

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)

reassess the income of the other person in accordance with the provisions of section 153A, if that Assessing Officer is satisfied that the books of account or documents or assets, seized or requisitioned, have a bearing on the determination of the total income of such other person for the relevant assessment year or years referred to in sub-section

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)

reassess the income of the other person in accordance with the provisions of section 153A, if that Assessing Officer is satisfied that the books of account or documents or assets, seized or requisitioned, have a bearing on the determination of the total income of such other person for the relevant assessment year or years referred to in sub-section

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)

reassess the income of the other person in accordance with the provisions of section 153A, if that Assessing Officer is satisfied that the books of account or documents or assets, seized or requisitioned, have a bearing on the determination of the total income of such other person for the relevant assessment year or years referred to in sub-section

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

v. ACIT 180 taxmann.com 805. In that case, the Hon’ble Delhi High Court examined the identical question whether the Jurisdictional Assessing Officer retains power to issue notice under section 148 after the introduction of section 151A and the 2022 Scheme. The Court referred to its earlier binding decision in TKS Builders (P.) Ltd.167 taxmann.com 759 and held that both

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

MR GAJANAN PARSHURAM KHISMATRAO,THANE vs. ITO WARD 3(2), KALYAN

Bench: Shri Prashant Maharishi & Shri Sandeep Singh Karhail

reassess income chargeable to tax if he has reason to believe that income for any assessment year has escaped assessment. The word "reason" in the phrase "reason to believe" would mean cause or justification. If the Assessing Officer has cause or justification to know or suppose that income had escaped assessment, it can be said to have reason to believe

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

v. ITO [1966] 59 ITR 652, while interpreting the sections\n31, 34 (1) & (2) of the Income Tax Act 1922, (corresponding to the provisions\nof sections 148, 153 and 253 of 1961 Act) has held that 'finding' means the\nfinding necessary for giving relief in respect of the assessment year in question\nand the proviso to section

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

v. ITO [1966] 59 ITR 652, while interpreting the sections\n31, 34 (1) & (2) of the Income Tax Act 1922, (corresponding to the provisions\nof sections 148, 153 and 253 of 1961 Act) has held that 'finding' means the\nfinding necessary for giving relief in respect of the assessment year in question\nand the proviso to section

M/S THE MAHARASHTRA STATE CO. OP BANK LTD.,MUMBAI vs. ITO-1(3)(3), MUMBAI

In the result, the appeal of the In the result, the appeal of the assessee is allowed partly assessee is allowed partly whereas the appeal of the Revenue is dismissed

Bench: Shri Om Prakash Kant () & Shri Sandeep Singh Karhail () Assessment Year: 2013-14

47) of the act view of the decision view of the decision above, it is evident that during t it is evident that during the pending proceedings of the SARFAESI Act SARFAESI Act, the assessee cannot be treated as the assessee cannot be treated as owner of the assets possessed by it for recovery of its outstanding owner

DY CIT-1(3)(2), MUMBAI vs. MAHARASHTRA STATE CO-OPERATIVE BANK LIMITED, MUMBAI

In the result, the appeal of the In the result, the appeal of the assessee is allowed partly assessee is allowed partly whereas the appeal of the Revenue is dismissed

Bench: Shri Om Prakash Kant () & Shri Sandeep Singh Karhail () Assessment Year: 2013-14

47) of the act view of the decision view of the decision above, it is evident that during t it is evident that during the pending proceedings of the SARFAESI Act SARFAESI Act, the assessee cannot be treated as the assessee cannot be treated as owner of the assets possessed by it for recovery of its outstanding owner

TATA MOTORS LTD,MUMBAI vs. ACIT 2(3), MUMBAI

In the result, appeal of the assessee is partly allowed

Bench: Shri Vikas Awasthy& Shri S.Rifaur Rahmanआअसं.631/मुं/2013 (िन.व. 2008-09) Tata Motors Limited Bombay House, 24,Homi Mody Street, Hutama Chowk, Mumbai – 400001. Pan: Aaact-2727-Q ...... अपीलाथ"/Appellant बनाम Vs. The Addl. Commissioner Of Income Tax Circle -2(3), Mumbai. Aaykar Bhavan, M.K.Road, Mumbai – 400 020 ....."ितवादी/Respondent अपीलाथ" "ारा/ Appellant By : Shri J.D.Mistry, Sr.Advocate With Shri Nikhil Tiwari,Advocate "ितवादी "ारा/Respondent By : Ms. Vatsala Jha, Cit-Dr & Shri Manoj Kumar Singh, Sr.Ar सुनवाई की ितिथ/ Date Of Hearing : 10/11/2023 घोषणा की ितिथ/ Date Of Pronouncement : 05/02/2024 आदेश/Order Per Vikas Awasthy, Jm:

v. Soyuz Industrial Resources Ltd. [2015] 58 taxmann.com 336/232 Taxman 414 decided the issue that Where re-assessment proceedings were initiated after expiry of four years from end of relevant years, sanction for issuance of notice for re- assessment proceedings was to be granted by Joint Commissioner and not by commissioner as per provisions of section 151(2

KOTAK MAHINDRA BANK LIMITED,MUMBAI vs. ADD/JOINT/DEPUTY/ACIT, NATIONAL E-ASSESSMENT CENTRE, DELHI

Section 14A(2) of the Act, read\n40\nITA Nos.4056/Mum/2023 & Others\nM/s. Kotak Mahindra Bank Ltd.\nwith Rule 8D of the Rules, before applying the theory of apportionment, the AO needs to\nrecord satisfaction that having regard to the kind of the assessee, suo moto disallowance\nunder Section 14A was not correct. It will be in those cases where