DCIT (IT) 4(2)(1), MUMBAI vs. DIPENDU BAPALAL SHAH, MUMBAI

In the result, both the appeals of the Revenue are dismissed

Bench: Shri R.C.Sharma, Am & Shri Ram Lal Negi, Jm

reassessment proceedings. Thus, while the learned AO has followed the due procedure of law laid down by the Supreme Court in the case of in the case of GKN Driveshafts (India) Ltd. v. ITO (2003) 259 ITR 19 (SC) as far as procedure of re- assessment proceedings are concerned. 16. Further, the Appellant in this regard had submitted that

THE SYNTHETIC & ART SILK MILLS RESEARCH ASSOCIATION,MUMBAI vs. CIT (EXEM), MUMBAI

In the result, the appeal of assessee is allowed

Bench: Smt. Kavitha Rajagopal, Jm & Ms Padmavathy S, Am

reassessment proceedings under section 147 of the Act, the alternate claim of exemption under section 10(21) is made by the assessee. From the perusal of records all the details pertaining to the alternate claim of the assessee have been submitted and are part of the records. Therefore there is merit in the claim of the ld AR that

ROCKLINE DEVELOPERS P. LTD,MUMBAI vs. ITO 9(3)(4), MUMBAI

In the result, ground “A” raised in the appeal by the assessee stands dismissed

21 SOT 79 (Mum) is altogether different. The issue was whether capital receipts which do not constitute income under the I.T.Act can be brought to tax u/s.H5JB. Here in this case there is revenue receipt duly taxable and such income under reference is only entitle for some deduction. Hence such cases are having different context. Similarly, the ratio of Sutlaj

DCIT 5(2), MUMBAI vs. LAHOTI OVERSEAS LTD, MUMBAI

In the result, appeal of the assessee company in ITA

Bench: Shri Amit Shukla & Shri Ramit Kocharआयकर अपील सं./I.T.A. No. 3812/Mum/2012 ("नधा"रण वष" / Assessment Year : 2003-04) Dy. Commissioner Of Income M/S Lahoti Overseas Ltd., बनाम/ Tax , 5(2),Room No. 571, 307, Arun Chambers, V. 5 Th Floor, Tardeo Road, Tardeo, Aayakar Bhavan, Mumbai - 400034. M.K. Road, Mumbai – 400 020. "थायी लेखा सं./Pan : Aaacl2578 H .. (अपीलाथ" /Appellant) (""यथ" / Respondent)

21,54,000 5.3.2 The LAO has enforced the provisions of sub-sec. 5 of 80IA of the Act and adjusted b/f loss/depreciation etc set off in earlier years against other sources of income against the profits declared by the appellant from the said windmill power division in Assessment Year 2009-10. For the purpose of determining of quantum

JAYANTILAL RAJMAL SETH,MUMBAI vs. DCIT-CC-4(3), MUMBAI, MUMBAI

Bench: Shri Om Prakash Kant () & Shri Raj Kumar Chauhan () Assessment Year: 2018-19 Jayantilal Rajmal Seth, Dcit-Cc-4(3), A-3, Saibaba Shopping Centre, Bkc, Mumbai-400051. Mumbai Central, Vs. Mumbai-400008. Pan No. Agepj 0499 E Appellant Respondent

section 148A(b) providing opportunity to the assessee; under section 148A(b) providing opportunity to the assessee; thirdly, consider the reply under section 148A(c); and fourthly, pass rdly, consider the reply under section 148A(c); and fourthly, pass rdly, consider the reply under section 148A(c); and fourthly, pass a speaking order under section 148A(d) determining whether

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

5) of section 158BA], shall be made within a period of one year from the end of the month of such revival or within the period specified in this section or sub-section (1) of section 153B 18[or section 158BE], whichever is later. (9) The provisions of this section as they stood immediately before the commencement of the Finance

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

5) of section 158BA], shall be made within a period of one year from the end of the month of such revival or within the period specified in this section or sub-section (1) of section 153B 18[or section 158BE], whichever is later. (9) The provisions of this section as they stood immediately before the commencement of the Finance

VIACOM 18 MEDIA PVT LTD,MUMBAI vs. ASSISTANT COMMISSIONER OF INCOME TAX-16(1), MUMBAI

Appeals of the assessee are allowed partly for statistical purposes whereas appeal of the Revenue is dismissed

Bench: Shri Om Prakash Kant () & Shri Raj Kumar Chauhan ()

reassessment are pending in respect of an assessee, in computing the period for determining the additional the period for determining the additional interest payable to such interest payable to such assessee under this sub assessee under this sub-section, the period beginning from the section, the period beginning from the date on which such refund is withheld by the Assessing

VIACOM 18 MEDIA PVT LTD,MUMBAI vs. ASSISTANT COMMISSIONER OF INCOME TAX-16(1), MUMBAI

Appeals of the assessee are allowed partly for statistical purposes whereas appeal of the Revenue is dismissed

Bench: Shri Om Prakash Kant () & Shri Raj Kumar Chauhan ()

reassessment are pending in respect of an assessee, in computing the period for determining the additional the period for determining the additional interest payable to such interest payable to such assessee under this sub assessee under this sub-section, the period beginning from the section, the period beginning from the date on which such refund is withheld by the Assessing

ASSISTANT COMMISSIONER OF INCOMETAX, MUMBAI vs. VIACOM18 MEDIA PVT LTD, MUMBAI

Appeals of the assessee are allowed partly for statistical purposes whereas appeal of the Revenue is dismissed

Bench: Shri Om Prakash Kant () & Shri Raj Kumar Chauhan ()

reassessment are pending in respect of an assessee, in computing the period for determining the additional the period for determining the additional interest payable to such interest payable to such assessee under this sub assessee under this sub-section, the period beginning from the section, the period beginning from the date on which such refund is withheld by the Assessing

MANOHAR MANAK ALLOYS P.LTD,MUMBAI vs. ACIT 4(2), MUMBAI

Appeal is allowed

reassessment proceedings culminating into passing of the order dated 30.12.2019. Thus, 21 Assessment Years: 2017-18 in view of the above judgments of the Hon‘ble Supreme Court and the Hon‘ble High Court as well the factual matrix of the instant case, we hold that period of limitation as prescribed in Section 263(2) of the Act started running

BARCLAYS BANK PLC,MUMBAI vs. CIT (INTERNATIONAL TAXATION)-RANGE-1, MUMBAI

In the result, the appeal by the assessee stands partly allowed

Bench: Shri Shamim Yahya (Am) & Shri Amarjit Singh (Jm)

reassessment order passed by the Assessing Officer with the prior approval of the Commissioner as provided in sub-section (12) of section 144BA. (14b) The central Government may make a scheme, by notification in the Official Gazette, for the purposes of issuance of directions by the dispute resolution panel, so as to impart greater efficiency, transparency and account ability

M/S. RAVI FOUNDATION ,MUMBAI vs. PR. CIT-17, MUMBAI

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

21 A.Y. 2010-11 Court held that the original order would stand effaced by the subsequent order. Srihari was, therefore, a case where the subject matter of the original order of assessment as well as of the order of reassessment was the same. This is distinct from the situation in the subsequent judgment of 3 (2001) 118 Taxman

RITESH SINGH ACIT CIRCLE 3 3 1 MUMBAI, MUMBAI vs. TREND ELECTRONICS LIMITED, MUMBAI

In the result, all result, all the three appeals are allowed for three appeals are allowed for statistical purpose statistical purpose

Bench: Shri Om Prakash Kant () & Shri Raj Kumar Chauhan ()

21 Trend Electronics Limited exhaustive examination of the statutory framework and binding exhaustive examination of the statutory framework and binding exhaustive examination of the statutory framework and binding precedents, including precedents, including S.V. Kondaskar v. V.M. Deshpande S.V. Kondaskar v. V.M. Deshpande (AIR 1972 SC 878), Sundaresh Bhatt, Liquidator of ABG Shipyard v. Sundaresh Bhatt, Liquidator of ABG Shipyard

NARAINDAS GULABRAI TULSIANI,DELHI vs. ACIT, INT. TAX CIRCLE 4(2)(1),, MUMBAI

In the result, all appeals filed by the respective assesses are allowed

Bench: Shri Amit Shukla & Shri Vikram Singh Yadav

21, Barakhamba Road, New Delhi-110001 [PAN: AFKPT5682G] 2 Pratab Gulabrai Tulsiani and group Assessee by : Shri Ashok Khandelwal & Akash Khandelwal, Revenue by : Shri Krishna Kumar, Sr.DR Date of Hearing : 28-07-2025 Date of Pronouncement : 29-07-2025 O R D E R PER BENCH : These appeals are filed by the aforesaid assessees against the orders of the Assessing

PARTAB GULABRAI TULSIANI,DELHI vs. ACIT, INT. TAX CIRCLE 4(2)(1), MUMBAI, MUMBAI

In the result, all appeals filed by the respective assesses are allowed

Bench: Shri Amit Shukla & Shri Vikram Singh Yadav

21, Barakhamba Road, New Delhi-110001 [PAN: AFKPT5682G] 2 Pratab Gulabrai Tulsiani and group Assessee by : Shri Ashok Khandelwal & Akash Khandelwal, Revenue by : Shri Krishna Kumar, Sr.DR Date of Hearing : 28-07-2025 Date of Pronouncement : 29-07-2025 O R D E R PER BENCH : These appeals are filed by the aforesaid assessees against the orders of the Assessing

JAWAHARLAL GULABRAI TULSIANI,DELHI vs. ACIT, INT. TAX CIRCLE 4(2)(1), MUMBAI

In the result, all appeals filed by the respective assesses are allowed

Bench: Shri Amit Shukla & Shri Vikram Singh Yadav

21, Barakhamba Road, New Delhi-110001 [PAN: AFKPT5682G] 2 Pratab Gulabrai Tulsiani and group Assessee by : Shri Ashok Khandelwal & Akash Khandelwal, Revenue by : Shri Krishna Kumar, Sr.DR Date of Hearing : 28-07-2025 Date of Pronouncement : 29-07-2025 O R D E R PER BENCH : These appeals are filed by the aforesaid assessees against the orders of the Assessing

NARAINDAS GULABRAI TULSIANI,DELHI vs. ACIT, INT. TAX CIRCLE 4(2)(1), MUMBAI

In the result, all appeals filed by the respective assesses are allowed

Bench: Shri Amit Shukla & Shri Vikram Singh Yadav

21, Barakhamba Road, New Delhi-110001 [PAN: AFKPT5682G] 2 Pratab Gulabrai Tulsiani and group Assessee by : Shri Ashok Khandelwal & Akash Khandelwal, Revenue by : Shri Krishna Kumar, Sr.DR Date of Hearing : 28-07-2025 Date of Pronouncement : 29-07-2025 O R D E R PER BENCH : These appeals are filed by the aforesaid assessees against the orders of the Assessing

THE TATA POWER COMPANY LTD,MUMBAI vs. PR CIT 2, MUMBAI

In the result, appeal is allowed, as indicated above

Bench: Shri Saktijit Dey () & Shri Rajesh Kumar ()

5. Strongly relying upon the observations of learned PCIT, the learned departmental representative submitted, the order passed under section 263 of the Act is not barred by limitation as it is very much clear that learned PCIT has revised the assessment order passed under section 143(3) r.w.s. 147 of the Act. He submitted, the re-assessment order, since