THE ESTATE INVESTMENT COMPANY PRIVATE LIMITED,MUMBAI vs. DCIT CENTRAL CIRCLE 8(1), MUMBAI

3012/Mum/2025

Bench: SHRI AMIT SHUKLA (Judicial Member), SHRI ARUN KHODPIA (Accountant Member)

reassessment proceedings initiated under section 148 are quashed for lack of jurisdiction in terms of the Faceless Assessment Scheme; and (iii) the assessment orders are further invalidated for non-compliance with CBDT Circular No. 19 of 2019 owing to the absence of a valid pre-generated DIN. The remaining grounds pertaining to interest under sections 234A, 234B

JAMNADAS VIRJI SHARES AND STOCK BROKERS PRIVATE LIMITED,MUMBAI vs. DEPUTY COMMISSIONER OF INCOME TAX 4(3)(1), MUMBAI

234B of Rs.\n96,480/- and under section 234D of Rs. 7,238/- and CIT(A) erred in\nconfirming the same.\nIn appeal No. ITA No. 8362/MUM/2025 for A.Y. 2015–16\n1. The Appellant submits the Assessing Officer (AO) erred assuming\njurisdiction under section 147 of the Act and the learned\nCommissioner (Appeals) (CIT(A) erred in confirming his action

EI BENEFICARY TRUST ,MUMBAI vs. DEPUTY COMMISSIONER OF INCOME TAX CENTRAL CIRCLE -8(1), MUMBAI

3230/Mum/2025 Govind

Bench: SHRI AMIT SHUKLA (Judicial Member), SHRI ARUN KHODPIA (Accountant Member)

reassessment proceedings under section 148. Accordingly, the ratio laid down therein squarely applies to the present case. 33. The learned Departmental Representative (DR), on his part, sought to defend the orders of the Assessing Officer and the learned CIT(A) with considerable fervor. He submitted that the seized excel sheets and loose papers though not part of the statutory books

GOVIND CORPORATION ,MUMBAI vs. DEPUTY COMMISSIONER OF INCOME TAX CENTRAL CIRCLE -8(1), MUMBAI

section 234A and 234B of the Act be deleted or consequentially reduced.\n\nThe Appellants craves leave to add, amend, omit or alter the above grounds of appeal before or during the hearing of the appeal.\n\n40. From a careful perusal of the grounds raised by the assessee in connected assessment years, it emerges that the challenge revolves primarily

JM FINANCIAL PROPERTY FUND I,MUMBAI vs. INCOME TAX OFFICER, WARD - 25(1)(1), MUMBAI, MUMBAI

In the result, the appeal of the assessee for assessment year

Bench: Shri Om Prakash Kant () & Shri Sandeep Singh Karhail ()

reassessment proceeding be held as without jurisdiction, bad in law and void jurisdiction, bad in law and void-ab-initio. Ground Nos. 4 to 10 are without prejudice to Ground Nos. 1 to 3 Ground Nos. 4 to 10 are without prejudice to Ground Nos. 1 to 3 Ground Nos. 4 to 10 are without prejudice to Ground

JM FINANCIAL PROPERTY FUND I,MUMBAI vs. INCOME TAX OFFICER, WARD - 25(1)(1), MUMBAI, MUMBAI

In the result, the appeal of the assessee for assessment year

Bench: Shri Om Prakash Kant () & Shri Sandeep Singh Karhail ()

reassessment proceeding be held as without jurisdiction, bad in law and void jurisdiction, bad in law and void-ab-initio. Ground Nos. 4 to 10 are without prejudice to Ground Nos. 1 to 3 Ground Nos. 4 to 10 are without prejudice to Ground Nos. 1 to 3 Ground Nos. 4 to 10 are without prejudice to Ground

ABHUBHAI HIRABHAI DESAI,MUMBAI vs. DCIT CIRCLE 19(1), MUMBAI

In the result, the appeal of the assessee is allowed

sections": [ "147", "148", "153C", "153A", "132", "133(6)", "143(3)", "234A", "234B", "234C", "234D", "271(1)(c)" ], "issues": "Whether the AO erred in initiating reassessment

GAMNARAM OKHAJI PRAJAPATI ,MUMBAI vs. DCIT. CIRCLE 1(2)(1), MUMBAI

Appeal is allowed

Bench: SHRI RAHUL CHAUDHARY, JUDICIAL MEMBER SHRI PRABHASH SHANKAR (Accountant Member)

Section 234A and 234B be deleted.” 3. When the appeal was taken up for hearing the Learned Authorized Representative for the Assessee, at the outset, challenged the validity of reassessment

EI BENEFICIARY TRUST ,MUMBAI vs. DEPUTY COMMISSIONER OF INCOME TAX CENTRAL CIRCLE -8(1), MUMBAI

section 234A and 234B of the Act be deleted or consequentially reduced.\nThe Appellants craves leave to add, amend, omit or alter the above grounds of appeal before or during the hearing of the appeal.\n40. From a careful perusal of the grounds raised by the assessee in connected assessment years, it emerges that the challenge revolves primarily around interrelated

JAMNADAS VIRJI SHARES AND STOCK BROKERS PRIVATE LIMITED,MUMBAI vs. DEPUTY COMMISSIONER OF INCOME TAX 4(3)(1), MUMBAI

reassessment, was retracted and discredited. The addition of dividend income for AY 2016-17 was also found to be erroneous as it was based on a computation sheet inconsistency and taxed exempt income indirectly.", "result": "Allowed", "sections": [ "37(1)", "147", "148", "10(34)", "234A", "234B

JAMNADAS VIRJI SHARES AND STOCK BROKERS PRIVATE LIMITED ,MUMBAI vs. DCIT, 4(3)(1), MUMBAI

234B of Rs.\n96,480/- and under section 234D of Rs. 7,238/- and CIT(A) erred in\nconfirming the same.\nIn appeal No. ITA No. 8362/MUM/2025 for A.Y. 2015–16\n1. The Appellant submits the Assessing Officer (AO) erred assuming\njurisdiction under section 147 of the Act and the learned\nCommissioner (Appeals) (CIT(A) erred in confirming his action

DCIT, CENTRAL CIRCLE-8(1), MUMBAI, MUMBAI vs. E I RESORTS AND CLUBS PVT LTD, MUMBAI

3213/Mum/2025

Bench: SHRI AMIT SHUKLA (Judicial Member), SHRI ARUN KHODPIA (Accountant Member)

reassessment proceedings initiated under section 148 are quashed for lack of jurisdiction in terms of the Faceless Assessment Scheme; and (iii) the assessment orders are further invalidated for non-compliance with CBDT Circular No. 19 of 2019 owing to the absence of a valid pre-generated DIN. (iv) the assessment orders are further invalidated for issue of defective notice under

DCIT, CENTRAL CIRCLE-8(1), MUMBAI, MUMBAI vs. EI RESORTS & CLUBS PVT LTD, MUMBAI

3213/Mum/2025

Bench: SHRI AMIT SHUKLA (Judicial Member), SHRI ARUN KHODPIA (Accountant Member)

reassessment proceedings initiated under section 148 are quashed for lack of jurisdiction in terms of the Faceless Assessment Scheme; and (iii) the assessment orders are further invalidated for non-compliance with CBDT Circular No. 19 of 2019 owing to the absence of a valid pre-generated DIN. (iv) the assessment orders are further invalidated for issue of defective notice under

JAMNADAS VIRJI SHARES AND STOCK BROKERS PVT LTD,MUMBAI vs. DEPUTY COMMISSIONER OF INCOME TAX 4(3)(1), MUMBAI

234B of Rs.\n96,480/- and under section 234D of Rs. 7,238/- and CIT(A) erred in\nconfirming the same.\nIn appeal No. ITA No. 8362/MUM/2025 for A.Y. 2015–16\n1. The Appellant submits the Assessing Officer (AO) erred assuming\njurisdiction under section 147 of the Act and the learned\nCommissioner (Appeals) (CIT(A) erred in confirming his action

RAMESH AMRATLAL BRAHMBHATT ,MUMBAI vs. ITO WARD 34(3)(2), MUMBAI

In the result, the reassessment order dated 20

Bench: Shri Saktijit Dey & Shri Makarand Vasant Mahadeokarramesh Amratlal Ito Ward 34(3)(2), Brahmbhatt Kautilya Bhavan, 43 Rajnigandha, Vs. Bandra Kurla Gulmohar Cross Road No. Complex, Mumbai – 11, J V P D Scheme, 400 051 Juhu, Mumbai-400 049 Pan/Gir No. Aabpb7235R (Applicant) (Respondent) Assessee By Shri K. Gopal & Ms. Neha Paranjpe, Ld. Ars Revenue By Shri Annavaram Kosuri, Ld. Dr Date Of Hearing 23.02.2026 Date Of Pronouncement 25.02.2026

234B and 234C of the Act. 11. The Appellant seeks leave to add, alter and amend the above grounds whenever required. Facts in Brief 3. The assessee filed return of income declaring total income of Rs. 6,11,400/-. Subsequently, notice under section 148 was issued on 29.07.2022 pursuant to the order passed under section 148A(d). The reassessment

GOVIND CORPORATION,MUMBAI vs. DEPUTY COMMISSIONER OF INCOME TAX CENTRAL CIRCLE -8(1), MUMBAI

section 234A and\n234B of the Act. The Appellant prays that the interest under\nsection 234A and 234B of the Act be deleted or consequentially\nreduced.\n\nThe Appellants craves leave to add, amend, omit or alter the above\ngrounds of appeal before or during the hearing of the appeal.\n\n40. From a careful perusal of the grounds raised

EI BENEFICIARY TRUST ,MUMBAI vs. DEPUTY COMMISSIONER OF INCOME TAX CENTRAL CIRCLE -8(1), MUMBAI

section 234A and\n234B of the Act. The Appellant prays that the interest under\nsection 234A and 234B of the Act be deleted or consequentially\nreduced.\n\nThe Appellants craves leave to add, amend, omit or alter the above\ngrounds of appeal before or during the hearing of the appeal.\n\n40. From a careful perusal of the grounds raised

NUCLEAR POWER CORPORATION OF INDIA LTD.,MUMBAI vs. ACIT(OSD) RANGE 3(2), MUMBAI

Bench: Shri Om Prakash Kant () & Ms. Kavitha Rajagopal () Assessment Year: 1998-99 & Assessment Year: 1999-2000 & Assessment Year: 2000-01 & Assessment Year: 2001-02 & Assessment Year: 2002-03 & Assessment Year: 2003-04 & Assessment Year: 2004-05 & Assessment Year: 2005-06 Nuclear Power Corporation Of Acit, Range-3(2), India Ltd., Aayakar Bhavan, M.K. Road, Vikram Sarabhai Bhavan, Vs. Mumbai-400021. Central Avenue, Anushakti Nagar, Mumbai-400094. Pan No. Aaacn 3154 F Appellant Respondent

234B of Rs.8,46,25,483. The appellant denies liability to such Rs.8,46,25,483. The appellant denies liability to such Rs.8,46,25,483. The appellant denies liability to such interest. interest. 20. Each one of the above grounds of appeal is rounds of appeal is without prejudice to the other. without prejudice to the other. 3. Briefly