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

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, and 234C

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, and 234C

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

reassessment under section 147 is\ninvalid, and requires to be cancelled.\n8. The learned CIT(A) / NFAC erred in ignoring the additional evidence\nsubmitted vide letter dated 1st November, 2023 and relied upon in\nthe written submissions before CIT(A) / NFAC.\n9. The CIT(A) / NFAC erred in confirming the addition of Rs. 3,25,500/-\nbeing purchase of gold

THE INDIAN HOTELS COMPANY LTD,MUMBAI vs. ASST CIT CIR 2(2), MUMBAI

Accordingly, Ground No.1 and 4 raised by the Assessee is allowed while all the other grounds raised by the Assessee are dismissed as having being rendered infructuous

Bench: SHRI OM PRAKASH KANT, ACCOUNTANT MEMBER SHRI RAHUL CHAUDHARY (Judicial Member)

section 147 of the Act and in view of absence of a categorical finding either in the reasons recorded or in the assessment order, that the appellant has failed to disclose fully and truly all material facts, no action of reassessment can be made after a period of four years from the end of the relevant Assessment Year

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

NUCLEAR POWER CORPORATION OF INDIA LTD,,MUMBAI vs. ADDL. C.I.T,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

THE DY CIT 3(2), MUMBAI vs. M/S. NUCLEAR POWER CORPORATION OF INDIA LTD, 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

NUCLEAR POWER CORPORATION OF INDIA LTD,,MUMBAI vs. ADDL. C.I.T,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

NUCLEAR POWER CORPORATION OF INDIA LTD,,MUMBAI vs. ADDL. C.I.T,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

NUCLEAR POWER CORPORATION OF INDIA LTD,MUMBAI vs. ADDL CIT RG 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

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

NUCLEAR POWER CORPORATION OF INDIA LTD.,MUMBAI vs. ACIT 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

NUCLEAR POWER CORPORATION OF INDIA LTD.,MUMBAI vs. ADDL.COMMR.OF INCOME TAX, SPL. RG.32, 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

NUCLEAR POWER CORPORATION OF INDIA LTD,,MUMBAI vs. ADDL. C.I.T,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

NUCLEAR POWER CORPORATION OF INDIA LTD,MUMBAI vs. ADDL CIT RG 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

SHAH CONSTRUCTION COMPANY LTD,MUMBAI vs. DY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-1(3), MUMBAI

Appeal is allowed

Bench: SHRI B.R. BASKARAN, ACCOUNTANT MEMBER SHRI RAHUL CHAUDHARY (Judicial Member)

reassessment proceedings. Ground Nos. 2 & 3 are directed against the disallowances made on merits. Ground No. 4 pertains to interest charged under Section 234B

M/S. J S REALTY PVT. LTD., ,MUMBAI vs. ITO, WARD-12(3)(1), MUMBAI

Accordingly, Ground No. 4 to 9 pertaining to the merits of the matter are dismissed as being infructuous

3 pertains to the validity of reassessment 6. proceedings where as Ground No. 4 to 9 challenge the merits of the addition. Ground No. 10 related to levy of interest under Section 234B