BIRLA CARBON INDIA PRIVATE LIMITED,MUMBAI vs. THE PRINCIPAL COMMISSIONER OF INCOME TAX, MUMBAI - 5, MUMBAI

In the result, the appeal is allowed as indicated above

Bench: Shri Saktijit Dey & Shri Narendra Kumar Billaiyabirla Carbon India Private Limited The Principal Commissioner Of Ground Floor, Aditya Birla Centre, Income Tax Room No. 515, 5Th Floor, Aaykar S. K. Ahire Marg, Worli, Vs. Mumbai-400 030 Bhavan, M. K. Road, Mumbai-400 020 Pan/Gir No. Aascs 9916 L (Appellant) : (Respondent) Appellant By : Shri Madhur Agarwal Respondent By : Shri Satyaprakash R. Singh Date Of Hearing : 16.09.2025 Date Of Pronouncement : 22.09.2025 O R D E R Per Saktijit Dey: In The Present Appeal, The Assessee Has Called Into Question The Validity Of The Order Dated 25.03.2025, Passed U/S. 263 Of The Income Tax Act, 1961 (‘The Act’ For Short) By Learned Principal Commissioner Of Income Tax (‘Ld.Pcit’ For Short), Pertaining To The Assessment Year (A.Y.) 2018-19. 2. Thought Multiple Grounds Have Been Raised In The Memorandum Of Appeal, However, The Assessee Has Raised A Pertinent Preliminary Issue, Challenging The Competence & Jurisdiction Of Ld. Pcit To Invoke Powers U/S. 263 Of The Act To Revise An Assessment Order Passed U/S. 144C(13) Of The Act, In Pursuance To The Directions Of Learned Dispute Resolution Panel (Ld. Drp).

246A and section 253 of the Act. That however, no amendment is made in section 263 of the Act as a consequence of insertion of section 144C of the Act to deem such orders being capable of being revised. That therefore, the memorandum, circular, etc. support the Assessee's stand that once the Assessing Officer passes an order in accordance

ACCENTURE SOLUTIONS PRIVATE LIMITED,MUMBAI vs. DY. COMMISSIONER OF INCOME TAX, MUMBAI

In the result, the appeal is allowed as indicated above

Bench: Shri Saktijit Dey, Vp & Shri Girish Agrawal, Am Accenture Solutions Private Limited Pr. Cit, 501, 5Th Floor, Plat 3, Godrej & Boycee Compound, Vikhroli (W), Vikhroli S.O., Vs. Aayakar Bhavan, M. K. Road, Mumbai-400 079 Mumbai-400 020 Pan/Gir No. (Appellant) : (Respondent) Appellant By : Shri Nishant Thakkar Respondent By : Shri Satya Pal Kumar Date Of Hearing : 18.08.2025 Date Of Pronouncement : 28.08.2025 O R D E R Per Saktijit Dey, Vp: The Captioned Appeal Has Been Filed By The Assessee, Assailing The Order Dated 20.03.2025, Passed U/S. 263 Of Income Tax Act, 1961 (‘The Act’ For Short) By Learned Principal Commissioner Of Income Tax, Mumbai-6 (‘Ld. Pcit’ For Short), Pertaining To The Assessment Year (A.Y.) 2017-18. 2. We Have Heard The Parties & Perused The Materials Available On Record. The Short Issue Arising For Consideration Is Whether The Final Assessment Order Passed U/S. 144C(13) Of The Act, Can Be Subjected To Revisionary Jurisdiction U/S. 263 Of The Act. For Deciding This Issue, Few Necessary Facts Are Required To Be Considered. The Assessee Is A Resident Corporate Entity Engaged In The Business Of Providing Information Technology (It)/Information Technology Enabled Service (Ites) To Its Group Companies As Well As Consulting Services To Its Clients. For The Assessment Year Under Dispute, The Assessee Filed

246A and section 253 of the Act. That however, no amendment is made in section 263 of the Act as a consequence of insertion of section 144C of the Act to deem such orders being capable of being revised. That therefore, the memorandum, circular, etc. support the Assessee's stand that once the Assessing Officer passes an order in accordance

U S ROOFS LTD.,,NAVI MUMBAI vs. ADDL/JT/DY/ACIT/ITO, NFE-ASS C, DELHI DELHI, DELHI

Bench: Shri Kuldip Singh & Shri Amarjit Singh

reassessment order dated March 28, 2013 be quashed as bad in law and void ab initio, as no valid notice under section 143(2) of the Act has been issued and served on the Appellant. 4.1. On the facts and in the circumstances of the case and in law, the Ld. AO erred in rejecting the books of accounts

U S ROOFS LTD.,,NAVI MUMBAI vs. ADDL/JT/DY/ACIT/ITO, NFE-ASS C, DELHI DELHI, DELHI

Bench: Shri Kuldip Singh & Shri Amarjit Singh

reassessment order dated March 28, 2013 be quashed as bad in law and void ab initio, as no valid notice under section 143(2) of the Act has been issued and served on the Appellant. 4.1. On the facts and in the circumstances of the case and in law, the Ld. AO erred in rejecting the books of accounts

U S ROOFS LTD.,,NAVI MUMBAI vs. ADDL/JT/DY/ACIT/ITO, NFE-ASS C, DELHI DELHI, DELHI

Bench: Shri Kuldip Singh & Shri Amarjit Singh

reassessment order dated March 28, 2013 be quashed as bad in law and void ab initio, as no valid notice under section 143(2) of the Act has been issued and served on the Appellant. 4.1. On the facts and in the circumstances of the case and in law, the Ld. AO erred in rejecting the books of accounts

U S ROOFS LTD.,,NAVI MUMBAI vs. ADDL/JT/DY/ACIT/ITO, NFE-ASS C, DELHI DELHI, DELHI

Bench: Shri Kuldip Singh & Shri Amarjit Singh

reassessment order dated March 28, 2013 be quashed as bad in law and void ab initio, as no valid notice under section 143(2) of the Act has been issued and served on the Appellant. 4.1. On the facts and in the circumstances of the case and in law, the Ld. AO erred in rejecting the books of accounts

U S ROOFS LTD.,,NAVI MUMBAI vs. ADDL/JT/DY/ACIT/ITO, NFE-ASS C, DELHI DELHI, DELHI

Bench: Shri Kuldip Singh & Shri Amarjit Singh

reassessment order dated March 28, 2013 be quashed as bad in law and void ab initio, as no valid notice under section 143(2) of the Act has been issued and served on the Appellant. 4.1. On the facts and in the circumstances of the case and in law, the Ld. AO erred in rejecting the books of accounts

KOTAK MAHINDRA BANK LIMITED,MUMBAI vs. DCIT 2 3 1, MUMBAI

In the result, all the grounds of appeal of assessee is allowed

Bench: Shri Pawan Singh& Smt.Renu Jauhri

section 254 for which appeal is clearly maintainable u/s 246A(1)(b) of the Act. c. the Appeal by the appellant aggrieved by an order of reassessment

KOTAK MAHINDRA BANK LIMITED,MUMBAI vs. DCIT 2(3)(1), MUMBAI

In the result, all the grounds of appeal of assessee is allowed

Bench: Shri Pawan Singh& Smt.Renu Jauhri

section 254 for which appeal is clearly maintainable u/s 246A(1)(b) of the Act. c. the Appeal by the appellant aggrieved by an order of reassessment

KOTAK MAHINDRA BANK LIMITED,MUMBAI vs. DCIT 2(3)(1), MUMBAI

In the result, all the grounds of appeal of assessee is allowed

Bench: Shri Pawan Singh& Smt.Renu Jauhri

section 254 for which appeal is clearly maintainable u/s 246A(1)(b) of the Act. c. the Appeal by the appellant aggrieved by an order of reassessment

KOTAK MAHINDRA BANK LIMITED,MUMBAI vs. DCIT 2(3)(1), MUMBAI

In the result, all the grounds of appeal of assessee is allowed

Bench: Shri Pawan Singh& Smt.Renu Jauhri

section 254 for which appeal is clearly maintainable u/s 246A(1)(b) of the Act. c. the Appeal by the appellant aggrieved by an order of reassessment

KOTAK MAHINDRA BANK LIMITED,MUMBAI vs. DCIT 2(3)(1), MUMBAI

In the result, all the grounds of appeal of assessee is allowed

Bench: Shri Pawan Singh& Smt.Renu Jauhri

section 254 for which appeal is clearly maintainable u/s 246A(1)(b) of the Act. c. the Appeal by the appellant aggrieved by an order of reassessment

KOTAK MAHINDRA BANK LIMITED,MUMBAI vs. DCIT 2(3)(1), MUMBAI

In the result, all the grounds of appeal of assessee is allowed

Bench: Shri Pawan Singh& Smt.Renu Jauhri

section 254 for which appeal is clearly maintainable u/s 246A(1)(b) of the Act. c. the Appeal by the appellant aggrieved by an order of reassessment

KUDOS FINANCE AND INVESTMENTS PVT. LTD.,PUNE vs. ITO, WARD-14 (2)(1), MUMBAI

246A of the Act. As per Section\n246A(1)(a) of the Act an intimation issued under Section 143(1) of\nthe Act passed under Section 143(3) of the Act is an order\nappealable before the CIT(A). Further, bare perusal of Section 263 of\nthe Act shows that the scope of revision under the said section

TATA AIG GENERAL INSURANCE COMAPANY LTD,MUMBAI vs. ASST CIT 2(3), MUMBAI

In the result, the appeal of the assessee is allowed

246A of the Act. However, a new scheme of dispute resolution was brought into the Act by insertion of Sec. 144C of the Act in the context of „eligible assessee‟ prescribed therein. Sec. 144C of the Act contains 15 subsections and provides for a mechanism for dispute resolution, powers of Dispute Resolution Panel, definition of Dispute Resolution Panel, eligible assessee

STRIDES ARCOLAB LTD,NAVI MUMBAI vs. DCIT CIR 10(3),

Bench: Shri Amit Shukla, Jm & Shri S. Rifaur Rahman, Am आयकरअपीलसं./ I.T.A. No.2877/Mum/2014 (निर्धारणवर्ा / Assessment Year: 2009-10) Strides Shasun Limited Dcit Cir. 15(3)(2) (Formerly Known As R. No. 451, 4Th Floor, Strides Arcolab Limited) बिधम/ Aayakar Bhavan, M. K. 201, Devavrata, Sector 17, Road, Mumbai-400 020 Vs. Vashi, Navi Mumbai – 400 703 स्थायीलेखासं./जीआइआरसं./ Pan No. Aadcs8104P (अपीलाथी/Appellant) (प्रत्यथी / Respondent) : अपीलाथीकीओरसे/ Appellant By : Shri Percy Pardiwala/ Shri Ketan Ved /Shri Ninad Patade, Ld. Ars प्रत्यथीकीओरसे/Respondent By : Ms. Vatsalaa Jha, Ld. Dr सुनवाईकीतारीख/ : 18.01.2023 Date Of Hearing घोषणाकीतारीख / : 28.02.2023 Date Of Pronouncement आदेश / O R D E R Per Amit Shukla : The Aforesaid Appeal Has Been Filed By Assessee Against The Order Dated 26.02.2014 Passed U/S 143(3) R.W.S. 144C(13) In 2

246A of the Act. However, a new scheme of dispute resolution was brought into the Act by insertion of Sec. 144C of the Act in the context of „eligible assessee‟ prescribed therein. Sec. 144C of the Act contains 15 subsections and provides for a mechanism for dispute resolution, powers of Dispute Resolution Panel, definition of Dispute Resolution Panel, eligible assessee

ATOS INDIA P.LTD,MUMBAI vs. DCIT RG 14(1)(1), MUMBAI

In the result, the appeal filed by the assessee stands allowed on the additional grounds

Bench: Shri G. S. Pannu & Shri Amit Shukla, Jm आयकरअपीलसं./ I.T.A. No. 1795/Mum/2017 (ननधधारणवर्ा / Assessment Year: 2012-13) Dcit-14(1)1), Atos India Pvt. Ltd., Aayakar Bhavan Godrej & Boyce Complex, बनाम/ Mumbai Plant 5, Pirojshanagar, Vs. Lbs Marg, Vikhroli (West), Mumbai-400079 स्थधयीलेखधसं./जीआइआरसं./ Pan No. Aaaco2461J (अपीलधथी/Appellant) (प्रत्यथी / Respondent) : अपीलधथीकीओरसे/ Appellant By : Shri Dhanesh Bafna /Chandni Sha /Riddhi Maru /Kinjal Patel, Ld. Ars प्रत्यथीकीओरसे/Respondent By : Dr. Yogesh Kamat, Ld. Dr सुनवधईकीतधरीख/ 01.06.2022 & : 25.01.2023 Date Of Hearing घोर्णधकीतधरीख / : 23.02.2023 Date Of Pronouncement आदेश / O R D E R Per Amit Shukla: 1. The Aforesaid Appeal Has Been Filed By The Assessee Against The Final Assessment Order Passed U/S 143(3) R.W.S. 144C(13) In 2

246A of the Act. However, a new scheme of dispute resolution was brought into the Act by insertion of Sec. 144C of the Act in the context of „eligible assessee‟ prescribed therein. Sec. 144C of the Act contains 15 subsections and provides for a mechanism for dispute resolution, powers of Dispute Resolution Panel, definition of Dispute Resolution Panel, eligible assessee

GENERAL LIFESCIENCE DISTRIBUTORS GMBH,MUMBAI vs. COMMISSIONER OF INCOME TAX (APPEALS)-54, MUMBAI

In the result, both the appeals filed by the Assessee stands allowed in the enumerated terms, for statistical purposes

Bench: Shri.Narendra Kumar Choudhry () & Shri Gagan Goyal ()

reassessment proceedings were initiated and an ex-parte order was passed on 27.12.2019 under section 144 r.w.s. 147 of the Income-tax Act, 21961 4 ITA 2422 & 2423/Mum/2023 General Lifescience Distributors Gmbh (Act), thereby completing the assessment and making an addition of Rs 8,32,24,480 to the total income of the said company. 12. That thereafter, penalty proceedings