THE NEW INDIA ASSURANCE CO. LTD ,MUMBAI vs. DEPUTY COMMISSIONER OF INCOME TAX, CIRCLE -3(2)(2), MUMBAI

reassessment order passed under section\n143(3) read with section 147 of the Income Tax Act (‘the\nAct’) as valid.\n\n2. The CIT(A) failed to appreciate the fact that in the reasons\nrecorded, the AO has not disclosed any specific non-\ndisclosure of material facts by the appellant.”\n\n8. We have heard the both the sides

THE NEW INDIA ASSURANCE CO. LTD,MUMBAI vs. ASSISTANT COMMISSIONER OF INCOME TAX , INCOME TAX OFFICER, NFAC, MUMBAI

Accordingly, in terms of the aforesaid, Ground No. 3 to\n7 raised by the Assessee pertaining to merits of such\nadditions/disallowances are dismissed as having been rendered\ninfructuous

Bench: "CLEAN_TEXT": "IN THE INCOME TAX APPELLATE TRIBUNAL\n\"I\" BENCH, MUMBAI\n\nSHRI VIKRAM SINGH YADAV , ACCOUNTANT MEMBER\nSHRI RAHUL CHAUDHARY (Judicial Member)

reassessment order passed under section\n143(3) read with section 147 of the Income Tax Act (‘the\nAct’) as valid.\n\n2.\nThe CIT(A) failed to appreciate the fact that in the reasons\nrecorded, the AO has not disclosed any specific non-\ndisclosure of material facts by the appellant.”\n\n8.\nWe have heard the both the sides

SURENDRA GARG HUF ,MUMBAI vs. ITO- 19(3)(4), MUMBAI

reassessment proceedings on incorrect understanding of\nfacts. We note that the Assessing Officer had identified the Assessee\nas a beneficiary of accommodation entries taken by the Assessee in\nrespect of sale of 44200 shares of KGN Enterprises. Admittedly, in\naggregate 44,200 share of KGN Enterprises were sold by the\nAssessee during the previous year(s) relevant to Assessment Years

THE NEW INDIA ASSURANCE CO. LTD ,MUMBAI vs. DEPUTY COMMISSIONER OF INCOME TAX, CIRCLE-3(2)(2), MUMBAI

reassessment order passed under section \n143(3) read with section 147 of the Income Tax Act (‘the \nAct’) as valid. \n2. The CIT(A) failed to appreciate the fact that in the reasons \nrecorded, the AO has not disclosed any specific non \ndisclosure of material facts by the appellant.” \n8. We have heard the both the sides in relation

DCIT 3.2.1, MUMBAI vs. THE NEW INDIA ASSURANCE CO LIMITED, MUMBAI

Accordingly, in terms of the aforesaid, Ground No. 3 to\n7 raised by the Assessee pertaining to merits of such\nadditions/disallowances are dismissed as having been rendered\ninfructuous

reassessment order passed under section\n143(3) read with section 147 of the Income Tax Act (‘the\nAct’) as valid.\n\n2. The CIT(A) failed to appreciate the fact that in the reasons\nrecorded, the AO has not disclosed any specific non-\ndisclosure of material facts by the appellant.”\n\n8. We have heard the both the sides

SURENDRA GARG HUF,MUMBAI vs. ITO - 19(3)(4), MUMBAI

reassessment proceedings on incorrect understanding of\nfacts. We note that the Assessing Officer had identified the Assessee\nas a beneficiary of accommodation entries taken by the Assessee in\nrespect of sale of 44200 shares of KGN Enterprises. Admittedly, in\naggregate 44,200 share of KGN Enterprises were sold by the\nAssessee during the previous year(s) relevant to Assessment Years

DCIT 3.2.1, MUMBAI vs. THE NEW INDIA ASSURANCE CO LIMITED, MUMBAI

reassessment order passed under section \n143(3) read with section 147 of the Income Tax Act (‘the \nAct’) as valid. \n2. The CIT(A) failed to appreciate the fact that in the reasons \nrecorded, the AO has not disclosed any specific non- \ndisclosure of material facts by the appellant.” \n8. We have heard the both the sides in relation

SHRI AMIT MANGILAL JAIN,MUMBAI vs. ACIT, - 33(1), MUMBAI

In the result, both the above appeals are allowed

Bench: Shri Sandeep Gosain & Shri Prabhash Shankar

reassess taking into consideration the other material in respect of completed assessments/unabated assessments. Meaning thereby, in respect of completed/unabated assessments, no addition can be made by the AO in absence of any incriminating material found during the course of search under Section 132 or requisition under Section 132A of the Act, 1961. However, the completed/unabated assessments can be re-opened

THE NEW INDIA ASSURANCE CO LTD,MUMBAI vs. DEPUTY COMMISSIONER OF INCOME TAX, CIRCLE 3(2)(2), MUMBAI

Accordingly, Ground No.1 to 4 raised by the Assessee are allowed

Bench: SHRI VIKRAM SINGH YADAV , ACCOUNTANT MEMBER SHRI RAHUL CHAUDHARY (Judicial Member)

reassessment proceedings were initiated in the case of the Assessee which culminated into passing of Assessment Order, dated 29/06/2016 under Section 143(3) read with Section 147 of the Act. Thereafter, the case was again reopened under Section 147 of the Act after recording the reason and after obtaining the approval from the competent authority. The notice under Section

DCIT 3.2.1, MUMBAI vs. THE NEW INDIA ASSURANCE CO LIMITED, MUMBAI

Accordingly, Ground No.1 to 4 raised by the Assessee are allowed

Bench: SHRI VIKRAM SINGH YADAV, ACCOUNTANT MEMBER SHRI RAHUL CHAUDHARY (Judicial Member)

reassessment proceedings were initiated in the case of the Assessee which culminated into passing of Assessment Order, dated 29/06/2016 under Section 143(3) read with Section 147 of the Act. Thereafter, the case was again reopened under Section 147 of the Act after recording the reason and after obtaining the approval from the competent authority. The notice under Section

DCIT 3.2.1, MUMBAI vs. THE NEW INDIA ASSURANCE CO LIMITED, MUMBAI

Accordingly, Ground No.1 to 4 raised by the Assessee are allowed

Bench: SHRI VIKRAM SINGH YADAV , ACCOUNTANT MEMBER SHRI RAHUL CHAUDHARY (Judicial Member)

reassessment proceedings were initiated in the case of the Assessee which culminated into passing of Assessment Order, dated 29/06/2016 under Section 143(3) read with Section 147 of the Act. Thereafter, the case was again reopened under Section 147 of the Act after recording the reason and after obtaining the approval from the competent authority. The notice under Section

THE NEW INDIA ASSURANCE CO. LTD ,MUMBAI vs. DEPUTY COMMISSIONER OF INCOME TAX, CIRCLE 3(2)(2), MUMBAI

Accordingly, Ground No.1 to 4 raised by the Assessee are allowed

Bench: SHRI VIKRAM SINGH YADAV, ACCOUNTANT MEMBER SHRI RAHUL CHAUDHARY (Judicial Member)

reassessment proceedings were initiated in the case of the Assessee which culminated into passing of Assessment Order, dated 29/06/2016 under Section 143(3) read with Section 147 of the Act. Thereafter, the case was again reopened under Section 147 of the Act after recording the reason and after obtaining the approval from the competent authority. The notice under Section

CHEMOX EXPORTS IMPORTS PVT LTD,MUMBAI vs. INCOME TAX DEPARTMENT, ASSESSMENT UNIT, DELHI

reassessment proceedings under the\namended provision of law, more particularly, as amended by the Finance Act, 2021.\n17\nआयकर अपीलीय अधिकरण\nINCOME TAX APPELLATE TRIBUNAL\nI.T.A. No. 3954/Mum/2024\nIt never intended the authorities concerned to continue with the proceedings from\nthe stage of the issuance of notices under section 148, nor is the directions to that\neffect. And there cannot

KASHYAP KANIYALAL MEHTA,MUMBAI vs. DCIT CC-4(1), MUMBAI

In the result, appeals of the assessee are allowed

section 147 after the search dated 06.10.2017, then the present reassessment order dated 28.12.2018, which is founded upon the same search and the same nature of allegations, deserves to be quashed following the said binding precedent. 25

KASHYAP KANIYALAL MEHTA,MUMBAI vs. DCIT CC-4(1), MUMBAI

In the result, appeals of the assessee are allowed

section 147 after the search dated 06.10.2017, then the present reassessment order dated 28.12.2018, which is founded upon the same search and the same nature of allegations, deserves to be quashed following the said binding precedent. 25

KASHYAP KANIYALAL MEHTA,MUMBAI vs. DCIT, CC-4(1), MUMBAI

In the result, appeals of the assessee are allowed

section 147 after the search dated 06.10.2017, then the present reassessment order dated 28.12.2018, which is founded upon the same search and the same nature of allegations, deserves to be quashed following the said binding precedent. 25

KASHYAP KANIYALAL MEHTA,MUMBAI vs. DCIT CC-4(1), MUMBAI

In the result, appeals of the assessee are allowed

section 147 after the search dated 06.10.2017, then the present reassessment order dated 28.12.2018, which is founded upon the same search and the same nature of allegations, deserves to be quashed following the said binding precedent. 25

KASHYAP KANIYALAL MEHTA,MUMBAI vs. DCIT CC-4(1), MUMBAI

In the result, appeals of the assessee are allowed

section 147 after the search dated 06.10.2017, then the present reassessment order dated 28.12.2018, which is founded upon the same search and the same nature of allegations, deserves to be quashed following the said binding precedent. 25