R. KUNDAN & CO.,MUMBAI vs. ITO WD 14(3)(2), MUMBAI

Bench: Shri Joginder Singh & Shri Rajesh Kumar

250; CIT v Srinivasan & Gopalan 23 ITR 87 (SC) it was held that a definition or interpretation clause, which extends the meaning of a word, should not be construed as taking away its ordinary meaning. Further, such a clause should be so interpreted as not to destroy the basic concept or essential meaning of the expression defined, unless there

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

250 or section 254 or section 260 or section 262 or section 263 or section 264 shall be made within the time specified in sub- section (3). (5A) Where the Transfer Pricing Officer gives effect to an order or direction under section 263 by an order under section 92CA and forwards such order to the Assessing Officer, the Assessing Officer

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

250 or section 254 or section 260 or section 262 or section 263 or section 264 shall be made within the time specified in sub- section (3). (5A) Where the Transfer Pricing Officer gives effect to an order or direction under section 263 by an order under section 92CA and forwards such order to the Assessing Officer, the Assessing Officer

ESTATE OF VANDRAVAN P SHAH,MUMBAI vs. ASSISTANT COMISSIONER OF INCOME TAX, CIRCLE 19(3), MUMBAI

In the result all the three captioned appeals are dismissed

Bench: Sandeep Gosain () & Shri Om Prakash Kant ()

reassessment are accordingly rejected. The ground no. The ground no. 1 of the appeal is dismissed. the appeal is dismissed. Estate of Vandravan P Shah Estate of Vandravan P Shah ITA No. 5401, 5402 & 5403/MUM/2024 13. The ground Nos s. 3 and 4 of the appeal relate to the merit of . 3 and 4 of the appeal relate

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 ()

250 or section 254 or section 260 section 260 or section 262 or or section 263 or section 264, wholly or partly, , wholly or partly, otherwise than by making a fresh assessment or reassessment, otherwise than by making a fresh assessment or reassessment, otherwise than by making a fresh assessment or reassessment, the assessee shall be entitled to receive

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 ()

250 or section 254 or section 260 section 260 or section 262 or or section 263 or section 264, wholly or partly, , wholly or partly, otherwise than by making a fresh assessment or reassessment, otherwise than by making a fresh assessment or reassessment, otherwise than by making a fresh assessment or reassessment, the assessee shall be entitled to receive

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 ()

250 or section 254 or section 260 section 260 or section 262 or or section 263 or section 264, wholly or partly, , wholly or partly, otherwise than by making a fresh assessment or reassessment, otherwise than by making a fresh assessment or reassessment, otherwise than by making a fresh assessment or reassessment, the assessee shall be entitled to receive

DCIT CEN CIR 8(4), MUMBAI vs. SAVITA OIL TECHNOLOGIES LTD, MUMBAI

Appeal is allowed

Bench: Shri Mahavir Singh & Shri Ramit Kocharआयकर अपीऱ सं./I.T.A. No.7620/Mum/2016 (नििाारण वर्ा / Assessment Year : 2010-11)

reassessment, the assessee shall be entitled to receive, in addition to the interest payable under sub-section (1), an additional interest on such amount of refund calculated at the rate of three per cent per annum, for the period beginning from the date following the date of expiry of the time allowed under sub-section (5) of section

M/S THE MAHARASHTRA STATE CO. OP BANK LTD.,MUMBAI vs. ITO-1(3)(3), MUMBAI

In the result, the appeal of the In the result, the appeal of the assessee is allowed partly assessee is allowed partly whereas the appeal of the Revenue is dismissed

Bench: Shri Om Prakash Kant () & Shri Sandeep Singh Karhail () Assessment Year: 2013-14

250, section 254, section 260, section 262, section 263, or section 254, section 260, section 262, section 263, or section 254, section 260, section 262, section 263, or section 264 or in an order of any court in a proceeding section 264 or in an order of any court in a proceeding section 264 or in an order

DY CIT-1(3)(2), MUMBAI vs. MAHARASHTRA STATE CO-OPERATIVE BANK LIMITED, MUMBAI

In the result, the appeal of the In the result, the appeal of the assessee is allowed partly assessee is allowed partly whereas the appeal of the Revenue is dismissed

Bench: Shri Om Prakash Kant () & Shri Sandeep Singh Karhail () Assessment Year: 2013-14

250, section 254, section 260, section 262, section 263, or section 254, section 260, section 262, section 263, or section 254, section 260, section 262, section 263, or section 264 or in an order of any court in a proceeding section 264 or in an order of any court in a proceeding section 264 or in an order

INCOME TAX OFFICER-13(3)(1), MUMBAI vs. SHRI KIRITBHAI K. THUMMAR, MUMBAI

In the result, assessee‟s cross objection is allowed for statistical purpose

Bench: Shri Om Prakash Kant & Shri Sandeep Singh Karhail

250 of the Income Tax Act, 1961 (“the Act”) by the learned Commissioner of Income Tax (Appeals)–45, Mumbai, [“learned CIT(A)”], for the assessment year 2012–13. ITA no.697/Mum./2018 Revenue’s Appeal : A.Y. 2012–13 2. In its appeal, the Revenue has raised following grounds: “1. On the facts and circumstances of the case

ACIFFT, CIRCLE-2(1)(1), MUMBAI vs. M/S BHARAT PETROLEUM CORPORATION LIMITED, MUMBAI

In the result, appeals of the revenue are dismissed and appeals of the assessee are partly allowed for statistical purpose

Bench: Shri C.N. Prasad, Hon'Ble & Shri M. Balaganesh, Hon'Ble

250 or section 254 or section 260 or section 262 or section 263 or section 264; wholly or partly, otherwise than by making a fresh assessment or revenue expenditure-assessment, the assessee would be entitled to receive, in addition to the interest payable under sub-section (1), an additional interest on such amount of refund calculated at the rate

BHARAT PETROLEUM CORPORATION LIMITED,MUMBAI vs. DY. CIT RANGE-2(1)(1), MUMBAI

In the result, appeals of the revenue are dismissed and appeals of the assessee are partly allowed for statistical purpose

Bench: Shri C.N. Prasad, Hon'Ble & Shri M. Balaganesh, Hon'Ble

250 or section 254 or section 260 or section 262 or section 263 or section 264; wholly or partly, otherwise than by making a fresh assessment or revenue expenditure-assessment, the assessee would be entitled to receive, in addition to the interest payable under sub-section (1), an additional interest on such amount of refund calculated at the rate

BHARAT PETROLEUM CORPORATION LIMITED,MUMBAI vs. DY. CIT RANGE-2(1)(1), MUMBAI

In the result, appeals of the revenue are dismissed and appeals of the assessee are partly allowed for statistical purpose

Bench: Shri C.N. Prasad, Hon'Ble & Shri M. Balaganesh, Hon'Ble

250 or section 254 or section 260 or section 262 or section 263 or section 264; wholly or partly, otherwise than by making a fresh assessment or revenue expenditure-assessment, the assessee would be entitled to receive, in addition to the interest payable under sub-section (1), an additional interest on such amount of refund calculated at the rate

ACIT, CIRCLE-2(1)(1), MUMBAI, MUMBAI vs. M/S BHARAT PETROLEUM CORPORATION LIMITED, MUMBAI

In the result, appeals of the revenue are dismissed and appeals of the assessee are partly allowed for statistical purpose

Bench: Shri C.N. Prasad, Hon'Ble & Shri M. Balaganesh, Hon'Ble

250 or section 254 or section 260 or section 262 or section 263 or section 264; wholly or partly, otherwise than by making a fresh assessment or revenue expenditure-assessment, the assessee would be entitled to receive, in addition to the interest payable under sub-section (1), an additional interest on such amount of refund calculated at the rate

ACIT, CIRCLE -2(1)(1), MUMBAI vs. M/S. BHARAT PETROLEUM CORPORATION LIMITED, MUMBAI

In the result, appeals of the revenue are dismissed and appeals of the assessee are partly allowed for statistical purpose

Bench: Shri C.N. Prasad, Hon'Ble & Shri M. Balaganesh, Hon'Ble

250 or section 254 or section 260 or section 262 or section 263 or section 264; wholly or partly, otherwise than by making a fresh assessment or revenue expenditure-assessment, the assessee would be entitled to receive, in addition to the interest payable under sub-section (1), an additional interest on such amount of refund calculated at the rate

KRINA MAHESH MARU,MUMBAI vs. INCOME TAX OFFICER 41(2)(2), MUMBAI

In the result, the appeal of the assessee is allowed for sult, the appeal of the assessee is allowed for sult, the appeal of the assessee is allowed for statistical purposes

Bench: Shri Om Prakash Kant () & Shri Raj Kumar Chauhan () Assessment Year: 2015-16 Krina Mahesh Maru, Ito-41(2)(2), A-1, Mahesh Krupa Building, Kautilya Bhavan, Vs. Devidayal Cross Road, Mulund Bandra Kurla Complex, West-400080. Mumbai-400020. Pan No. Aeupv 8901 P Appellant Respondent

6. I learnt that the assessment in my case was reopened in order to verify the source of investment made towards purchase order to verify the source of investment made towards purchase order to verify the source of investment made towards purchase of an immovable property be of an immovable property bearing Flat No. B1703, Tirumala aring Flat No. B1703

SHRI DINESHKUMAR C. DOSHI,MUMBAI vs. INCOME TAX OFFICER 19(1)(4), MUMBAI

The appeals of the assessee are dismissed

Bench: Shri Joginder Singh

reassessment proceedings. Explanation-1 to section 147 of the Act supports my view. Thus, the first ground raised by the assessee is having no merit, consequently, dismissed. 3. So far as, the issue with respect to confirmation of addition to the extent of 6.5% of the alleged bogus purchases as against the addition @12.5% made by the Ld. Assessing Officer

INCOME TAX OFFICER-12(3)(1), MUMBAI, MUMBAI vs. MANJU DIAMONDS PVT. LTD., MUMBAI

In the result, the appeal of the Revenue is allowed for statistical purposes whereas the application under Rule 27 of statistical purposes whereas the application under Rule 27

Bench: Shri Om Prakash Kant () & Shri Raj Kumar Chauhan () Assessment Year: 2017-18 Ito-12(3)(1), Manju Diamonds Pvt. Ltd., R.No. 145, 1St Floor, Aayakar 57/59, 1St Floor, Nagdevi Street, Vs. Bhavan, M.K. Road, Maszid Bunder, Mumbai-400020. Mumbai-400 003. Pan No. Aaecm 6609 G Appellant Respondent

6. We have heard rival submissions of the parties and perused We have heard rival submissions of the parties and perused We have heard rival submissions of the parties and perused the relevant materials on record the relevant materials on record including paper book containing including paper book containing pages 1 to 388. It would be apposite at this stage

ITO 25 (3)(3), MUMBAI vs. RAHUL KANTILAL SHAH, MUMBAI

In the result, the appeal filed by the revenue is dismissed

Bench: Shri M Balaganesh, Accountat Member & Shri Pavan Kumar Gadaleita No. 6805 /Mum/2018 (A.Y: 2012-13 ) Ito- 25(3)(3) Vs. Rahul Kantilal Shah Room No. 606, 6Th Floor 701, Saroj Bldg, C-10, Pratyakshakar Sardar Vallabhbhai Bhavan, Bkc, Bandra (E) Patel Road, Mumbai -400051. Vile Parle (W) Mumbai-400056. "थायी लेखा सं./जीआइआर सं./Pan/Gir No. : Aaips0543C Appellant .. Respondent Appellant By : Mr.T.Shankar.Dr Respondent By : Mr.Anuj Kishnadwala.Ar Date Of Hearing 09.05.2022 Date Of Pronouncement 26.07.2022 आदेश / O R D E R Per Pavan Kumar Gadale, Jm: This Appeal Is Filed The By The Revenue Against The Separate Orders Of The Commissioner Of Income Tax (Appeals)-77, Mumbai Passed U/S 143(3) & 250 Of The Act.

6. Contra, the Ld. AR submitted that in the case of unsecured loans, the A.O. has made addition of the opening balances of loan accounts carried forwarded from earlier years and also disallowed the interest paid on loans by invoking the provisions of section 68 of the Act. Whereas in respect of M/s Time Star Pvt Ltd unsecured loan