ACIT-6(1)(1), MUMBAI, MUMBAI vs. ARMSTRONG ENERGY PVT. LTD., MUMBAI

Bench: Hon’Ble Shri Sandeep Gosain & Hon’Ble Shri Prabhash Shankarm/S Armstrong Energy Pvt. Vs. Dcit 6(1) (1), Mumbai Ltd. Room No. 504, 5Th 5Th Floor, Militia Apartment, Floor, Aayakar Bhavan, Mathur Pakhadi Road, M.K. Road, Mazgaon, Mumbai 400020 Mumbai - 400010 Pan/Gir No. Aafca3807R (Applicant) (Respondent) Acit 6(1) (1), Mumbai Vs. M/S Armstrong Energy Pvt. Room No. 504, 5Th Floor, Ltd. Aayakar Bhavan, M.K. 5Th Floor, Militia Road, Apartment, Mathur Mumbai 400020 Pakhadi Road, Mazgaon, Mumbai - 400010 Pan/Gir No. Aafca3807R (Applicant) (Respondent) Assessee By Shri Nishit Gandhi Revenue By Shri Rajesh Kumar Yadav (Cit-Dr) Date Of Hearing 10.12.2025 Date Of Pronouncement 16.02.2026 आदेश / Order Per Sandeep Gosain, Jm: M/S. Armstrong Energy Pvt. Ltd.

section 251(1)(a) is applicable only in cases where assessment order is passed u/s 144 of the IT Act, 1961. The set aside by the CIT(A) is totally bad in law 2. On the facts and circumstances of the case and in law, the Ld. CIT(A) has erred by dismissing the ground that the reassessment

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

AMINA ASLAM QURESHI,MUMBAI vs. INCOME TAX OFFICER WARD 22(1)(1) MUMBAI , MUMBAI

In the result the appeal filed by the assessee stands allowed

Bench: Smt. Beena Pillai () & Shri Omkareshwar Chidara ()

reassessment proceedings under section 148 which is bad in law and required to be quashed. 2 ITA No.769/Mum/2025; A.Y. 2017-18 Amina Aslam Qureshi 2. On the facts and circumstances of the case and law, the Ld CIT(A) grossly erred & failed to appreciate that the reopening of assessment vide notice u/s 148 of the Act dated 29/07/2022 i.e After

PRAKSH PUSHPARAJ GOLCHA,ANDHERI (W) vs. COMMISSIONER OF INCOME-TAX (APPEALS), NFAC, DELHI

In the result, the appeal is allowed for statistical purposes

Bench: Shri Narender Kumar Choudhry & Shri Prabhash Shankarpraksh Pushparaj Golcha, V/S. Assistant Commissioner Of 6A, Shivkrupa H Wing, बनाम Income Tax– 24(3), Old Nagardas Road, M/O Finance, Income Tax Andheri(W), Department, National Faceless Mumbai-400 069, Appeal Centre(Nfac), Delhi Maharashtra स्थायी लेखा सं./जीआइआर सं./Pan/Gir No: Aabpg9404H Appellant/अपीलार्थी .. Respondent/प्रतिवादी

reassessment, Capital gains or the addition made u/s 69C of the Act vis- à-vis the submissions of the assessee. Apparently, the ld. CIT(A) has failed to adjudicate on the issues with an open mind and his hurried conclusion only reflects a prejudiced and predetermined approach in brushing aside the contentions of the assessee and the evidences furnished

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

section 147 cannot be used as a ploy for roving verification or fishing enquiry into completed matters.\n\n63\nITA No.3012/Mum/2025 and others\nThe Estate Investment Company Pvt. Ltd. and others\nThe Assessing Officer's act of extrapolating entries found in one year to reopen other years is precisely the mischief which the Court sought to prevent. On this count

M/S. NAVKAR INDIA,SURAT vs. ACIT CC -1(3), MUMBAI

In the result, the appeal of the assessee is allowed

section 251(2) of the Act also.”\n11.2 The facts and circumstances of the instant case being\nidentical, respectively following the finding of the Tribunal in the\ncase Rare Diamonds (supra), the enhancement made by the Ld.\nCIT(A) is hereby deleted. The ground Nos. 7 and 8 of the appeal are\naccordingly allowed.\n12. The ground

RANJIT PATHAK ,MUMBAI vs. DCIT CIRCLE 42(3)(1), MUMBAI

In the result, both the appeals of the assessee are allowed

Section 251(1)(a) of the Act and, vide order\ndated 8/11/2024, set aside the reassessment order passed under\nSection

RANJIT PATHAK,MUMBAI vs. DCIT CIRCLE 42(3)(1), MUMBAI

In the result, both the appeals of the assessee are allowed

Section 251(1)(a) of the Act and, vide order\ndated 8/11/2024, set aside the reassessment order passed under\nSection

GOVIND CORPORATION ,MUMBAI vs. DCIT CENTRAL CIRCLE 8(1), MUMBAI

In the result, appeals for these two years are also allowed

251(2) of the Act. The Appellants therefore submit that the enhancement\nof Rs. 17,71,235 is bad in law and should be deleted.\nGround no.3 (b)\nWithout prejudice to above, the CIT(A) erred in enhancing the addition under\nsection 69A/698 by Rs 17,71,235 as being cash applied towards purchase of\nunregistered land at Dhokawade. Alibaug

NIMISH VIVEK JUVEKAR ,MUMBAI vs. ITO WARD 20(2)(1), MUMBAI

In the result, appeal of the assessee is allowed for statistical\npurposes

sections": [ "148A(b)", "148A(d)", "148", "151A", "10(38)", "147", "144", "142(1)", "251(1)(a)" ], "issues": "The main issue is the validity of the reassessment

PRAKASH ISHWARADAS SUHANDA,MUMBAI vs. INCOME TAX OFFICER-27(2)(5), MUMBAI

Bench: SHRI PRASHANT MAHARISHI, ACCOUNTANT MEMBER SHRI RAHUL CHAUDHARY (Judicial Member)

reassessment proceedings on the presumption that the assessee had not filed the return of income whereas the return of income for the Assessment year 2009-2010 was filed by the Appellant with the Office of Income Tax Officer, Ward 22(2)(2). It was submitted that income tax returns for subsequent assessment years 2010-2011 to 2013- 2014 were also

M/S. ALUCAST ENGINEERING PVT LTD ,MUMBAI vs. DEPUTY COMMISSIONER OF INCOME TAX CIRCLE 6(1)(1), MUMBAI

In the result, the appeal is allowed for statistical purposes

Bench: Shri Sandeep Gosain & Shri Prabhash Shankarm/S Alucast Engineering V/S. Deputy Commissioner Of Pvt. Ltd. Company, 3/18, Ac बनाम Income Tax, Circle – 6(1)(1), Market,Tardeo Road, Room No. 504, Aayakar Tulsiwadi S.O., Mumbai–400 Bhavan, M.K. Road, Mumbai 034, Maharashtra – 400020, Maharashtra स्थायी लेखा सं./जीआइआर सं./Pan/Gir No: Aahca9486C Appellant/अपीलार्थी .. Respondent/प्रतिवादी

reassessment proceedings under taken for AY 2012-13 with regard to alleged bogus transaction as per information from Investigation wing, Baroda on escaped income of Rs 86.98 cr. was accepting the transaction genuine by the DCIT- 19(1),Mumbai. 7.1 We further note that the ld.CIT(A) has once again reproduced the contents of the assessment order from pages

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)

section 251 of the Act are indeed wide, but they are not unbounded. They must operate within the framework of issues arising out of the assessment before the CIT(A) and cannot extend to introducing new sources of income that were never the subject of consideration before the Assessing Officer. The Hon’ble Supreme Court in CIT v. Shapoorji Pallonji

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

In the result, appeals for these two years are also allowed

section 251(2).\nFurthermore, the addition by way of enhancement arises out of the\nsame excel sheet which has already been dealt by us while dealing with\nground no.3 as well as by the Coordinate Bench in assessee's own case\nreferred above. In view of these factual positions and provision of the\nAct, enhancement so made