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

reassessment, as the case may be, under the said 15[sub- sections (1), (1A), (2), (3) and (3A)], shall be extended by twelve months. (5) Where effect to an order under section 250 or section 254

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

reassessment, as the case may be, under the said 15[sub- sections (1), (1A), (2), (3) and (3A)], shall be extended by twelve months. (5) Where effect to an order under section 250 or section 254

H.K.ENTERPRISES,MUMBAI vs. DCIT, CENTRAL CIRCLE-2(4), MUMBAI

In the result, all the eight appeals filed by the assessee are allowed

Bench: Shri Sandeep Gosain & Shri Prabhash Shankar

254(d) of the Act before the Hon’ble Income Tax Settlement Commission (ITSC) in the absence of any incriminating evidence found at time the of search. Therefore, we have decided to dispose off these grounds through the present consolidated order. 4. The Ld. AR appearing on behalf of the assessee reiterating the same arguments as were raised

H.K. ENTERPRISES,MUMBAI vs. DY CIT-CC-2(4), MUMBAI

In the result, all the eight appeals filed by the assessee are allowed

Bench: Shri Sandeep Gosain & Shri Prabhash Shankar

254(d) of the Act before the Hon’ble Income Tax Settlement Commission (ITSC) in the absence of any incriminating evidence found at time the of search. Therefore, we have decided to dispose off these grounds through the present consolidated order. 4. The Ld. AR appearing on behalf of the assessee reiterating the same arguments as were raised

H.K. ENTERPRISES,MUMBAI vs. DY CIT -CC-2(4), MUMBAI

In the result, all the eight appeals filed by the assessee are allowed

Bench: Shri Sandeep Gosain & Shri Prabhash Shankar

254(d) of the Act before the Hon’ble Income Tax Settlement Commission (ITSC) in the absence of any incriminating evidence found at time the of search. Therefore, we have decided to dispose off these grounds through the present consolidated order. 4. The Ld. AR appearing on behalf of the assessee reiterating the same arguments as were raised

H.K. ENTERPRISES,MUMBAI vs. DY CIT CC - 2(4), MUMBAI

In the result, all the eight appeals filed by the assessee are allowed

Bench: Shri Sandeep Gosain & Shri Prabhash Shankar

254(d) of the Act before the Hon’ble Income Tax Settlement Commission (ITSC) in the absence of any incriminating evidence found at time the of search. Therefore, we have decided to dispose off these grounds through the present consolidated order. 4. The Ld. AR appearing on behalf of the assessee reiterating the same arguments as were raised

H.K. ENTERPRISES,MUMBAI vs. DY CIT-CC-2(4), MUMBAI

In the result, all the eight appeals filed by the assessee are allowed

Bench: Shri Sandeep Gosain & Shri Prabhash Shankar

254(d) of the Act before the Hon’ble Income Tax Settlement Commission (ITSC) in the absence of any incriminating evidence found at time the of search. Therefore, we have decided to dispose off these grounds through the present consolidated order. 4. The Ld. AR appearing on behalf of the assessee reiterating the same arguments as were raised

H.K. ENTERPRISES,MUMBAI vs. DY CIT-CC-2(4), MUMBAI

In the result, all the eight appeals filed by the assessee are allowed

Bench: Shri Sandeep Gosain & Shri Prabhash Shankar

254(d) of the Act before the Hon’ble Income Tax Settlement Commission (ITSC) in the absence of any incriminating evidence found at time the of search. Therefore, we have decided to dispose off these grounds through the present consolidated order. 4. The Ld. AR appearing on behalf of the assessee reiterating the same arguments as were raised

H.K. ENTERPRISES,MUMBAI vs. DY CIT - CC-2(4), MUMBAI

In the result, all the eight appeals filed by the assessee are allowed

Bench: Shri Sandeep Gosain & Shri Prabhash Shankar

254(d) of the Act before the Hon’ble Income Tax Settlement Commission (ITSC) in the absence of any incriminating evidence found at time the of search. Therefore, we have decided to dispose off these grounds through the present consolidated order. 4. The Ld. AR appearing on behalf of the assessee reiterating the same arguments as were raised

M/S. PATANJALI FOODS LTD (FORMERLY KNOWN AS RUCHI SOYA INDUSTRIES LTD),MUMBAI vs. DY COMM OF INCOME TAX- CENTRAL CIRCLE-7(2), MUMBAI

In the result, the appeal and cross objections of the assessee are partly allowed and the appeals of the revenue are dismissed

Bench: Shri Aby T. Varkey, Jm & Shri S Rifaur Rahman, Am आयकर अपील सं/ I.T. A. No. 1172/Mum/2023 (निर्धारण वर्ा / Assessment Year: 2010-11) & आयकर अपील सं/ I.T. A. No. 1175/Mum/2023 (निर्धारण वर्ा / Assessment Year: 2012-13) & आयकर अपील सं/ I.T. A. No. 1176/Mum/2023 (निर्धारण वर्ा / Assessment Year: 2012-13)

reassessment, if any, relating to any assessment year falling within the period of six assessment years referred to in sub-section (1) is pending on the date of initiation of the search u/s. 132 of the Act shall abate. In the present case before us, however, though the second proviso to sub-section (1) of section 153A would not apply

DCIT, CC-7(2), MUMBAI vs. M/S. PATANJALI FOODS LTD.,( FORMERLY KNOWN AS RUCHI SOYA INDUSTRIES LTD,, MUMBAI

In the result, the appeal and cross objections of the assessee are partly allowed and the appeals of the revenue are dismissed

Bench: Shri Aby T. Varkey, Jm & Shri S Rifaur Rahman, Am आयकर अपील सं/ I.T. A. No. 1172/Mum/2023 (निर्धारण वर्ा / Assessment Year: 2010-11) & आयकर अपील सं/ I.T. A. No. 1175/Mum/2023 (निर्धारण वर्ा / Assessment Year: 2012-13) & आयकर अपील सं/ I.T. A. No. 1176/Mum/2023 (निर्धारण वर्ा / Assessment Year: 2012-13)

reassessment, if any, relating to any assessment year falling within the period of six assessment years referred to in sub-section (1) is pending on the date of initiation of the search u/s. 132 of the Act shall abate. In the present case before us, however, though the second proviso to sub-section (1) of section 153A would not apply

DCIT, CC-7(2), MUMBAI vs. M/S. PATANJALI FOODS LTD.,( FORMERLY KNOWN AS RUCHI SOYA INDUSTRIES LTD,, MUMBAI

In the result the appeal filed by the revenue stands dismissed

Bench: Shri Sandeep Gosain & Shri Prabhash Shankar

reassessment, if any, relating to any assessment year falling within the period of six assessment years referred to 11 Patanjali Foods Ltd, Mumbai. in sub-section (1) is pending on the date of initiation of the search u/s. 132 of the Act shall abate. In the present case before us, however, though the second proviso to sub-section (1

DCIT, CC-7(2), MUMBAI vs. M/S. PATANJALI FOODS LTD.,( FORMERLY KNOWN AS RUCHI SOYA INDUSTRIES LTD,, MUMBAI

In the result the appeal filed by the revenue stands dismissed

Bench: Shri Sandeep Gosain & Shri Prabhash Shankar

reassessment, if any, relating to any assessment year falling within the period of six assessment years referred to 11 Patanjali Foods Ltd, Mumbai. in sub-section (1) is pending on the date of initiation of the search u/s. 132 of the Act shall abate. In the present case before us, however, though the second proviso to sub-section (1

DCIT, CIR-3(3)(1), MUMBAI vs. SICOM LIMITED, MUMBAI CITY

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

Bench: Shri Pavan Kumar Gadale & Shri Gagan Goyalita Nos. 2034 & 2035/Mum/2023 (A.Y:1999-2000 &1998-99) Dcit, Circle-3(3)(1), Vs. M/S Sicom Limited, Room No.609, Solitaire Corporate Aayakar Bhavan, Park, Building No.4, M.K. Road, Guru Nanak Marg, Mumbai-400020. Chakala, Midc S.O, Mumbai-400093. Pan/Gir No. : Aaacs5524J Appellant .. Respondent

254 or section 260 or section 262 or section 263 or section 264, wholly or partly, otherwise than by making a fresh assessment or reassessment, the assessee shall be entitled to receive, in addition to the interest payable under sub section (1

ACIT-3(2)(1), MUMBAI vs. MAHARASHTRA AIRPORT DEVELOPMENT COMPANY LTD., MUMBAI

254 or section 260 or section 262 or section 263 or section\n264. For ready perusal relevant provision is extracted as under:\n“153. Time limit for completion of assessment, reassessment and\nrecomputation\n(3) Notwithstanding anything contained in user-sections (1

M/S. PATANJALI FOODS LTD (FORMERLY KNOWN AS RUCHI SOYA INDUSTRIES LTD),MUMBAI vs. DY COMM OF INCOME TAX- CENTRAL CIRCLE-7(2), MUMBAI

In the result the appeal filed by the revenue stands\ndismissed

Bench: Shri Sandeep Gosain&\Nshri Prabhash Shankar\N\Ni.T.A. No. 319& 321/Mum/2023\Na.Ys: 2007-08 & 2011-12\N\Npatanjali Food Ltd (Formerly Vs\Nknown As Ruchi Soya\Nindustries Ltd)\N616, Tulsiani Chambers,\Nnariman Point, Mumbai\Npan - Aaacr2892L\Ndy. Cit, Cc – 7(2)\N655, 6Th Floor, Aayakar\Nbhavan, Mk Road, Mumbai\N400020.\N(Appellant)\N(Respondent)\N\Ni.T.A. No. 1173 & 1174/Mum/2023\Na.Ys: 2007-08, 2011-12\Ndy. Cit, Cc – 7(2)\N655, 6Th Floor, Aayakar\Nbhavan, Mk Road, Mumbai\N400020.\N(Appellant)\Nvs\Npatanjali\Nfood\Nltd\N(Formerly Known As Ruchi\Nsoya Industries Ltd)\N616, Tulsiani Chambers,\Nnariman Point, Mumbai\Npan – Aaacr2892L\N(Respondent)\N\Nassessee By\Nrevenue By\Ndate Of Hearing\Ndate Of Pronouncement\N\Nshri Ss Nagar (Virtually Appeared) &\Nshri B Maheshwari\Nshri Ra Dhyani, Cit Dr\N11.08.2025\N15.09.2025\N\Norder\N\Nper: Shri. Sandeep Gosain, J.M.:\Nthe Present Appeals Have Been Filed By The Assessee\Nchallenging The Different Impugned Orders Passed Under\Nsection 250 Of The Income Tax Act, 1961 (‘The Act'), By The\Nnational Faceless Appeal Centre (Nfac) / Cit(A) For The\N Assessment Year 2007-08 & 2011-12.\N\N2. Since All The Issues Involved In These Two Appeals Are\Ncommon & Identical, Therefore, They Have Been Clubbed,\Nheard Together & Consolidated Order Is Being Passed For\Nthe Sake Of Convenience & Brevity.\N\Nita No. 319/Mum/2023, A.Y 2007-08\N\N3. At The Time Of Hearing Ld.Ar Stated At Bar That Assessee\Nwants To Withdraw The Present Appeal. Therefore, Considering\Nthe Statement Of The Ld.Ar, The Present Appeal Filed By The\Nassessee Stands Dismissed As Withdrawn.\N\N3.

reassessment, if any, relating\nto any assessment year falling within the period of six assessment years referred to\nin sub-section (1) is pending on the date of initiation of the search u/s.132 of the\nAct shall abate. In the present case before us, however, though the second proviso\nto sub-section (1) of section 153A would not apply

PATANJALI FOODS LTD (FORMERLY KNOWN AS RUCHI SOYA INDUSTRIES LTD),MUMBAI vs. DY COMM OF INCOME TAX-CENTRAL CIRCLE-7(2), MUMBAI

In the result the appeal filed by the revenue stands\ndismissed

Bench: Shri Sandeep Gosain&\Nshri Prabhash Shankar\N\Ni.T.A. No. 319& 321/Mum/2023\Na.Ys: 2007-08 & 2011-12\Npatanjali Food Ltd (Formerly Vs Dy. Cit, Cc – 7(2)\Nknown As Ruchi Soya 655, 6Th Floor, Aayakar\Nindustries Ltd) Bhavan, Mk Road, Mumbai\N616, Tulsiani Chambers, 400020.\Nnariman Point, Mumbai\Npan - Aaacr2892L\N(Respondent)\N(Appellant)\N\Ni.T.A. No. 1173 & 1174/Mum/2023\Na.Ys: 2007-08, 2011-12\Ndy. Cit, Cc – 7(2) Vs Patanjali Food Ltd\N655, 6Th Floor, Aayakar (Formerly Known As Ruchi\Nbhavan, Mk Road, Mumbai Soya Industries Ltd)\N400020.\N616, Tulsiani Chambers,\N(Appellant) Nariman Point, Mumbai\Npan – Aaacr2892L\N(Respondent)\N\Nassessee By Shri Ss Nagar (Virtually Appeared) &\Nshri B Maheshwari\Nrevenue By Shri Ra Dhyani, Cit Dr\Ndate Of Hearing 11.08.2025\Ndate Of Pronouncement 15.09.2025\N\Norder\N\Nper: Shri. Sandeep Gosain, J.M.:\N\Nthe Present Appeals Have Been Filed By The Assessee\Nchallenging The Different Impugned Orders Passed Under\Nsection 250 Of The Income Tax Act, 1961 (‘The Act'), By The\Nnational Faceless Appeal Centre (Nfac) / Cit(A) For The\N Assessment Year 2007-08 & 2011-12.\N\N2. Since All The Issues Involved In These Two Appeals Are\Ncommon & Identical, Therefore, They Have Been Clubbed,\Nheard Together & Consolidated Order Is Being Passed For\N\Nthe Sake Of Convenience & Brevity.\N\Nita No. 319/Mum/2023, A.Y 2007-08\N\N3. At The Time Of Hearing Ld.Ar Stated At Bar That Assessee\Nwants To Withdraw The Present Appeal. Therefore, Considering\Nthe Statement Of The Ld.Ar, The Present Appeal Filed By The\Nassessee Stands Dismissed As Withdrawn.\N\N3.

reassessment, if any, relating\nto any assessment year falling within the period of six assessment years referred to\n\nin sub-section (1) is pending on the date of initiation of the search u/s.132 of the\nAct shall abate. In the present case before us, however, though the second proviso\nto sub-section (1) of section 153A would not apply

DCIT(IT)-4(1)(2), MUMBAI vs. ARUN MADHAVACHARI RANGACHARI, MUMBAI

254 of the Income\nTax Act, 1961 (“the Act\") by the learned Commissioner of Income Tax\n(Appeals)-58, Mumbai, [“learned CIT(A)”], for the assessment year 2011-12.\n2.\nIn the appeal, the Revenue has raised the following grounds:\n“1) \"Whether on the facts and circumstances of the case, the Id. CIT(A) erred\nin following the decision