THE TATA POWER COMPANY LTD,MUMBAI vs. PR CIT 2, MUMBAI

In the result, appeal is allowed, as indicated above

Bench: Shri Saktijit Dey () & Shri Rajesh Kumar ()

reassessment proceedings, the period of limitation provided for under Sub-section (2) of Section 263 of the Act would begin

HINDUSTAN CONSTRUCTION COMPANY,MUMBAI vs. PR. CIT-6, MUMBAI

Appeal is allowed

2) of the Act, the PCIT had time till 31.03.2021 to pass order under Section 263 of the Act. He submitted that as per the provisions of Section 147 of the Act the Assessing Officer had the power to assess other income along with the escaped income in respect of which reassessment

BHUVNESHWARI VYAPAAR PRIVATE LTD ,MUMBAI vs. PRINCIPLE COMMISSIONER OF INCOME TAX P-CIT,MUMBAI-1, MUMBAI

In the result, appeal of the assessee is allowed

Bench: Shri Prashant Maharishi, Am & Shri Pavan Kumar Gadale, Jm Bhuvneshwari Vyapaar Private Limited Pcit,Mumbai-1 710/A Wing Dattani Plaza Room No. 330, 3 R D Floor, Aayakar Vs. Commercial Premises, Safed Pool, Bhavan, M.K.Road, Mumbai-400 020 Andheri Kurla Road, Andheri East, Mumbai- 400 072 (Appellant) (Respondent) Pan No. Aadcb4386N

reassessment proceeding. The jurisdiction of the Commissioner to invoke his revisional power was questioned on the ground of limitation, as provided for in sub-section (2) of Section 263

JEEVANDEEP EDUMEDIA PRIVATE LIMITED,MUMBAI vs. PRINCIPLE CIT-6, MUMBAI

In the result, the a In the result, the appeal of the assessee is stands allowed

Bench: Shri Om Prakash Kant () & Ms. Kavitha Rajagopal () Assessment Year: 2020-21 Jeevandeep Edumedia Pvt. Ltd., Pr. Cit-6, 1St Floor, Sun Paradise Business 501,5Th Floor, Aayakar Bhavan, Plaza, Senapati Bapat Marg, Vs. Maharishi Karve Road, Lower Parel (West), Mumbai-400020. Mumbai-400013. Pan No. Aabcj 0180 G Appellant Respondent

263 of the Act. 2.3 In response, the assessee submitted that the Assessing Offic In response, the assessee submitted that the Assessing Offic In response, the assessee submitted that the Assessing Officer had indeed examined the allowability of the CSR expenditure under had indeed examined the allowability of the CSR expenditure under had indeed examined the allowability

ROYAL WESTERN INDIA TURF CLUB,MUMBAI vs. PR. CIT -8, MUMBAI

In the result, appeal is allowed, as indicated above

Bench: Shri Saktijit Dey () & Shri Rajesh Kumar ()

reassessment proceedings, the period of limitation provided for under Sub-section (2) of Section 263 of the Act would begin

M/S. RAVI FOUNDATION ,MUMBAI vs. PR. CIT-17, MUMBAI

In the result, the appeal of the assessee is hereby allowed

reassessment proceedings, the period of limitation provided for under Sub-section (2) of Section 263 of the Act would begin

ICICI BANK LTD.,MUMBAI vs. THE DY CIT -2(3)(1), MUMBAI

In the result we hold that the learned principal

Bench: Shri Prashant Maharishi, Am & Shri Pavan Kumar Gadale, Jm Icici Bank Limited The Dy. Commissioner Of Icici Bank Towers, Income-Tax-2(3)(1), Aayakar Bhavan, 5 Th Floor, Bandra Kurla Complex, Vs. Bandra (East), Room No.552, Mumbai-400 051 M.K.Road, Mumbai-400 020 (Appellant) (Respondent) Pan No. Aaaci1195H Appellant By : Ms Arati Vissanji, Ar Respondent By : Shri Nikhil Chaudhary, Cit Dr Date Of Hearing: 13.01.2022 Date Of Pronouncement : 08.03.2022

reassessment order u/s 143 (3) read with Section 147 of the act was passed on 31 December 2018. Therefore, apparently if the learned PCIT would like to revise the order passed u/s 143 (3) of the act which was passed on 25th of March 2015, the time limit set under the provisions of Section 263 (2

THE J.K. TRUST BOMBAY,MUMBAI vs. CIT (E), MUMBAI

The appeal of the assessee is allowed

Bench: Shri Joginder Singh & Shri N.K. Pradhanassessment Year: 2012-13 M/S The J. K. Trust Cit (Exemption) Bombay, R. No.617, 6Th Floor, बनाम/ New Hind House, Piramal Chambers, Vs. Narottam Morrjee Marg, Lalbaug, Ballard Estate, Mumbai-400012 Mumbai-400001

2) No order shall be made under sub-section (1) - (a) to revise an order of reassessment made under section 147, or (b) after the expiry of two years from the date of the order sought to be revised. . . . 9. From a reading of sub-section (1) of section 263

MAHARASHTRA AIRPORT DEVELOPMENT,MUMBAI vs. PR CIT 3, MUMBAI

The appeal of the assessee is allowed

Bench: Shri Joginder Singh & Shri Rajesh Kumarassessment Year: 2011-12 M/S Maharashtra Airport Pr. Cit-3, Development Company 612, 6Th Floor, बनाम/ Ltd. Aayakar Bhavan, Vs. 8Th Floor, World Trade M. K. Road, Centre, Tower No.1, Mumbai-400020 Cuffe Parade, Mumbai-400005 ("नधा"रती /Assessee) (राज"व /Revenue) Pan. No. Aadcm9623M

2) No order shall be made under sub-section (1) - (a) to revise an order of reassessment made under section 147, or (b) after the expiry of two years from the date of the order sought to be revised. . . . 9. From a reading of sub-section (1) of section 263

KONARK STRUCTURAL ENGG PRIVATE LIMITED,MUMBAI vs. PRINCIPAL COMMISSIONER OF INCOME TAX-12, MUMBAI

In the result, the appeal of assessee is allowed

Bench: Sri Mahavir Singh, Jm & Sri Manoj Kumar Aggarwal, Am

263 was to be in respect of issues which formed the subject matter of the reassessment, after the original assessment was reopened, the commencement of limitation would be with reference to the order of reassessment. The present case does not fall in that category. 15 Sub-section (2

BARCLAYS BANK PLC,MUMBAI vs. CIT (INTERNATIONAL TAXATION)-RANGE-1, MUMBAI

In the result, the appeal by the assessee stands partly allowed

Bench: Shri Shamim Yahya (Am) & Shri Amarjit Singh (Jm)

reassessment order passed by the Assessing Officer with the prior approval of the Commissioner as provided in sub-section (12) of section 144BA. (14b) The central Government may make a scheme, by notification in the Official Gazette, for the purposes of issuance of directions by the dispute resolution panel, so as to impart greater efficiency, transparency and account ability

JAYANTILAL RAJMAL SETH,MUMBAI vs. DCIT-CC-4(3), MUMBAI, MUMBAI

Bench: Shri Om Prakash Kant () & Shri Raj Kumar Chauhan () Assessment Year: 2018-19 Jayantilal Rajmal Seth, Dcit-Cc-4(3), A-3, Saibaba Shopping Centre, Bkc, Mumbai-400051. Mumbai Central, Vs. Mumbai-400008. Pan No. Agepj 0499 E Appellant Respondent

2 and 3 of the appeal, the assessee, through he assessee, through its Ld. Counsel, has challenged the very validity of the reassessment its Ld. Counsel, has challenged the very validity of the reassessment its Ld. Counsel, has challenged the very validity of the reassessment proceedings undertaken under section 147 of the Act, contending ceedings undertaken under section

SHAILESH ASALRAJ JAIN,MUMBAI vs. PRINCIPAL COMMISSIONER OF INCOME TAX, MUMBAI 20, MUMBAI

In the result, the appeal of the assessee is allowed

Bench: Shri Om Prakash Kant () & Shri Rahul Chaudhary () Assessment Year: 2018-19

reassessment cannot be examined in proceedings arising from section 263 is devoid of merit. It is well- proceedings arising from section 263 is devoid of merit. proceedings arising from section 263 is devoid of merit. settled that a jurisdictional defect strikes at the foundation of settled that a jurisdictional defect strikes at the foundation of settled that a jurisdictional defect

M/S. GLINT INFRAPROJECTS PVT. LTD,MUMBAI vs. PR. COMM OF INCOME TAX OFFICER, , MUMBAI-1

In the result, the appeal filed

Bench: Shri Om Prakash Kant () & Shri Rahul Chaudhary () Assessment Year: 2012-13 M/S Glint Infraprojects Pvt. Pr. Cit-1, Ltd, Room No. 330, 3Rd Floor, 5Th Floor, Sunteck Centre, 37- Vs. Aayakar Bhavan, Maharshi 40, Subhash Road, Vile Parle Karve Road, (East), Mumbai-400020. Mumbai-400057. Pan No. Aadcg 5620 L Appellant Respondent Assessee By : Mr. Rakesh Joshi Revenue By : Mr. Ashok Kumar Kardam, Cit-Dr : Date Of Hearing 02/11/2022 Date Of Pronouncement : 27/12/2022

section 263 of the Act Act issues have been raised, which issues have been raised, which were not subject matter of the reassessment proceeding and therefore two subject matter of the reassessment proceeding and therefore two subject matter of the reassessment proceeding and therefore two years period contemplated under subsection 2

SOMA ENTERPRISE LIMITED,MUMBAI vs. THE PCIT (CENTRAL), MUMBAI-1, MUMBAI

In the result, all the appeals of the assessee are partly allowed

reassessment proceedings, the period of limitation provided for under sub-section (2) of section 263 of the Act would begin

SOMA ENTERPRISE LIMITED,HYDERABAD vs. THE PCIT (CENTRAL), MUMBAI-1, MUMBAI

In the result, all the appeals of the assessee are partly allowed

reassessment proceedings, the period of limitation provided for under sub-section (2) of section 263 of the Act would begin

SOMA ENTERPRISES LIMITED,MUMBAI vs. THE PCIT,(CENTRAL)-MUMBAI-1, MUMBAI

In the result, all the appeals of the assessee are partly allowed

reassessment proceedings, the period of limitation provided for under sub-section (2) of section 263 of the Act would begin

SOMA ENTERPRISE LIMITED,HYDERABAD vs. THE PCIT (CENTRAL), MUMBAI-1, MUMBAI

In the result, all the appeals of the assessee are partly allowed

reassessment proceedings, the period of limitation provided for under sub-section (2) of section 263 of the Act would begin