CORNERSTONE ONDEMAND LIMITED ,MUMBAI vs. ASSISTANT COMMISSIONER OF INCOME TAX (INTERNATIONAL TAXATION )-291)(1), MUMBAI

Bench: Shri Amit Shukla, Jm & Ms Padmavathy S, Am

reassessed has the effect of reducing the loss or converting such loss into income. (3) to (5)**** (6) The under-reported income, for the purposes of this section, shall not include the following, namely:— (a) the amount of income in respect of which the assessee offers an explanation and the Assessing Officer or the Commissioner (Appeals) or the Commissioner

CONNERSTONE ONDEMAND LIMITED,MUMBAI vs. ASSISTANT COMMISSIONER OF INCOME TAX (INTERNATIONAL TAXATION )-2(1)(1), MUMBAI

Bench: Shri Amit Shukla, Jm & Ms Padmavathy S, Am

reassessed has the effect of reducing the loss or converting such loss into income. (3) to (5)**** (6) The under-reported income, for the purposes of this section, shall not include the following, namely:— (a) the amount of income in respect of which the assessee offers an explanation and the Assessing Officer or the Commissioner (Appeals) or the Commissioner

CORNERSTONE ONDEMAND LIMITED ,MUMBAI vs. ACIT(IT)-2(1)(1), MUMBAI

Bench: Shri Amit Shukla, Jm & Ms Padmavathy S, Am

reassessed has the effect of reducing the loss or converting such loss into income. (3) to (5)**** (6) The under-reported income, for the purposes of this section, shall not include the following, namely:— (a) the amount of income in respect of which the assessee offers an explanation and the Assessing Officer or the Commissioner (Appeals) or the Commissioner

CORNERSTONE ONDEMAND LIMITED ,MUMBAI vs. ASSISTANT COMMISSIONER OF INCOME TAX (INTERNATIONAL TAXATION )-2(1)(1), MUMBAI

Bench: Shri Amit Shukla, Jm & Ms Padmavathy S, Am

reassessed has the effect of reducing the loss or converting such loss into income. (3) to (5)**** (6) The under-reported income, for the purposes of this section, shall not include the following, namely:— (a) the amount of income in respect of which the assessee offers an explanation and the Assessing Officer or the Commissioner (Appeals) or the Commissioner

CORNERSTONE ONDEMAND LIMITED ,MUMBAI vs. ASSISTANT COMMISSIONER OF INCOME TAX (INTERNATIONAL TAXATION )-2(1)(1), MUMBAI

Bench: Shri Amit Shukla, Jm & Ms Padmavathy S, Am

reassessed has the effect of reducing the loss or converting such loss into income. (3) to (5)**** (6) The under-reported income, for the purposes of this section, shall not include the following, namely:— (a) the amount of income in respect of which the assessee offers an explanation and the Assessing Officer or the Commissioner (Appeals) or the Commissioner

ACIT 4(2)(1), MUMBAI vs. GLORISHINE IMPEX PRIVATE LIMITED, MUMBAI

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

270A is a self contained code that for the first time segregates “under reporting” and “misreporting" of income and provides a structured, objective regime of penalty. Sub section (1) authorises imposition of penalty where the Assessing Officer, Commissioner (Appeals) or Principal Commissioner or Commissioner, in the course of proceedings, finds that any person has under reported his income. Sub section

M/S G M BUILDERS,MUMBAI vs. PCIT(MUMBAI), OLD-ACIT CIRCLE-22(1), PIRAMAL CHAMBER, MUMBAI

In the result, the appeal by the assessee is allowed

Bench: Shri Amarjit Singhshri Sandeep Singh Karhailm/S. G M Builders, 115, Veena Beena Shipping Center, Turner Road, Bandra West, Mumbai - 400050 Pan – Aaafg1872G ……………. Appellant

270A(2)(b) of the Act, which reads as follows: – “(2) A person shall be considered to have under-reported his income, if— (a) the income assessed is greater than the income determined in the return processed under clause (a) of sub-section (1) of section 143; (b) the income assessed is greater than the maximum amount not chargeable

ALRAMEEZ CONSTRUCTION PVT LTD ,MUMBAI vs. NATIONAL FACELESS APPEAL CENTRE , MUMBAI

In the result grounds of appeal raised by assessee is allowed

Bench: Shri Kuldip Singh & Shri Gagan Goyalm/S Alrameez Construction Pvt. Ltd. 707/708, 7Th Floor, Jms Business Centre Behram Baug, Oshiwara Link Road, Jogeshwari West, Mumbai-400 080 Pan: Aafca8078A ...... Appellant Vs. Cit/Nfac Delhi ..... Respondent

reassessed or recomputed in a preceding order. (11) No addition or disallowance of an amount shall form the basis for imposition of penalty, if such addition or disallowance has formed the basis of imposition of penalty in the case of the person for the same or any other assessment year. (12) The penalty referred to in sub-section (1) shall

DCIT-14(1)(1), MUMBAI vs. HINDUSTAN DIAMOND COMPANY PVT. LTD., MUMBAI

In the result, appeal of the revenue bearing ITA 166/Mum/2024 is dismissed

Bench: Shriamarjit Singh & Shri Anikesh Banerjee

reassessed has the effect income, both are positive; hence, this of reducing the loss or clause is not applicable to the Appellant. converting such loss into income. 5.6. From the above, it is clear that the case of appellant does not fit into any of the above clauses of section 270A

RAMEE HOTELS PRIVATE LIMITED ,MUMBAI vs. DEPUTY COMMISSIONER OF INCOME TAX CENTRAL CIRCLE 6 2 MUMBAI, MUMBAI

In the result, the appeals of the assessee are allowed

270A", "Section 274", "Section 36(1)(iii)", "Section 143(3)" ], "issues": "Whether additions made under section 153C r.w.s 153A for unabated assessment years are valid without incriminating material." } } " } } } Whether reassessment

ARHAM ANMOL PROJECTS PRIVATE LIMITED,VILLAGE VALSHIND, BHIWANDI vs. CIRCLE 1 KALYAN, KALYAN, THANE

In the result, the legal grounds challenging the validity of the assessment are dismissed

Bench: Shri Amit Shukla & Shri Makarand Vasant Mahadeokararham Anmol Projects Dcit Circle 1, Private Limited 2Nd Floor, Rani H. No. 1113, Ground Vs. Mansion, Murbad Floor, Arham Logiparc, Road, Kalyan Nh-3, Nashik Highway, (West), Thane, Village Valshind, Maharashtra – 421 Bhiwandi, Maharashtra – 301 421 302. Pan/Gir No. Aagca9644P (Applicant) (Respondent) Assessee By Shri Subhash Bains, Ld. Ar Revenue By Shri Surendra Mohan, Ld. Dr Date Of Hearing 28.01.2026 Date Of Pronouncement 26.03.2026

270A of the Act, and the order of CIT (Appeal)/NFAC is not correct as per procedure in confirming the same, hence the same is requested to be set aside. 6. On the facts and in the circumstances of the case and in law, the Ld. AO erred in initiating penalty u/s 272A

DEUPTY COMMISSIONER OF INCOME TAX, MUMBAI vs. ANAND RATHI COMMODITIES LIMITED, MUMBAI

section 270A of the Act were also\ninitiated.\n5.\nAggrieved by the reassessment order, the assessee carried\nthe matter in appeal

NILESH SHAMJI BHARANI ,MUMBAI vs. DCIT CENTRAL CIRCLE -4(1), MUMBAI

In the result, the appeals by the assessee for the

reassessment under Section\n148 of the Act. The said approval cannot be granted in a mechanical manner\nas it acts as a linkage between the facts considered and conclusion reached.\nIn the instant case, merely appending the phrase \"Yes\" does not appropriately\nalign with the mandate of Section 151 of the Act as it fails to set out any\ndegree

COLOUR YELLOW PRODUCTIONS PVT LTD,MUMBAI vs. ITO WARD-16(1)(1), MUMBAI

In the result, the appeal of the assessee is dismissed as\nwithdrawn

reassessment, without any adverse finding or\naddition, cannot constitute misreporting of income. Therefore, the case is doesn't\nfalls within the section 270A

NILESH SHAMJI BHARANI ,MUMBAI vs. DCIT, CENTRAL CIRCLE 4(1), MUMBAI

In the result, the appeals by the assessee for the

reassessment under Section\n148 of the Act. The said approval cannot be granted in a mechanical manner\nas it acts as a linkage between the facts considered and conclusion reached.\nIn the instant case, merely appending the phrase \"Yes\" does not appropriately\nalign with the mandate of Section 151 of the Act as it fails to set out any\ndegree

NILESH SHAMJI BHARANI ,MUMBAI vs. DCIT, CENTRAL CIRCLE -4(1), MUMBAI

In the result, the appeals by the assessee for the assessment years

Bench: Shri Sandeep Singh Karhailsmt. Renu Jauhri

270A and section 271AAC(1) were initiated for the assessment year 2017-18, and penalty proceedings under section 271AAB(1A)(b) of the Act were initiated for the assessment year 2018-19. The AO vide separate orders levied penalties under aforesaid sections for the assessment years 2012-13 to 2018-19. The learned CIT(A), vide separate impugned orders, upheld

NILESH SHAMJI BHARANI,MUMBAI vs. DCIT-CC-4(1), MUMBAI

In the result, the appeals by the assessee for the assessment years

Bench: Shri Sandeep Singh Karhailsmt. Renu Jauhri

270A and section 271AAC(1) were initiated for the assessment year 2017-18, and penalty proceedings under section 271AAB(1A)(b) of the Act were initiated for the assessment year 2018-19. The AO vide separate orders levied penalties under aforesaid sections for the assessment years 2012-13 to 2018-19. The learned CIT(A), vide separate impugned orders, upheld

NILESH SHAMJI BHARANI ,MUMBAI vs. DCIT-CENTRAL CIRCLE -4(1), MUMBAI

In the result, the appeals by the assessee for the assessment years

Bench: Shri Sandeep Singh Karhailsmt. Renu Jauhri

270A and section 271AAC(1) were initiated for the assessment year 2017-18, and penalty proceedings under section 271AAB(1A)(b) of the Act were initiated for the assessment year 2018-19. The AO vide separate orders levied penalties under aforesaid sections for the assessment years 2012-13 to 2018-19. The learned CIT(A), vide separate impugned orders, upheld