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

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

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

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

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

reassessment has the effect of reducing the loss or converting a loss into positive income.\n\n10. In the present case, it is common ground that for the year under consideration the tax liability determined upon processing the return under section 143(1)(a) and the tax liability determined upon completion of assessment under section 143(3) are both

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

6) of the Act, which does not justify levy of penalty in the present case. The learned AR also relied upon various judicial pronouncements to support its submission that revisionary proceedings under section 263 of the Act cannot be initiated to direct initiation of penalty proceedings. 11. On the other hand, the learned Departmental Representative vehemently relied upon the impugned

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

6) or sub-section (7), where under- reported income is in consequence of any misreporting thereof by any person, the penalty referred to in sub-section (1) shall be equal to two hundred per cent of the amount of tax payable on under-reported income. (9) The cases of misreporting of income referred to in sub-section (8) 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(2) and thus it cannot be called that

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

reassessments u/s 153C for the assessment years\nfor which he issued notice u/s 153C of the Act, but in those assessments, he did\nnot make any addition on the basis of documents for which satisfaction was\nrecorded while initiating proceedings u/s 153C of the Act. For ready reference,\nthe addition made for disallowance of interest expenditure on lease hold land

ADDL CIT R G 7(1), MUMBAI vs. NOVARTIS INDIA LTD ( FORMERLY KNOWN AS HINDUSTAN CIBA GIEGY LTD. ), MUMBAI

Bench: Shri Amit Shukla, Hon'Ble & Shri S. Rifaur Rahman, Hon'Blem/S. Novartis India Limited V. Asst. Commissioner Of Income –Tax - 7(2)(2) {Earlier Addl. Commissioner Of Income –Tax – 7(1)} 6Th& 7Th Floor 1St Floor, Aayakar Bhavan Inspire Bkc M.K. Road, Mumbai - 400020 “G” Block, Bkc Main Road Bandra Kurla Complex, Bandra (E) Mumbai – 400051 Pan: Aaach2914F (Appellant) (Respondent) Addl. Commissioner Of Income –Tax – 7(1) V. M/S. Novartis India Limited Room No. 622, Aayakar Bhavan {Earlier Known As Hindustan Ciba Giegy Ltd.,} Sandoz House, Dr. A.B. Road M.K. Road, Mumbai - 400020 Worli, Mumbai – 400018 Pan: Aaach2914F (Appellant) (Respondent) Co No.190/Mum/2011 [Arising Out Of Ita No.6772/Mum/2010 (A.Y. 2002-03)] M/S. Novartis India Limited V. Addl. Commissioner Of Income –Tax – 7(1)} Room No. 622, Aayakar Bhavan {Earlier Known As Hindustan Ciba Giegy Ltd.,} Sandoz House, Dr. A.B. Road M.K. Road, Mumbai - 400020 Worli, Mumbai – 400018 Pan: Aaach2914F (Appellant) (Respondent)

270A, section 271, section 271A,section 271J or section 272A; or (b) an order passed by an Assessing Officer under clause (c) of section 158BC, in respect of search initiated under section 132 or books of account, other documents or any assets requisitioned under section 132A, after the 30th day of June, 1995, but before the 1st day of January

HARSHA BOJARAO DEVRAJ ,MUMBAI vs. INCOME TAX OFFICER WARD 41(3)(1), MUMBAI

Bench: SHRI RAHUL CHAUDHARY, JUDICIAL MEMBER SHRI BIJAYANANDA PRUSETH (Accountant Member)

reassessment proceedings initiated under Section 147 of the Act, which are void ab initio and liable to be quashed, as the Assessing Officer failed to comply with the mandatory statutory requirements for recording the requisite satisfaction of the Principal Commissioner of Income Tax before issuing notice under Section 148 of the Act. GROUND NO. 2: ADDITION

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

In the result, the appeals of the assessee are allowed

Bench: Shri Om Prakash Kant & Ms. Kavitha Rajagopal

reassessments u/s 153C for the assessment assessment years for which he issued notice u/s 153C of the Act for which he issued notice u/s 153C of the Act, but in those assessment those assessments, he did not make any addition on the basis of not make any addition on the basis of documents for which satisfaction was which satisfaction

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

In the result, the appeals of the assessee are allowed

Bench: Shri Om Prakash Kant & Ms. Kavitha Rajagopal

reassessments u/s 153C for the assessment assessment years for which he issued notice u/s 153C of the Act for which he issued notice u/s 153C of the Act, but in those assessment those assessments, he did not make any addition on the basis of not make any addition on the basis of documents for which satisfaction was which satisfaction

RAMEE HOTELS PRIVATE LIMITED ,MUMBAI vs. ASST. COMMISSIONER OF INCOME TAX CENTRAL CIRCLE , MUMBAI

In the result, the appeals of the assessee are allowed

Bench: Shri Om Prakash Kant & Ms. Kavitha Rajagopal

reassessments u/s 153C for the assessment assessment years for which he issued notice u/s 153C of the Act for which he issued notice u/s 153C of the Act, but in those assessment those assessments, he did not make any addition on the basis of not make any addition on the basis of documents for which satisfaction was which satisfaction

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

In the result, the appeals of the assessee are allowed

Bench: Shri Om Prakash Kant & Ms. Kavitha Rajagopal

reassessments u/s 153C for the assessment assessment years for which he issued notice u/s 153C of the Act for which he issued notice u/s 153C of the Act, but in those assessment those assessments, he did not make any addition on the basis of not make any addition on the basis of documents for which satisfaction was which satisfaction

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

RATAN RAJMAL MEHTA ,MUMBAI vs. INCOME TAX OFFICER WARD 23(3)(1), MUMBAI

Bench: Smt. Beena Pillai, Jm & Shri Arun Khodpia, Am Ratan Rajmal Mehta Income Tax Officer, Ward 5, Harihar Niwas, Besant Road, 22(3)(1), Mumbai Vs. Santacruz (West), Mumbai – 400054. Pan/Gir No. Bdipm2252G (Appellant) : (Respondent) Assessee By : Shri Ketan Vajani (Virtually) Respondent By : Shri Annavaran Kasuri, Sr. Ar. Date Of Hearing : 01.09.2025 Date Of Pronouncement : 03.09.2025 O R D E R Per Arun Khodpia, Am:

reassessment proceedings would not have been initiated the assessee would not have declared the correct income, thus, had under reported her income, accordingly, liable to be penalized under the provisions of section 270A of the Act. Penalty of Rs. 175440/- imposed on the assessee in terms of Clause (a) of subsection (2) of section 270A of the Act that

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