RAHUL SAUNIK,MUMBAI vs. ITO WARD 24(3)(1), MUMBAI

In the result, the appeal of the assessee is allowed

Bench: Shri Pawan Singh & Shri Makarand Vasant Mahadeokarrahul Saunik Ito Ward - 24(3)(1), 81 Santosh Tower, Mumbai Lokhandwala, 3Rd Cross Vs. Piramal Chamber, Lane, Andheri (W), Mumbai-400 012. Mumbai – 400 053 Pan/Gir No. Aslps2176G (Applicant) (Respondent) Assessee By Shri Jatin Shah, Ld. Ar Revenue By Shri Annavaram Kosuri, Ld. Dr Date Of Hearing 13.04.2026 Date Of Pronouncement 17.04.2026

8,69,241/- levied under section 270A of the Act be deleted. 10. Per contra, the Learned Departmental Representative strongly relied upon the orders of the Assessing Officer and the Learned CIT(A).The Learned DR contended that the Assessing Officer had rightly invoked the provisions of section 270A of the Act, as the assessed income was higher than

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

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

8 ITA 3747, 3751, 3753, 3752 and 5677/Mum/2024 Cornerstone Ondemand Limited this Court in Dharamendra Textile Processors' case (supra), was that according to this Court the effect and difference between section 271(1)(c) and section 276C of the Act was lost sight of in case of Dilip N. Shroff (supra). However, it must be pointed out that in Dharamendra

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

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

8 ITA 3747, 3751, 3753, 3752 and 5677/Mum/2024 Cornerstone Ondemand Limited this Court in Dharamendra Textile Processors' case (supra), was that according to this Court the effect and difference between section 271(1)(c) and section 276C of the Act was lost sight of in case of Dilip N. Shroff (supra). However, it must be pointed out that in Dharamendra

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

8 ITA 3747, 3751, 3753, 3752 and 5677/Mum/2024 Cornerstone Ondemand Limited this Court in Dharamendra Textile Processors' case (supra), was that according to this Court the effect and difference between section 271(1)(c) and section 276C of the Act was lost sight of in case of Dilip N. Shroff (supra). However, it must be pointed out that in Dharamendra

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

8 ITA 3747, 3751, 3753, 3752 and 5677/Mum/2024 Cornerstone Ondemand Limited this Court in Dharamendra Textile Processors' case (supra), was that according to this Court the effect and difference between section 271(1)(c) and section 276C of the Act was lost sight of in case of Dilip N. Shroff (supra). However, it must be pointed out that in Dharamendra

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

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

8 ITA 3747, 3751, 3753, 3752 and 5677/Mum/2024 Cornerstone Ondemand Limited this Court in Dharamendra Textile Processors' case (supra), was that according to this Court the effect and difference between section 271(1)(c) and section 276C of the Act was lost sight of in case of Dilip N. Shroff (supra). However, it must be pointed out that in Dharamendra

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

reassessed has the effect of reducing the loss or converting such loss into income.” 13. Therefore, as per the learned PCIT, since in the present case, the assessee did not file its original return of income and the income assessed 8 vide order passed under section 143(3) read with section 147 of the Act is greater than the maximum

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

GRAMEEN IMPACT INVESTMENT INDIA PVT LTD,MUMBAI vs. NATIONAL -E ASSESSMENT CENTRE , DELHI

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

Bench: Shri Aby T Varkey () & Shri Om Prakash Kant () Assessment Year: 2018-19 Grameen Impact Investments India National-E-Assessment Pvt. Ltd., Centre, 306, 3Rd Floor, A Wing, Devroop Vs. New Delhi-110 001. Building, 36, Turner Road, Bandra West, Mumbai-400050. Pan No. Aaacr 9005 R Appellant Respondent Assessee By : Mr. K. Shivaram & Mr. Shashi Bekal, Ars : Revenue By Mr. Satyapal Kumar, Dr Date Of Hearing : 19/12/2022 Assessment Year: 2015-16 & Assessment Year: 2016-17 Grameen Impact Investments India Dy. Cit-13(3)(1), Pvt. Ltd., Room No. 229, Aayakar 306, 3Rd Floor, A Wing, Devroop Vs. Bhavan, M.K. Road, Building, 36, Turner Road, Bandra Mumbai-400050. West, Mumbai-400050. Pan No. Aaacr 9005 R Appellant Respondent

reassessment made pursuant to an audit note. The pursuant to an audit note. The claim was disallowed on the ground that the payment of claim was disallowed on the ground that the payment of claim was disallowed on the ground that the payment of gratuity to the director was an exgratia payment; that at gratuity to the director

RITESH SINGH ACIT CIRCLE 3 3 1 MUMBAI, MUMBAI vs. TREND ELECTRONICS LIMITED, MUMBAI

In the result, all result, all the three appeals are allowed for three appeals are allowed for statistical purpose statistical purpose

Bench: Shri Om Prakash Kant () & Shri Raj Kumar Chauhan ()

270A of the Income-tax Act, 1961 (in short the ‘Act’) (in short the ‘Act’) for AY 2018-19. 2. The core issue The core issue arising in these appeals is narrow and legal arising in these appeals is narrow and legal in character, namely, in character, namely, whether the learned CIT(A) CIT(A) was justified in not adjudicating

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

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

DARBARI INDUSTRIES,MUMBAI vs. ASSISTANT COMMISSIONER OF INCOME TAX - 41(1)(1), MUMBAI

In the result, the appeal of the assessee is allowed on legal ground, and the reassessment order is quashed

Bench: Shri Pawan Singh & Shri Makarand Vasant Mahadeokardarbari Industries Acit - 41(1)(1) 110, Champaklal 8Th Floor, Kautilya Udyog Bhavan, Sion Vs. Bhavan, C-41-43, Koliwada Road, Sion Avenue 3, Near Videsh (West), Mumbai – Bhavan, G-Block, Bkc, 400 022. Bandra Kurla Complex, Bandra East, Mumbai- 400 051 Pan/Gir No. Aaafd3277E (Applicant) (Respondent) Assessee By Shri Bhupendra Shah, Ld. Ar Revenue By Shri Annavaram Kosuri, Ld. Dr Date Of Hearing 16.04.2026 Date Of Pronouncement 21.04.2026

270A were also initiated. 5. Aggrieved, the assessee preferred appeal before the learned CIT(A). In the statement of facts, the assessee reiterated that it had furnished all necessary evidences to establish the genuineness of loans and had also sought cross-examination of persons whose statements were relied upon. It was further contended that the reassessment proceedings were invalid

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

In the result, the appeals by the assessee for the

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

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

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