SHYAM KUMAR SADASHIVAN PILLAI,MUMBAI vs. INCOME TAX OFFICER, CIRCLE 27(3)(1), NAVI MUMBAI

In the result, the appeal is allowed

Bench: Ms Padmavathy S, Am & Shri Raj Kumar Chauhan, Jm

271F, section 271FA, section 271FAB, section 271FB, section 271G, section 271GA, section 271GB, section 271H, section 271-I, section 271J, clause (c) or clause (d) of sub-section (1) or sub-section (2) of section 272A, sub-section (1) of section 272AA or section 272B or sub-section (1) or sub-section (1A) of section 272BB or sub-section

RAKESH JAIN AS THE LEGAL HEIR OF BHAWARLAL SHRILAL JAIN ,MUMBAI vs. ITO WARD-1 PALGHAR , MUMBAI

In the result, all four appeals of the assessee stand allowed

Bench: Shri Saktijit Dey & Shri Makarand Vasant Mahadeokar1. Ita No. 7674/Mum/2025 (Assessment Year: 2013-14) 2. Ita No. 7675/Mum/2025 (Assessment Year: 2013-14) 3. Ita No. 7676/Mum/2025 (Assessment Year: 2013-14) & 4. Ita No. 7677/Mum/2025 (Assessment Year: 2013-14) Rakesh Jain As Legal Ito Ward-1, Heir Of Bhawarlal Shrilal Bidco Road, Jain, Vs. Palghar, Shop 5, Vaibhav Complex, Maharashtra – Irani Road, Malyan, 401 404 Dahanu Road, Thane – 401602, Maharashtra. Pan/Gir No. Abjpj5270F (Applicant) (Respondent) Assessee By Shri Suchek Anchaliya, Ld. Ar Revenue By Shri Annavaram Kosuri, Ld. Dr Date Of Hearing 05.02.2026 Date Of Pronouncement 09.02.2026 आदेश / Order Per Makarand Vasant Mahadeokar, Am: These Four Appeals Are Directed Against Separate Orders Passed By The Commissioner Of Income-Tax (Appeals), National Faceless Appeal Centre, Delhi [Hereinafter Referred To As “Cit(A)”], All Dated 26.09.2025 & 18.09.2025, For Assessment Year 2013– 14. Since The Issues Involved In All The Appeals Arise Out Of The Same Set Of Facts & Relate To Proceedings Initiated In The Name Of Late Shri Bhawarlal Shrilal Jain, These Appeals Were Heard Together & Are Being Disposed Of By This Common Order For The Sake Of Convenience & Brevity.

reassessment proceedings void ab initio. The defect goes to the root of the matter and is not a mere procedural irregularity capable of being cured under section 292B of the Act. The Assessing Officer having failed to initiate proceedings in the name of the legal representative in terms of section 159 of the Act, the assessment order dated 28.09.2021 passed

RAKESH JAIN AS THE LEGAL HEIR OF BHAWARLAL SHRILAL JAIN ,MUMBAI vs. ITO WARD 1, PALGHAR , THANE

In the result, all four appeals of the assessee stand allowed

Bench: Shri Saktijit Dey & Shri Makarand Vasant Mahadeokar1. Ita No. 7674/Mum/2025 (Assessment Year: 2013-14) 2. Ita No. 7675/Mum/2025 (Assessment Year: 2013-14) 3. Ita No. 7676/Mum/2025 (Assessment Year: 2013-14) & 4. Ita No. 7677/Mum/2025 (Assessment Year: 2013-14) Rakesh Jain As Legal Ito Ward-1, Heir Of Bhawarlal Shrilal Bidco Road, Jain, Vs. Palghar, Shop 5, Vaibhav Complex, Maharashtra – Irani Road, Malyan, 401 404 Dahanu Road, Thane – 401602, Maharashtra. Pan/Gir No. Abjpj5270F (Applicant) (Respondent) Assessee By Shri Suchek Anchaliya, Ld. Ar Revenue By Shri Annavaram Kosuri, Ld. Dr Date Of Hearing 05.02.2026 Date Of Pronouncement 09.02.2026 आदेश / Order Per Makarand Vasant Mahadeokar, Am: These Four Appeals Are Directed Against Separate Orders Passed By The Commissioner Of Income-Tax (Appeals), National Faceless Appeal Centre, Delhi [Hereinafter Referred To As “Cit(A)”], All Dated 26.09.2025 & 18.09.2025, For Assessment Year 2013– 14. Since The Issues Involved In All The Appeals Arise Out Of The Same Set Of Facts & Relate To Proceedings Initiated In The Name Of Late Shri Bhawarlal Shrilal Jain, These Appeals Were Heard Together & Are Being Disposed Of By This Common Order For The Sake Of Convenience & Brevity.

reassessment proceedings void ab initio. The defect goes to the root of the matter and is not a mere procedural irregularity capable of being cured under section 292B of the Act. The Assessing Officer having failed to initiate proceedings in the name of the legal representative in terms of section 159 of the Act, the assessment order dated 28.09.2021 passed

RAKESH JAIN AS THE LEGAL HEIR OF BHAWARLAL SHRILAL JAIN,MUMBAI vs. ITO WARD 1 PALGHAR, THANE

In the result, all four appeals of the assessee stand allowed

Bench: Shri Saktijit Dey & Shri Makarand Vasant Mahadeokar1. Ita No. 7674/Mum/2025 (Assessment Year: 2013-14) 2. Ita No. 7675/Mum/2025 (Assessment Year: 2013-14) 3. Ita No. 7676/Mum/2025 (Assessment Year: 2013-14) & 4. Ita No. 7677/Mum/2025 (Assessment Year: 2013-14) Rakesh Jain As Legal Ito Ward-1, Heir Of Bhawarlal Shrilal Bidco Road, Jain, Vs. Palghar, Shop 5, Vaibhav Complex, Maharashtra – Irani Road, Malyan, 401 404 Dahanu Road, Thane – 401602, Maharashtra. Pan/Gir No. Abjpj5270F (Applicant) (Respondent) Assessee By Shri Suchek Anchaliya, Ld. Ar Revenue By Shri Annavaram Kosuri, Ld. Dr Date Of Hearing 05.02.2026 Date Of Pronouncement 09.02.2026 आदेश / Order Per Makarand Vasant Mahadeokar, Am: These Four Appeals Are Directed Against Separate Orders Passed By The Commissioner Of Income-Tax (Appeals), National Faceless Appeal Centre, Delhi [Hereinafter Referred To As “Cit(A)”], All Dated 26.09.2025 & 18.09.2025, For Assessment Year 2013– 14. Since The Issues Involved In All The Appeals Arise Out Of The Same Set Of Facts & Relate To Proceedings Initiated In The Name Of Late Shri Bhawarlal Shrilal Jain, These Appeals Were Heard Together & Are Being Disposed Of By This Common Order For The Sake Of Convenience & Brevity.

reassessment proceedings void ab initio. The defect goes to the root of the matter and is not a mere procedural irregularity capable of being cured under section 292B of the Act. The Assessing Officer having failed to initiate proceedings in the name of the legal representative in terms of section 159 of the Act, the assessment order dated 28.09.2021 passed

RAKESH JAIN AS THE LEGAL HEIR OF BHAWARLAL SHRILAL JAIN ,MUMBAI vs. ITO WARD -1 PALGHAR , THANE

In the result, all four appeals of the assessee stand allowed

Bench: Shri Saktijit Dey & Shri Makarand Vasant Mahadeokar1. Ita No. 7674/Mum/2025 (Assessment Year: 2013-14) 2. Ita No. 7675/Mum/2025 (Assessment Year: 2013-14) 3. Ita No. 7676/Mum/2025 (Assessment Year: 2013-14) & 4. Ita No. 7677/Mum/2025 (Assessment Year: 2013-14) Rakesh Jain As Legal Ito Ward-1, Heir Of Bhawarlal Shrilal Bidco Road, Jain, Vs. Palghar, Shop 5, Vaibhav Complex, Maharashtra – Irani Road, Malyan, 401 404 Dahanu Road, Thane – 401602, Maharashtra. Pan/Gir No. Abjpj5270F (Applicant) (Respondent) Assessee By Shri Suchek Anchaliya, Ld. Ar Revenue By Shri Annavaram Kosuri, Ld. Dr Date Of Hearing 05.02.2026 Date Of Pronouncement 09.02.2026 आदेश / Order Per Makarand Vasant Mahadeokar, Am: These Four Appeals Are Directed Against Separate Orders Passed By The Commissioner Of Income-Tax (Appeals), National Faceless Appeal Centre, Delhi [Hereinafter Referred To As “Cit(A)”], All Dated 26.09.2025 & 18.09.2025, For Assessment Year 2013– 14. Since The Issues Involved In All The Appeals Arise Out Of The Same Set Of Facts & Relate To Proceedings Initiated In The Name Of Late Shri Bhawarlal Shrilal Jain, These Appeals Were Heard Together & Are Being Disposed Of By This Common Order For The Sake Of Convenience & Brevity.

reassessment proceedings void ab initio. The defect goes to the root of the matter and is not a mere procedural irregularity capable of being cured under section 292B of the Act. The Assessing Officer having failed to initiate proceedings in the name of the legal representative in terms of section 159 of the Act, the assessment order dated 28.09.2021 passed

APTIVAA MIDDLE EAST FZE,DUBAI, UNITED ARAB EMIRATES vs. DEPUTY COMMISSIONER OF INCOME TAX, CIRCLE 1(1)(2), INTERNATIONAL TAXATION, MUMBAI, MAHARASTRA

In the result of the file by the assessee stands partly allowed as indicated hereinabove

Bench: Smt. Beena Pillai () & Ms. Padmavathy S. ()

271F of the Act and section 271(1)(c) of the Act for the subject year as the same is bad in law.” Brief facts of the case are as under: 2. M/s. Aptivaa Middle East FZE Dubai, UAE (hereinafter referred to the assessee) is a 100% subsidiary of M/s. Aptivaa Consulting Solutions Pvt. Ltd (hereinafter referred to as Aptivaa

APTIVAA MIDDLE EAST FZE,DUBAI, UNITED ARAB EMIRATES vs. DEPUTY COMMISSIONER OF INCOME TAX, CIRCLE 1(1)(2), INTERNATIONAL TAXATION, MUMBAI, MAHARASTRA

In the result of the file by the assessee stands partly allowed as indicated hereinabove

Bench: Smt. Beena Pillai () & Ms. Padmavathy S. ()

271F of the Act and section 271(1)(c) of the Act for the subject year as the same is bad in law.” Brief facts of the case are as under: 2. M/s. Aptivaa Middle East FZE Dubai, UAE (hereinafter referred to the assessee) is a 100% subsidiary of M/s. Aptivaa Consulting Solutions Pvt. Ltd (hereinafter referred to as Aptivaa

APTIVAA MIDDLE EAST FZE,MUMBAI vs. DEPUTY COMMISSION OF INCOME TAX, CIRCLE 1(1)(2), INTERNATIONAL TAXATION, MUMBAI, MUMBAI

In the result of the file by the assessee stands partly allowed as indicated hereinabove

Bench: Smt. Beena Pillai () & Ms. Padmavathy S. ()

271F of the Act and section 271(1)(c) of the Act for the subject year as the same is bad in law.” Brief facts of the case are as under: 2. M/s. Aptivaa Middle East FZE Dubai, UAE (hereinafter referred to the assessee) is a 100% subsidiary of M/s. Aptivaa Consulting Solutions Pvt. Ltd (hereinafter referred to as Aptivaa

M/S MUMBADEVI VEYHICLES,MUMBAI vs. ITO WARD 41(4)(2), MUMBAI

In the result the appeal of the assessee is allowed

Bench: Shri Saktijit Dey & Shri Makarand Vasant Mahadeokarm/S. Mumbadevi Ito Ward 41(4)(2), Veyhicles Room No. 854B, 8Th Shop No. 18, Suyash Vs. Floor, Kautilya Shopping Centre, Nnp, A. Bhavan, Bkc, K. Vaidya Marg, Goregaon Bandra (East), (E), Mumbai-400 065 Mumbai-400 051 Pan/Gir No. Aaofm0851F (Applicant) (Respondent) Assessee By Ms. Dinkle Hariya & Ms. Sruti Kalyanikar, Ld. Ars Revenue By Shri Annavaram Kosuri, Ld. Dr Date Of Hearing 19.02.2026 Date Of Pronouncement 24.02.2026

reassessment, the Assessing Officer initiated penalty proceedings under section 271(1)(c) of the Act for alleged concealment of income / furnishing of inaccurate particulars of income. Separate penalty proceedings under section 271F

PALLAVI KAMAL SHAH,MUMBAI vs. INCOME TAX OFFICER, INCOME TAX DEPARTMENT

In the result, appeal of the assessee is dismissed

Bench: Shri Pawan Singh& Smt. Renu Jauhri(Physical Hearing) Pallavi Kamal Shah Ito, Ward-30(1)(1), Mumbai A-601, Bhimsen Chs Ltd., Marve Vs Maharashtra-400051. Road, Malad West, Maharashtra - 400064. [Pan: Avops7447Q] Appellant / Assessee Respondent / Revenue

reassessment on 24th September 2021. V. LIBERTY: The appellant craves leave to add, alter, delete or modify all or any of the above ground at the time of hearing.” 2. Brief facts of the case are that assessee has not filed return of income, the assessing officer has information that assessee traded into share transaction aggregating of Rs. 4.48 crore

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

APTIVAA MIDDLE EAST FZE,DUBAI vs. DEPUTY COMMISSIONER OF INCOME TAX, CIRCLE 1(1)(2), INTERNATIONAL TAXATION , MUMBAI

The appeal of the assessee is allowed

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

271F of the Act and section 271(1)(e) of the Act for the subject year as the same is bad in law.” 2. The assessee is a non-resident company incorporated as per the regulations of UAE and is registered with the RAK Investment Authority Free Zone, UAE on 01.04.2010. The assessee is the wholly owned subsidiary

NARENDRA KHIMJI SAVLA,MUMBAI vs. ITO WARD 6(1)(1), MUMBAI, MUMBAI

In the result, the appeal is allowed for statistical\npurposes

reassessment proceedings under section\n148 which is bad in law and required to be quashed.\n6. On the facts and circumstances of the case and in law the Ld CIT(A) erred\nin confirming addition of Rs.1,37,85,000 on account of alleged\nborrowing of cash loan without considering the fact that no material was\nprovided to appellant

SUSHIL RAJBANSHI GUPTA,BHANDUP WEST MUMBAI vs. WARD 41(4)(4), KAUTILYA BHAVAN BKC MUMBAI

Bench: SHRI OM PRAKASH KANT, ACCOUNTANT MEMBER SHRI RAHUL CHAUDHARY (Judicial Member)

reassessment as set in section 147 to 151A of the Act. The order under section 147 is therefore illegal and without jurisdiction. 2. On the facts and circumstances of the case and in law, the notice under section 148 is bad in law and without jurisdiction as the jurisdictional conditions of section 147 to 151 have not been complied with

JANKALYAN NAGARI SAHAKARI PATSANSTHA MAR SHAHAPUR,SHAHAPUR vs. DCIT CIRCLE 1, KALYAN

In the result, the appeal of the assessee is allowed for\nstatistical purposes

reassessment by order\ndated 13.03.2024 passed under section 147 read with section\n144B of the Act. While accepting the returned income as the\nstarting point, the Assessing Officer made the following additions\nand disallowances:\nBad debts: Rs. 6,00,000/-\nDisallowance of provisions: Rs. 25,23,174/-\nDeduction under section 80P(2)(c):Rs. 35,205/-\n5. Accordingly, the total

SEEMA HEERA,MUMBAI vs. ASSISTANT COMMISSIONER OF INCOME TAX (OSD) (IT) - 2(2)(1), MUMBAI

In the result appeal of the assessee is allowed

Bench: Shri Pavan Kumar Gadale, Judicialmember & Shri Girish Agrawalassessment Year: 2010-11

271F of the Act dated 26.12.2017. The Appellant prays that the penalty proceedings u/s 274 read with section 271 of the Act be dropped. 8. The Ld. CIT (A) has erred upholding the action of the Ld. AO in the levying interest u/s 234A, 234B and 234C of the Act.” 3. Brief facts of the case are that assessee

PARIN ENGINEERS,MUMBAI vs. WARD 27(2)(1), MUMBAI, MUMBAI

In the result, the appeal is allowed

sections": [ "250", "147", "148", "142(1)", "271(1)(C)", "271F" ], "issues": "Whether reassessment proceedings were legally valid when the firm

MOHAMED IMRAN MOHAMED SIDDIQUE KHAN,MUMBAI vs. ITO WARD 26(2)(3), MUMBAI

The appeal is partly allowed in above terms

sections": [ "Sec. 147", "Sec. 148", "Sec. 131", "Sec. 142", "Sec. 133(6)", "Sec. 274", "Sec. 271", "Sec. 144", "Sec. 68", "Sec. 271(1)(C)", "Sec. 271F", "Sec. 250", "Sec. 54" ], "issues": "Whether the reassessment