INCOME TAX OFFICER (IT)-3(2)(1), KAUTILYA BHAWAN vs. SHAPOORJI PALLONJI MISTRY, MUMBAI

In the result, appeal filed by the Revenue is dismissed

Bench: Shri Amit Shukla & Shri Girish Agrawal

reassess under unamended section 147, (b) issuance of notice under unamended section 148, (c) in accordance with time limit in terms of unamended section 149 and (d) sanction under unamended section 151 of the Act. 3 ITA Nos. 3674/Mum/2025 and ors. Shapoorji Pallonji Mistry AYs 2015-16 and 2016-17 5. Whether section 3(1

ITO(IT)-3(2)(1), MUMBAI vs. SHAPOORJI PALLONJI MISTRY, MUMBAI

Bench: Shri Amit Shukla & Shri Girish Agrawal

reassess under unamended section 147, (b) issuance of notice under unamended section 148, (c) in accordance with time limit in terms of unamended section 149 and (d) sanction under unamended section 151 of the Act. 3 ITA Nos.3674/Mum/2025 and ors. Shapoorji Pallonji Mistry AYs 2015-16 and 2016-17 5. Whether section 3(1

DCIT 3.2.1, MUMBAI vs. THE NEW INDIA ASSURANCE CO LIMITED, MUMBAI

1. The CIT(A) erred in confirming the action of the AO by\ntreating the reassessment order passed under section\n143(3

DCIT 3.2.1, MUMBAI vs. THE NEW INDIA ASSURANCE CO LIMITED, MUMBAI

1. The CIT(A) erred in confirming the action of the AO by\ntreating the reassessment order passed under section\n143(3

DCIT CEN CIR 8(4), MUMBAI vs. SAVITA OIL TECHNOLOGIES LTD, MUMBAI

Appeal is allowed

Bench: Shri Mahavir Singh & Shri Ramit Kocharआयकर अपीऱ सं./I.T.A. No.7620/Mum/2016 (नििाारण वर्ा / Assessment Year : 2010-11)

3) of section 143 or section 144 or] section 147 or section 154 or section 155 or section 250 or section 254 or section 260 or section 262 or section 263 or section 264 or an order of the Settlement Commission under sub- section (4) of section 245D, the amount on which interest was payable under sub-section (1

THE NEW INDIA ASSURANCE CO. LTD,MUMBAI vs. ASSISTANT COMMISSIONER OF INCOME TAX , INCOME TAX OFFICER, NFAC, MUMBAI

Accordingly, in terms of the aforesaid, Ground No. 3 to\n7 raised by the Assessee pertaining to merits of such\nadditions/disallowances are dismissed as having been rendered\ninfructuous

Bench: "CLEAN_TEXT": "IN THE INCOME TAX APPELLATE TRIBUNAL\n\"I\" BENCH, MUMBAI\n\nSHRI VIKRAM SINGH YADAV , ACCOUNTANT MEMBER\nSHRI RAHUL CHAUDHARY (Judicial Member)

1.\nThe CIT(A) erred in confirming the action of the AO by\ntreating the reassessment order passed under section\n143(3

THE NEW INDIA ASSURANCE CO. LTD ,MUMBAI vs. DEPUTY COMMISSIONER OF INCOME TAX, CIRCLE -3(2)(2), MUMBAI

1. The CIT(A) erred in confirming the action of the AO by\ntreating the reassessment order passed under section\n143(3

MAHARASHTRA STATE ELECTRICITY TRANSMISSION COMPANY LTD.,,MUMBAI vs. THE INCOME TAX OFFICER, WARD-14(2)(3), MUMBAI

In the result, the appeal of the assessee is al

Bench: Shri Vikas Awasthy () & Shri Om Prakash Kant () Assessment Year: 2011-12 Maharashtra State Electricity Income-Tax Officer, Ward Transmission Company Ltd., 14(2)(3), Plot No. C-19 E Block, Vs. Aayakar Bhavan, Maharshi Prakashganga, Bandra-Kurla Karve Road, Complex, Bandra (East), Mumbai-400020. Mumbai-400051. Pan No. Aaecm 2936 N Appellant Respondent Assessee By : Mr. Ketan Ved, Ar Revenue By : Mr. Harishankar Lal, Dr : Date Of Hearing 15/11/2022 Date Of Pronouncement : 29/12/2022

1 are hereby dismissed.” ” 3. Before us, the assessee has only challenged validity of the us, the assessee has only challenged validity of the us, the assessee has only challenged validity of the reassessment. 4. Before us the Before us the Ld. counsel of the assessee submitted that of the assessee submitted that reasons recorded by the Assessing Officer

NAVNIDHI STEEL AND ENGG CO. P.LTD,MUMBAI vs. DCIT 5(2)(1), MUMBAI

The appeal of the assessee is dismissed

Bench: Shri Joginder Singh, Assessment Year: 2007-08

reassessment proceedings even when intimation under section 143(1) had been issued. 19. Inevitable conclusion is that High Court has wrongly applied Adani Exports case (supra) which has no application to the case on the facts in view of the conceptual difference between section 143(1) and section 143(3

DCIT 3.2.1, MUMBAI vs. THE NEW INDIA ASSURANCE CO LIMITED, MUMBAI

Accordingly, in terms of the aforesaid, Ground No. 3 to\n7 raised by the Assessee pertaining to merits of such\nadditions/disallowances are dismissed as having been rendered\ninfructuous

1. The CIT(A) erred in confirming the action of the AO by\ntreating the reassessment order passed under section\n143(3

MANOHAR MANAK ALLOYS P.LTD,MUMBAI vs. ACIT 4(2), MUMBAI

Appeal is allowed

reassessment‘. Section 143, as a whole, is a provision regarding assessment. The modalities and procedure for assessment have been provided for in sub- section (1), which is different from the procedure under sub- section (2) read with sub-section (3

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

3) in the present case allowed the deduction which was claimed under Section 36(1)(vii), Section 36(1)(viia) and in respect of foreign exchange rate difference. Neither in the first order of reassessment

DCIT 10(2), MUMBAI vs. CAPAGEMINI CONSULTING INDIA P. LTD ( NOW KNOWN AS CAPGEMINI INDIA P.LTD, MUMBAI

The appeal of the revenue stands dismissed and the cross-objection filed by the assessee also dismissed

Bench: Shri Amit Shukla, Jm & Shri Rajesh Kumar, Am

1) The learned Commissioner of Income-tax (Appeals) erred in holding that the Assessing Officer correctly assumed jurisdiction u/s.147 when the conditions precedent were not satisfied. 2) The learned Commissioner of Income-tax (Appeals) failed to consider that the Assessing Officer did not have "reason to believe" that income chargeable to tax had escaped Assessment. 3) The learned Commissioner

CAPGEMINI CONSULTING INIDA P.LTD ( NOW KNOWN AS CAPGEMINI INDIA P.LTD),MUMBAI vs. DCIT 10(2), MUMBAI

The appeal of the revenue stands dismissed and the cross-objection filed by the assessee also dismissed

Bench: Shri Amit Shukla, Jm & Shri Rajesh Kumar, Am

1) The learned Commissioner of Income-tax (Appeals) erred in holding that the Assessing Officer correctly assumed jurisdiction u/s.147 when the conditions precedent were not satisfied. 2) The learned Commissioner of Income-tax (Appeals) failed to consider that the Assessing Officer did not have "reason to believe" that income chargeable to tax had escaped Assessment. 3) The learned Commissioner

ITO (3) 2(2), MUMBAI vs. R.K. EDUCATIONAL FOUNDATION, MUMBAI

The appeal of the revenue stands dismissed and the cross-objection filed by the assessee also dismissed

Bench: Shri Amit Shukla, Jm & Shri Rajesh Kumar, Am

1) The learned Commissioner of Income-tax (Appeals) erred in holding that the Assessing Officer correctly assumed jurisdiction u/s.147 when the conditions precedent were not satisfied. 2) The learned Commissioner of Income-tax (Appeals) failed to consider that the Assessing Officer did not have "reason to believe" that income chargeable to tax had escaped Assessment. 3) The learned Commissioner

M/S THE MAHARASHTRA STATE CO. OP BANK LTD.,MUMBAI vs. ITO-1(3)(3), MUMBAI

In the result, the appeal of the In the result, the appeal of the assessee is allowed partly assessee is allowed partly whereas the appeal of the Revenue is dismissed

Bench: Shri Om Prakash Kant () & Shri Sandeep Singh Karhail () Assessment Year: 2013-14

1) and (2) shall apply apply apply to to to the the the following following following classes classes classes of of of assessments, assessments, assessments, reassessments and recomputation which may, subject reassessments and recomputation which may, subject reassessments and recomputation which may, subject to the provisions of sub to the provisions of sub-sections (3

DY CIT-1(3)(2), MUMBAI vs. MAHARASHTRA STATE CO-OPERATIVE BANK LIMITED, MUMBAI

In the result, the appeal of the In the result, the appeal of the assessee is allowed partly assessee is allowed partly whereas the appeal of the Revenue is dismissed

Bench: Shri Om Prakash Kant () & Shri Sandeep Singh Karhail () Assessment Year: 2013-14

1) and (2) shall apply apply apply to to to the the the following following following classes classes classes of of of assessments, assessments, assessments, reassessments and recomputation which may, subject reassessments and recomputation which may, subject reassessments and recomputation which may, subject to the provisions of sub to the provisions of sub-sections (3

THE NEW INDIA ASSURANCE CO. LTD ,MUMBAI vs. DEPUTY COMMISSIONER OF INCOME TAX, CIRCLE-3(2)(2), MUMBAI

1. The CIT(A) erred in confirming the action of the AO by \ntreating the reassessment order passed under section \n143(3

SMALL INDUSTRIES DEVELOPMENT BANK OF INDIA,MUMBAI vs. DEPUTY COMMISSIONER OF INCOME TAX CIRCLE 3(3)(1),MUMBAI, MUMBAI

Bench: Justice (Retd.) C V Bhadang & Ms Padmavathy S, Am

3. The assessee is a company functioning as Principal Financial Institution for promotion, financing and development of Micro, Small & Medium Enterprises and to co-ordinate the functions of Institutions engaged in similar activities. The assessee filed the return of income for AY 2016-17 on 29.09.2016 declaring a total income of Rs. 1552,64,02,200/- under the normal provisions