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

31,85,340/-. Thereafter, the case was reopened under\nSection 147 of the Act vide notice dated 16/03/2016 issued\nunder Section 148 of the Act. The assessment culminated into\npassing of the Assessment Order, dated 29/12/2017, under\nSection 143(3) read with Section 147 of the Act whereby income\nof the Assessee was determined at INR.3

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

31,85,340/-. Thereafter, the case was reopened under\nSection 147 of the Act vide notice dated 16/03/2016 issued\nunder Section 148 of the Act. The assessment culminated into\npassing of the Assessment Order, dated 29/12/2017, under\nSection 143(3) read with Section 147 of the Act whereby income\nof the Assessee was determined at INR.3

SURENDRA GARG HUF,MUMBAI vs. ITO - 19(3)(4), MUMBAI

reassessment proceedings initiated under Section\n147 of the Act. In that case also the judgment of the Hon'ble\nSupreme Court in the case of Abhisar Buildwell Private Ltd. (Supra)\ndealing with the interpretation of provisions contained in Section\n153A of the Act and the judgment of Hon'ble High Court of\nRajasthan in the case of Shyam Sunder Khandelwal

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)

31,85,340/-. Thereafter, the case was reopened under\nSection 147 of the Act vide notice dated 16/03/2016 issued\nunder Section 148 of the Act. The assessment culminated into\npassing of the Assessment Order, dated 29/12/2017, under\nSection 143(3) read with Section 147 of the Act whereby income\nof the Assessee was determined at INR.3

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

31,85,340/-. Thereafter, the case was reopened under\nSection 147 of the Act vide notice dated 16/03/2016 issued\nunder Section 148 of the Act. The assessment culminated into\npassing of the Assessment Order, dated 29/12/2017, under\nSection 143(3) read with Section 147 of the Act whereby income\nof the Assessee was determined at INR.3

SHANTILAL NAROTTAMDAS PANCHAL,MALAD EAST vs. ITO-41(3)(4), MUMBAI, BANDRA KURLA COMPLEX

Appeal is allowed

Bench: Him.

31 March 2021. The expiry of time fell within the time period contemplated by Section 3 of TOLA read with its notifications. Resultantly, the Revenue had time until 30 June 2021 to issue a reassessment

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

31,85,340/-. Thereafter, the case was reopened under \nSection 147 of the Act vide notice dated 16/03/2016 issued \nunder Section 148 of the Act. The assessment culminated into \npassing of the Assessment Order, dated 29/12/2017, under \nSection 143(3) read with Section 147 of the Act whereby income \nof the Assessee was determined at INR.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

31,85,340/-. Thereafter, the case was reopened under\nSection 147 of the Act vide notice dated 16/03/2016 issued\nunder Section 148 of the Act. The assessment culminated into\npassing of the Assessment Order, dated 29/12/2017, under\nSection 143(3) read with Section 147 of the Act whereby income\nof the Assessee was determined at INR.3

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

reassessment under Sections 148A and 148, and/or in passing the impugned orders dated 30 July 2022 and/or 28th July 2023 under the said provisions. The actions are contrary to law, beyond the jurisdiction of the Assessing Officer, and the impugned orders are liable to be quashed. 2. erred in passing order under section 147 of the Act by reopening

JAYANTILAL RAJMAL SETH,MUMBAI vs. DCIT-CC-4(3), MUMBAI, MUMBAI

Bench: Shri Om Prakash Kant () & Shri Raj Kumar Chauhan () Assessment Year: 2018-19 Jayantilal Rajmal Seth, Dcit-Cc-4(3), A-3, Saibaba Shopping Centre, Bkc, Mumbai-400051. Mumbai Central, Vs. Mumbai-400008. Pan No. Agepj 0499 E Appellant Respondent

section 147(a) (as the provision stood at the relevant time) stood at the relevant time) fulfilment of the two requisite conditions fulfilment of the two requisite conditions in that regard is essential. At that stage, the final outcome of the in that regard is essential. At that stage, the final outcome of the in that regard is essential

KETUKUMAR KRISHNAVADAN PARIKH ,MUMBAI vs. ITO WARD 42(1)(3), MUMBAI

In the result the appeal filed by the assessee for assessment year 2017-18 and 2018-19 stands allowed

Bench: Smt. Beena Pillai () I.T.A. No. 4503/Mum/2025 Assessment Year: 2017-18 & I.T.A. No. 4502/Mum/2025 Assessment Year: 2018-19

31 March 2021; 4 ITA No.4502/Mum/2025; A.Y. 2018-19 Ketukumar Krishnavadan Parikh c. Section 3(1) of TOLA overrides Section 149 of the Income- tax Act only to the extent of relaxing the time limit for issuance of a reassessment

KETUKUMAR KRISHNAVADAN PARIKH,MUMBAI vs. ITO WARD 42(1)(3), MUMBAI

In the result the appeal filed by the assessee for assessment year 2017-18 and 2018-19 stands allowed

Bench: Smt. Beena Pillai () I.T.A. No. 4503/Mum/2025 Assessment Year: 2017-18 & I.T.A. No. 4502/Mum/2025 Assessment Year: 2018-19

31 March 2021; 4 ITA No.4502/Mum/2025; A.Y. 2018-19 Ketukumar Krishnavadan Parikh c. Section 3(1) of TOLA overrides Section 149 of the Income- tax Act only to the extent of relaxing the time limit for issuance of a reassessment

GAMNARAM OKHAJI PRAJAPATI ,MUMBAI vs. DCIT. CIRCLE 1(2)(1), MUMBAI

Appeal is allowed

Bench: SHRI RAHUL CHAUDHARY, JUDICIAL MEMBER SHRI PRABHASH SHANKAR (Accountant Member)

31 March 2021, contemplated under section 3(1) of TOLA. Resultantly, the authority specified under section 151(i) of the new regime can grant sanction till 30 June 2021. 79. Under Finance Act 2021, the assessing officer was required to obtain prior approval or sanction of the specified authorities at four stages: a. Section 148A(a) - to conduct any enquiry

SHRI AMIT MANGILAL JAIN,MUMBAI vs. ACIT, - 33(1), MUMBAI

In the result, both the above appeals are allowed

Bench: Shri Sandeep Gosain & Shri Prabhash Shankar

section 132A after 31st May, 2003 but on or before 31 March, 2021, the Assessing Officer shall have jurisdiction to issue notice to such person to furnish the return of income as specified in the notice or assess or reassess

JAIN MACHINE TOOLS ,MUMBAI vs. INCOME TAX OFFICER, WARD 26(1)(7), MUMBAI

In the result, the appeal of the assessee is allowed

Bench: Shri Om Prakash Kant () & Shri Sunil Kumar Singh () Assessment Year: 2012-13 Jain Machine Tools, Ito, Ward 26(1)(7), 16, Meghal Industrial Estate, Room 625, 6Th Floor, Kautilya Vs. Devidayal Road, Mulund (West) Bhavan, C-41 To C-43, G Block, Mumbai-400080. Bandra Kurla Complex, Bandra (East), Mumbai-400051. Pan No. Aacfj 6163 H Appellant Respondent

section 147 of the Act, an assessment completed u/s 143(3) of the Act could be reopened beyond the completed u/s 143(3) of the Act could be reopened beyond the completed u/s 143(3) of the Act could be reopened beyond the period of four years from the end of the relevant assessment year iod of four years from

RATAN N MOTWANI (HUF),MUMBAI vs. ITO WARD 23(3)(1), MUMBAI

In the result, assessee’s appeal is allowed

Bench: Smt. Beena Pillai & Smt.Renu Jauhri7 (A.Y.2017-18)

31 March 2021, contemplated under Section 3(1) of TOLA. Resultantly, the authority specified under Section 151(i) of the new regime can grant sanction till 30 June 2021." 3.8 Thus, Hon'ble Court answered second question also in favour of revenue that extension provided under TOLA will cover not only time limit under section 149 but also the time

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

In the result, both appeals by the Revenue are dismissed and the\ntwo Cross Objections of the assessee are allowed

reassessment under Sections 148A and 148, and/or in passing\nthe impugned orders dated 30 July 2022 and/or 28th July 2023 under the said\nprovisions. The actions are contrary to law, beyond the jurisdiction of the\nAssessing Officer, and the impugned orders are liable to be quashed.\n2. erred in passing order under section 147 of the Act by reopening

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

31,85,340/-. Thereafter, the case was reopened under \nSection 147 of the Act vide notice dated 16/03/2016 issued \nunder Section 148 of the Act. The assessment culminated into \npassing of the Assessment Order, dated 29/12/2017, under \nSection 143(3) read with Section 147 of the Act whereby income \nof the Assessee was determined at INR.3