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

Accordingly, Ground No.1 to 4 raised by the Assessee are allowed

Bench: SHRI VIKRAM SINGH YADAV , ACCOUNTANT MEMBER SHRI RAHUL CHAUDHARY (Judicial Member)

reassessment proceedings are bad in law on account of ‘change of opinion’, the issues that arise for consideration is whether during the original assessment proceedings the issue was scrutinized by the Assessing Officer. In case the answer is in affirmative, then it can be contended that since the assessing officer had formed a view on the issue during the original

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

Accordingly, Ground No.1 to 4 raised by the Assessee are allowed

Bench: SHRI VIKRAM SINGH YADAV, ACCOUNTANT MEMBER SHRI RAHUL CHAUDHARY (Judicial Member)

reassessment proceedings are bad in law on account of ‘change of opinion’, the issues that arise for consideration is whether during the original assessment proceedings the issue was scrutinized by the Assessing Officer. In case the answer is in affirmative, then it can be contended that since the assessing officer had formed a view on the issue during the original

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

Accordingly, Ground No.1 to 4 raised by the Assessee are allowed

Bench: SHRI VIKRAM SINGH YADAV , ACCOUNTANT MEMBER SHRI RAHUL CHAUDHARY (Judicial Member)

reassessment proceedings are bad in law on account of ‘change of opinion’, the issues that arise for consideration is whether during the original assessment proceedings the issue was scrutinized by the Assessing Officer. In case the answer is in affirmative, then it can be contended that since the assessing officer had formed a view on the issue during the original

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

Accordingly, Ground No.1 to 4 raised by the Assessee are allowed

Bench: SHRI VIKRAM SINGH YADAV, ACCOUNTANT MEMBER SHRI RAHUL CHAUDHARY (Judicial Member)

reassessment proceedings are bad in law on account of ‘change of opinion’, the issues that arise for consideration is whether during the original assessment proceedings the issue was scrutinized by the Assessing Officer. In case the answer is in affirmative, then it can be contended that since the assessing officer had formed a view on the issue during the original

KASHYAP KANIYALAL MEHTA,MUMBAI vs. DCIT CC-4(1), MUMBAI

In the result, appeals of the assessee are allowed

reassessment orders to be passed u/s 153A by taking recourse to the provisions of the section 153C of the Act. Because the cause of action for the said incriminating information for different amounts had originated in different search(es) in the different premises of other assessees and for the same, the mandatory route legislated u/s 153Cof the Act must

KASHYAP KANIYALAL MEHTA,MUMBAI vs. DCIT CC-4(1), MUMBAI

In the result, appeals of the assessee are allowed

reassessment orders to be passed u/s 153A by taking recourse to the provisions of the section 153C of the Act. Because the cause of action for the said incriminating information for different amounts had originated in different search(es) in the different premises of other assessees and for the same, the mandatory route legislated u/s 153Cof the Act must

KASHYAP KANIYALAL MEHTA,MUMBAI vs. DCIT CC-4(1), MUMBAI

In the result, appeals of the assessee are allowed

reassessment orders to be passed u/s 153A by taking recourse to the provisions of the section 153C of the Act. Because the cause of action for the said incriminating information for different amounts had originated in different search(es) in the different premises of other assessees and for the same, the mandatory route legislated u/s 153Cof the Act must

KASHYAP KANIYALAL MEHTA,MUMBAI vs. DCIT, CC-4(1), MUMBAI

In the result, appeals of the assessee are allowed

reassessment orders to be passed u/s 153A by taking recourse to the provisions of the section 153C of the Act. Because the cause of action for the said incriminating information for different amounts had originated in different search(es) in the different premises of other assessees and for the same, the mandatory route legislated u/s 153Cof the Act must

KASHYAP KANIYALAL MEHTA,MUMBAI vs. DCIT CC-4(1), MUMBAI

In the result, appeals of the assessee are allowed

reassessment orders to be passed u/s 153A by taking recourse to the provisions of the section 153C of the Act. Because the cause of action for the said incriminating information for different amounts had originated in different search(es) in the different premises of other assessees and for the same, the mandatory route legislated u/s 153Cof the Act must

KASHYAP KANIYALAL MEHTA,MUMBAI vs. DCIT CC-4(1), MUMBAI

In the result, appeals of the assessee are allowed

reassessment orders to be passed u/s 153A by taking recourse to the provisions of the section 153C of the Act. Because the cause of action for the said incriminating information for different amounts had originated in different search(es) in the different premises of other assessees and for the same, the mandatory route legislated u/s 153Cof the Act must

KASHYAP KANIYALAL MEHTA,MUMBAI vs. DCIT CC-4(1), MUMBAI

In the result, appeals of the assessee are allowed

reassessment orders to be passed u/s 153A by taking recourse to the provisions of the section 153C of the Act. Because the cause of action for the said incriminating information for different amounts had originated in different search(es) in the different premises of other assessees and for the same, the mandatory route legislated u/s 153Cof the Act must

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

41,000/-. The Ld.AR submitted that the last date to issue notice u/s.148 within the 3 years was 31/03/2022 for income that is escaped to have assessment is less than 50,00,000/-. 7.1 The Ld.AR submitted that as per reopened provisions under new regime amended by Finance Act 2021 the first proviso to section 148, refers to provision specifying

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

41,000/-. The Ld.AR submitted that the last date to issue notice u/s.148 within the 3 years was 31/03/2022 for income that is escaped to have assessment is less than 50,00,000/-. 7.1 The Ld.AR submitted that as per reopened provisions under new regime amended by Finance Act 2021 the first proviso to section 148, refers to provision specifying

MR NILESH BHARANI,MUMBAI vs. DCIT CC 4(1), MUMBAI

Bench: Shri Amit Shukla, Jm & Shri Amarjit Singh, Am आयकरअपीलसं./ I.T.A. No. 612/Mum/2020 (निर्धारणवर्ा / Assessment Year: 2011-12)

41 I.T.A. No. 612/Mum/2020 Mr. Nilesh Bharani Thus, as per him, undisputedly the assessment jurisdiction was correctly lying with the ITO ward 20(2)(4) Mumbai when the impugned reassessment proceeding was initiated on 28/03/2018 by issuing the notice u/s 148 of the Act. 33. It was also pleaded on behalf of the assessee that in case, the revenue pleads

SHAH CONSTRUCTION COMPANY LTD,MUMBAI vs. DY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-1(3), MUMBAI

Appeal is allowed

Bench: SHRI B.R. BASKARAN, ACCOUNTANT MEMBER SHRI RAHUL CHAUDHARY (Judicial Member)

reassessment proceedings citing that loan waived by the bank under the One Time Settlement Scheme as well as the interest on such loan waived during the relevant previous year resulted in income liable to tax in the hands of the Appellant during the relevant previous year in terms of Section 41

SURBHIT IMPEX PRIVATE LIMITED ,MUMBAI vs. PRINCIPAL COMMISSIONER OF INCOME TAX -8, MUMBAI

In the result, the appeal of the assessee is allowed

reassessment.\n7.\nWithout prejudice to the above, on facts and circumstances of the case\nand in law, the Ld. PCIT has erred in issuing a Notice and passing an\norder under section 263 of the Act when a sum of Rs.33,00,000/- was\npaid back in the latter year and the remaining amount was shown as\noutstanding

SATISH HARNAMDAS SETHI,MUMBAI vs. NATIONAL FACELESS ASSESSMENT CENTRE DELHI, DELHI

In the result, appeal of the assessee is allowed

Bench: Ms Kavitha Rajagopal & Shri Girish Agrawalassessment Year: 2017-18

reassessment order passed under section 147 r.w.s. 144B of Act in pursuance to the said notice are against the well settled provisions of law and the same may be quashed and set aside. 3. Addition under head income from other invoking the provisions of section 56(2)(vii)(b) of the Act unjustified - 1,41

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

Appeal is allowed

Bench: Him.

41(3)(4), Mumbai Kautilya Bhavan, Bandra Kurla Complex, Mumbai – 400051. Maharashtra. …………. Respondent Appearance For the Appellant/Assessee : Shri Ravindra Poojary For the Respondent/Department : Shri Bhagirath Ramawat Date Conclusion of hearing : 12.11.2025 Pronouncement of order : 23.12.2025 O R D E R [ Per Rahul Chaudhary, Judicial Member: 1. The present appeal preferred by the Assessee is directed against the order, dated 12/02/2025