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

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

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

ANNAPURNA BUILDCON INFRA PRIVATE LIMITED,MUMBAI vs. DCIT, CENTRAL CIRCLE 1, THANE, THANE

In the result, the appeal of the assessee for AY

Bench: Shri B.R. Baskaran\Nand\Nshri Anikesh Banerjee\N\Nita No.6827/Mum/2024\Nita No.6828/Mum/2024\Nita No.6829/Mum/2024\Nita No.6830/Mum/2024\Nita No.6831/Mum/2024\Nita No.6832/Mum/2024\Nita No.6833/Mum/2024\Nita No.6834/Mum/2024\N\Na.Y. 2019-20\Na.Y. 2020-21\Na.Y. 2016-17\Na.Y. 2014-15\Na.Y. 2017-18\Na.Y. 2015-16\Na.Y. 2018-19\Na.Y. 2021-22\N\Nannapurna Buildcon Infra Vs Dcit, Central Circle-1, Thane\Nprivate Limited,\Nroom No.10, 6Th Floor, Ashar\Nshop No.6, Ground Floor,\Nit Park, Wagle Industrial\Nrachana Chs Ltd, Opp.\Nestate, Thane(W).\Nmcf Club, Jogurs Park,\Nborivali (West),\Nmumbai\Npan: Aahca7229F\Nappellant\Nrespondent\N\Nfor Assessee : Shri Vijay Mehta\Nfor Revenue: Dr. K.R. Subhash Cit-Dr\Ndate Of Hearing: 12-02-2025\Ndate Of Pronouncement: 06-03-2025\N\Norder\N\Nper Bench :\Nall The Appeals Filed By The Assessee Are Directed Against The\Ncommon Order Dt.25-10-2024 Passed By The Ld. Commissioner Of\Nincome Tax (Appeals)-Pune-11, [‘Ld.Cit(A)] & They Relate To Ays.\N2014-15 To 2021-22. Since Common Issues Are Urged In These Appeals,\Nthey Were Heard Together. Hence, They Are Being Disposed Of By This\Ncommon Order, For The Sake Of Convenience.\N\N2. The Common Issue Contested In All These Years Is Related To The\Naddition Of Estimated Profit On The Alleged On-Money Received By The\Nassessee On Sale Of Flats.\N\N2.

section 153A of the Act permits reopening of assessments\nof assessment years beyond six years (those years are referred to as\n“relevant assessment years) subject to fulfillment of certain conditions.\nIn the instant case, the AO has reopened the assessment of AY.\n2014-15 also invoking the 4th proviso to sec.153A of the Act. The\nassessee is challenging

SHAILESH ASALRAJ JAIN,MUMBAI vs. PRINCIPAL COMMISSIONER OF INCOME TAX, MUMBAI 20, MUMBAI

In the result, the appeal of the assessee is allowed

Bench: Shri Om Prakash Kant () & Shri Rahul Chaudhary () Assessment Year: 2018-19

reassessment cannot be examined in proceedings arising from section 263 is devoid of merit. It is well- proceedings arising from section 263 is devoid of merit. proceedings arising from section 263 is devoid of merit. settled that a jurisdictional defect strikes at the foundation of settled that a jurisdictional defect strikes at the foundation of settled that a jurisdictional defect

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

42(1)(3), Krishnavadan Parikh Kautilya Bhavan, C- F-2201, Orchid Suburbia, 41 to C-43, G-Block, Kandivli(W), Link Road, Bandra Kurla Mumbai-400067 Complex, Bandra (E), PAN: AABPP6438Q Mumbai - 400051 (Appellant) (Respondent) Appellant by Shri Hitesh Jain Respondent by Shri Nagnath Pasale, SR. D.R. Date of Hearing 19.08.2025 Date of Pronouncement 29.08.2025 ORDER Per: Smt. Beena Pillai

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

42(1)(3), Krishnavadan Parikh Kautilya Bhavan, C- F-2201, Orchid Suburbia, 41 to C-43, G-Block, Kandivli(W), Link Road, Bandra Kurla Mumbai-400067 Complex, Bandra (E), PAN: AABPP6438Q Mumbai - 400051 (Appellant) (Respondent) Appellant by Shri Hitesh Jain Respondent by Shri Nagnath Pasale, SR. D.R. Date of Hearing 19.08.2025 Date of Pronouncement 29.08.2025 ORDER Per: Smt. Beena Pillai

ANNAPURNA BUILDCON INFRA PRIVATE LIMITED,THANE vs. DCIT, CENTRAL CIRCLE-1, THANE

In the result, the appeal of the assessee for AY

Bench: Shri B.R. Baskaran\Nand\Nshri Anikesh Banerjee\Nita No.6827/Mum/2024 - A.Y. 2019-20\Nita No.6828/Mum/2024 - A.Y. 2020-21\Nita No.6829/Mum/2024 - A.Y. 2016-17\Nita No.6830/Mum/2024 - A.Y. 2014-15\Nita No.6831/Mum/2024 - A.Y. 2017-18\Nita No.6832/Mum/2024 - A.Y. 2015-16\Nita No.6833/Mum/2024 - A.Y. 2018-19\Nita No.6834/Mum/2024 - A.Y. 2021-22\Nannapurna Buildcon Infra Vs Dcit, Central Circle-1, Thane\Nprivate Limited,\Nroom No.10, 6Th Floor, Ashar\Nshop No.6, Ground Floor,\Nit Park, Wagle Industrial\Nrachana Chs Ltd, Opp.\Nestate, Thane(W).\Nmcf Club, Jogurs Park,\Nborivali (West),\Nmumbai\Nappellant\Nrespondent\Npan: Aahca7229F\Nfor Assessee : Shri Vijay Mehta\Nfor Revenue: Dr. K.R. Subhash Cit-Dr\Ndate Of Hearing: 12-02-2025\Ndate Of Pronouncement: 06-03-2025\Norder\Nper Bench :\Nall The Appeals Filed By The Assessee Are Directed Against The\Ncommon Order Dt.25-10-2024 Passed By The Ld. Commissioner Of\Nincome Tax (Appeals)-Pune-11, [‘Ld.Cit(A)] & They Relate To Ays.\N2014-15 To 2021-22. Since Common Issues Are Urged In These Appeals,\Nthey Were Heard Together. Hence, They Are Being Disposed Of By This\Ncommon Order, For The Sake Of Convenience.\N2. The Common Issue Contested In All These Years Is Related To The\Naddition Of Estimated Profit On The Alleged On-Money Received By The\Nassessee On Sale Of Flats.\N2.

section 153A of the Act permits reopening of assessments\nof assessment years beyond six years (those years are referred to as\n“relevant assessment years) subject to fulfillment of certain conditions.\nIn the instant case, the AO has reopened the assessment of AY.\n2014-15 also invoking the 4th proviso to sec.153A of the Act. The\nassessee is challenging

ANNAPURNA BUILDCON INFRA PRIVATE LIMITED,MUMBAI vs. DCIT, CENTRAL CIRCLE 1, THANE, THANE

In the result, the appeal of the assessee for AY

Bench: Shri B.R. Baskaran\Nand\Nshri Anikesh Banerjee\N\Nita No.6827/Mum/2024\Nita No.6828/Mum/2024\Nita No.6829/Mum/2024\Nita No.6830/Mum/2024\Nita No.6831/Mum/2024\Nita No.6832/Mum/2024\Nita No.6833/Mum/2024\Nita No.6834/Mum/2024\N\Nα.Υ. 2019-20\Nα.Υ. 2020-21\Nα.Υ. 2016-17\Nα.Υ. 2014-15\Nα.Υ. 2017-18\Nα.Υ. 2015-16\Nα.Υ. 2018-19\Nα.Υ. 2021-22\N\Nannapurna Buildcon Infra\Nprivate Limited,\Nshop No.6, Ground Floor,\Nrachana Chs Ltd, Opp.\Nmcf Club, Jogurs Park,\Nborivali (West),\Nmumbai\Npan: Aahca7229F\Nappellant\Nvs\Ndcit, Central Circle-1, Thane\Nroom No.10, 6Th Floor, Ashar\Nit Park, Wagle Industrial\Nestate, Thane(W).\Nrespondent\N\Nfor Assessee : Shri Vijay Mehta\Nfor Revenue: Dr. K.R. Subhash Cit-Dr\Ndate Of Hearing: 12-02-2025\Ndate Of Pronouncement: 06-03-2025\N\Norder\N\Nper Bench :\Nall The Appeals Filed By The Assessee Are Directed Against The\Ncommon Order Dt.25-10-2024 Passed By The Ld. Commissioner Of\Nincome Tax (Appeals)-Pune-11, [‘Ld.Cit(A)] & They Relate To Ays.\N2014-15 To 2021-22. Since Common Issues Are Urged In These Appeals,\Nthey Were Heard Together. Hence, They Are Being Disposed Of By This\Ncommon Order, For The Sake Of Convenience.\N\N2. The Common Issue Contested In All These Years Is Related To The\Naddition Of Estimated Profit On The Alleged On-Money Received By The\Nassessee On Sale Of Flats.\N\N2.

section 153A of the Act permits reopening of assessments\nof assessment years beyond six years (those years are referred to as\n“relevant assessment years) subject to fulfillment of certain conditions.\nIn the instant case, the AO has reopened the assessment of AY.\n2014-15 also invoking the 4th proviso to sec.153A of the Act. The\nassessee is challenging

ANNAPURNA BUILDCON INFRA PRIVATE LIMITED,MUMBAI vs. DCIT, CENTRAL CIRCLE 1, THANE, THANE

In the result, the appeal of the assessee for AY

Bench: Shri B.R. Baskaran\Nand\Nshri Anikesh Banerjee\Nita No.6827/Mum/2024 - A.Y. 2019-20\Nita No.6828/Mum/2024 - A.Y. 2020-21\Nita No.6829/Mum/2024 - A.Y. 2016-17\Nita No.6830/Mum/2024 - A.Y. 2014-15\Nita No.6831/Mum/2024 - A.Y. 2017-18\Nita No.6832/Mum/2024 - A.Y. 2015-16\Nita No.6833/Mum/2024 - A.Y. 2018-19\Nita No.6834/Mum/2024 - A.Y. 2021-22\Nannapurna Buildcon Infra Vs Dcit, Central Circle-1, Thane\Nprivate Limited,\Nroom No.10, 6Th Floor, Ashar\Nshop No.6, Ground Floor,\Nit Park, Wagle Industrial\Nrachana Chs Ltd, Opp.\Nestate, Thane(W).\Nmcf Club, Jogurs Park,\Nborivali (West),\Nmumbai\Nappellant\Nrespondent\Npan: Aahca7229F\Nfor Assessee : Shri Vijay Mehta\Nfor Revenue: Dr. K.R. Subhash Cit-Dr\Ndate Of Hearing: 12-02-2025\Ndate Of Pronouncement: 06-03-2025\Norder\Nper Bench :\Nall The Appeals Filed By The Assessee Are Directed Against The\Ncommon Order Dt.25-10-2024 Passed By The Ld. Commissioner Of\Nincome Tax (Appeals)-Pune-11, [‘Ld.Cit(A)] & They Relate To Ays.\N2014-15 To 2021-22. Since Common Issues Are Urged In These Appeals,\Nthey Were Heard Together. Hence, They Are Being Disposed Of By This\Ncommon Order, For The Sake Of Convenience.\N2. The Common Issue Contested In All These Years Is Related To The\Naddition Of Estimated Profit On The Alleged On-Money Received By The\Nassessee On Sale Of Flats.\N2.

section 153A of the Act permits reopening of assessments\nof assessment years beyond six years (those years are referred to as\n“relevant assessment years) subject to fulfillment of certain conditions.\nIn the instant case, the AO has reopened the assessment of AY.\n2014-15 also invoking the 4th proviso to sec.153A of the Act. The\nassessee is challenging

ANNAPURNA BUILDCON INFRA PRIVATE LIMITED,MUMBAI vs. DCIT, CENTRAL CIRCLE 1, THANE, THANE

In the result, the appeal of the assessee for AY

Bench: Shri B.R. Baskaran\Nand\Nshri Anikesh Banerjee\N\Nita No.6827/Mum/2024 - A.Y. 2019-20\Nita No.6828/Mum/2024 - A.Y. 2020-21\Nita No.6829/Mum/2024 - A.Y. 2016-17\Nita No.6830/Mum/2024 - A.Y. 2014-15\Nita No.6831/Mum/2024 - A.Y. 2017-18\Nita No.6832/Mum/2024 - A.Y. 2015-16\Nita No.6833/Mum/2024 - A.Y. 2018-19\Nita No.6834/Mum/2024 - A.Y. 2021-22\N\Nannapurna Buildcon Infra Vs Dcit, Central Circle-1, Thane\Nprivate Limited,\Nroom No.10, 6Th Floor, Ashar\Nshop No.6, Ground Floor,\Nit Park, Wagle Industrial\Nrachana Chs Ltd, Opp. Estate, Thane(W).\Nmcf Club, Jogurs Park,\Nborivali (West),\Nmumbai\Nappellant\Npan: Aahca7229F\Nrespondent\N\Nfor Assessee : Shri Vijay Mehta\Nfor Revenue: Dr. K.R. Subhash Cit-Dr\Ndate Of Hearing: 12-02-2025\Ndate Of Pronouncement: 06-03-2025\N\Norder\Nper Bench :\Nall The Appeals Filed By The Assessee Are Directed Against The\Ncommon Order Dt.25-10-2024 Passed By The Ld. Commissioner Of\Nincome Tax (Appeals)-Pune-11, [‘Ld.Cit(A)] & They Relate To Ays.\N2014-15 To 2021-22. Since Common Issues Are Urged In These Appeals,\Nthey Were Heard Together. Hence, They Are Being Disposed Of By This\Ncommon Order, For The Sake Of Convenience.\N\N2. The Common Issue Contested In All These Years Is Related To The\Naddition Of Estimated Profit On The Alleged On-Money Received By The\Nassessee On Sale Of Flats.\N\N2.

section 153A of the Act permits reopening of assessments\nof assessment years beyond six years (those years are referred to as\n“relevant assessment years) subject to fulfillment of certain conditions.\nIn the instant case, the AO has reopened the assessment of AY.\n2014-15 also invoking the 4th proviso to sec.153A of the Act. The\nassessee is challenging