PRAKASH COTTON MILLS PVT LTD,MUMBAI vs. DY CIT, CIRCLE 8(2)(1), MUMBAI

In the result, ground No. 9 to 14 is allowed

Section 147 of the Act for initiating reassessment proceeding as,\ntill today, no asset of M/s. Kanha& Co. has been distributed as provided in\nSec. 45

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

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

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 were quashed by the Hon’ble Bombay High Court. However, in the case before us, the Assessing Officer had not scrutinized the issue of deductibility of payments made to auto dealers under Section 37 of the Act (read with Explanation 1 thereto) during the regular scrutiny assessment proceedings. Therefore, the question of the Assessing Officer forming ‘another view

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 were quashed by the Hon’ble Bombay High Court. However, in the case before us, the Assessing Officer had not scrutinized the issue of deductibility of payments made to auto dealers under Section 37 of the Act (read with Explanation 1 thereto) during the regular scrutiny assessment proceedings. Therefore, the question of the Assessing Officer forming ‘another view

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 were quashed by the Hon’ble Bombay High Court. However, in the case before us, the Assessing Officer had not scrutinized the issue of deductibility of payments made to auto dealers under Section 37 of the Act (read with Explanation 1 thereto) during the regular scrutiny assessment proceedings. Therefore, the question of the Assessing Officer forming ‘another view

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 were quashed by the Hon’ble Bombay High Court. However, in the case before us, the Assessing Officer had not scrutinized the issue of deductibility of payments made to auto dealers under Section 37 of the Act (read with Explanation 1 thereto) during the regular scrutiny assessment proceedings. Therefore, the question of the Assessing Officer forming ‘another view

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

APCOTEX INDUSTRIES LIMITED,RAOGARH vs. INCOME TAX OFFICER - CIRCLE 15(1)(1), MUMBAI

section 143(3) determining total income of Rs. 13,40,45,570/-. Subsequently, a reassessment under section 143(3) read

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 - 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

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)

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 that the correct jurisdiction for the purpose was with the ACIT Circle 20(2) Mumbai only at that time then the alleged notice issued