VIDHI ENTERPRISES,MUMBAI vs. DEPUTY COMMISSIONER OF INCOME TAX, MUMBAI

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

Bench: Shri Om Prakash Kant () Before Shri Om Prakash Kant () Before Shri Om Prakash Kant () & Shri Sandeep Singh Karhail () Shri Sandeep Singh Karhail () Shri Sandeep Singh Karhail ()

reassess the income in respect of any issue, which has escaped the income in respect of any issue, which has escaped the income in respect of any issue, which has escaped assessment, and such issue comes to his notice subsequently in ment, and such issue comes to his notice subsequently in ment, and such issue comes to his notice subsequently

GOBINDRAM JAGDISH KAKWANI,MUMBAI vs. ITO INTERNATIONAL TAXATION WARD 3(1)(1), MUMBAI

In the result, appeal filed by the assessee partly allowed

Bench: Shri S. Rifaur Rahman, Hon'Ble & Shri Sandeep Singh Karhail, Hon’Blegobindram Jagdish Kakwani Vs. Ito (It)- Ward 3(1)(1) C/O Gulabani & Co. Ca, Air India Building 507, 5Th Floor, Shree Prasad House Nariman Point 35Th Road, Off Linking Road Mumbai-400021 Bandra (West), Mumbai- 400050 Pan: Awopk5474C (Appellant) (Respondent)

2 Gobindram Jagdish Kakwani 5. The Assessing Officer observed that the assessee has taken sale consideration of ₹.52,50,000/- whereas the market value of the property was ₹.69,32,000/-. Assessing Officer also observed that assessee in his computation of capital gain has claimed deduction u/s. 54 of the Act for the purchase of new property amounting

VINAY ARUN JOSHI,THANE vs. PCIT CENTRAL MUMBAI-1, MUMBAI

In the result, the appeal of the assessee is allowed

reassess the total income for the\nentire six years block assessment period even in case of completed/unabated\nassessment. As per the second proviso to Section 153A, only pending\nassessment/reassessment shall stand abated and the AO would assume the\njurisdiction with respect to such abated assessments. It does not provide that\nall completed/unabated assessments shall abate. If the submission on behalf

DAMJI J GALA,KHANDILKAR ROAD vs. ITO 19(1)(4), TARDEO ROAD

In the result the appeal filed by the assessee stands partly\nallowed

sections": [ "148", "147", "50C", "2(47)", "139(1)", "45", "53A" ], "issues": "1. Validity of reassessment proceedings under Section 148/147. 2

PANKAJ DHANDHARIA,MUMBAI vs. ACIT-22(1), MUMBAI

Appeal is dismissed

reassessment proceedings under\nsection 147 of the act cannot be initiated merely on the ground\nthat the learned assessing officer has lost sight of the statutory\nprovisions like 50C, 43CA and section 56 (2

ADARSH DEVELOPERS,MUMBAI vs. ITO, WARD 22(3)(1), MUMBAI, MUMBAI

In the result, the appeal filed by the assessee stands allowed

Bench: Smt. Beena Pillai () & Shri Jagadish ()

2 I.T.A. No. 7945/Mum/2025 4. The learned CIT(A) erred in upholding the Section 50C addition without considering the valuation report submitted by the appellant demonstrating that the stamp duty value did not represent the correct fair market value. 5. The learned CIT(A) erred in confirming the addition of R2,42,590/- towards estimated gross profit without granting

DANISH SHEIKH,USA vs. INCOME TAX OFFICER INTL TAX WARD 4(2)(1), MUMBAI

In the result, the appeal of the assessee is allowed

Bench: Shri Rahul Chaudhary & Smt. Renu Jauhriआयकर अपील सुं./Ita No. 1034/Mum/2025 (नििाारण वर्ा / Assessment Year :2016-17) Danish Sheikh V/S. Ito International Tax, 18, Old Planters Road, बिाम Ward 4(2)(1) Beverly, Usa-999999 Kautilya Bhavan, 6Th Floor, Bandra (E), Mumbai- 400051 स्थायी लेखा सं./जीआइआर सं./Pan/Gir No: Fjxps3005Q Appellant/अपीलार्थी .. Respondent/प्रनिवादी निर्ााररती की ओर से /Assessee By: Shri Pradip Kapasi राजस्व की ओर से /Revenue By: Shri Krishna Kumar, Sr. Dr.

50C and 56(2)(vii)(b) of the Act. This was the statutory requirement to be adhered to by the assessing authorities before making any addition on account of the deeming fiction. GROUND NO 4: FAILURE BY AO TO ESTABLISH/IGNORE FACTS FOR PAYMENTS MADE BY THE APPELLANT No Payment whatsoever was made by the appellant in excess of the agreement

VALUKKO INFRASTRUSTURE LIMITED,MUMBAI vs. INCOME TAX OFFICER, 11(3)(2), MUMBAI

In the result, the appeal of the assessee is allowed

Bench: Shri Rahul Chaudhary & Smt. Renu Jauhriआयकर अपील सुं./Ita No. 1034/Mum/2025 (नििाारण वर्ा / Assessment Year :2016-17) Danish Sheikh V/S. Ito International Tax, 18, Old Planters Road, बिाम Ward 4(2)(1) Beverly, Usa-999999 Kautilya Bhavan, 6Th Floor, Bandra (E), Mumbai- 400051 स्थायी लेखा सं./जीआइआर सं./Pan/Gir No: Fjxps3005Q Appellant/अपीलार्थी .. Respondent/प्रनिवादी निर्ााररती की ओर से /Assessee By: Shri Pradip Kapasi राजस्व की ओर से /Revenue By: Shri Krishna Kumar, Sr. Dr.

50C and 56(2)(vii)(b) of the Act. This was the statutory requirement to be adhered to by the assessing authorities before making any addition on account of the deeming fiction. GROUND NO 4: FAILURE BY AO TO ESTABLISH/IGNORE FACTS FOR PAYMENTS MADE BY THE APPELLANT No Payment whatsoever was made by the appellant in excess of the agreement

ALRAMEEZ CONSTRUCTION PVT LTD ,MUMBAI vs. NATIONAL FACELESS APPEAL CENTRE , MUMBAI

In the result grounds of appeal raised by assessee is allowed

Bench: Shri Kuldip Singh & Shri Gagan Goyalm/S Alrameez Construction Pvt. Ltd. 707/708, 7Th Floor, Jms Business Centre Behram Baug, Oshiwara Link Road, Jogeshwari West, Mumbai-400 080 Pan: Aafca8078A ...... Appellant Vs. Cit/Nfac Delhi ..... Respondent

reassessed or recomputed in a preceding order. (11) No addition or disallowance of an amount shall form the basis for imposition of penalty, if such addition or disallowance has formed the basis of imposition of penalty in the case of the person for the same or any other assessment year. (12) The penalty referred to in sub-section (1) shall

SHRI RAJESH RAMCHANDRA DAKE,PANVEL vs. DY CIT CC-1, MUMBAI

reassess the total income, taking into consideration the incriminating material unearthed during the search and other material available with the AO including the income declared in the returns\" and as in the instant case the addition is based on the incriminating material such as the information qua selling of lands by the Assessee, found from the valuable group of cases

BAJRANGLAL BHAWARLAL SHARMA,BORIVALI EAST vs. INCOME TAX OFFICER, KAUTILYA BHAVAN

Bench: SHRI RAHUL CHAUDHARY (Judicial Member)

Reassessment proceedings under section 147 are liable to be quashed. 2 Assessment Year 2017-2018 2. On the facts and in the circumstances of the case and in law Honble CIT(A) has erred in confirming the action of Ld. Assessing Officer in framing the impugned assessment order under section 143(3)/147 r.w.s.144B by not referring the matter

NILESH PRAVINCHANDRA DOSHI,MUMBAI vs. INCOME TAX OFFICER WARD 42(1)(3), MUMBAI, MAHARASHTRA, MUMBAI

Bench: Shri Amit Shukla & Shri Makarand Vasant Mahadeokarnilesh Pravinchandra Ito Ward 42(1)(3), Doshi Kautilya Bhavan, B/29, Pushpanjali Vs. Bandra Kurla Building, Jambli Gully, Complex, Bandra Borivali West, Mumbai- East, 400 092 Mumbai-400 051 Pan/Gir No. Amcpd6391D (Applicant) (Respondent) Assessee By Shri Jay Shah, Ld. Ar Revenue By Shri Surendra Mohan, Ld. Dr Date Of Hearing 08.01.2026 Date Of Pronouncement 12.01.2026

reassessment proceedings, the Assessing Officer made the following additions: 1. Rs. 1,26,730/- under section 56(2)(vii)(b) on account of difference between stamp duty valuation and agreement value of immovable property. 2. Rs. 7,401/- on account of difference in savings bank interest. 3. Rs. 80,639/- on account of alleged omission of Long Term Capital Gain

MR GAJANAN PARSHURAM KHISMATRAO,THANE vs. ITO WARD 3(2), KALYAN

Bench: Shri Prashant Maharishi & Shri Sandeep Singh Karhail

2. The Ld. CIT (A) failed to appreciate that there is no escapement of any Gajanan Parshuram Khismatrao ITA no.817/Mum./2020 income and as such the impugned notice u/s 148 is bad in law. 3. The Ld. CIT (A) also failed to appreciate the transfer of the land in question has taken place during the previous year relevant to assessment

ACIT -7(1)(1), MUMBAI, MUMBAI vs. MAZAGON DOCK SHIPBUILDERS LTD., MUMBAI

In the result, appeal of the Revenue is dismissed

Bench: Shri Sandeep Gosain & Shri Girish Agrawalassessment Year: 2005-06 Assistant Commissioner Of Mazagon Dock Shipbuilders Income Tax-7(1)(1), Ltd. Mumbai Mazdock House, Dockyard Vs. Road, Mazagon, Mumbai – 400010 (Pan: Aaacm8029) (Appellant) (Respondent)

2. Grounds taken by the Revenue are reproduced as under: I. Whether, on the facts and in the circumstances of the case and in law, the Ld. CITA) has erred in quashing the reassessment proceedings on the ground that there was no new material before the AO to reopen the case, without appreciating the fact that the issue of LTCG

RELIANCE INDUSTRIES LIMITED,MUMBAI vs. DY COMMISSIONER OF INCOME TAX CIRCLE-3(4), MUMBAI

In the result, both the appeals of the assessee and both the appeals of the revenue are treated as partly allowed

Bench: Shri B.R. Baskaran (Am) & Shri Pavan Kumar Gadale (Jm)

reassess the company's income, then it would have stated in section 115J that 'income of the company as accepted by the Assessing Officer'. In the absence of the same and on the language of section 115J, it will have to held that view taken by the Tribunal is correct and the High Court has erred in reversing the said

RELIANCE INDUSTRIES LTD.,MUMBAI vs. ACIT CIRCLE 3(4), MUMBAI

In the result, both the appeals of the assessee and both the appeals of the revenue are treated as partly allowed

Bench: Shri B.R. Baskaran (Am) & Shri Pavan Kumar Gadale (Jm)

reassess the company's income, then it would have stated in section 115J that 'income of the company as accepted by the Assessing Officer'. In the absence of the same and on the language of section 115J, it will have to held that view taken by the Tribunal is correct and the High Court has erred in reversing the said

DCIT-3(4), MUMBAI vs. M/S RELIANCE INDUSTRIES LIMITED, MUMBAI

In the result, both the appeals of the assessee and both the appeals of the revenue are treated as partly allowed

Bench: Shri B.R. Baskaran (Am) & Shri Pavan Kumar Gadale (Jm)

reassess the company's income, then it would have stated in section 115J that 'income of the company as accepted by the Assessing Officer'. In the absence of the same and on the language of section 115J, it will have to held that view taken by the Tribunal is correct and the High Court has erred in reversing the said

DCIT- 3(4) , MUMBAI vs. M/S RELIANCE INDUSTRIES LIMITED, MUMBAI

In the result, both the appeals of the assessee and both the appeals of the revenue are treated as partly allowed

Bench: Shri B.R. Baskaran (Am) & Shri Pavan Kumar Gadale (Jm)

reassess the company's income, then it would have stated in section 115J that 'income of the company as accepted by the Assessing Officer'. In the absence of the same and on the language of section 115J, it will have to held that view taken by the Tribunal is correct and the High Court has erred in reversing the said