SAI PRERNA CO-OP. CREDIT SOCIETY LTD,MUMBAI vs. ITO WD 17(3) (2) , MUMBAI

In the result, appeals of the assessee and the Revenue are In the result, appeals of the assessee and the Revenue are In the result, appeals of the assessee and the Revenue are decided as under:

Bench: Shri Kuldip Singh () & Shri Om Prakash Kant () Ita Nos. 217, 220 & 221, 218 & 219, 215, 214/Mum/2023 Assessment Years: 2013-14, 2016-17, 2017-18, 2018-19, 2020-21 Sai Prerana Co-Op Credit Ito-17(3)(2), Society Ltd., Room No. 126, 1St Floor, Vs. 317, Puran Aasha Bldg, Gr. Fl. Kautilya Bhavan, C-41 To C- Narashi Natha Street, Katha 43, G Block Bandra Kurla Bazar Masjid Bunder (W), Complex, Bandra (East), Mumbai-400 009. Mumbai-400051. Pan No. Aadts 5638 M Appellant Respondent

reassessment has to be based on fulfllment of certain prec fulfllment of certain precondition and if the concept of “change ondition and if the concept of “change of opinion” is removed, as contended on behalf of the of opinion” is removed, as contended on behalf of the of opinion” is removed, as contended on behalf of the Department, then

SAI PRERNA CO-OP. CREDIT SOCIETY LTD,MUMBAI vs. ITO WD 17(3) (2) , MUMBAI

In the result, appeals of the assessee and the Revenue are In the result, appeals of the assessee and the Revenue are In the result, appeals of the assessee and the Revenue are decided as under:

Bench: Shri Kuldip Singh () & Shri Om Prakash Kant () Ita Nos. 217, 220 & 221, 218 & 219, 215, 214/Mum/2023 Assessment Years: 2013-14, 2016-17, 2017-18, 2018-19, 2020-21 Sai Prerana Co-Op Credit Ito-17(3)(2), Society Ltd., Room No. 126, 1St Floor, Vs. 317, Puran Aasha Bldg, Gr. Fl. Kautilya Bhavan, C-41 To C- Narashi Natha Street, Katha 43, G Block Bandra Kurla Bazar Masjid Bunder (W), Complex, Bandra (East), Mumbai-400 009. Mumbai-400051. Pan No. Aadts 5638 M Appellant Respondent

reassessment has to be based on fulfllment of certain prec fulfllment of certain precondition and if the concept of “change ondition and if the concept of “change of opinion” is removed, as contended on behalf of the of opinion” is removed, as contended on behalf of the of opinion” is removed, as contended on behalf of the Department, then

ITO-26(2)(1), MUMBAI vs. SAI PRERANA CO-OP CREDIT SOCIETY LTD, MUMBAI

In the result, appeals of the assessee and the Revenue are In the result, appeals of the assessee and the Revenue are In the result, appeals of the assessee and the Revenue are decided as under:

Bench: Shri Kuldip Singh () & Shri Om Prakash Kant () Ita Nos. 217, 220 & 221, 218 & 219, 215, 214/Mum/2023 Assessment Years: 2013-14, 2016-17, 2017-18, 2018-19, 2020-21 Sai Prerana Co-Op Credit Ito-17(3)(2), Society Ltd., Room No. 126, 1St Floor, Vs. 317, Puran Aasha Bldg, Gr. Fl. Kautilya Bhavan, C-41 To C- Narashi Natha Street, Katha 43, G Block Bandra Kurla Bazar Masjid Bunder (W), Complex, Bandra (East), Mumbai-400 009. Mumbai-400051. Pan No. Aadts 5638 M Appellant Respondent

reassessment has to be based on fulfllment of certain prec fulfllment of certain precondition and if the concept of “change ondition and if the concept of “change of opinion” is removed, as contended on behalf of the of opinion” is removed, as contended on behalf of the of opinion” is removed, as contended on behalf of the Department, then

ITO-26(2)(1) , MUMBAI vs. SAI PRERANA CO-OP CREDIT SOCIETY LTD, MUMBAI

In the result, appeals of the assessee and the Revenue are In the result, appeals of the assessee and the Revenue are In the result, appeals of the assessee and the Revenue are decided as under:

Bench: Shri Kuldip Singh () & Shri Om Prakash Kant () Ita Nos. 217, 220 & 221, 218 & 219, 215, 214/Mum/2023 Assessment Years: 2013-14, 2016-17, 2017-18, 2018-19, 2020-21 Sai Prerana Co-Op Credit Ito-17(3)(2), Society Ltd., Room No. 126, 1St Floor, Vs. 317, Puran Aasha Bldg, Gr. Fl. Kautilya Bhavan, C-41 To C- Narashi Natha Street, Katha 43, G Block Bandra Kurla Bazar Masjid Bunder (W), Complex, Bandra (East), Mumbai-400 009. Mumbai-400051. Pan No. Aadts 5638 M Appellant Respondent

reassessment has to be based on fulfllment of certain prec fulfllment of certain precondition and if the concept of “change ondition and if the concept of “change of opinion” is removed, as contended on behalf of the of opinion” is removed, as contended on behalf of the of opinion” is removed, as contended on behalf of the Department, then

INCOME TAX OFFICER-26(2)(1), MUMBAI vs. SAI PRERANA CO-OP CREDIT SOCIETY LTD., MUMBAI

In the result, appeals of the assessee and the Revenue are In the result, appeals of the assessee and the Revenue are In the result, appeals of the assessee and the Revenue are decided as under:

Bench: Shri Kuldip Singh () & Shri Om Prakash Kant () Ita Nos. 217, 220 & 221, 218 & 219, 215, 214/Mum/2023 Assessment Years: 2013-14, 2016-17, 2017-18, 2018-19, 2020-21 Sai Prerana Co-Op Credit Ito-17(3)(2), Society Ltd., Room No. 126, 1St Floor, Vs. 317, Puran Aasha Bldg, Gr. Fl. Kautilya Bhavan, C-41 To C- Narashi Natha Street, Katha 43, G Block Bandra Kurla Bazar Masjid Bunder (W), Complex, Bandra (East), Mumbai-400 009. Mumbai-400051. Pan No. Aadts 5638 M Appellant Respondent

reassessment has to be based on fulfllment of certain prec fulfllment of certain precondition and if the concept of “change ondition and if the concept of “change of opinion” is removed, as contended on behalf of the of opinion” is removed, as contended on behalf of the of opinion” is removed, as contended on behalf of the Department, then

INCOME TAX OFFICER-26(2)(1), MUMBAI vs. SAI PRERANA CO-OP CREDIT SOCIETY LTD., MUMBAI

In the result, appeals of the assessee and the Revenue are In the result, appeals of the assessee and the Revenue are In the result, appeals of the assessee and the Revenue are decided as under:

Bench: Shri Kuldip Singh () & Shri Om Prakash Kant () Ita Nos. 217, 220 & 221, 218 & 219, 215, 214/Mum/2023 Assessment Years: 2013-14, 2016-17, 2017-18, 2018-19, 2020-21 Sai Prerana Co-Op Credit Ito-17(3)(2), Society Ltd., Room No. 126, 1St Floor, Vs. 317, Puran Aasha Bldg, Gr. Fl. Kautilya Bhavan, C-41 To C- Narashi Natha Street, Katha 43, G Block Bandra Kurla Bazar Masjid Bunder (W), Complex, Bandra (East), Mumbai-400 009. Mumbai-400051. Pan No. Aadts 5638 M Appellant Respondent

reassessment has to be based on fulfllment of certain prec fulfllment of certain precondition and if the concept of “change ondition and if the concept of “change of opinion” is removed, as contended on behalf of the of opinion” is removed, as contended on behalf of the of opinion” is removed, as contended on behalf of the Department, then

NAVRATAN MANAGEMENT PRIVATE LIMITED,MUMBAI vs. DY.COMM CENTRAL CIRCLE 8(4) MUMBAI, MUMBAI

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

reassessment proceedings were initiated. The AO added an amount under Section 56(2)(viia) of the Act on account of purchasing

TUTOR INVESTMENT& FINANCE PVT LTD,MUMBAI vs. DCIT, CENTRAL CIRCLE 6(4), MUMBAI

In the result, the appeal of the assesse bearing ITA No

Bench: the ITAT, Mumbai Bench “E”, which, vide its order in ITA No. 6752/Mum/2017 dated 15.06.2018, upheld the revisionary order passed under Section 263 of the Act.

section 56(2)(vii)(b) of the Act. The said addition pertained to the issuance of 10 lakh shares by the assessee at Rs.200 per share to M/s Chinar Commercials Pvt. Ltd. & M/s Chinar Finvest Pvt Ltd, for a total consideration of Rs.20 crores. During the reassessment

SAPPHIRE FOODS INDIA LIMITED,MUMBAI vs. DCIT, CIRCLE 3(3)(1), MUMBAI, MUMBAI

In the result, the appeal is partly allowed

reassessment order:\n6. The Ld. CIT(A) erred in holding that the mistake on the part of the\nLd. AO in quoting section 56(2

SHILPA GAUTAM,MUMBAI vs. ITO, (INT TX), WARD-2(3)(1), MUMBAI

Section 56(2)(vii)(b) of the Act, and therefore, the same are being taken up together hereinafter. The relevant facts in brief are that the Appellant, a non-resident 3. individual, did not file return of income for the Assessment Year 2016-17. Based upon the information received by the Assessing Officer that the Appellant has purchased an immovable

ACIT CIRCLE 22(1), MUMBAI vs. RAJENDRA NARPATMAL LODHA, MUMBAI

Appeal is dismissed

Bench: Shri Amit Shukla, Jm & Ms Padmavathy S, Am

reassessment proceedings by issue of notice under section 148A of the income tax act (the Act). The AO, after passing an order under clause (d) of section 148A issued a notice under section 148 requiring the assessee to file the return of income. The AO also called on the assessee to file the necessary details and to explain why addition

ASST. COMMISSIONER OF INCOME TAX, MUMBAI vs. AADHAAR WHOLESALE TRADING AND DISTRIBUTION LTD., MUMBAI

In the result, appeals of revenue are dismissed and cross\nobjection of the assessee is allowed

reassessment\nproceedings was valid, it is only to be seen whether there was prima\nfacie some material on the basis of which the department could\nreopen the case. The sufficiency or correctness of the material is not a\nthing to be considered at this stage. The Ld. CIT(A) has also relied on\nthe decisions in the cases of Aravali

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.

56(2)(vii)(b) provides that no addition should be made on account of the differencing Agreement Value and the Stamp Duty Value in cases where there is a time difference between the date of agreement and the date of registration provided the payment in full or in part has been made by any account payee cheque or draft

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.

56(2)(vii)(b) provides that no addition should be made on account of the differencing Agreement Value and the Stamp Duty Value in cases where there is a time difference between the date of agreement and the date of registration provided the payment in full or in part has been made by any account payee cheque or draft

GLOBAL BUSINESS CONEXXTIONS PVT.LTD.,MADHYA PRADESH vs. ACIT/DCIT-5(3), MUMBAI

reassessment proceedings were initiated against the Appellant 11. on the ground that income liable to tax in the hands of the Appellant as deemed dividend under Section 2(22)(e) of the Act had escaped assessment. The Assessing Officer made addition of INR 11,83,73,433/- under Section 2(22)(e) of the Act which was confirmed

SAI PRERNA CO-OP. CREDIT SOCIETY LTD,MUMBAI vs. ITO WD 17(3) (2) , MUMBAI

In the result, the appeal of the assessee is partly allowed

Bench: Shri Kuldip Singh () & Shri Om Prakash Kant () Assessment Year: 2012-13 Sai Prerana Co-Op Society Ltd., Ito-7(3)(2), 317, Puran Aasha Bldg. Gr. Fl. Room No. 126, 1St Floor, Narashi Natha Street, Katha Vs. Kautilya Bhavan, C-41 To C- Bazar Musjid Bunder (W), 43 Block, Bandra Kurla Mumbai-400 009. Complex, Bandra (East) Mumbai-400051. Pan No. Aadts 5638 M Appellant Respondent Assessee By : Ms. Ruby Srivastava & Mr. Bharat Kumar, Ca Revenue By : Mr. Milind S. Chavan, Dr Date Of Hearing : 27/04/2023 : Date Of Pronouncement 28/04/2023 Order

reassessment has to be based on fulfllment of certain precondition and if the concept of “change fulfllment of certain precondition and if the concept of “change fulfllment of certain precondition and if the concept of “change of opinion” is removed, as contended on behalf of the of opinion” is removed, as contended on behalf of the of opinion” is removed

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

JAIPRAKASH L. SINGH,MUMBAI vs. ACIT 31(2)(1), MUMBAI

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

2) to Section 150, which restricted the applicability of the\nprovision of Sec. 150 in a case where 6 years have already\nlapsed when appeal order was passed. Since in the present\ncase the appeal order for 2007-08 & 2007-08 was admittedly\npassed on 19.04.2018, but till that time 6 years from