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

6\ngrounds of appeal which are taken up hereinafter in seriatim.\nGround No.1 & 2\n26. Ground No. 1 & 2 raised by the Assessee challenged the validity\nof the reassessment proceedings read as under:\n“1. The CIT(A) erred in confirming the action of the AO by\ntreating the reassessment order passed under section

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

6\ngrounds of appeal which are taken up hereinafter in seriatim.\nGround No.1 & 2\n26. Ground No. 1 & 2 raised by the Assessee challenged the validity\nof the reassessment proceedings read as under:\n\"1. The CIT(A) erred in confirming the action of the AO by\ntreating the reassessment order passed under section

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

6\ngrounds of appeal which are taken up hereinafter in seriatim.\n\nGround No.1 & 2\n\n26. Ground No. 1 & 2 raised by the Assessee challenged the validity\nof the reassessment proceedings read as under:\n\n“1. The CIT(A) erred in confirming the action of the AO by\ntreating the reassessment order passed under section

THE NEW INDIA ASSURANCE CO. LTD,MUMBAI vs. ASSISTANT COMMISSIONER OF INCOME TAX , INCOME TAX OFFICER, NFAC, MUMBAI

Accordingly, in terms of the aforesaid, Ground No. 3 to\n7 raised by the Assessee pertaining to merits of such\nadditions/disallowances are dismissed as having been rendered\ninfructuous

Bench: "CLEAN_TEXT": "IN THE INCOME TAX APPELLATE TRIBUNAL\n\"I\" BENCH, MUMBAI\n\nSHRI VIKRAM SINGH YADAV , ACCOUNTANT MEMBER\nSHRI RAHUL CHAUDHARY (Judicial Member)

6\ngrounds of appeal which are taken up hereinafter in seriatim.\n\nGround No.1 & 2\n\n26.\nGround No. 1 & 2 raised by the Assessee challenged the validity\nof the reassessment proceedings read as under:\n\n“1. The CIT(A) erred in confirming the action of the AO by\ntreating the reassessment order passed under section

SURENDRA GARG HUF,MUMBAI vs. ITO - 19(3)(4), MUMBAI

reassessment proceedings on incorrect understanding of\nfacts. We note that the Assessing Officer had identified the Assessee\nas a beneficiary of accommodation entries taken by the Assessee in\nrespect of sale of 44200 shares of KGN Enterprises. Admittedly, in\naggregate 44,200 share of KGN Enterprises were sold by the\nAssessee during the previous year(s) relevant to Assessment Years

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

6 \ngrounds of appeal which are taken up hereinafter in seriatim. \nGround No.1 & 2 \n26. Ground No. 1 & 2 raised by the Assessee challenged the validity \nof the reassessment proceedings read as under: \n“1. The CIT(A) erred in confirming the action of the AO by \ntreating the reassessment order passed under section

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

Accordingly, in terms of the aforesaid, Ground No. 3 to\n7 raised by the Assessee pertaining to merits of such\nadditions/disallowances are dismissed as having been rendered\ninfructuous

6\ngrounds of appeal which are taken up hereinafter in seriatim.\n\nGround No.1 & 2\n\n26. Ground No. 1 & 2 raised by the Assessee challenged the validity\nof the reassessment proceedings read as under:\n\n“1. The CIT(A) erred in confirming the action of the AO by\ntreating the reassessment order passed under section

LIC HOUSING FINANCE LIMITED,MUMBAI vs. ACIT 2(2)(1), MUMBAI, AAYKAR BHAVAN, MUMBAI

In the result, the appeal of the assessee is allowed

Bench: Shri Om Prakash Kant () & Shri Raj Kumar Chauhan () Assessment Year: 2017-18

6. We must also keep in mind the conceptual difference between power to review and power to reassess. The between power to review and power to reassess. The between power to review and power to reassess. The assessing officer has no power to review; he has the power assessing officer has no power to review; he has the power assessing

SALTWATER STUDIO LLP,MUM vs. NATIONAL FACELESS ASSESSMENT CENTRE, DELHI

In the result, the appeal of the assessee is allowed

Bench: Shri Aby T. Varkey, Jm & Shri Om Prakash Kant, Am आयकरअपीलसं/ I.T.A. No.13/Mum/2023 (निर्धारणवर्ा / Assessment Year: 2017-18) बिधम / Saltwater Studio Llp Nfac, Delhi 103, Corporate Corner, F Block, Northe Block, Vs. Sunder Nagar, Near Dalmia New Delhi-110001 College, Malad (West) Mumbai-400 064 स्थधयीलेखधसं/.जीआइआरसं/.Pan/Gir No. : Ackfs1653D (अपीलार्थी / Appellant) .. (प्रत्यर्थी / Respondent)

section (1) has been initiated; (b) in a case where an assessment or reassessment has the effect of reducing the loss declared in the return or converting that 6

JAYANTILAL RAJMAL SETH,MUMBAI vs. DCIT-CC-4(3), MUMBAI, MUMBAI

Bench: Shri Om Prakash Kant () & Shri Raj Kumar Chauhan () Assessment Year: 2018-19 Jayantilal Rajmal Seth, Dcit-Cc-4(3), A-3, Saibaba Shopping Centre, Bkc, Mumbai-400051. Mumbai Central, Vs. Mumbai-400008. Pan No. Agepj 0499 E Appellant Respondent

reassessment order dated 25.02.2022 as having become infructuous and, accordingly, 25.02.2022 as having become infructuous and, accordingly, 25.02.2022 as having become infructuous and, accordingly, proceeded to issue a fresh notice under section 148A(b) of the Act proceeded to issue a fresh notice under section 148A(b) of the Act proceeded to issue a fresh notice under section 148A

SHRI AMIT MANGILAL JAIN,MUMBAI vs. ACIT, - 33(1), MUMBAI

In the result, both the above appeals are allowed

Bench: Shri Sandeep Gosain & Shri Prabhash Shankar

reassessment based on such documents must be made only under section 153C and not u/s 147. Therefore, the invocation of section 147 in this context is not legally valid. 5.4 The ld.AR has strongly relied upon the latest decision of hon'ble Bombay High Court in the case of Sejal Jewellery 2025(2) TMI 870-Bombay wherein it held that

INCOME TAX OFFICER-12(3)(1), MUMBAI, MUMBAI vs. MANJU DIAMONDS PVT. LTD., MUMBAI

In the result, the appeal of the Revenue is allowed for statistical purposes whereas the application under Rule 27 of statistical purposes whereas the application under Rule 27

Bench: Shri Om Prakash Kant () & Shri Raj Kumar Chauhan () Assessment Year: 2017-18 Ito-12(3)(1), Manju Diamonds Pvt. Ltd., R.No. 145, 1St Floor, Aayakar 57/59, 1St Floor, Nagdevi Street, Vs. Bhavan, M.K. Road, Maszid Bunder, Mumbai-400020. Mumbai-400 003. Pan No. Aaecm 6609 G Appellant Respondent

reassessment completed u/s 147 of the Act is concerned, before the Ld. CIT(A), the assessee Ld. CIT(A), the assessee referred to the provisions of section 153C of referred to the provisions of section 153C of the Act and submitted that information was obtained from the the Act and submitted that information was obtained from

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 143(3) had been done in the case of appellant. 4. In the facts and circumstances of the case and in law, the Learned CIT 4. In the facts and circumstances of the case and in law, the Learned CIT 4. In the facts and circumstances of the case and in law, the Learned CIT (A) has erred

MR. SATYA PRAKASH SINGH,MUMBAI vs. ITO, WARD-28(3)(1), VASHI

In the result, the ground so taken by the assessee so far as it relates to challenging the order of the AO as passed beyond the period of limitation is hereby allowed

Bench: Justice (Retd.) Shri C.V. Bhadang & Shri Vikram Singh Yadav

reassessment or recomputation, as the case may be, ends before the end of the month, such period shall be extended to the end of such month.] Explanation 2.—For the purposes of this section, where, by an order referred to in clause (i) of sub-section (6

ITO-28(3)(1), MUMBAI, MUMBAI vs. SATYA PRAKASH SINGH, MUMBAI

In the result, the ground so taken by the assessee so far as it relates to challenging the order of the AO as passed beyond the period of limitation is hereby allowed

Bench: Justice (Retd.) Shri C.V. Bhadang & Shri Vikram Singh Yadav

reassessment or recomputation, as the case may be, ends before the end of the month, such period shall be extended to the end of such month.] Explanation 2.—For the purposes of this section, where, by an order referred to in clause (i) of sub-section (6

JCIT CENT. CIR. - 1(4), MUMBAI vs. GRASIM INDUSTRIES LTD, MUMBAI

The appeal of the Revenue is dismissed whereas appeal of the assessee is partly allowed for statistical purposes

Bench: Shri Om Prakash Kant () & Ms. Kavitha Rajagopal () Assessment Year: 2010-11 Grasim Industries Limited, The Dcit Cc-1(4), Corporate Finance Division, Room No. 902, 9Th Floor, Old Vs. A-2, Aditya Birla Centre, S.K. Cgo Building, M.K. Road, Ahire Marg, Worli, Mumbai-400020. Mumbai-400030. Pan No. Aaacg 4464 B Appellant Respondent Assessment Year: 2010-11 Jcit (Osd), Central Circle- Grasim Industries Limited, 1(4), A-Wing, 2Nd Floor, Aditya Room No. 902, Pratishtha Vs. Birla Centre, S.K. Ahire Bhavan, 9Th Floor, Old Cgo Marg, Worli, Building Annexe, Mumbai-400030. Mumbai-400020. Pan No. Aaacg 4464 B Appellant Respondent Assessee By : Mr. Yogesh Thar & Mr. Chaitanya Joshi Revenue By : Dr. Kishor Dhule, Cit-Dr Date Of Hearing : 03/04/2024 : Date Of Pronouncement 29/04/2024

reassessment as well as merit of the ment as well as merit of the addition. 5. The Ld. CIT(A) though up The Ld. CIT(A) though upheld the validity of the notice issued held the validity of the notice issued u/s 153C of the Act however, held that under the proceedings of u/s 153C of the Act however, held

SANJIB SUDHIR PRADHAN,MUMBAI vs. INCOME TAX OFFICER, 15(1)(1), MUMBAI

In the result, the appeal by the assessee is partly allowed for statistical purposes

Bench: Shri Om Prakash Kant & Shri Sandeep Singh Karhail

section 68 of the Act in receipts of agricultural activity. 12. The brief facts of the case pertaining to this issue, as emanating from the record, are: During the year under consideration, the assessee has shown agricultural income of Rs. 6,25,200. During the reassessment

SANJIB SUDHIR PRADHAN,MUMBAI vs. ITO, 15(1)(1), MUMBAI

In the result, the appeal by the assessee is partly allowed for statistical purposes

Bench: Shri Om Prakash Kant & Shri Sandeep Singh Karhail

section 68 of the Act in receipts of agricultural activity. 12. The brief facts of the case pertaining to this issue, as emanating from the record, are: During the year under consideration, the assessee has shown agricultural income of Rs. 6,25,200. During the reassessment