ASST CIT CIR 2, THANE vs. SALASAR DEVELOPERS, THANE

The appeals of the Revenue are dismissed

Bench: Shri Joginder Singh & Shri N.K. Pradhan

reassess' to completed assessment proceedings. vi. Insofar as pending assessments are concerned, the jurisdiction to make the original assessment and the assessment under Section 153A merges into one. Only one assessment shall be made separately for each AY on the basis of the findings of the search and any other material existing or brought on the record

ASST CIT CIR 2, THANE vs. SALASAR DEVELOPERS, THANE

The appeals of the Revenue are dismissed

Bench: Shri Joginder Singh & Shri N.K. Pradhan

reassess' to completed assessment proceedings. vi. Insofar as pending assessments are concerned, the jurisdiction to make the original assessment and the assessment under Section 153A merges into one. Only one assessment shall be made separately for each AY on the basis of the findings of the search and any other material existing or brought on the record

M/S.BALAJI BULLION & COMMODITIES (INDIA) PRIVATE LIMITED,MUMBAI vs. DCIT CENTRAL CIRCLE-40, MUMBAI

In the result, both the appeals are allowed

Bench: Shri Prashant Maharishi, Am & Shri Amarjit Singh, Jm Balaji Bullion & Commodities The Dy. Commissioner Of (India) Private Limited Income–Tax, 118/120, 3Rd Floor, Ashoka Central Circle–40, Vs. House Zavri Baazar, Mumbai Mumbai-400 002 (Appellant) (Respondent) Pan No. Aadcbo236F Balaji Universal Tradelinks P. The Dy. Commissioner Of Ltd. Income–Tax, 118/120, 3Rd Floor, Ashoka Central Circle–40, Vs. House Zavri Baazar, Mumbai Mumbai-400 002

66,124/- on account of Alleged Expenses Capitalised. Looking to the facts and in the circumstances of your Appellant's case the said addition made by the Ld. A.O. is incorrect and invalid and ought to be deleted. 17. On the facts and the circumstances of the case and in law, the Ld. A. O. erred in not re-computing

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

reassessment proceedings in the case of the Assessee. In\nthe present case the return of income was filed by the Assessee for\nthe Assessment Year 2012-2013 was processed under Section\n143(1) of the Act and no scrutiny assessment was framed on the\nAssessee under Section 143(3) of the Act. Therefore, it was\nirrelevant whether the income

BHUSHAN VASANT PARELKAR,MUMBAI vs. WARD 41(2)(1), MUMBAI, MUMBAI

In the result, appeal of the assessee is allowed

Bench: Smt Beena Pillai & Shri Girish Agrawalassessment Year: 2013-14 Bhushan Vasant Parelkar Income Tax Officer, A-204 Saikripa, Navghar Ward 41(2)(1), Road, Mulund East S.O, Vs Mumbai Mumbai - 400081 (Pan: Akdpp6556D) Appellant Respondent Present For: Appellant By : Shri Dharan Gandhi, Advocate Respondent By : Shri Bhagirath Ramawat, Sr. Dr Date Of Hearing : 21.01.2026 Date Of Pronouncement : 30.01.2026 O R D E R Per Girish Agrawal: This Appeal Filed By The Assessee Is Against The Order Of Ld. Cit(A), National Faceless Appeal Centre (Nfac), Delhi, Vide Order No. Itba/Nfac/S/250/2025-26/1079866363(1), Dated 22.08.2025, Passed Against The Assessment Order By Ito, Ward-41(2)(1),, U/S. 147 Of The Income-Tax Act (Hereinafter Referred To As The “Act”), Dated 31.05.2023 For Assessment Year 2013-14. 2. Grounds Taken By The Assessee Are Reproduced As Under: “The Ld. Cit(A) Erred In Confirming The Action Of Ld. Ao Of Reopening The Assessment U/S 147 Although The Reopening Is Time Barred & Hence Bad In Law. Bhushan Vasant Parelkar Ay 2013-14

66,76,000/- has escaped assessment within the meaning of section 147 of the Act. Accordingly, notice u/s.148 was issued on 31.05.2021. 4.1. Chronology of events which took place in the present case for which the relevant material is on record is tabulated below for ready reference, as furnished by the ld. Counsel for the assessee: Sr.No. Event Date/days 1

MANOHAR MANAK ALLOYS P.LTD,MUMBAI vs. ACIT 4(2), MUMBAI

Appeal is allowed

reassessment order passed by ld. A.O. 147 r.w.s.143(3) holding wrongly the said assessment order erroneous as well as prejudicial to the interest of revenue. 2. That the ld. Principal CIT while setting aside the assessment order has erred in erroneously applying the concept of accrual system of accounting in the case by overlooking the concept of real income theory

BERMACO ENERGY SYSTEMS LTD,NAVI MUMBAI vs. DCIT CC 47, MUMBAI

In the result, appeal for A

reassessment orders when the search was initiated or the requisition was made. 22. In the light of our discussion, we find it difficult to uphold the view of the Tribunal expressed in Para 9.6 of its order that since the returns of income filed by the assessee for all the six years under consideration before the search took place were

BERMACO ENERGY SYSTEMS LTD,NAVI MUMBAI vs. DCIT CC 47, MUMBAI

In the result, appeal for A

reassessment orders when the search was initiated or the requisition was made. 22. In the light of our discussion, we find it difficult to uphold the view of the Tribunal expressed in Para 9.6 of its order that since the returns of income filed by the assessee for all the six years under consideration before the search took place were

BERMACO ENERGY SYSTEMS LTD,NAVI MUMBAI vs. DCIT CC 47, MUMBAI

In the result, appeal for A

reassessment orders when the search was initiated or the requisition was made. 22. In the light of our discussion, we find it difficult to uphold the view of the Tribunal expressed in Para 9.6 of its order that since the returns of income filed by the assessee for all the six years under consideration before the search took place were

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

reassessment proceedings in the case of the Assessee. In\nthe present case the return of income was filed by the Assessee for\nthe Assessment Year 2012-2013 was processed under Section\n143(1) of the Act and no scrutiny assessment was framed on the\nAssessee under Section 143(3) of the Act. Therefore, it was\nirrelevant whether the income

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)

1) of section 153A. This amendment will take effect from 1st June, 2015. 65 I.T.A. No. 612/Mum/2020 Mr. Nilesh Bharani 55. Thus, on a bare perusal of the plain language of the above explanation in respect of the amendment introduced in the section 153C of the Act w.e.f. 01/06/2015, we find that it mandates that in case any information

M/S. PATANJALI FOODS LTD (FORMERLY KNOWN AS RUCHI SOYA INDUSTRIES LTD),MUMBAI vs. DY COMM OF INCOME TAX- CENTRAL CIRCLE-7(2), MUMBAI

In the result, the appeal and cross objections of the assessee are partly allowed and the appeals of the revenue are dismissed

Bench: Shri Aby T. Varkey, Jm & Shri S Rifaur Rahman, Am आयकर अपील सं/ I.T. A. No. 1172/Mum/2023 (निर्धारण वर्ा / Assessment Year: 2010-11) & आयकर अपील सं/ I.T. A. No. 1175/Mum/2023 (निर्धारण वर्ा / Assessment Year: 2012-13) & आयकर अपील सं/ I.T. A. No. 1176/Mum/2023 (निर्धारण वर्ा / Assessment Year: 2012-13)

reassessment, if any, relating to any assessment year falling within the period of six assessment years referred to in sub-section (1) is pending on the date of initiation of the search u/s. 132 of the Act shall abate. In the present case before us, however, though the second proviso to sub-section (1) of section 153A would not apply

DCIT, CC-7(2), MUMBAI vs. M/S. PATANJALI FOODS LTD.,( FORMERLY KNOWN AS RUCHI SOYA INDUSTRIES LTD,, MUMBAI

In the result, the appeal and cross objections of the assessee are partly allowed and the appeals of the revenue are dismissed

Bench: Shri Aby T. Varkey, Jm & Shri S Rifaur Rahman, Am आयकर अपील सं/ I.T. A. No. 1172/Mum/2023 (निर्धारण वर्ा / Assessment Year: 2010-11) & आयकर अपील सं/ I.T. A. No. 1175/Mum/2023 (निर्धारण वर्ा / Assessment Year: 2012-13) & आयकर अपील सं/ I.T. A. No. 1176/Mum/2023 (निर्धारण वर्ा / Assessment Year: 2012-13)

reassessment, if any, relating to any assessment year falling within the period of six assessment years referred to in sub-section (1) is pending on the date of initiation of the search u/s. 132 of the Act shall abate. In the present case before us, however, though the second proviso to sub-section (1) of section 153A would not apply

DCIT 2(2)(1), MUMBAI vs. STATE BANK OF INDIA, MUMBAI

The appeal of the Revenue is dismissed

Bench: Shri Joginder Singh & Shri N.K. Pradhanassessment Year: 1995-96 Dcit-2(2)(1), M/S State Bank Of India, R. No.545, Financial Reporting & बनाम/ Aayakar Bhavan Taxation Department, 3Rd Vs. M.K. Road, Floor, Corporate Centre, Mumbai-400020 State Bank Bhavan, Madam Cama Road, Nariman Point, Mumbai-400021 (राज"व /Revenue) ("नधा"रती /Assessee) P.A. No. Aaacs8577K

66,97, 81,957/-. The AO competed the assessment on 13.2.04 u/s. 133 of the Act determing the income of assessee at Rs.26,35,49,42,360/- 2.Effective ground of appeal is about not granting of interest u/s.244A of the Act.The brief facts of the case are that the assessee had offered "interest accrued but not due on securities

DCIT, CC-7(2), MUMBAI vs. M/S. PATANJALI FOODS LTD.,( FORMERLY KNOWN AS RUCHI SOYA INDUSTRIES LTD,, MUMBAI

In the result the appeal filed by the revenue stands dismissed

Bench: Shri Sandeep Gosain & Shri Prabhash Shankar

reassessment, if any, relating to any assessment year falling within the period of six assessment years referred to 11 Patanjali Foods Ltd, Mumbai. in sub-section (1) is pending on the date of initiation of the search u/s. 132 of the Act shall abate. In the present case before us, however, though the second proviso to sub-section (1

DCIT, CC-7(2), MUMBAI vs. M/S. PATANJALI FOODS LTD.,( FORMERLY KNOWN AS RUCHI SOYA INDUSTRIES LTD,, MUMBAI

In the result the appeal filed by the revenue stands dismissed

Bench: Shri Sandeep Gosain & Shri Prabhash Shankar

reassessment, if any, relating to any assessment year falling within the period of six assessment years referred to 11 Patanjali Foods Ltd, Mumbai. in sub-section (1) is pending on the date of initiation of the search u/s. 132 of the Act shall abate. In the present case before us, however, though the second proviso to sub-section (1

KASHYAP KANIYALAL MEHTA,MUMBAI vs. DCIT CC-4(1), MUMBAI

In the result, appeals of the assessee are allowed

66,83,960/-. The said return was processed under section 143(1) of the Act and no scrutiny assessment was framed thereafter. Subsequently, information was received from the Directorate of Investigation, Kolkata indicating that the assessee had allegedly booked accommodation entries in the nature of long-term capital gains through certain penny stock companies. Based on the said information

KASHYAP KANIYALAL MEHTA,MUMBAI vs. DCIT CC-4(1), MUMBAI

In the result, appeals of the assessee are allowed

66,83,960/-. The said return was processed under section 143(1) of the Act and no scrutiny assessment was framed thereafter. Subsequently, information was received from the Directorate of Investigation, Kolkata indicating that the assessee had allegedly booked accommodation entries in the nature of long-term capital gains through certain penny stock companies. Based on the said information