THE ESTATE INVESTMENT COMPANY PRIVATE LIMITED,MUMBAI vs. DCIT CENTRAL CIRCLE 8(1), MUMBAI

unexplained money stand deleted for want of evidence; (ii) the reassessment proceedings initiated under section 148 are quashed for lack

SH. KAMAL GALANI,MUMBAI vs. ACIT 23 (3), MUMBAI

In the result appeal filed by the assesee for Asst

Bench: Shri Mahavir Singh & Shri G. Manjunatha

reassessment order is passed. It is enough if the Assessing Officer can show tentatively or prima facie on the basis of the reasons recorded and with reference to the documents available on record that income has escaped assessment." ix. The above decision of the Hon'ble High Court of Delhi has been authoritative in saying that there should be nexus

M/S A J COAL PVT LTD.,MUMBAI vs. ITO 6 (1)(1), MUMBAI

In the result, both the appeals of the assessee and the In the result, both the appeals of the assessee and the In the result, both the appeals of the assessee and the Revenue are dismissed

Bench: Shri Om Prakash Kant () & Ms. Kavitha Rajagopal () Assessment Year: 2009-10 Ito-6(1)(1), M/S A.J. Coal Pvt. Ltd., Aayakar Bhavan, 24A, Coal Depot, Sewree (E), Vs. Room No. 503, 5Th Floor, M.K. Mumbai-400015. Road, New Marine Lines, Mumbai-400020. Pan No. Aabca 0386 M Appellant Respondent Assessment Year: 2009-10 M/S A.J. Coal Pvt. Ltd., Ito-6(1)(1), C/O M/S Jayesh Sanghrajka & Aayakar Bhavan, Room No. 503, Co. Llp, 405, Hind Rajasthan Vs. 5Th Floor, M.K. Road, New Marine Centre, Ds Phalke Road, Dadar Lines, Mumbai-400020. (East), Mumbai-400014. Pan No. Aabca 0386 M Appellant Respondent

reassessment u/s 148 and hence such assessment made was bad in law and liable to be quashed. was bad in law and liable to be quashed. 2. On the facts and circumstances of the case and On the facts and circumstances of the case and On the facts and circumstances of the case and judicial proposition, Hon. CIT Appeals erred

ITO 6 (1)(1), MUMBAI vs. M/S A J COAL PVT LTD., MUMBAI

In the result, both the appeals of the assessee and the In the result, both the appeals of the assessee and the In the result, both the appeals of the assessee and the Revenue are dismissed

Bench: Shri Om Prakash Kant () & Ms. Kavitha Rajagopal () Assessment Year: 2009-10 Ito-6(1)(1), M/S A.J. Coal Pvt. Ltd., Aayakar Bhavan, 24A, Coal Depot, Sewree (E), Vs. Room No. 503, 5Th Floor, M.K. Mumbai-400015. Road, New Marine Lines, Mumbai-400020. Pan No. Aabca 0386 M Appellant Respondent Assessment Year: 2009-10 M/S A.J. Coal Pvt. Ltd., Ito-6(1)(1), C/O M/S Jayesh Sanghrajka & Aayakar Bhavan, Room No. 503, Co. Llp, 405, Hind Rajasthan Vs. 5Th Floor, M.K. Road, New Marine Centre, Ds Phalke Road, Dadar Lines, Mumbai-400020. (East), Mumbai-400014. Pan No. Aabca 0386 M Appellant Respondent

reassessment u/s 148 and hence such assessment made was bad in law and liable to be quashed. was bad in law and liable to be quashed. 2. On the facts and circumstances of the case and On the facts and circumstances of the case and On the facts and circumstances of the case and judicial proposition, Hon. CIT Appeals erred

THE ESTATE INVESTMENT COMPANY PRIVATE LIMITED,MUMBAI vs. DCIT CENTRAL CIRCLE 8(1), MUMBAI

3012/Mum/2025

Bench: SHRI AMIT SHUKLA (Judicial Member), SHRI ARUN KHODPIA (Accountant Member)

unexplained money stand deleted for want of evidence; (ii) the reassessment proceedings initiated under section 148 are quashed for lack

DCIT CEN CIR 1(1), MUMBAI vs. ARUNKUMAR R MEHTA, MUMBAI

In the result, appeal filed by the revenue is dismissed

Bench: Shri G. Manjunatha & Shri Ram Lal Negidcit, Central Circle-1(1) Vs. Arun Kumar R. Mehta Room No.903, 9Th Floor 1608, Prasad Chamber Old Cgo(Annexe) Behind Tbz, Opera House M.K.Road Mumbai-400 004 Mumbai-400 020 Pan/Gir No.Aabpm3327M Appellant) .. Respondent)

reassessments are pending for those assessment year(s) on the date of search under section 132; there is no obstacle in making addition under section 153A provided some incriminating material in the case of the assessee for any assessment year(s) (referred to in clause (b) of section 153A(1) is unearthed as a result of search under section

AKSHAY KUMAR SAXENA,MUMBAI vs. ITO-4(2)(1), MUMBAI

In the result, the appeal of the assessee is allowed

Bench: Shri Om Prakash Kant () & Shri Sunil Kumar Singh () Assessment Year: 2013-14 Akshay Kumar Saxena, Ito-4(2)(1), A-1604 Rushi Heights, Riddhi Room No. 1702, 17Th Floor, Vs. Gardens Filmcity Road, Malad (E), Air India Building, Nariman Point, Mumbai-400097. Mumbai-400021. Pan No. Axsps 3020 R Appellant Respondent

reassessment order assessment order dated 25/05/2022 has reproduced the relevant document which has reproduced the relevant document which has reproduced the relevant document which was seized in search of M/ in search of M/s Bhagwati Developers s Bhagwati Developers. The assessee contended that entire money contended that entire money for acquisition of flat for acquisition of flat was paid

TANISHQ BUILDERS,MUMBAI vs. THE ACIT CC 2(3), MUMBAI

In the result, the appeal filed by the assessee is allowed, and the appeal filed by the Revenue is dismissed

Bench: SHRI AMIT SHUKLA (Judicial Member), SHRI ARUN KHODPIA (Accountant Member)

reassessment framed under section 147 read with section 143(3) of the Income-tax Act, 1961 (“the Act”). The appeals are cross in nature, founded upon the same appellate order and the same evidentiary base, albeit assailing the same in different directions; accordingly, they are taken up together and are being dealt with by this consolidated order. 2. The sole

ACIT,CENTRAL CIRCLE-2(3), MUMBAI, MUMBAI vs. TANISHQ BUILDERS, MUMBAI

In the result, the appeal filed by the assessee is allowed, and the appeal filed by the Revenue is dismissed

Bench: SHRI AMIT SHUKLA (Judicial Member), SHRI ARUN KHODPIA (Accountant Member)

reassessment framed under section 147 read with section 143(3) of the Income-tax Act, 1961 (“the Act”). The appeals are cross in nature, founded upon the same appellate order and the same evidentiary base, albeit assailing the same in different directions; accordingly, they are taken up together and are being dealt with by this consolidated order. 2. The sole

THE ESTATE INVESTMENT COMPANY PRIVATE LIMITED,MUMBAI vs. DCIT CENTRAL CIRCLE 8(1), MUMBAI

unexplained money are devoid of\nfactual and legal foundation. In the result, the additions\nsustained under the head “Capital Gains” amounting to\n₹4,96,95,000, and under section 69A amounting to ₹2,50,000,\ncannot be upheld and are hereby deleted.\n\n42. Having disposed of the additions of merits, we now turn\nto legal ground concerning

DCIT, CENTRAL CIRCLE-8(1), MUMBAI, MUMBAI vs. THE ESTATE INVESTMENT COMPANY PVT LTD, MUMBAI

unexplained money are devoid of\nfactual and legal foundation. In the result, the additions\nsustained under the head “Capital Gains” amounting to\n₹4,96,95,000, and under section 69A amounting to ₹2,50,000,\ncannot be upheld and are hereby deleted.\n\n42. Having disposed of the additions of merits, we now turn\nto legal ground concerning

THE ESTATE INVESTMENT COMPANY PRIVATE LIMITED,MUMBAI vs. DEPUTY COMMISSIONER OF INCOME TAX CENTRAL CIRCLE -8(1), MUMBAI

unexplained money are devoid of\nfactual and legal foundation. In the result, the additions\nsustained under the head “Capital Gains” amounting to\n₹4,96,95,000, and under section 69A amounting to ₹2,50,000,\ncannot be upheld and are hereby deleted.\n\n42. Having disposed of the additions of merits, we now turn\nto legal ground concerning

DCIT CENTRAL CIRCLE-8(1), MUMBAI, MUMBAI vs. THE ESTATE INVESTMENT COMPANY PRIVATE LIMITED, MUMBAI

unexplained money are devoid of\nfactual and legal foundation. In the result, the additions\nsustained under the head “Capital Gains” amounting to\n₹4,96,95,000, and under section 69A amounting to ₹2,50,000,\ncannot be upheld and are hereby deleted.\n\n42. Having disposed of the additions of merits, we now turn\nto legal ground concerning

DCIT, CENTRAL CIRCLE-8(1), MUMBAI, MUMBAI vs. THE ESTATE INVESTMENT COMPANY PVT LTD, MUMBAI

unexplained money are devoid of\nfactual and legal foundation. In the result, the additions\nsustained under the head “Capital Gains” amounting to\n₹4,96,95,000, and under section 69A amounting to ₹2,50,000,\ncannot be upheld and are hereby deleted.\n\n42. Having disposed of the additions of merits, we now turn\nto legal ground concerning

THE ESTATE INVESTMENT COMPANY PRIVATE LIMITED ,MUMBAI vs. DEPUTY COMMISSIONER OF INCOME TAX CENTRAL CIRCLE -8(1), MUMBAI

unexplained money are devoid of\nfactual and legal foundation. In the result, the additions\nsustained under the head “Capital Gains” amounting to\n₹4,96,95,000, and under section 69A amounting to ₹2,50,000,\ncannot be upheld and are hereby deleted.\n\n42. Having disposed of the additions of merits, we now turn\nto legal ground concerning

THE ESTATE INVESTMENT COMPANY PRIVATE LIMITED,MUMBAI vs. DEPUTY COMMISSIONER OF INCOME TAX CENTRAL CIRCLE -8(1), MUMBAI

unexplained money are devoid of\nfactual and legal foundation. In the result, the additions\nsustained under the head “Capital Gains” amounting to\n₹4,96,95,000, and under section 69A amounting to ₹2,50,000,\ncannot be upheld and are hereby deleted.\n\n42. Having disposed of the additions of merits, we now turn\nto legal ground concerning

THE ESTATE INVESTMENT COMPANY PRIVATE LIMITED,MUMBAI vs. DCIT CENTRAL CIRCLE 8(1), MUMBAI

unexplained money are devoid of\nfactual and legal foundation. In the result, the additions\nsustained under the head “Capital Gains” amounting to\n₹4,96,95,000, and under section 69A amounting to ₹2,50,000,\ncannot be upheld and are hereby deleted.\n\n42. Having disposed of the additions of merits, we now turn\nto legal ground concerning

HUBTOWN LIMITED,MUMBAI vs. ASSISTANT COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE 2(4), MUMBAI

In the result, the appeal of the assessee is allowed and the appeal of the revenue is dismissed

Bench: Shri Anikesh Banerjee & Shri Prabhash Shankar

Unexplained money, etc. 69A. Where in any financial year the assessee is found to be the owner of any money, bullion, jewellery or other valuable article and such money, bullion, jewellery or valuable article is not recorded in the books of account, if any, maintained by him for any source of income, and the assessee offers no explanation about