SWANSTON MULTIPLEX CINEMAS P.LTD,MUMBAI vs. ASST CIT CIR 11(1), MUMBAI

The appeal of the assessee is partly allowed

Bench: Shri Joginder Singh & Shri G. Manjunathaassessment Year: 2005-06 Swanston Multiplex Cinemas Acit, Private Limited, Circle-11(1), बनाम/ 9Th Floor, Viraj Towers, W.E. R. No.467, Vs. Highway Next To Andheri Aayakar Bhavan, Flyover Andheri (East), M. K. Road, Mumai-400093 Mumbai-400020 ("नधा"रती/Assessee) (राज"व /Revenue) Pan No.:-Aafcs6295K

reassessment was held to be valid. In the case of Convergys Customer Management v. Asst. DIT, (2013) 357 ITR 177 (Del), where there being prima facie material in the possession of the Assessing Officer to form a tentative belief that section 9(1)(i) held attracted, said reason by itself constituted a relevant ground to reopen the assessment

DCIT 5(2), MUMBAI vs. LAHOTI OVERSEAS LTD, MUMBAI

In the result, appeal of the assessee company in ITA

Bench: Shri Amit Shukla & Shri Ramit Kocharआयकर अपील सं./I.T.A. No. 3812/Mum/2012 ("नधा"रण वष" / Assessment Year : 2003-04) Dy. Commissioner Of Income M/S Lahoti Overseas Ltd., बनाम/ Tax , 5(2),Room No. 571, 307, Arun Chambers, V. 5 Th Floor, Tardeo Road, Tardeo, Aayakar Bhavan, Mumbai - 400034. M.K. Road, Mumbai – 400 020. "थायी लेखा सं./Pan : Aaacl2578 H .. (अपीलाथ" /Appellant) (""यथ" / Respondent)

reassessments can be framed u/s 147/148 of the Act if no new tangible material has come to the notice of the A.O. as there is no reason to believe based upon the new tangible material coming into the possession of the A.O. which could lead to forming an opinion that an income has escaped assessment, thus, it would warrant that

DCIT (IT) 1(3)(2), MUMBAI vs. B4U INTERNATIONAL HOLDINGS LTD,

In the result, both the appeals of the revenue are dismissed

Bench: Shri B.R. Baskaran (Am) & Shri Ravish Sood(Jm)

Permanent Establishment in India, the Ld CIT(A) also held that the additions made by the AO is not sustainable. The revenue is challenging the decision rendered by Ld CIT(A). 7. We heard the parties and perused the record. We notice the Ld CIT(A) has held that the reopening of assessment is bad in law by considering

DCIT(IT)-4(1)(2), MUMBAI vs. ARUN MADHAVACHARI RANGACHARI, MUMBAI

reassessment proceedings u's 147 of the Income tax Act in the\ncase of Sh. Arun Rangachari has been initiated and in the said proceedings, the above\nstated Income has been added in the hands of Sh. Arun Rangachari on substantive\nbasis.\n14 The notice u/s 148 of the IT Act was issued on 30/03/2016. But the case was\nreferred

WORLD SPORT GROUP (MAURITIUS) LTD,MUMBAI vs. DCIT (IT) 4(3)(2), MUMBAI

In the result, appeal of the assessee is allowed

147 of the Act. 3. Based on the facts and circumstances of the case and in law, the AO/Hon'ble DRP have erred in assessing the receipts pursuant to the Facilitation Services Deed ('FS Deed') as income of the Appellant disregarding that such receipts are already taxed in the hands of World Sport Group (India) Private Limited ('WSGI") and thereby

DORF KETAL CHEMICALS (I) P.LTD,MUMBAI vs. DCIT CEN CIR 45, MUMBAI

In the result, the appeal of the revenue is dismissed

Bench: Shri M.Balaganesh, Am & Shri Amarjit Singh, Jm M/S. Dorf Ketal Chemicals India Vs. Commissioner Of Income Private Limited Tax (Appeals) – 50 Room No.514, 5Th Floor 3, Dorf Ketal Tower Ramchandra Lane Earnest House Opp. Idbi Bank Nariman Point Kanchpada, Malad West Churchgate, Mumbai – 400 064 Mumbai - 400021 Pan/Gir No. Aaacd3819P (Appellant) .. (Respondent)

reassessment done u/s 147 of the Act and proceedings u/s 153A of the Act. Thus, the tribunal remanded the case back to file of CIT(A) for adjudication of claim of dividend received from its Brazilian subsidiary as exempt in India in view of beneficial provisions in DTAA between India and Brazil. 3.1. We find that this Tribunal had placed

ADIT (IT)-3(1), MUMBAI vs. M/S. GLOBAL CRICKET CORPORATION PTE. LTD., MUMBAI

Appeal of the Revenue is dismissed, and cross-objection by the Assessee are disposed off as infructuous

reassessment proceedings were initiated, inter alia, in view of the information/material gathered during the assessment proceedings for the Assessment Year 2002-03 and assessment order dated 31.03.2005 was passed under Section 147 read with Section 143(3) of the Act. 1.2. Appeals preferred by the Assessee for the Assessment Year 2002-03 and 2003-04 were partly allowed

M/S. GLOBAL CRICKET CORPORATION PTE. LTD.,MUMBAI vs. ADIT (INT. TAXATION) - 3(1), MUMBAI

Appeal of the Revenue is dismissed, and cross-objection by the Assessee are disposed off as infructuous

reassessment proceedings were initiated, inter alia, in view of the information/material gathered during the assessment proceedings for the Assessment Year 2002-03 and assessment order dated 31.03.2005 was passed under Section 147 read with Section 143(3) of the Act. 1.2. Appeals preferred by the Assessee for the Assessment Year 2002-03 and 2003-04 were partly allowed

M/S. GLOBAL CRICKET CORPORATION PTE. LTD.,MUMBAI vs. DDIT IT-3(1), MUMBAI

Appeal of the Revenue is dismissed, and cross-objection by the Assessee are disposed off as infructuous

reassessment proceedings were initiated, inter alia, in view of the information/material gathered during the assessment proceedings for the Assessment Year 2002-03 and assessment order dated 31.03.2005 was passed under Section 147 read with Section 143(3) of the Act. 1.2. Appeals preferred by the Assessee for the Assessment Year 2002-03 and 2003-04 were partly allowed

JCIT (IT) (OSD)-4(1)(2), MUMBAI vs. ARUN RANGACHARI, MUMBAI

reassessment proceedings u's 147 of the\nIncome Tax Act in the case of Sh. Arun Rangachari has been\ninitiated and in the said proceedings, the above stated income has\nbeen added in the hands of Sh. Arun Rangachari on substantive\nbasis.\n14 The notice u/s 148 of the IT Act was issued on 30/03/2016.\nBut the case was referred

KHANGARAM K. DEWASI,MUMBAI vs. DCIT- CC-2(3), MUMBAI

In the result, the appeal

Bench: Shri Om Prakash Kant () & Shri Sandeep Singh Karhail () Assessment Year: 2008-09 & Assessment Year: 2009-10 & Assessment Year: 2010-11 Mr. Khangaram K. Dewasi, Prop. The Dcit, Central Circle-2(3), Of Shreenathji Metal & Alloys, Mumbai-21 Shop No. 5, Sultan Market, Opp. Vs. Ash Krishna Bldg. Andheri Ghatkoper Road, Sakinaka, Andheri (East), Mumbai-400072. Pan No. Aeepd 8897 C Appellant Respondent Assessee By : Mr. Bharat Kumar, Ar Revenue By : Mr. Ajeya Kumar Ojha, Dr Date Of Hearing : 28/06/2022 Date Of Pronouncement : 05/08/2022

u/s. 147 and notice u/s148 of the IT Act may be issued accordingly. the IT Act may be issued accordingly.” 7. The Ld. counsel Ld. counsel of the assessee submitted that presumably the of the assessee submitted that presumably the source of information for the source of information for the Assessing Officer is a list of suspicious is a list

KHANGARAM K DEWASI,MUMBAI vs. DCIT ,CC-2(3), MUMBAI

In the result, the appeal

Bench: Shri Om Prakash Kant () & Shri Sandeep Singh Karhail () Assessment Year: 2008-09 & Assessment Year: 2009-10 & Assessment Year: 2010-11 Mr. Khangaram K. Dewasi, Prop. The Dcit, Central Circle-2(3), Of Shreenathji Metal & Alloys, Mumbai-21 Shop No. 5, Sultan Market, Opp. Vs. Ash Krishna Bldg. Andheri Ghatkoper Road, Sakinaka, Andheri (East), Mumbai-400072. Pan No. Aeepd 8897 C Appellant Respondent Assessee By : Mr. Bharat Kumar, Ar Revenue By : Mr. Ajeya Kumar Ojha, Dr Date Of Hearing : 28/06/2022 Date Of Pronouncement : 05/08/2022

u/s. 147 and notice u/s148 of the IT Act may be issued accordingly. the IT Act may be issued accordingly.” 7. The Ld. counsel Ld. counsel of the assessee submitted that presumably the of the assessee submitted that presumably the source of information for the source of information for the Assessing Officer is a list of suspicious is a list

KHANGARAM K. DEWASI,MUMBAI vs. DCIT, CC-2(3), MUMBAI

In the result, the appeal

Bench: Shri Om Prakash Kant () & Shri Sandeep Singh Karhail () Assessment Year: 2008-09 & Assessment Year: 2009-10 & Assessment Year: 2010-11 Mr. Khangaram K. Dewasi, Prop. The Dcit, Central Circle-2(3), Of Shreenathji Metal & Alloys, Mumbai-21 Shop No. 5, Sultan Market, Opp. Vs. Ash Krishna Bldg. Andheri Ghatkoper Road, Sakinaka, Andheri (East), Mumbai-400072. Pan No. Aeepd 8897 C Appellant Respondent Assessee By : Mr. Bharat Kumar, Ar Revenue By : Mr. Ajeya Kumar Ojha, Dr Date Of Hearing : 28/06/2022 Date Of Pronouncement : 05/08/2022

u/s. 147 and notice u/s148 of the IT Act may be issued accordingly. the IT Act may be issued accordingly.” 7. The Ld. counsel Ld. counsel of the assessee submitted that presumably the of the assessee submitted that presumably the source of information for the source of information for the Assessing Officer is a list of suspicious is a list

ITO 2(1)(1), MUMBAI vs. AAA TECHNOLOGIES P.LTD, MUMBAI

Bench: Shri C.N. Prasad, Hon'Ble & Shri Manoj Kumar Aggarwal, Hon'Ble

reassessment order passed u/s. 143(3) r.w.s 147 of the Act is quashed, the appeal filed by the Revenue for the A.Y. 2009-10 will not survive and the same is dismissed as infructuous. 14. Now we take up the appeal in ITA.No. 3455/Mum/2017 for the A.Y.2012-13. This appeal is filed by the Revenue challenging the order

ITO 2(1)(1), MUMBAI vs. AAA TECHNOLOGIES P.LTD, MUMBAI

Bench: Shri C.N. Prasad, Hon'Ble & Shri Manoj Kumar Aggarwal, Hon'Ble

reassessment order passed u/s. 143(3) r.w.s 147 of the Act is quashed, the appeal filed by the Revenue for the A.Y. 2009-10 will not survive and the same is dismissed as infructuous. 14. Now we take up the appeal in ITA.No. 3455/Mum/2017 for the A.Y.2012-13. This appeal is filed by the Revenue challenging the order

PARTAB GULABRAI TULSIANI,DELHI vs. ACIT, INT. TAX CIRCLE 4(2)(1), MUMBAI, MUMBAI

In the result, all appeals filed by the respective assesses are allowed

Bench: Shri Amit Shukla & Shri Vikram Singh Yadav

reassessment stage nor at the appellate stage, has the assessee been able to produce satisfactory details sufficiency of assessee‟s additional evidence filed during appellate proceedings, adds weight to the specific findings given and lacunae pointed out in para supra due to which the peak credit in these accounts was held as taxable in India. In view of the above

JAWAHARLAL GULABRAI TULSIANI,DELHI vs. ACIT, INT. TAX CIRCLE 4(2)(1), MUMBAI

In the result, all appeals filed by the respective assesses are allowed

Bench: Shri Amit Shukla & Shri Vikram Singh Yadav

reassessment stage nor at the appellate stage, has the assessee been able to produce satisfactory details sufficiency of assessee‟s additional evidence filed during appellate proceedings, adds weight to the specific findings given and lacunae pointed out in para supra due to which the peak credit in these accounts was held as taxable in India. In view of the above

NARAINDAS GULABRAI TULSIANI,DELHI vs. ACIT, INT. TAX CIRCLE 4(2)(1), MUMBAI

In the result, all appeals filed by the respective assesses are allowed

Bench: Shri Amit Shukla & Shri Vikram Singh Yadav

reassessment stage nor at the appellate stage, has the assessee been able to produce satisfactory details sufficiency of assessee‟s additional evidence filed during appellate proceedings, adds weight to the specific findings given and lacunae pointed out in para supra due to which the peak credit in these accounts was held as taxable in India. In view of the above

NARAINDAS GULABRAI TULSIANI,DELHI vs. ACIT, INT. TAX CIRCLE 4(2)(1),, MUMBAI

In the result, all appeals filed by the respective assesses are allowed

Bench: Shri Amit Shukla & Shri Vikram Singh Yadav

reassessment stage nor at the appellate stage, has the assessee been able to produce satisfactory details sufficiency of assessee‟s additional evidence filed during appellate proceedings, adds weight to the specific findings given and lacunae pointed out in para supra due to which the peak credit in these accounts was held as taxable in India. In view of the above