WIN CABLE & DATACOM P.LTD,MUMBAI vs. ASST CIT (TDS) 3(1), MUMBAI

In the result, appeals filed by the assessee are hereby allowed

Bench: S/Shri R.C. Sharma (Am) & Amarjit Singh (Jm) I.T.A. No. 3635/Mum/2016(Assessment Year 2001-02)

section 147, also roping in the cases of aassessment apart from reassessment, it is clear that the assessment of payee shall also include assessment made under 147. Thus, the maximum time limit for initiating and completing the proceedings u/s 201(1

NAVNIDHI STEEL AND ENGG CO. P.LTD,MUMBAI vs. DCIT 5(2)(1), MUMBAI

The appeal of the assessee is dismissed

Bench: Shri Joginder Singh, Assessment Year: 2007-08

reassessment proceedings even when intimation under section 143(1) had been issued. 19. Inevitable conclusion is that High Court has wrongly applied Adani Exports case (supra) which has no application to the case on the facts in view of the conceptual difference between section 143(1) and section 143(3) of the Act. 24 Navnidhi Steel & Engg

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)

1. The CIT(A) erred in confirming the action of the AO by\ntreating the reassessment order passed under section\n143(3) read with section 147 of the Income Tax Act (‘the\nAct’) as valid.\n\n2.\nThe CIT(A) failed to appreciate the fact that in the reasons\nrecorded, the AO has not disclosed any specific non-\ndisclosure

ASSISTANT COMMISSIONER OF INCOME TAX CIRCLE- 41(1)(1), MUMBAI, KAUTILYA BHAWAN, BKC vs. JAJ INTERNATIONAL, MUMBAI

In the result, the grounds relating to merit the file of the Ld

Bench: Shri Om Prakash Kant () & Shri Sunil Kumar Singh ()

147, section 148, section 149, section 151 and section 153, where the tion 148, section 149, section 151 and section 153, where the tion 148, section 149, section 151 and section 153, where the Assessing Officer is satisfied that, Assessing Officer is satisfied that,— (a)any money, bullion, jewellery or other valuable article or thing, seized or any money, bullion

ASSISTANT COMMISSIONER OF INCOME TAX, KAUTILYA BHAWAN vs. JAJ INTERNATIONAL, MUMBAI

In the result, the grounds relating to merit the file of the Ld

Bench: Shri Om Prakash Kant () & Shri Sunil Kumar Singh ()

147, section 148, section 149, section 151 and section 153, where the tion 148, section 149, section 151 and section 153, where the tion 148, section 149, section 151 and section 153, where the Assessing Officer is satisfied that, Assessing Officer is satisfied that,— (a)any money, bullion, jewellery or other valuable article or thing, seized or any money, bullion

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

1. The CIT(A) erred in confirming the action of the AO by\ntreating the reassessment order passed under section\n143(3) read with section 147 of the Income Tax Act (‘the\nAct’) as valid.\n2. The CIT(A) failed to appreciate the fact that in the reasons\nrecorded, the AO has not disclosed any specific non-\nITA

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

1. The CIT(A) erred in confirming the action of the AO by\ntreating the reassessment order passed under section\n143(3) read with section 147 of the Income Tax Act (‘the\nAct’) as valid.\n2. The CIT(A) failed to appreciate the fact that in the reasons\nrecorded, the AO has not disclosed any specific

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

1. The CIT(A) erred in confirming the action of the AO by\ntreating the reassessment order passed under section\n143(3) read with section 147 of the Income Tax Act (‘the\nAct’) as valid.\n\n2. The CIT(A) failed to appreciate the fact that in the reasons\nrecorded, the AO has not disclosed any specific non-\ndisclosure

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 proceedings initiated under Section 147 of the Act are held to be legally valid. Both grounds Section 147 of the Act are held to be legally valid. Both grounds Section 147 of the Act are held to be legally valid. Both grounds raised in the applicatio raised in the application under Rule 27 stand rejected. n under Rule

DCIT CEN CIR 8(4), MUMBAI vs. SAVITA OIL TECHNOLOGIES LTD, MUMBAI

Appeal is allowed

Bench: Shri Mahavir Singh & Shri Ramit Kocharआयकर अपीऱ सं./I.T.A. No.7620/Mum/2016 (नििाारण वर्ा / Assessment Year : 2010-11)

reassessment, the assessee shall be entitled to receive, in addition to the interest payable under sub-section (1), an additional interest on such amount of refund calculated at the rate of three per cent per annum, for the period beginning from the date following the date of expiry of the time allowed under sub-section (5) of section

DY COMMISSIONER OF INCOME TAX (EXEMPTION)-2(1), MUMBAI vs. SHREE SAI BABA SANSTHAN TRUST (SHIRDI), MUMBAI

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

147 of the Act, without bringing any new tangible\nmaterial to support his view of escapement of income is valid or not?\n(c) Whether the Ld CIT(A) was justified in rejecting the claim of the\nassessee that the deduction of 15% allowed u/s 11(1)(a) of the Act\nshould be allowed on gross receipts?\n(d) Whether

SHREE SAI BABA SANTHAN TRUST MUMBAI ,MUMBAI vs. DCIT(EXEMPTION), MUMBAI

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

147 of the Act, without bringing any new tangible\nmaterial to support his view of escapement of income is valid or not?\n(c) Whether the Ld CIT(A) was justified in rejecting the claim of the\nassessee that the deduction of 15% allowed u/s 11(1)(a) of the Act\nshould be allowed on gross receipts?\n(d) Whether

INCOME TAX OFFICER (IT)-3(2)(1), KAUTILYA BHAWAN vs. SHAPOORJI PALLONJI MISTRY, MUMBAI

In the result, appeal filed by the Revenue is dismissed

Bench: Shri Amit Shukla & Shri Girish Agrawal

Sections 147, 148, 149 and 151 as they stood prior to their amendment by way of Finance Act, 2021 that would govern such notices. 4. Whether such action u/s. 3 (1) of TOLA included (a) the power to assess or reassess

HATHWAY C-NET P. LTD,MUMBAI vs. TAX RECOVERY (TDS) 1, MUMBAI

The appeals of the assessees are allowed

Bench: Shri Joginder Singh & Shri Ashwani Taneja

section 147, also roping in the cases of aassessment apart from reassessment, it is clear that the assessment of payee shall also include assessment made under 147. Thus, the maximum time limit for initiating and completing the proceedings u/s 201(1

HATHWAY CABLE & DATACOM LTD,MUMBAI vs. TRO (TDS) RG 1, MUMBAI

The appeals of the assessees are allowed

Bench: Shri Joginder Singh & Shri Ashwani Taneja

section 147, also roping in the cases of aassessment apart from reassessment, it is clear that the assessment of payee shall also include assessment made under 147. Thus, the maximum time limit for initiating and completing the proceedings u/s 201(1

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

1. The CIT(A) erred in confirming the action of the AO by\ntreating the reassessment order passed under section\n143(3) read with section 147 of the Income Tax Act (‘the\nAct’) as valid.\n\n2. The CIT(A) failed to appreciate the fact that in the reasons\nrecorded, the AO has not disclosed any specific non-\n\ndisclosure

KOTAK MAHINDRA BANK LIMITED,MUMBAI vs. ADD/JOINT/DEPUTY/ACIT, NATIONAL E-ASSESSMENT CENTRE, DELHI

section 143(1) and needs to be deleted.\nITA No. 4056/Mum/2023 (A.Y.2012-13)\n10. The brief facts of the case are that the assessee filed its e-return of income\ndeclaring total income at Rs. 1299, 92, 77,220/- on 13.04.2017 in response to the\nnotice issued u/s. 148 of the Act. Thereafter, the assessee filed its letter seeking\nreasons

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

Accordingly, Ground No.1 to 4 raised by the Assessee are allowed

Bench: SHRI VIKRAM SINGH YADAV, ACCOUNTANT MEMBER SHRI RAHUL CHAUDHARY (Judicial Member)

reassessment proceedings were initiated in the case of the Assessee which culminated into passing of Assessment Order, dated 29/06/2016 under Section 143(3) read with Section 147 of the Act. Thereafter, the case was again reopened under Section 147 of the Act after recording the reason and after obtaining the approval from the competent authority. The notice under Section