ACIT-231, MUMBAI vs. MILESTONE REAL ESTATE FUND, MUMBAI

Accordingly, Ground No. 6 raised by the Revenue is dismissed

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

147,08,42,740/- after making addition of INR 127,93,22,744/- [136,23,14,178 less INR 8,29,19,134] by denying the exemption claimed by the Assessee under Section 10(23FB) of the Act in respect of the income received from investment (AYs: 2015-16, 2017-18 & 2018-19) made in the Venture Capital Undertaking

ACIT 23-1, MUMBAI vs. MILESTONE REAL ESTATE FUND, MUMBAI

Accordingly, Ground No. 6 raised by the Revenue is dismissed

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

147,08,42,740/- after making addition of INR 127,93,22,744/- [136,23,14,178 less INR 8,29,19,134] by denying the exemption claimed by the Assessee under Section 10(23FB) of the Act in respect of the income received from investment (AYs: 2015-16, 2017-18 & 2018-19) made in the Venture Capital Undertaking

ACIT, PIRAMAL CHAMBERS vs. MILESTONE REAL ESTATE FUND, MUMBAI

147,08,42,740/- after making addition of INR 127,93,22,744/- [136,23,14,178 less INR 8,29,19,134] by denying the exemption claimed by the Assessee under Section 10(23FB) of the Act in respect of the income received from investment made in the Venture Capital Undertaking, and addition

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)

reassessment proceedings\nwere initiated within a period of four years from the end of the\nrelevant assessment year and therefore, First Proviso to Section\n147 of the Act was not applicable. Placing reliance upon\nParagraph 6.1.1 and 6.1.2 of the order impugned, the Learned\nDepartmental Representative submitted that the reasons\n\nITA No. 2616-2623 /Mum /2024

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

reassessment proceedings\nwere initiated within a period of four years from the end of the\nrelevant assessment year and therefore, First Proviso to Section\n147 of the Act was not applicable. Placing reliance upon\nParagraph 6.1.1 and 6.1.2 of the order impugned, the Learned\nDepartmental Representative submitted that the reasons\n==End of OCR for page 15==\nrecorded fully satisfied

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

reassessment proceedings\nwere initiated within a period of four years from the end of the\nrelevant assessment year and therefore, First Proviso to Section\n147 of the Act was not applicable. Placing reliance upon\nParagraph 6.1.1 and 6.1.2 of the order impugned, the Learned\nDepartmental Representative submitted that the reasons\nITA No. 2616-2623 /Mum /2024

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

reassessment proceedings\nwere initiated within a period of four years from the end of the\nrelevant assessment year and therefore, First Proviso to Section\n147 of the Act was not applicable. Placing reliance upon\nParagraph 6.1.1 and 6.1.2 of the order impugned, the Learned\nDepartmental Representative submitted that the reasons\n\nITA No. 2616-2623 /Mum /2024

THE TATA POWER COMPANY LTD,MUMBAI vs. PR CIT 2, MUMBAI

In the result, appeal is allowed, as indicated above

Bench: Shri Saktijit Dey () & Shri Rajesh Kumar ()

u/s 143(3) r.w.s. 144C(13) 11-12-2017 Assessment order passed under section 143(3) r.w.s. 147 of the Act 8. On a careful reading of the impugned order of learned PCIT passed under section 263 of the Act, it becomes very much clear that he has revised the assessment order passed under section 143(3) r.w.s. 147

ACIT, CIR-1(2)(1), MUMBAI vs. M/S. CHERYL ADVISORY PVT LTD., MUMBAI

In the result, the appeal of the Revenue is partly allowed

Bench: Shri Om Prakash Kant () & Shri Narender Kumar Choudhry () Assessment Year: 2013-14

10 on the determination of the income of the assessee i.e. other person. ination of the income of the assessee i.e. other person. ination of the income of the assessee i.e. other person. Thus the second condition Thus the second condition of section 153C(1)(b) i.e. of section 153C(1)(b) i.e. any information contained therein , also , also does

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

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

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

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

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

reassessment proceedings\nwere initiated within a period of four years from the end of the\nrelevant assessment year and therefore, First Proviso to Section\n147 of the Act was not applicable. Placing reliance upon\nParagraph 6.1.1 and 6.1.2 of the order impugned, the Learned\nDepartmental Representative submitted that the reasons\n\nITA No. 2616-2623 /Mum /2024

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

Section 14 of \nIRDA Act, 1999, which limits the payment of Commission \nor brokerage to 10. The circular specifically state, \"No \npayment of any kind including \"administrative or servicing \ncharges\" is permitted to be made to the agent or broker in \nrespect of the business in respect of which he is paid \nagency commission or brokerage. Since Dealers

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 147 of the Act, an assessment completed u/s 143(3) of the Act could be reopened beyond the completed u/s 143(3) of the Act could be reopened beyond the completed u/s 143(3) of the Act could be reopened beyond the period of four years from the end of the relevant assessment year iod of four years from

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

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 No. 2616-2623 /Mum /2024, ITA No. 2845, 2841, 2836, 2834, \n2827

SAI PRERNA CO-OP. CREDIT SOCIETY LTD,MUMBAI vs. ITO WD 17(3) (2) , MUMBAI

In the result, the appeal of the assessee is partly allowed

Bench: Shri Kuldip Singh () & Shri Om Prakash Kant () Assessment Year: 2012-13 Sai Prerana Co-Op Society Ltd., Ito-7(3)(2), 317, Puran Aasha Bldg. Gr. Fl. Room No. 126, 1St Floor, Narashi Natha Street, Katha Vs. Kautilya Bhavan, C-41 To C- Bazar Musjid Bunder (W), 43 Block, Bandra Kurla Mumbai-400 009. Complex, Bandra (East) Mumbai-400051. Pan No. Aadts 5638 M Appellant Respondent Assessee By : Ms. Ruby Srivastava & Mr. Bharat Kumar, Ca Revenue By : Mr. Milind S. Chavan, Dr Date Of Hearing : 27/04/2023 : Date Of Pronouncement 28/04/2023 Order

14 case was reopened u/s 147 of the Act on the ground that the assessee had claimed deduction u/s the Act on the ground that the assessee had claimed deduction u/s the Act on the ground that the assessee had claimed deduction u/s 80P of the Act. The Act. The reasons to believe that income escaped to believe that income