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

In the result, both appeals by the Revenue are dismissed and the\ntwo Cross Objections of the assessee are allowed

13-15\nfor reasons\n3. 19th January\n2022\nNotice u/s 142(1) of the Act\n16-18\n4. 10th February\n2022\nNotice u/s143(2)\nr.w.s 147 providing 19-28\nreasons for reopening\n5. 16th February\n2022\nNotice u/s 142(1) of the Act\n29-30\n6. 1st March 2022\nObjection filed\nreopening for\nreassessment\nwith respect

ITO(IT)-3(2)(1), MUMBAI vs. SHAPOORJI PALLONJI MISTRY, MUMBAI

In the result, both appeals by the Revenue are dismissed and the\ntwo Cross Objections of the assessee are allowed

13-15\nfor reasons\n3.\n19th January\n2022\nNotice u/s 142(1) of the Act\n16-18\n4.\n10th February\n2022\nNotice u/s143(2)\nr.w.s 147 providing 19-28\nreasons for reopening\n5.\n16th February\n2022\nNotice u/s 142(1) of the Act\n29-30\n6.\n1st March 2022\nObjection filed\nreopening for\nreassessment\nwith\nrespect

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

reassessment 9 ITA Nos. 3674/Mum/2025 and ors. Shapoorji Pallonji Mistry AYs 2015-16 and 2016-17 7. 25th May 2022 Notice u/s 148A(b) along with statements 44-79 and 20th June of Sanjay Periwal and Harshavardhan Kalyan 2022 and BSE Equity Expiry trade Part 1 -4 8. 24th June 2022 Reply to show cause notice u/s 148A(b

PRAFUL ARJUN RANE ,MUMBAI vs. ITO INT TAX WARD-4(1)(1), MUMBAI

In the result, appeal of the assessee is allowed

Bench: SHRI SAKTIJIT DEY, HON’BLE (Vice President), SHRI GIRISH AGRAWAL (Accountant Member)

reassessment notices for past assessment years only if the time limit survives according to Section 149(1)(b) of the old regime, that is, six years from the end of the relevant assessment year, and (iv) all notices issued invoking the time limit under Section 149(1)(b) of the old regime will have to be dropped if the income

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

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

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

b) i.e. any information contained therein , also , also does not apply in the case of the assessee. does not apply in the case of the assessee. In such circumstances provisions of section 153C of the Act cannot In such circumstances provisions of section 153C of the Act cannot In such circumstances provisions of section 153C of the Act cannot

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)

u/s 153C of the Act, issues a notice u/s 153C to file a return of income for reassessment, then he makes an assessment / reassessment of such income u/s 153A of the Act. 65. Now, the entire procedure is the same except under different sections having two separate contingencies. In our opinion, the Legislature has not left any discretion

DY.CIT (E) -2(1) , MUMBAI vs. MUMBAI EDUCATIONAL TRUST, MUMBAI

Bench: Shri Prashant Maharishi, Am & Shri Rahul Chaudhary, Jm

147 of the Act was taken. 05. It was found during the F.Y. 2009-10 i.e. A.Y. 2010-11 that properties of the assessee were used by the specified persons. It was found that M/s Ideen Furniture Pvt. Ltd had occupied 8th i. floor of the assessee‟s trust building at Bandra Reclamation without any payment. The above

DY.CIT (E) -2(1) , MUMBAI vs. MUMBAI EDUCATIONAL TRUST, MUMBAI

Bench: Shri Prashant Maharishi, Am & Shri Rahul Chaudhary, Jm

147 of the Act was taken. 05. It was found during the F.Y. 2009-10 i.e. A.Y. 2010-11 that properties of the assessee were used by the specified persons. It was found that M/s Ideen Furniture Pvt. Ltd had occupied 8th i. floor of the assessee‟s trust building at Bandra Reclamation without any payment. The above

DY.CIT (E) -2(1) , MUMBAI vs. MUMBAI EDUCATIONAL TRUST, MUMBAI

Bench: Shri Prashant Maharishi, Am & Shri Rahul Chaudhary, Jm

147 of the Act was taken. 05. It was found during the F.Y. 2009-10 i.e. A.Y. 2010-11 that properties of the assessee were used by the specified persons. It was found that M/s Ideen Furniture Pvt. Ltd had occupied 8th i. floor of the assessee‟s trust building at Bandra Reclamation without any payment. The above

DY.CIT (E) -2(1) , MUMBAI vs. MUMBAI EDUCATIONAL TRUST, MUMBAI

Bench: Shri Prashant Maharishi, Am & Shri Rahul Chaudhary, Jm

147 of the Act was taken. 05. It was found during the F.Y. 2009-10 i.e. A.Y. 2010-11 that properties of the assessee were used by the specified persons. It was found that M/s Ideen Furniture Pvt. Ltd had occupied 8th i. floor of the assessee‟s trust building at Bandra Reclamation without any payment. The above

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

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)

b) supra with regard to the time limit for completion of the proceedings. It was stated that the appeal filed by the assessee is still pending before the Hon’ble High Court of Bombay. 8. Thus, we notice that the Hon’ble Bombay High Court has held that the proceedings initiated u/s 201(1)/201(1A) should be completed within

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

13. One thing further to be noticed is that intimation under section 143(1)(a) is given without prejudice to the provisions of section 143(2). Though technically the intimation issued was deemed to be a demand notice issued under section 156, that did not per se preclude the right of the Assessing Officer to proceed under section

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

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 Original notice under section 148 which 31.05.2021 is deemed

MOHAMEDALI SHABANALI BADAMI,MUMBAI vs. ITO 25(2)(1), MUMBAI

In the result, appeal of the assessee is allowed

Bench: Shri Amit Shukla & Shri Girish Agrawalassessment Year: 2015-16

147 of the Act. Subsequently, ld. Assessing Officer passed an order u/s. 148A(d), dated 19.04.2022, wherein it was noted that information was flagged in accordance with Risk Management Strategy (RMS) which constituted information with the ld. Assessing Officer suggesting that income chargeable to tax had escaped assessment for the purpose of section 148 and section 148A. No reply

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