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

139 or in\nresponse to a notice issued under sub-section (1)\nof section 142 or section 148 or to disclose fully and truly\nall material facts necessary for his assessment, for that\n assessment year”\n12. As per First Proviso to Section 147 of the Act, no action under\n==End of OCR for page 9==\nSection 147

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

139 or in\nresponse to a notice issued under sub-section (1)\nof section 142 or section 148 or to disclose fully and truly\nall material facts necessary for his assessment, for that\n assessment year”\n\n12. As per First Proviso to Section 147 of the Act, no action under\n\nITA No. 2616-2623 /Mum /2024

DCIT-1(2)1, MUMBAI., MUMBAI vs. PATIL CONSTRUCTION AND INFRASTRUCTURE LTD, MUMBAI

In the result In the result, all the three appeals filed by the revenue s filed by the revenue are dismissed

Bench: Shri Sandeep Gosain, Hon’Ble & Ms. Padmavathy S., Hon’Ble

1)] Notwithstanding anything contained in section 139, section 147, section 148, section 149, section 151 and section section 147, section 148, section 149, section 151 and section section 147, section 148, section 149, section 151 and section 153, in the case of a person where a search is initiated under 153, in the case of a person where a search

DCIT-1(2)1, MUMBAI, MUMBAI vs. PATIL CONSTRUCTION AND INFRASTRUCTURE LTD, MUMBAI

In the result In the result, all the three appeals filed by the revenue s filed by the revenue are dismissed

Bench: Shri Sandeep Gosain, Hon’Ble & Ms. Padmavathy S., Hon’Ble

1)] Notwithstanding anything contained in section 139, section 147, section 148, section 149, section 151 and section section 147, section 148, section 149, section 151 and section section 147, section 148, section 149, section 151 and section 153, in the case of a person where a search is initiated under 153, in the case of a person where a search

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 ()

139, section 147, section 148, section 149, section 151 and section section 147, section 148, section 149, section 151 and section section 147, section 148, section 149, section 151 and section 153, where the Assessing Officer is satisfied that any money, 153, where the Assessing Officer is satisfied that any money, 153, where the Assessing Officer is satisfied that

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 ()

139, section 147, section 148, section 149, section 151 and section section 147, section 148, section 149, section 151 and section section 147, section 148, section 149, section 151 and section 153, where the Assessing Officer is satisfied that any money, 153, where the Assessing Officer is satisfied that any money, 153, where the Assessing Officer is satisfied that

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

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

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 153A. The section reads as under: Assessment in case of search or requisition. 153A. (1) Notwithstanding anything contained in section 139, section 147, section 148, section 149, section 151 and section 153, in the case of a person where a search is initiated under section 132 or books of account, other documents or any assets are requisitioned under section

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

139, [Notwithstanding anything contained in section 147, section 148 section 148, section 149, section 151 and and section 153, where the Assessing Officer is satisfied that, where the Assessing Officer is satisfied that,- (a) any money, bullion, jewellery or other valuable article or any money, bullion, jewellery or other valuable article or any money, bullion, jewellery or other valuable article

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

139 or in\nresponse to a notice issued under sub-section (1)\nof section 142 or section 148 or to disclose fully and truly\nall material facts necessary for his assessment, for that\n assessment year”\n\n12. As per First Proviso to Section 147 of the Act, no action under\n\nITA No. 2616-2623 /Mum /2024

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

139(1) of the Act, is an allowable\ndeduction u/s. 36(1) (va) of the Act.\ne.\nThe Appellant prays that the addition made u/s. 36(1) (va) in respect of LWF amounting\nto Rs. 31,812/- be deleted and the AO be directed to allow deduction of Rs. 16, 16,236/-\nu/s. 43B of the Act.\n5. without prejudice

ATUL SHAMJI BHARANI,MUMBAI vs. DCIT CC- 4(1), MUMBAI

In the result, appeal by the assessee for the

u/s 153C of the Act\n153C. (1)Notwithstanding anything contained in section 139, section 147,\nsection 148, section 149, section 151 and section 153, where the Assessing\nOfficer is satisfied that,—\n(a) any money, bullion, jewellery or other valuable article or thing,\nseized or requisitioned, belongs to; or\n(b) any books of account or documents, seized or requisitioned

ATUL SHAMJI BHARANI,MUMBAI vs. DCIT CC- 4(1), MUMBAI

In the result, appeal by the assessee for the

u/s 153C of the Act\n153C. (1)Notwithstanding anything contained in section 139, section 147,\nsection 148, section 149, section 151 and section 153, where the Assessing\nOfficer is satisfied that, —\n(a)\nany money, bullion, jewellery or other valuable article or thing,\nseized or requisitioned, belongs to; or\n(b)\nany books of account or documents, seized or requisitioned

SAMBHAVANATH INFRABUILD FARMS (SUCCESSOR TO LODHA CONSTRUCTION P. LTD P. LTD.,MUMBAI vs. ASSTT. CIT, CENTRAL CIRCLE-7(3), MUMBAI

Bench: Shri C.N. Prasad, Hon'Ble & Shri S. Rifaur Rahman, Hon'Blesambhavnath Infrabuild & Farms Pvt. Ltd., V. Asst. Cit– Central Circle – 7(3) {Successor To Lodha Construction Pvt. Ltd.,} Room No. 655, 6Th Floor 412, 4Th Floor, 17G Vardhaman Chamber Aayakar Bhavan, M.K. Road Cawasji Patel Road, Horniman Circle Mumbai - 400020 Fort, Mumbai - 400001 Pan: Aalcs1394M (Appellant) (Respondent) Assessee By : Shri Anuj Kisnadwala Department By Shri B.K. Bagchi

139, section 147, section 148, section 149, section 151 and section 153 made it clear that provisions of these sections are not made applicable to the assessments covered by the provisions of section 153A or 153C of the Act. 2.3.5 The Appellant submits that under the provisions of section 147 of the Act, the Assessing Officer is having power

SHRI AMIT MANGILAL JAIN,MUMBAI vs. ACIT, - 33(1), MUMBAI

In the result, both the above appeals are allowed

Bench: Shri Sandeep Gosain & Shri Prabhash Shankar

u/s 133A of the Act were refereed in the assessment order. 6.2 For ready reference we quote section 153C as under:- " 153C. [Notwithstanding anything contained in section 139, section 147, section 148, section 149, section 151 and section 153, where the Assessing Officer is satisfied that,- (a) any money, bullion, jewellery or other valuable article or thing, seized or requisitioned

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)

139 or in response to a notice issued under sub-section (1) of section 142 or section 148 or to disclose fully and truly all material facts necessary for his assessment, for that assessment year” 12. As per First Proviso to Section 147 of the Act, no action under ITA No. 2616-2623 /Mum /2024

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)

139 or in response to a notice issued under sub-section (1) of section 142 or section 148 or to disclose fully and truly all material facts necessary for his assessment, for that assessment year” 12. As per First Proviso to Section 147 of the Act, no action under ITA No. 2616-2623 /Mum /2024

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)

139 or in response to a notice issued under sub-section (1) of section 142 or section 148 or to disclose fully and truly all material facts necessary for his assessment, for that assessment year” 12. As per First Proviso to Section 147 of the Act, no action under ITA No. 2616-2623 /Mum /2024