ESTATE OF VANDRAVAN P SHAH,MUMBAI vs. ASSISTANT COMISSIONER OF INCOME TAX, CIRCLE 19(3), MUMBAI

In the result all the three captioned appeals are dismissed

Bench: Sandeep Gosain () & Shri Om Prakash Kant ()

2(1), Mumbai, that a search under section 132 of the Act had been conducted in the case search under section 132 of the Act had been conducted in the case search under section 132 of the Act had been conducted in the case of M/s Navjeevan Charitable Trust M/s Navjeevan Charitable Trust. The search revealed that the . The search

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 148

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

2 raised by the Assessee challenged the validity\nof the reassessment proceedings and read as under:\n\"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

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 148

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 148

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

2 raised by the Assessee challenged the validity\nof the reassessment proceedings and read as under:\n“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 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 148

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)

2 raised by the Assessee challenged the validity\nof the reassessment proceedings and read as under:\n\n\"1.\nThe 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

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

reassess under unamended section 147, (b) issuance of notice under unamended section 148, (c) in accordance with time limit in terms of unamended section 149 and (d) sanction under unamended section 151 of the Act. 3 ITA Nos. 3674/Mum/2025 and ors. Shapoorji Pallonji Mistry AYs 2015-16 and 2016-17 5. Whether section 3(1) of TOLA creates a legal

SHIVALIK VENTURES PRIVATE LIMITED,MUMBAI vs. DCIT CC 8(1) , MUMBAI, MUMBAI

u/s 148 of the Act was issued. In response to the\nsame, the assessee filed the return of income on 03/02/2023 declaring total income\nat Rs.5,78,019/- and book profit of Rs.60,41,205/-. The AO while completing the\nassessment under section 147 made the following disallowance:\n(i) Disallowance under section 40(a)(ia) of the Act. Rs.1

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

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

AJAY MULTI PROJECTS PRIVATE LIMITED,MUMBAI vs. DCIT, CIRCLE 4(1)(1), MUMBAI, AAYKAR BHAWAN, MUMBAI

In the result, the appeal of the assessee is allowed

Bench: Shri Om Prakash Kant () & Ms. Kavitha Rajagopal () Assessment Year: 2016-17 Ajay Multi Projects Pvt. Ltd., Dcit, Circle-4(1)(1), 2Nd Floor, C.J. House, 285 Aayakar Bhavan, Vs. Princess Street, Marine Lines, Mumbai-400020. Mumbai-400002. Pan No. Aadca 0338 H Appellant Respondent

u/s. 148 the Act for reopening of the assessment by the Assessing Officer. Ajay Multi Projects Pvt. Ltd Ajay Multi Projects Pvt. Ltd 2. The notice u/s148 is bad in law and 2. The notice u/s148 is bad in law and without jurisdiction without jurisdiction as the jurisdictional requirements of section 147 to 151 have as the jurisdictional requirements

RAJNISH BHARTI HUF,MUMBAI vs. THE INCOME TAX OFFICER 20(3)(1), MUMBAI , LALBAUG, MUMBAI

In the result, both the appeals of the In the result, both the appeals of the assessee are dismissed assessee are dismissed whereas appeals of the Revenue are allowed

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

u/s 148 is not illegal and bad in law. Therefore, notice issued u/s 148 is not illegal and bad in law. Therefore, notice issued u/s 148 is not illegal and bad in law. Therefore, it is very clear that the notice issued u/s 148 is Therefore, it is very clear that the notice issued u/s 148 is Therefore

RAJNISH BHARTI HUF,MUMBAI vs. THE INCOME TAX OFFICER 20(3)(1), MUMBAI, LALBAUG, MUMBAI

In the result, both the appeals of the In the result, both the appeals of the assessee are dismissed assessee are dismissed whereas appeals of the Revenue are allowed

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

u/s 148 is not illegal and bad in law. Therefore, notice issued u/s 148 is not illegal and bad in law. Therefore, notice issued u/s 148 is not illegal and bad in law. Therefore, it is very clear that the notice issued u/s 148 is Therefore, it is very clear that the notice issued u/s 148 is Therefore

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

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

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

section 153C of the Act cannot be invoked in the case of the assessee. be invoked in the case of the assessee. Thus, the Assessing Officer Thus, the Assessing Officer has correctly invoked reassessment proceedings u/s 147 of the Act has correctly invoked reassessment proceedings u/s 147 of the Act has correctly invoked reassessment proceedings u/s 147