SUDESH DHANRAJ MURPANA (HUF),MUMBAI vs. THE INCOME TAX OFFICER, WARD 23(3)(1, MUMBAI

In the result, appeal of the assessee is allowed

Bench: Shri Amit Shukla & Shri Girish Agrawalassessment Year: 2013-14 Sudesh Dhanraj Murpana Income Tax Officer – 23(3) (1) (Huf) Matru Mandir, Tardeo, Grant 401 Somdhan Bldg, Perry Road, Cross Road Bandra (West), Vs. Mumbai - 400007 Mumbai 400050

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

NARESH AMRATLAL SHAH,MUMBAI vs. ITO WARD-27(2)(1), MUMBAI

In the result, the appeal of the In the result, the appeal of the Assessee is allowed allowed

Bench: Shri Om Prakash Kant () & Shri Raj Kumar Chauhan ()

u/s. 148 for the A.Y. 2015 issued on 28/07/2022 which is admittedly barred by issued on 28/07/2022 which is admittedly barred by issued on 28/07/2022 which is admittedly barred by limitation under the ne limitation under the new provision of Section 149(1) w provision of Section 149(1) and it is not covered under TOLA. Accordingly

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

Bench: Shri Amit Shukla & Shri Girish Agrawal

reassessment with respect to 31-43 9 ITA Nos.3674/Mum/2025 and ors. Shapoorji Pallonji Mistry AYs 2015-16 and 2016-17 7. 25th May 2022 and 20th June 2022 Notice u/s 148A(b) along with statements of Sanjay Periwal and Harshavardhan Kalyan and BSE Equity Expiry trade Part 1-4 44-79 8. 24th June 2022 Reply to show cause notice

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

u/s. 3 (1) of TOLA included (a) the power to assess or 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

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

Bench: Shri Amit Shukla & Shri Girish Agrawal

reassessment with respect to 31-43 9 ITA Nos.3674/Mum/2025 and ors. Shapoorji Pallonji Mistry AYs 2015-16 and 2016-17 7. 25th May 2022 and 20th June 2022 Notice u/s 148A(b) along with statements of Sanjay Periwal and Harshavardhan Kalyan and BSE Equity Expiry trade Part 1-4 44-79 8. 24th June 2022 Reply to show cause notice

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

KETUKUMAR KRISHNAVADAN PARIKH,MUMBAI vs. ITO WARD 42(1)(3), MUMBAI

In the result the appeal filed by the assessee for assessment year 2017-18 and 2018-19 stands allowed

Bench: Smt. Beena Pillai () I.T.A. No. 4503/Mum/2025 Assessment Year: 2017-18 & I.T.A. No. 4502/Mum/2025 Assessment Year: 2018-19

147 to 151 are machinery provisions. Therefore, they must be given an interpretation that is consistent with the object and purpose of the Income Tax Act. ………………. "75. After 1 April 2021, the new regime has specified different authorities for granting sanctions under Section 151. The new regime is beneficial to the assesse because it specifies a higher level of authority

KETUKUMAR KRISHNAVADAN PARIKH ,MUMBAI vs. ITO WARD 42(1)(3), MUMBAI

In the result the appeal filed by the assessee for assessment year 2017-18 and 2018-19 stands allowed

Bench: Smt. Beena Pillai () I.T.A. No. 4503/Mum/2025 Assessment Year: 2017-18 & I.T.A. No. 4502/Mum/2025 Assessment Year: 2018-19

147 to 151 are machinery provisions. Therefore, they must be given an interpretation that is consistent with the object and purpose of the Income Tax Act. ………………. "75. After 1 April 2021, the new regime has specified different authorities for granting sanctions under Section 151. The new regime is beneficial to the assesse because it specifies a higher level of authority

ELSIE HUBALD,MUMBAI vs. INT TAX WARD 2(2)(1), MUMBAI

Accordingly, ground nos. 1 and 2 raised by the assessee are allowed

Bench: Ms Padmavathy S, Am & Shri Raj Kumar Chauhan, Jm

u/s 69 of the act. 4. On the facts and in the circumstances of the case and in law, the learned DRP erred in rejecting the objections raised against the proposed addition of Rs.43,67,491/- and the learned A.O. erred in making addition of an amount of Rs.43,67,491/- as unexplained investment u/s69

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

APTIVAA MIDDLE EAST FZE,DUBAI, UNITED ARAB EMIRATES vs. DEPUTY COMMISSIONER OF INCOME TAX, CIRCLE 1(1)(2), INTERNATIONAL TAXATION, MUMBAI, MAHARASTRA

In the result of the file by the assessee stands partly allowed as indicated hereinabove

Bench: Smt. Beena Pillai () & Ms. Padmavathy S. ()

149(1)(b) in the absence of any income escaped assessment represented in the form of "asset" 3. On the facts and circumstances of the case and in law, the notice dated March 17, 2023 issued under section 143(2) of the Act by the Ld. AO is invalid, bad in law and liable to be quashed

ACIT-19(3), MUMBAI vs. RAMCHAND THAKURDAS JHAMTANI, THANE

Accordingly, all the grounds raised by the Revenue in the departmental appeal in relation to the relief granted by the CIT(A) on merits are dismissed as having been rendered infructuous

Bench: SHRI RAHUL CHAUDHARY, JUDICIAL MEMBER SMT RENU JAUHRI (Accountant Member)

reassessment proceedings culminated into passing of the Assessment Order, dated 29/05/2023, passed under Section 147 read with Section 144B of the Act. The appeal preferred by the Assessee against the aforesaid Assessment Order was allowed by the CIT(A) vide Order, dated 16/05/2024. Being aggrieved, the Revenue has preferred the present appeal before the Tribunal ITA No. 3552/Mum/2024

APTIVAA MIDDLE EAST FZE,DUBAI, UNITED ARAB EMIRATES vs. DEPUTY COMMISSIONER OF INCOME TAX, CIRCLE 1(1)(2), INTERNATIONAL TAXATION, MUMBAI, MAHARASTRA

In the result of the file by the assessee stands partly allowed as indicated hereinabove

Bench: Smt. Beena Pillai () & Ms. Padmavathy S. ()

149(1)(b) in the absence of any income escaped assessment represented in the form of "asset" 3. On the facts and circumstances of the case and in law, the notice dated March 17, 2023 issued under section 143(2) of the Act by the Ld. AO is invalid, bad in law and liable to be quashed

APTIVAA MIDDLE EAST FZE,MUMBAI vs. DEPUTY COMMISSION OF INCOME TAX, CIRCLE 1(1)(2), INTERNATIONAL TAXATION, MUMBAI, MUMBAI

In the result of the file by the assessee stands partly allowed as indicated hereinabove

Bench: Smt. Beena Pillai () & Ms. Padmavathy S. ()

149(1)(b) in the absence of any income escaped assessment represented in the form of "asset" 3. On the facts and circumstances of the case and in law, the notice dated March 17, 2023 issued under section 143(2) of the Act by the Ld. AO is invalid, bad in law and liable to be quashed

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

PANKAJ CHANDRAKANT PIMPLE,BORIVALI (WEST), MUMBAI vs. INT TAX WARD 3(3)(1), MUMBAI

Bench: Ms. Kavitha Rajagopal, Jm & Smt. Renu Jauhri, Am

b) and notice u/s. 148 and pass order u/s 148A(d) as after 19/07/2022 same can be done in a faceless manner, therefore the reassessment proceedings is bad in law 3. The learned CIT (DRP-2) failed to appreciate that the AO issued reopening notice beyond period of three years, approval was required to be taken as per provisions

ACIT-15(3)(2), MUMBAI, MUMBAI vs. SURYA FERROUS ALLOYS PVT LTD, MUMBAI

Appeal are dismissed as having been rendered infructuous

Bench: SHRI PRASHANT MAHARISHI, ACCOUNTANT MEMBER SHRI RAHUL CHAUDHARY (Judicial Member)

149 of the Act, the reopening is time barred. 2. The Id JAO had no jurisdiction to issue show cause notice u/s 148A(b) dated 30/05/2022 pass order u/s 148A(d) dated 26/07/2022 and issue notice u/s 148 dated 26/07/2022 as after 29/03/2022 same can be done in a faceless manner as provided u/s 144B i.e. by Faceless Assessing Officer