CHEMOX EXPORTS IMPORTS PVT LTD,MUMBAI vs. INCOME TAX DEPARTMENT, ASSESSMENT UNIT, DELHI

u/s 148A(d) of\nIncome Tax Act, 1961.\nMRITUNJAI KUMAR\nWARD 1(1)(1), MUMBAI\n7.\nThe aforementioned notices have to be considered in light of the\nprovisions of Section 151A of the Act, which reads as under :-\n8\nआयकर अपीलीय अधिकरण\nINCOME TAX APPELLATE TRIBUNAL\nI.T.A. No. 3954/Mum/2024\n“151A. (1) The Central Government may make a scheme

LIC HOUSING FINANCE LIMITED,MUMBAI vs. ACIT 2(2)(1), MUMBAI, AAYKAR BHAVAN, MUMBAI

In the result, the appeal of the assessee is allowed

Bench: Shri Om Prakash Kant () & Shri Raj Kumar Chauhan () Assessment Year: 2017-18

reassessment u/s 148 for the AY 2017-18 to bring to tax 18 to bring to tax alleged wrongful deduction u/s 80G of Rs. 4,86,48,800/ alleged wrongful deduction u/s 80G of Rs. 4,86,48,800/ alleged wrongful deduction u/s 80G of Rs. 4,86,48,800/- claimed by the Appellant Company since the said donations were

PARSHWA INVESTMENT ,MUMBAI vs. DEPUTY COMMISSIONER OF INCOME TAX CENTRAL CIRCLE 7(1), MUMBAI

In the result, the appeal of the assessee is allowed

Bench: Shri Om Prakash Kant () & Shri Raj Kumar Chauhan () Assessment Year: 2018-19 Parshwa Investment Deputy Commissioner Of B-602, Klassic Gold Hotel, Off Cg Income Tax, Central Circle-7(1) Road, Navrangpura, Ahmedabad, Vs. Room No. 803, 8Th Floor, Gujrat- 380009 Pratishtha Bhavan, Old Cgo Annexe, M.K.Road, Mumbai, Mumbai- 400020 Pan No. Aatfp 4387 Q Appellant Respondent

151A of the Act as per law laid down by the Hon'ble Bombay High Court in the case of Hexaware Technlogies Limited vs. ACIT [WP No. 1778/2023; order dated 03.05.2024]. 2. In the facts and circumstances of the case and in law, the Learned Assessing Officer has erred in not providing the sanction note of the Learned

ARHAM ANMOL PROJECTS PRIVATE LIMITED,VILLAGE VALSHIND, BHIWANDI vs. CIRCLE 1 KALYAN, KALYAN, THANE

In the result, the legal grounds challenging the validity of the assessment are dismissed

Bench: Shri Amit Shukla & Shri Makarand Vasant Mahadeokararham Anmol Projects Dcit Circle 1, Private Limited 2Nd Floor, Rani H. No. 1113, Ground Vs. Mansion, Murbad Floor, Arham Logiparc, Road, Kalyan Nh-3, Nashik Highway, (West), Thane, Village Valshind, Maharashtra – 421 Bhiwandi, Maharashtra – 301 421 302. Pan/Gir No. Aagca9644P (Applicant) (Respondent) Assessee By Shri Subhash Bains, Ld. Ar Revenue By Shri Surendra Mohan, Ld. Dr Date Of Hearing 28.01.2026 Date Of Pronouncement 26.03.2026

u/s 272A(1)(d) of the Act, and the order of CIT (Appeal)/NFAC is not correct as per procedure in confirming the same, hence the same is requested to be set aside. 7. The appellant craves leave to add, alter or delete all or modify any or all the above grounds of appeal as and when advised

ANTHONETTE JOAQUIM ANTHONY,MUMBAI vs. ITO INT TAX WARD 1(1)(1), MUMBAI

In the result, the appeal by the assessee is allowed

section 151A as held by Hon'ble\nJurisdictional Bombay High Court in case of Hexaware Technologies Limited\nvs. ACIT [WP 1778/2023; order dated 03.05.2024].\n\n2) In the facts and circumstances of the case and in law, the Ld. Assessing\nOfficer has erred in initiating the assessment u/s 147 by obtaining a mere\nmechanical sanction u/s 151 from competent authority

ACIT, CIRCLE-24(1), MUMBAI, MUMBAI vs. JASVINDER KALYAN SALUJA, MUMBAI

In the result, the cross the result, the cross-objections of the assessee are allowed of the assessee are allowed whereas appeal of the Revenue is dismissed

Bench: Shri Om Prakash Kant () & Shri Sunil Kumar Singh () Assessment Year: 2013-14 Acit, Circle-24(1), Jasvinder Kalyan Saluja, 601, 6Th Floor, K-1, Balkrishna Chs, Jp Piramal Chambers, Lalbaug, Vs. Road, Andheri West, Parel, Mumbai-400053. Mumbai-400012. Pan No. Amgps 5143 Q Appellant Respondent

151A of the Act Thirdly, the Ld. counsel submitted that in regular assessment , the Ld. counsel submitted that in regular assessment , the Ld. counsel submitted that in regular assessment proceedings completed on 29.03.2016 proceedings completed on 29.03.2016, all the issues in respect to all the issues in respect to the advance received were duly explained and therefore, reopening the advance

CYRUS PATEL ,MUMBAI vs. INCOME TAX OFFICER WARD 23(2)(1), MUMBAI

In the result, the appeal is allowed

Bench: SHRI SANDEEP GOSAIN (Judicial Member), SHRI PRABHASH SHANKAR (Accountant Member)

151A of the Act empowers the Central Government to make a scheme by notification for the purpose of assessment, reassessment or recomputation u/s. 147 or issuance of notice u/s. 148 or conducting of enquiries or issuance of notice u/s. 148A of the Act in a faceless manner.The Central government has issued a notification under the said section

MARK FOODS,MUMBAI vs. INCOME TAX OFFICER-28(2)(1), MUMBAI

In the result, both the appeals filed by assessee are allowed

Bench: Shri Saktijit Dey & Shri Girish Agrawal

reassessment proceedings u/s 147 instead of issuing notice under section 153C of the Act. 6. In the facts and circumstances of the case and in law, the Learned CIT (A) has erred in upholding the action of the Ld. Jurisdictional Assessing Officer of issuing notice u/s 148 on borrowed satisfaction merely relying on the basis of alleged information received without

GAMNARAM OKHAJI PRAJAPATI ,MUMBAI vs. DCIT. CIRCLE 1(2)(1), MUMBAI

Appeal is allowed

Bench: SHRI RAHUL CHAUDHARY, JUDICIAL MEMBER SHRI PRABHASH SHANKAR (Accountant Member)

section 151A of IT Act, 1961 as well as per CBDT instruction dated 29.3.2022 such reassessment notices are required to be issued by Faceless Assessing Officer under the scheme framed by the CBDT and not by Jurisdictional Assessing officer. 2.1 The re-assessment proceeding initiated and consequential reassessment proceeding initiated and consequential reassessment order passed u/s. 147

DARSHANA JATIN SHAH ,MUMBAI vs. ITO WARD 19(1)(1), MUMBAI

In the result, the appeal of the assessee is allowed

147 pursuant\nto notice issued under section 148 are sustainable in law,\nparticularly in light of the finding recorded by the Ld. CIT(A)\nregarding non-service of notice.\n17. The learned AR had strongly relied upon the statutory\nmandate contained in sections 148A(b) and 148 of the Act and\nthe provisions of section 282 read with Rule

GOVIND MANSHARAM DINGWA,MUMBAI vs. INCOME TAX OFFICER - 22(1)(1), MUMBAI

In the result, the appeal filed by the assessee is allowed for statistical purposes

Bench: Shri Sandeep Gosain

151A of the Act. Vide para 3 of the said notification, the Hon'ble CBDT u/s. 148 of the Act with effect from the date of the notification. The relevant portion (emphasis supplied) of the said notification is as under: For the purpose of this Scheme, (a) assessment, reassessment or recomputation under section 147

GOVIND MANSHARAM DINGWA,MUMBAI vs. INCOME TAX OFFICER - 22(1)(1), MUMBAI

In the result, the appeal filed by the assessee is allowed for statistical purposes

Bench: Shri Sandeep Gosain

151A of the Act. Vide para 3 of the said notification, the Hon'ble CBDT u/s. 148 of the Act with effect from the date of the notification. The relevant portion (emphasis supplied) of the said notification is as under: For the purpose of this Scheme, (a) assessment, reassessment or recomputation under section 147

SATISH HARNAMDAS SETHI,MUMBAI vs. NATIONAL FACELESS ASSESSMENT CENTRE DELHI, DELHI

In the result, appeal of the assessee is allowed

Bench: Ms Kavitha Rajagopal & Shri Girish Agrawalassessment Year: 2017-18

151A of the Act mandates that the notice under section 148 can only be issued by the faceless Assessing Officer and not by the jurisdictional Assessing Officer. The Appellant, therefore, prays that the jurisdictional Assessing Officer has no jurisdiction to issue the notice under section 148 of the Act. The Appellant, humbly, prays that the notice issued under section

RAMESH PURSHOTTAM MODI ,MUMBAI vs. INCOME TAX OFFICER CIRCLE 22(1), MUMBAI

In the result, the appeal of the assessee is allowed

Bench: Shri Saktijit Dey & Shri Makarand Vasant Mahadeokarramesh Purshottam Ito Circle 22(1) Modi Income Tax 303, Modi House, Linking Vs. Department, Road, Khar West, Piramal Chamber, Mumbai-400 052 Dr. Ss Rao Marg, Parel, Mumbai 0 400 012 Pan/Gir No. Aahpm2793F (Applicant) (Respondent) Assessee By Shri Ashwani Kumar A/W Ms. Deepali Aggarwal, Ld. Ars Revenue By Shri Umashankar Prasad, Ld. Dr Date Of Hearing 12.02.2026 Date Of Pronouncement 19.02.2026

147 of the Act. The assessee further contended that the transactions relating to investment in mutual fund units and the applicability of section 94(7) and section 94(8) of the Act had already been examined by the Assessing Officer during the original scrutiny proceedings and, therefore, reopening on the 4 Ramesh Purshottam Modi same set of facts was impermissible

INCOME TAX OFFICER, MUMBAI vs. UTTAMCHAND RAJMAL JAIN , MUMBAI

In the result the cross objection filed by the assessee stands allowed in terms of grounds 2, 5 and 7 and the appeal filed by the revenue stands dismissed

Bench: Smt. Beena Pillai () & Smt. Renu Jauhri ()

section 151A of the Act, and accordingly, the faceless reassessment order u/s. 147 dated 25/05/2023, is illegal and invalid. 7. The reassessment

ADARSH DEVELOPERS,MUMBAI vs. ITO, WARD 22(3)(1), MUMBAI, MUMBAI

In the result, the appeal filed by the assessee stands allowed

Bench: Smt. Beena Pillai () & Shri Jagadish ()

Section 50C is not applicable. 9. The appellant craves leave to add, alter or amend any of the grounds at the time of hearing. 2. Assesse has also raised additional grounds challenging the validity of notice u/s 148 and the consequent re-assessment proceedings, which are as under:- “1.0 On facts and circumstances of the case

DCIT-14(1)(1), MUMBAI vs. KALPANA MADHANI SECURITIES PVT. LTD, MUMBAI

In the result, the appeal filed by the revenue is dismissed and Cross

Bench: Shri Vikram Singh Yadav & Shri Raj Kumar Chauhandcit-14(1)(1) M/S. Kalpana Madhani R. No. 432, 4Th Floor, Aayakar Securities Pvt. Ltd. Bhavan, M. K. Road, Vs. 11/1102, Shanti Tower, Shanti Mumbai-400 020 Path, Near Garodia Nagar, Mumbai-400 077 Pan: Aabck2968H

151A of the Act. Thus, Notice u/s 148 dated 28/07/2022 is bad in law. 3. The Ld Assessing Officer erred in reopening of Assessment second time "due to change of opinion without appreciating that assessment u/s 143(3) of the Act for A.Y. 2014-15 was already completed on 29.03.2016 and thereafter the case was reopened u/s. 147 and assessment

RAMESH AMRATLAL BRAHMBHATT ,MUMBAI vs. ITO WARD 34(3)(2), MUMBAI

In the result, the reassessment order dated 20

Bench: Shri Saktijit Dey & Shri Makarand Vasant Mahadeokarramesh Amratlal Ito Ward 34(3)(2), Brahmbhatt Kautilya Bhavan, 43 Rajnigandha, Vs. Bandra Kurla Gulmohar Cross Road No. Complex, Mumbai – 11, J V P D Scheme, 400 051 Juhu, Mumbai-400 049 Pan/Gir No. Aabpb7235R (Applicant) (Respondent) Assessee By Shri K. Gopal & Ms. Neha Paranjpe, Ld. Ars Revenue By Shri Annavaram Kosuri, Ld. Dr Date Of Hearing 23.02.2026 Date Of Pronouncement 25.02.2026

147 of the Act is bad in law as the notice dated 29.07.2022 issued u/s 148 of the Act is barred by limitation and bad in law. 1. The notice dated 27.07.2022 issued under section 148 of the Act is barred by limitation as per the provisions of section 149 of the Act. Hence, the notice issued under section

ACIT CIRCLE-4(3)(1), MUMBAI, MUMBAI vs. JMP SECURITIES PVT LTD, MUMBAI

In the result, the cross objection by the assessee is allowed, while the Revenue’s appeal is dismissed

Bench: Ms. Padmavathy S & Shri. Sandeep Singh Karhail

u/s. 68 of the Act) of Rs. 4,44,11,556/- even while there is no application of mind by Ld. CIT (A) considering that the amounts dealt with in the CIT(A) order do not pertain to the assessment order appealed against?”” 3. While in its cross objection, the assessee has raised the following grounds: – “1) The National Faceless