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

153 referred to as the relevant assessment year) :\n\nProvided that where an assessment under sub-section (3)\nof section 143 or this section has been made for the\nrelevant assessment year, no action shall be taken under\nthis section after the expiry of four years from the end of\nthe relevant assessment year, unless any income\nchargeable

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)

153 referred to as the relevant assessment year) : Provided that where an assessment under sub-section (3) of section 143 or this section has been made for the relevant assessment year, no action shall be taken under this section after the expiry of four years from the end of the relevant assessment year, unless any income chargeable

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)

153 referred to as the relevant assessment year) : Provided that where an assessment under sub-section (3) of section 143 or this section has been made for the relevant assessment year, no action shall be taken under this section after the expiry of four years from the end of the relevant assessment year, unless any income chargeable

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

153 referred to as the relevant assessment year) :\n\nProvided that where an assessment under sub-section (3)\nof section 143 or this section has been made for the\nrelevant assessment year, no action shall be taken under\nthis section after the expiry of four years from the end of\nthe relevant assessment year, unless any income\nchargeable

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

153 referred to as the relevant assessment year) :\nProvided that where an assessment under sub-section (3)\nof section 143 or this section has been made for the\nrelevant assessment year, no action shall be taken under\nthis section after the expiry of four years from the end of\nthe relevant assessment year, unless any income\nchargeable

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

153 referred to as the relevant assessment year) : \n\n Provided that where an assessment under sub-section (3) \nof section 143 or this section has been made for the \nrelevant assessment year, no action shall be taken under \nthis section after the expiry of four years from the end of \nthe relevant assessment year, unless any income \nchargeable

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

153 referred to as the relevant assessment year) : \n\n Provided that where an assessment under sub-section (3) \nof section 143 or this section has been made for the \nrelevant assessment year, no action shall be taken under \nthis section after the expiry of four years from the end of \nthe relevant assessment year, unless any income \nchargeable

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)

153 referred to as the relevant assessment year) :\n\nProvided that where an assessment under sub-section (3)\nof section 143 or this section has been made for the\nrelevant assessment year, no action shall be taken under\nthis section after the expiry of four years from the end of\nthe relevant assessment year, unless any income\nchargeable

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

153 referred to as the relevant assessment year) :\nProvided that where an assessment under sub-section (3)\nof section 143 or this section has been made for the\nrelevant assessment year, no action shall be taken under\nthis section after the expiry of four years from the end of\nthe relevant assessment year, unless any income\nchargeable

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

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

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

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

153 referred to as the relevant assessment year) :\nProvided that where an assessment under sub-section (3) \nof section 143 or this section has been made for the \nrelevant assessment year, no action shall be taken under \nthis section after the expiry of four years from the end of \nthe relevant assessment year, unless any income \nchargeable

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

153 referred to as the relevant assessment year) :\n\nProvided that where an assessment under sub-section (3)\nof section 143 or this section has been made for the\nrelevant assessment year, no action shall be taken under\nthis section after the expiry of four years from the end of\nthe relevant assessment year, unless any income\nchargeable

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

153 referred to as the relevant assessment year) :\nProvided that where an assessment under sub-section (3)\nof section 143 or this section has been made for the\nrelevant assessment year, no action shall be taken under this\nsection after the expiry of four years from the end of\nthe relevant assessment year, unless any income\nchargeable

M/S. SUMER BUILDERS PRIVATE LIMITED,,MUMBAI vs. DCIT-CENTRAL CIRCLE-5(3),, MUMBAI

In the result, the appeal of the assessee is partly allowed

Bench: Shri Rajesh Kumar & Shri Ram Lal Negiassessment Year: 2011-12 M/S. Sumer Builders Pvt. The Dy. Commissioner Of Ltd., Income Tax, 220, Commerce House, Central Circle – 5(3), 140, Nagindas Master (Erstwhile The Assistant Road, Commissioner Of Income Vs. Fort, Mumbai – 400 023 Tax, Central Circle-36, Pan: Aaacs7947P Mumbai), 1906, 19Th Floor, Air India Building, Nariman Point, Mumbai - 400021 (Appellant) (Respondent) Present For: Assessee By : Shri Nishit Gandhi, A.R. Revenue By : Shri T.S. Khalsa, D.R. Date Of Hearing : 25.11.2020 Date Of Pronouncement : 08.01.2021 O R D E R

reassessment was issued read as follows: "Notwithstanding anything contained in section 139, section 147, section 148, section 149, section 151 and section 153, where the Assessing Officer is satisfied that any money, bullion, jewellery or valuable article or thing or books of account or documents seized or requisitioned belongs or belong to a person other than the person referred

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

153 of the Act. The jurisdictional requirement under Section 153C is thus The jurisdictional requirement under Section 153C is thus The jurisdictional requirement under Section 153C is thus contingent upon (i) the recovery of assets belonging to the assessee, contingent upon (i) the recovery of assets belonging to the assessee, contingent upon (i) the recovery of assets belonging

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

reassessment, because of the non abstante clause begins with the said sections. The language used in these sections, i.e. ‘notwithstanding anything contained’ in section 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