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)

u/s 148 is to be issued.” (Emphasis Supplied) 31. From the material on record it is apparent that the Assessing Officer had initiated reassessment proceedings for the Assessment Year 2012-2013 under Section 147 of the Act by issuance of notice under Section 148 of the Act on 30/03/2017. Thus, reassessment proceedings were initiated within a period of 4 years

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)

u/s 148 is to be issued.” (Emphasis Supplied) 31. From the material on record it is apparent that the Assessing Officer had initiated reassessment proceedings for the Assessment Year 2012-2013 under Section 147 of the Act by issuance of notice under Section 148 of the Act on 30/03/2017. Thus, reassessment proceedings were initiated within a period of 4 years

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 ()

u/s 143(3) r.w.s. 147 of on 20.12.2018 under the name as the legal heir of legal heir of late sh the Act on 20.12.2018 under the name as the Vandravan P. Shah Vandravan P. Shah, having PAN No. AARPSS9053J AARPSS9053J of the deceased. 4.7 The appeal was filed against the assessment order was filed against the assessment order

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

u/s \n37. In view of all the above, for the A.Y. 2010-11 I have reason \nto believe that income assessable to tax amounting to more than \nrupees fifty thousand has escaped assessment and hence notice \nu/s 148 is to be issued.” (Emphasis Supplied)\n31. From the material on record it is apparent that the Assessing \nOfficer had initiated reassessment

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

u/s 37. In view of all the\nabove, for the A.Y. 2012-13 I have reason to believe that\nincome assessable to tax amounting to more than rupees\nfifty thousand has escaped assessment and hence notice\nu/s 148 is to be issued.” (Emphasis Supplied)\n\n31. From the material on record it is apparent that the Assessing\nOfficer had initiated

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

u/s\nITA No. 2616-2623 /Mum /2024, ITA No. 2845, 2841, 2836, 2834,\n2827, 2830 & 2823 / Mum / 2024 & C.O. No. 97 & 96 / Mum / 2024\n Assessment Year 2010-2011, 2012-2013 to 2019-2020\n20\n37. In view of all the above, for the A.Y. 2010-11 I have reason\nto believe that income assessable to tax amounting to more

AMBUJA CEMENT INDIA P.LTD,MUMBAI vs. ASST CIT CIR 3(1), MUMBAI

In the result appeal of the assessee is allowed as indicated above

Bench: Shri Joginder Singh & Shri Ramit Kocharआयकर अपीऱ सं./I.T.A. No.2600/Mum/2014 (नििाारण वर्ा / Assessment Year : 2005-06)

160 (Bom) [Where 'reasons to believe' shows that income has escaped assessment based on the disclosures made by the assessee itself and there being no finding to the effect that the assessee has failed to fully and truly disclose all necessary facts for the purpose of assessment recourse to power u/s 147 cannot be sustained] Panchratna Co.-op. Housing Society

VIPUL IMPEX & INFRABUILD LTD.,MUMBAI vs. ACIT-4(2), MUMBAI

The appeals of the Revenue are allowed for statistical purposes

Bench: Shri Joginder Singh & Shri G. Manjunatha

reassessment was held to be valid. In the case of Convergys Customer Management v. Asst. DIT, (2013) 357 ITR 177 (Del), where there being prima facie material in the possession of the Assessing Officer to form a tentative belief that section 9(1)(i) held attracted, said reason by itself constituted a relevant ground to reopen the assessment

VIPUL IMPEX & INFRABUILD LTD.,MUMBAI vs. ACIT-4(2), MUMBAI

The appeals of the Revenue are allowed for statistical purposes

Bench: Shri Joginder Singh & Shri G. Manjunatha

reassessment was held to be valid. In the case of Convergys Customer Management v. Asst. DIT, (2013) 357 ITR 177 (Del), where there being prima facie material in the possession of the Assessing Officer to form a tentative belief that section 9(1)(i) held attracted, said reason by itself constituted a relevant ground to reopen the assessment

DCIT CIR. 4(3)(2), MUMBAI vs. VIPUL IMPEX & INFRABUILD LTD., MUMBAI

The appeals of the Revenue are allowed for statistical purposes

Bench: Shri Joginder Singh & Shri G. Manjunatha

reassessment was held to be valid. In the case of Convergys Customer Management v. Asst. DIT, (2013) 357 ITR 177 (Del), where there being prima facie material in the possession of the Assessing Officer to form a tentative belief that section 9(1)(i) held attracted, said reason by itself constituted a relevant ground to reopen the assessment

DCIT CIR. 4(3)(2), MUMBAI vs. VIPUL IMPEX & INFRABUILD LTD., MUMBAI

The appeals of the Revenue are allowed for statistical purposes

Bench: Shri Joginder Singh & Shri G. Manjunatha

reassessment was held to be valid. In the case of Convergys Customer Management v. Asst. DIT, (2013) 357 ITR 177 (Del), where there being prima facie material in the possession of the Assessing Officer to form a tentative belief that section 9(1)(i) held attracted, said reason by itself constituted a relevant ground to reopen the assessment

DCIT CIR. 4(3)(2), MUMBAI vs. VIPUL IMPEX & INFRABUILD LTD., MUMBAI

The appeals of the Revenue are allowed for statistical purposes

Bench: Shri Joginder Singh & Shri G. Manjunatha

reassessment was held to be valid. In the case of Convergys Customer Management v. Asst. DIT, (2013) 357 ITR 177 (Del), where there being prima facie material in the possession of the Assessing Officer to form a tentative belief that section 9(1)(i) held attracted, said reason by itself constituted a relevant ground to reopen the assessment

VIPUL IMPEX & INFRABUILD LTD.,MUMBAI vs. ACIT-4(2), MUMBAI

The appeals of the Revenue are allowed for statistical purposes

Bench: Shri Joginder Singh & Shri G. Manjunatha

reassessment was held to be valid. In the case of Convergys Customer Management v. Asst. DIT, (2013) 357 ITR 177 (Del), where there being prima facie material in the possession of the Assessing Officer to form a tentative belief that section 9(1)(i) held attracted, said reason by itself constituted a relevant ground to reopen the assessment

ITO 8(1)(4), MUMBAI vs. SENTIA DEVELOPERS LTD, MUMBAI

In the result, appeal filed by the Revenue is dismissed

Bench: Shri Aby T Varkey () & Shri Om Prakash Kant () Assessment Year: 2009-10

160 (Bom) (IT) (2012) 50 SOT 433 (Mum) (Trib.), f. International Global Networks BV v. DDIT f. International Global Networks BV v. DDIT (IT) (2012) 50 SOT 433 (Mum) (Trib.), g. General Insurance Corporation of India v. Dy .CIT (2012) Vol.114 g. General Insurance Corporation of India v. Dy .CIT (2012) Vol.114 g. General Insurance Corporation of India

FOREVER FLOURISHING FIN & INV. PVT LTD,MUMBAI vs. DCIT-CC-3(4), MUMBAI, MUMBAI

In the result, appeal for the assessment year 2012

Bench: Shri Om Prakash Kant () & Ms. Kavitha Rajagopal ()

147 cannot be quashed merely for the reason that during the course of the reassessment proceedings, the assessee has not been course of the reassessment proceedings, the assessee has not been course of the reassessment proceedings, the assessee has not been provided opportunity for cross provided opportunity for cross-examining the persons whose e persons whose statement have been related

FOREVER FLOURISHING FIN. & INV. PVT. LTD. ,MUMBAI vs. DCIT (CC)-3(4), MUMBAI, MUMBAI

In the result, appeal for the assessment year 2012

Bench: Shri Om Prakash Kant () & Ms. Kavitha Rajagopal ()

147 cannot be quashed merely for the reason that during the course of the reassessment proceedings, the assessee has not been course of the reassessment proceedings, the assessee has not been course of the reassessment proceedings, the assessee has not been provided opportunity for cross provided opportunity for cross-examining the persons whose e persons whose statement have been related

ITO 6(1)(3), MUMBAI vs. ARISTO REALTY DEVELOPERS LTD, MUMBAI

In the result, the appeal of Revenue appeal is dismissed

Bench: Sri Mahavir Singh, Jm & Sri Manoj Kumar Aggarwal, Am

160,60,88,464/- includes the amount payable to SBI Home Finance Ltd. amounting to ₹ 162,70,000/- against the O/o Debentures issued to them. 4) During the year 1/4/2004 no new secured loans are taken. 5) During the period 1/4/2004 to 31/3/2005 we have made the settlement with Punjab & Sind Bank, Vysya Bank Ltd. and SBI Finance

LESHARK GLOBAL LLP ,MUMBAI vs. DCIT CC 4(1), MUMBAI

In the result, all the appeals for A

147 which are for the benefit of the revenue and not an assessee, an assessee cannot be permitted to convert the reassessment proceedings as his appeal or revision, in disguise, and seek relief in respect of items earlier rejected or claim relief in respect of items not claimed in the original assessment proceedings, unless relatable to 'escaped income', and reagitate