INCOME TAX OFFICER-26(2)(1), MUMBAI vs. SAI PRERANA CO-OP CREDIT SOCIETY LTD., MUMBAI

In the result, appeals of the assessee and the Revenue are In the result, appeals of the assessee and the Revenue are In the result, appeals of the assessee and the Revenue are decided as under:

Bench: Shri Kuldip Singh () & Shri Om Prakash Kant () Ita Nos. 217, 220 & 221, 218 & 219, 215, 214/Mum/2023 Assessment Years: 2013-14, 2016-17, 2017-18, 2018-19, 2020-21 Sai Prerana Co-Op Credit Ito-17(3)(2), Society Ltd., Room No. 126, 1St Floor, Vs. 317, Puran Aasha Bldg, Gr. Fl. Kautilya Bhavan, C-41 To C- Narashi Natha Street, Katha 43, G Block Bandra Kurla Bazar Masjid Bunder (W), Complex, Bandra (East), Mumbai-400 009. Mumbai-400051. Pan No. Aadts 5638 M Appellant Respondent

147 of the Act is quashed as void ab initio void ab initio. The ground No. 1 and 2 of the appeal nd 2 of the appeal of the assessee are accordingly allowed. the assessee are accordingly allowed. 7. In ground No. 3, the assessee is seeking deduction u/s 80P of In ground No. 3, the assessee is seeking deduction

INCOME TAX OFFICER-26(2)(1), MUMBAI vs. SAI PRERANA CO-OP CREDIT SOCIETY LTD., MUMBAI

In the result, appeals of the assessee and the Revenue are In the result, appeals of the assessee and the Revenue are In the result, appeals of the assessee and the Revenue are decided as under:

Bench: Shri Kuldip Singh () & Shri Om Prakash Kant () Ita Nos. 217, 220 & 221, 218 & 219, 215, 214/Mum/2023 Assessment Years: 2013-14, 2016-17, 2017-18, 2018-19, 2020-21 Sai Prerana Co-Op Credit Ito-17(3)(2), Society Ltd., Room No. 126, 1St Floor, Vs. 317, Puran Aasha Bldg, Gr. Fl. Kautilya Bhavan, C-41 To C- Narashi Natha Street, Katha 43, G Block Bandra Kurla Bazar Masjid Bunder (W), Complex, Bandra (East), Mumbai-400 009. Mumbai-400051. Pan No. Aadts 5638 M Appellant Respondent

147 of the Act is quashed as void ab initio void ab initio. The ground No. 1 and 2 of the appeal nd 2 of the appeal of the assessee are accordingly allowed. the assessee are accordingly allowed. 7. In ground No. 3, the assessee is seeking deduction u/s 80P of In ground No. 3, the assessee is seeking deduction

SAI PRERNA CO-OP. CREDIT SOCIETY LTD,MUMBAI vs. ITO WD 17(3) (2) , MUMBAI

In the result, appeals of the assessee and the Revenue are In the result, appeals of the assessee and the Revenue are In the result, appeals of the assessee and the Revenue are decided as under:

Bench: Shri Kuldip Singh () & Shri Om Prakash Kant () Ita Nos. 217, 220 & 221, 218 & 219, 215, 214/Mum/2023 Assessment Years: 2013-14, 2016-17, 2017-18, 2018-19, 2020-21 Sai Prerana Co-Op Credit Ito-17(3)(2), Society Ltd., Room No. 126, 1St Floor, Vs. 317, Puran Aasha Bldg, Gr. Fl. Kautilya Bhavan, C-41 To C- Narashi Natha Street, Katha 43, G Block Bandra Kurla Bazar Masjid Bunder (W), Complex, Bandra (East), Mumbai-400 009. Mumbai-400051. Pan No. Aadts 5638 M Appellant Respondent

147 of the Act is quashed as void ab initio void ab initio. The ground No. 1 and 2 of the appeal nd 2 of the appeal of the assessee are accordingly allowed. the assessee are accordingly allowed. 7. In ground No. 3, the assessee is seeking deduction u/s 80P of In ground No. 3, the assessee is seeking deduction

ITO-26(2)(1), MUMBAI vs. SAI PRERANA CO-OP CREDIT SOCIETY LTD, MUMBAI

In the result, appeals of the assessee and the Revenue are In the result, appeals of the assessee and the Revenue are In the result, appeals of the assessee and the Revenue are decided as under:

Bench: Shri Kuldip Singh () & Shri Om Prakash Kant () Ita Nos. 217, 220 & 221, 218 & 219, 215, 214/Mum/2023 Assessment Years: 2013-14, 2016-17, 2017-18, 2018-19, 2020-21 Sai Prerana Co-Op Credit Ito-17(3)(2), Society Ltd., Room No. 126, 1St Floor, Vs. 317, Puran Aasha Bldg, Gr. Fl. Kautilya Bhavan, C-41 To C- Narashi Natha Street, Katha 43, G Block Bandra Kurla Bazar Masjid Bunder (W), Complex, Bandra (East), Mumbai-400 009. Mumbai-400051. Pan No. Aadts 5638 M Appellant Respondent

147 of the Act is quashed as void ab initio void ab initio. The ground No. 1 and 2 of the appeal nd 2 of the appeal of the assessee are accordingly allowed. the assessee are accordingly allowed. 7. In ground No. 3, the assessee is seeking deduction u/s 80P of In ground No. 3, the assessee is seeking deduction

ITO-26(2)(1) , MUMBAI vs. SAI PRERANA CO-OP CREDIT SOCIETY LTD, MUMBAI

In the result, appeals of the assessee and the Revenue are In the result, appeals of the assessee and the Revenue are In the result, appeals of the assessee and the Revenue are decided as under:

Bench: Shri Kuldip Singh () & Shri Om Prakash Kant () Ita Nos. 217, 220 & 221, 218 & 219, 215, 214/Mum/2023 Assessment Years: 2013-14, 2016-17, 2017-18, 2018-19, 2020-21 Sai Prerana Co-Op Credit Ito-17(3)(2), Society Ltd., Room No. 126, 1St Floor, Vs. 317, Puran Aasha Bldg, Gr. Fl. Kautilya Bhavan, C-41 To C- Narashi Natha Street, Katha 43, G Block Bandra Kurla Bazar Masjid Bunder (W), Complex, Bandra (East), Mumbai-400 009. Mumbai-400051. Pan No. Aadts 5638 M Appellant Respondent

147 of the Act is quashed as void ab initio void ab initio. The ground No. 1 and 2 of the appeal nd 2 of the appeal of the assessee are accordingly allowed. the assessee are accordingly allowed. 7. In ground No. 3, the assessee is seeking deduction u/s 80P of In ground No. 3, the assessee is seeking deduction

RAJDEEP MARKETING PVT. LTD.,MUMBAI vs. ITO, WD. 3(3)(1), MUMBAI

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

reassessment proceedings under section 147 of the I.T. Act. 2. The AO reopened the assessment of the year under consideration by issuing notice u/s 148 of the Act. The relevant portion of the reasons recorded by the assessing officer for reopening of assessment, which depicts the details of escaped income is extracted below:- “During the year the assessee company

SHRI. ASHOK KUMAR V SANGHI,MUMBAI vs. ITO WARD 2 (3)(2), MUMBAI

In the result, appeal by the assessee is partly allowed for statistical purpose

Bench: Shri Om Prakash Kant & Shri Sandeep Singh Karhail

reassessment proceedings in the case of assessee was initiated and notice under section 148 of the Act was issued on 17/03/2015 after recording of reasons. In response, assessee filed electronically return of income on 02/04/2015, declaring NIL total income. Pursuant thereto, statutory notices under section 143(2) and 142(1) of the Act were issued and assessee filed its reply

SHRI NARENDRA S SHAH,MUMBAI vs. DCIT, CC- 2(2), , MUMBAI

Bench: Shri Vikas Awasthy () & Shri Om Prakash Kant ()

147 of the IT Act 1961 by the the IT Act 1961 by the Ld AO without appreciating that the reopening is bad Ld AO without appreciating that the reopening is bad Ld AO without appreciating that the reopening is bad in law and the reason assigned for doing so are in law and the reason assigned for doing

DCIT, CC-2(2),, MUM vs. SHRI NARENDRA S SHAH, MUMBAI

Bench: Shri Vikas Awasthy () & Shri Om Prakash Kant ()

147 of the IT Act 1961 by the the IT Act 1961 by the Ld AO without appreciating that the reopening is bad Ld AO without appreciating that the reopening is bad Ld AO without appreciating that the reopening is bad in law and the reason assigned for doing so are in law and the reason assigned for doing

SHRI NARENDRA S SHAH,MUM vs. DCIT, CC-2(2), , MUM

Bench: Shri Vikas Awasthy () & Shri Om Prakash Kant ()

147 of the IT Act 1961 by the the IT Act 1961 by the Ld AO without appreciating that the reopening is bad Ld AO without appreciating that the reopening is bad Ld AO without appreciating that the reopening is bad in law and the reason assigned for doing so are in law and the reason assigned for doing

DCIT, CC-2(2), , MUM vs. SHRI NARENDRA S SHAH, MUM

Bench: Shri Vikas Awasthy () & Shri Om Prakash Kant ()

147 of the IT Act 1961 by the the IT Act 1961 by the Ld AO without appreciating that the reopening is bad Ld AO without appreciating that the reopening is bad Ld AO without appreciating that the reopening is bad in law and the reason assigned for doing so are in law and the reason assigned for doing

SHRI NARENDRA S SHAH,MUM vs. DCIT, CC-2(2),, MUM

Bench: Shri Vikas Awasthy () & Shri Om Prakash Kant ()

147 of the IT Act 1961 by the the IT Act 1961 by the Ld AO without appreciating that the reopening is bad Ld AO without appreciating that the reopening is bad Ld AO without appreciating that the reopening is bad in law and the reason assigned for doing so are in law and the reason assigned for doing

SHRI NARENDRA S SHAH ,MUMBAI vs. DCIT, CEN CIR-(2), , MUMBAI

Bench: Shri Vikas Awasthy () & Shri Om Prakash Kant ()

147 of the IT Act 1961 by the the IT Act 1961 by the Ld AO without appreciating that the reopening is bad Ld AO without appreciating that the reopening is bad Ld AO without appreciating that the reopening is bad in law and the reason assigned for doing so are in law and the reason assigned for doing

SHRI NARENDRA S SHAH,MUMBAI vs. DCIT, CC-2(2),, MUMBAI

Bench: Shri Vikas Awasthy () & Shri Om Prakash Kant ()

147 of the IT Act 1961 by the the IT Act 1961 by the Ld AO without appreciating that the reopening is bad Ld AO without appreciating that the reopening is bad Ld AO without appreciating that the reopening is bad in law and the reason assigned for doing so are in law and the reason assigned for doing

BHASKAR ARVIND KUMAR HINGAD,MUMBAI vs. ASSTT CIT-24(1), MUMBAI, MUMBAI

In the result, the appeal of the assessee stands allowed

Bench: Shri Pramod Kumar, Vp & Shri Aby T. Varkey, Jm आयकर अपील सं/ I.T.A. No.692/Mum/2022 (निर्धारण वर्ा / Assessment Years: 2014-15) Bhaskar Arvind Kumar बिधम/ Acit-24(1) Hingad 601, 6Th Floor, Piramal Vs. Flat No. 1, Ratnakar Chambers, Lalbaug, Parel, Building, 26 Narayan Mumbai-400012. Dhabolkar Road, Mumbai- 400006. स्थधयी लेखध सं./जीआइआर सं./Pan/Gir No. : Aacph2812F (अपीलार्थी /Appellant) .. (प्रत्यर्थी / Respondent) Assessee By: Shri Vijay Mehta Revenue By: Dr. Mahesh Akhade (Dr) सुनवाई की तारीख / Date Of Hearing: 29/08/2022 घोषणा की तारीख /Date Of Pronouncement: 21/10/2022 आदेश / O R D E R Per Aby T. Varkey, Jm: This Appeal Preferred By The Assessee Is Against The Order Of The Ld. Principal Commissioner Of Income Tax-20 [Hereinafter Referred To As The “Pcit”], Mumbai Dated 31.03.2022 For Assessment Year 2014- 15 Passed Under Section 263 Of The Income Tax Act, 1961 (Hereinafter Referred To As “The Act”).

reassessment u/s 147, the limitation period provided in Sec. 263(2) had to be reckoned from the date of order u/s 143(3) and not with reference to date of the order passed u/s 147/143(3). 33 A.Y. 2014-15 Bhaskar Arvind Kumar Hingad 33. Useful reference in this regard may also be made to the decision

ROYAL TWINKLE STAR CLUB PVT. LTD.,MUMBAI vs. DCIT CENTRAL CIRCLE-2(1), MUMBAI

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

Bench: Shri G.S. Pannu & Shri Sandeep Singh Karhail

reassessment proceedings, the assessee explained its modus operandi and submitted that the deposits received from its members/customers are accounted as “sales” in its books of accounts and the NAC paid to the members was booked as revenue expenses. The AO vide order dated 26/12/2016 passed under section 143(3) r/w section 147 of the Act did not agree with

ROYAL TWINKLE STAR CLUB P.LTD,MUMBAI vs. ACIT CEN CIR 2(4), MUMBAI

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

Bench: Shri G.S. Pannu & Shri Sandeep Singh Karhail

reassessment proceedings, the assessee explained its modus operandi and submitted that the deposits received from its members/customers are accounted as “sales” in its books of accounts and the NAC paid to the members was booked as revenue expenses. The AO vide order dated 26/12/2016 passed under section 143(3) r/w section 147 of the Act did not agree with

ROYAL TWINKLE STAR CLUB P.LTD,MUMBAI vs. ACIT CEN CIR 2(4), MUMBAI

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

Bench: Shri G.S. Pannu & Shri Sandeep Singh Karhail

reassessment proceedings, the assessee explained its modus operandi and submitted that the deposits received from its members/customers are accounted as “sales” in its books of accounts and the NAC paid to the members was booked as revenue expenses. The AO vide order dated 26/12/2016 passed under section 143(3) r/w section 147 of the Act did not agree with