BharatTax.net
SearchITATHigh CourtsSupreme CourtPhrasesAI ResearchHistory

Filters

BharatTax.net

Free search engine for ITAT (Income Tax Appellate Tribunal) judgments across all 28 benches in India.

Quick Links

  • Search Judgments
  • Browse by Bench
  • Recent Judgments

About

BharatTax provides free access to Income Tax Appellate Tribunal orders for legal research and reference.

© 2026 BharatTax.net. All rights reserved.

1,647 results for “reassessment u/s 147”+ Section 2(22)(e)clear

Sorted by relevance

Mumbai1,647Delhi1,432Chennai563Bangalore561Ahmedabad369Jaipur286Kolkata285Hyderabad280Chandigarh161Indore154Surat145Pune124Visakhapatnam123Rajkot113Raipur98Lucknow62Amritsar55Guwahati54Cuttack53Nagpur48Patna40Cochin37Agra35Telangana29Jodhpur26Dehradun22Allahabad21Karnataka20SC5Orissa4Ranchi4Panaji3Gauhati2Jabalpur2Kerala2Uttarakhand1Varanasi1Rajasthan1

Key Topics

Section 143(3)115Section 14776Addition to Income62Section 14860Section 153C58Section 153A49Reopening of Assessment32Disallowance27Section 139(1)

DCIT CC-8(2),MUMBAI, MUMBAI vs. RAKESH S KATHOTIA, MUMBAI

In the result appeal filed by the revenue stands dismissed

ITA 4295/MUM/2025[2017-18]Status: DisposedITAT Mumbai13 Oct 2025AY 2017-18

Bench: Shri Sandeep Gosain & Shri Prabhash Shankar

Section 132Section 153ASection 2(22)(e)Section 250

147 would give arbitrary powers to the Assessing Officers to re- open. We must also keep in mind the conceptual difference between power to review and power to re-assess. The assessing officer has no power to review; he has the power to reassess. But reassessment has to be based on fulfilment of certain pre-condition and if the concept

GLOBAL BUSINESS CONEXXTIONS PVT.LTD.,MADHYA PRADESH vs. ACIT/DCIT-5(3), MUMBAI

ITA 720/MUM/2023[2013-14]Status: Disposed

Showing 1–20 of 1,647 · Page 1 of 83

...
19
Reassessment19
Section 6817
Section 14A17
ITAT Mumbai
28 Jun 2023
AY 2013-14
For Appellant: Shri Jitendra SinghFor Respondent: Dr. Kishor Dhule
Section 143(3)Section 147Section 2(22)(e)

u/s 2(22)(e) of the Act without appreciating that as per the provisions of section 2(22)(e) of the Act, the loans and advances are considered as dividend only in the hands of the shareholder. Since the appellant is not a shareholder of Advantage Overseas Private Limited, provisions of section 2(22)(e

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:

ITA 220/MUM/2023[2016-17]Status: DisposedITAT Mumbai27 Apr 2023AY 2016-17

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

For Appellant: Mr. Bharat Kumar, ARFor Respondent: Mr. Milind S. Chavan, DR
Section 139(1)

reassessment proceedings , therefore, the issue is rendered merely academic and therefore, the issue is rendered merely academic and therefore, the issue is rendered merely academic and therefore, we are not adjudicating upon the same therefore, we are not adjudicating upon the same in this appeal in this appeal. 8. Now we take up the appeal of the assessee

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:

ITA 192/MUM/2023[2016-17]Status: DisposedITAT Mumbai27 Apr 2023AY 2016-17

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

For Appellant: Mr. Bharat Kumar, ARFor Respondent: Mr. Milind S. Chavan, DR
Section 139(1)

reassessment proceedings , therefore, the issue is rendered merely academic and therefore, the issue is rendered merely academic and therefore, the issue is rendered merely academic and therefore, we are not adjudicating upon the same therefore, we are not adjudicating upon the same in this appeal in this appeal. 8. Now we take up the appeal of the assessee

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:

ITA 195/MUM/2023[2020-21]Status: DisposedITAT Mumbai27 Apr 2023AY 2020-21

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

For Appellant: Mr. Bharat Kumar, ARFor Respondent: Mr. Milind S. Chavan, DR
Section 139(1)

reassessment proceedings , therefore, the issue is rendered merely academic and therefore, the issue is rendered merely academic and therefore, the issue is rendered merely academic and therefore, we are not adjudicating upon the same therefore, we are not adjudicating upon the same in this appeal in this appeal. 8. Now we take up the appeal of the assessee

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:

ITA 221/MUM/2023[2016-17]Status: DisposedITAT Mumbai27 Apr 2023AY 2016-17

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

For Appellant: Mr. Bharat Kumar, ARFor Respondent: Mr. Milind S. Chavan, DR
Section 139(1)

reassessment proceedings , therefore, the issue is rendered merely academic and therefore, the issue is rendered merely academic and therefore, the issue is rendered merely academic and therefore, we are not adjudicating upon the same therefore, we are not adjudicating upon the same in this appeal in this appeal. 8. Now we take up the appeal of the assessee

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:

ITA 217/MUM/2023[2013-14]Status: DisposedITAT Mumbai27 Apr 2023AY 2013-14

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

For Appellant: Mr. Bharat Kumar, ARFor Respondent: Mr. Milind S. Chavan, DR
Section 139(1)

reassessment proceedings , therefore, the issue is rendered merely academic and therefore, the issue is rendered merely academic and therefore, the issue is rendered merely academic and therefore, we are not adjudicating upon the same therefore, we are not adjudicating upon the same in this appeal in this appeal. 8. Now we take up the appeal of the assessee

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:

ITA 193/MUM/2023[2017-18]Status: DisposedITAT Mumbai27 Apr 2023AY 2017-18

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

For Appellant: Mr. Bharat Kumar, ARFor Respondent: Mr. Milind S. Chavan, DR
Section 139(1)

reassessment proceedings , therefore, the issue is rendered merely academic and therefore, the issue is rendered merely academic and therefore, the issue is rendered merely academic and therefore, we are not adjudicating upon the same therefore, we are not adjudicating upon the same in this appeal in this appeal. 8. Now we take up the appeal of the assessee

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:

ITA 194/MUM/2023[2018-19]Status: DisposedITAT Mumbai27 Apr 2023AY 2018-19

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

For Appellant: Mr. Bharat Kumar, ARFor Respondent: Mr. Milind S. Chavan, DR
Section 139(1)

reassessment proceedings , therefore, the issue is rendered merely academic and therefore, the issue is rendered merely academic and therefore, the issue is rendered merely academic and therefore, we are not adjudicating upon the same therefore, we are not adjudicating upon the same in this appeal in this appeal. 8. Now we take up the appeal of the assessee

RAMESH PREMJI SHAH,MUMBAI vs. DEPUTY COMMISSIONER OF INCOME TAX , MUMBAI

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

ITA 1985/MUM/2022[2012-13]Status: DisposedITAT Mumbai09 Jan 2023AY 2012-13

Bench: Shri Aby T. Varkey, Jm & Shri Amarjit Singh, Am आयकर अपील सं/ I.T.A. No.1985/Mum/2022 (निर्धारण वर्ा / Assessment Years: 2012-13) Ramesh Premji Shah बिधम/ Dcit 3-6 Shreeji Apartments 45 Aayakar Bhavan, Marine Vs. Jp Road Andheri (W), Lines, Mumbai-400020. Mumbai-400058. स्थधयी लेखध सं./जीआइआर सं./Pan/Gir No. : Aadps2715F (अपीलार्थी /Appellant) .. (प्रत्यर्थी / Respondent) Assessee By: Shri Subhas Bains Revenue By: Ms. Mahita Nair (Sr. Ar) सुनवाई की तारीख / Date Of Hearing: 19/10/2022 घोषणा की तारीख /Date Of Pronouncement: 09/01/2023 आदेश / O R D E R Per Aby T. Varkey, Jm: This Is An Appeal Preferred By The Assessee Against The Order Of The Ld. Commissioner Of Income Tax (Appeals)/Nfac, Delhi Dated 15.07.2022 For The Assessment Year 2012-13. 2. The Grounds Of Appeal Raised By The Assessee Are As Under: - “1The Cit(A)/Nfac Has Erred On The Facts & In The Circumstances Of The Case, In As Much As Upholding The Reassessment Order Passed By The Assessing Officer U/S 143(3) Rws 147 Of The It Act Dated 09.12.2019 Which Was Requested To Be Held As Illegal & Bad In Law As No Reassessment Can Be Made For Making Addition U/S 2(22)(E) Of The It Act U/S 147 Especially When The Disallowance Was Made From All The Details & Facts Available On Record And, Therefore, The Main Condition For Reopening The Case Beyond Four Years Which Is Failure On The Part Of Appellant To Disclose Fully & Truly All Material Facts Was Not Established By The Ao. Hon’Ble Itat Is Requested To Reverse The Order

For Appellant: Shri Subhas BainsFor Respondent: Ms. Mahita Nair (Sr. AR)
Section 143(3)Section 147Section 2(22)(e)Section 234ASection 271(1)(c)Section 71

reassessment order passed by the Assessing Officer u/s 143(3) rws 147 of the IT Act dated 09.12.2019 assessing total income at Rs,3,46,93,780/- as against returned income of Rs.1,85,690/-,which was requested to be held as a in law as the same was liable to be quashed and cancelled as the assessment order

M/S MULTIVENTURE FINANCIAL SERVICES PVT LTD.,MUMBAI vs. ITO 3 (2)(2), MUMBAI

In the result, the appeals of the Revenue are dismissed and the appeal of the assessee is allowed

ITA 4882/MUM/2019[2010-11]Status: DisposedITAT Mumbai22 Feb 2021AY 2010-11

Bench: Shri Rajesh Kumar & Shri Amarjit Singh

For Appellant: Shri Vishnu Aggarwal, A.RFor Respondent: Shri Bharat Andhala, D.R
Section 143(3)Section 2Section 2(47)

2(22)(e) of the Act. Since the facts in the present case are similar to one as decided by us in ITA No.3717/M/2019 A.Y. 2013-14 in ground Nos.4 to 6 wherein we have upheld the order of Ld. CIT(A) by dismissing the appeal of the Revenue. Therefore, our finding in ground Nos.4 to 6 of ITA No.3717/M/2019

ITO - 3(2)(2), MUMBAI vs. M/S MULTIVENTURE FINANCIAL SERVICES PVT. LTD, MUMBAI

In the result, the appeals of the Revenue are dismissed and the appeal of the assessee is allowed

ITA 3715/MUM/2019[2010-11]Status: DisposedITAT Mumbai22 Feb 2021AY 2010-11

Bench: Shri Rajesh Kumar & Shri Amarjit Singh

For Appellant: Shri Vishnu Aggarwal, A.RFor Respondent: Shri Bharat Andhala, D.R
Section 143(3)Section 2Section 2(47)

2(22)(e) of the Act. Since the facts in the present case are similar to one as decided by us in ITA No.3717/M/2019 A.Y. 2013-14 in ground Nos.4 to 6 wherein we have upheld the order of Ld. CIT(A) by dismissing the appeal of the Revenue. Therefore, our finding in ground Nos.4 to 6 of ITA No.3717/M/2019

MRS.PRABHABEN K. GALA,MUMBAI vs. ITO WARD-23(1)(3), MUMBAI

In the result, appeal of the assessee is partly allowed

ITA 3942/MUM/2018[2009-10]Status: DisposedITAT Mumbai26 Jul 2019AY 2009-10

Bench: Shri C.N. Prasad, Hon'Ble

For Appellant: Shri V.D. ParmarFor Respondent: Shri Chaitanya Anjaria
Section 143(1)Section 143(2)Section 143(3)Section 147Section 148Section 292B

E R PER C.N. PRASAD (JM) 1. These two appeals are filed by the assessee challenging the order of the Learned Commissioner of Income Tax (Appeals)–40, Mumbai [hereinafter in short “Ld.CIT(A)”] dated 02.01.2018 for the A.Ys. 2009-10 and 2010-11 in sustaining the validity of assessment order and also the additions/disallowance made in the assessment towards bogus

NITIN P. CHHEDA,MUMBAI vs. ITO 23(1)(3), MUMBAI

In the result, appeal of the assessee is partly allowed

ITA 3944/MUM/2018[2009-10]Status: DisposedITAT Mumbai26 Jul 2019AY 2009-10

Bench: Shri C.N. Prasad, Hon'Ble

For Appellant: Shri V.D. ParmarFor Respondent: Shri Chaitanya Anjaria
Section 143(1)Section 143(2)Section 143(3)Section 147Section 148Section 292B

E R PER C.N. PRASAD (JM) 1. These two appeals are filed by the assessee challenging the order of the Learned Commissioner of Income Tax (Appeals)–40, Mumbai [hereinafter in short “Ld.CIT(A)”] dated 01.01.2018 for the A.Ys. 2009-10 and 2010-11 in sustaining the validity of assessment order and also the additions/disallowance made in the assessment towards bogus

NITIN P. CHHEDA,MUMBAI vs. ITO 23(1)(3), MUMBAI

In the result, appeal of the assessee is partly allowed

ITA 3945/MUM/2018[2010-11]Status: DisposedITAT Mumbai26 Jul 2019AY 2010-11

Bench: Shri C.N. Prasad, Hon'Ble

For Appellant: Shri V.D. ParmarFor Respondent: Shri Chaitanya Anjaria
Section 143(1)Section 143(2)Section 143(3)Section 147Section 148Section 292B

E R PER C.N. PRASAD (JM) 1. These two appeals are filed by the assessee challenging the order of the Learned Commissioner of Income Tax (Appeals)–40, Mumbai [hereinafter in short “Ld.CIT(A)”] dated 01.01.2018 for the A.Ys. 2009-10 and 2010-11 in sustaining the validity of assessment order and also the additions/disallowance made in the assessment towards bogus

MRS.PRABHABEN K. GALA,MUMBAI vs. ITO WARD-23(1)(3), MUMBAI

In the result, appeal of the assessee is partly allowed

ITA 3943/MUM/2018[2010-11]Status: DisposedITAT Mumbai26 Jul 2019AY 2010-11

Bench: Shri C.N. Prasad, Hon'Ble

For Appellant: Shri V.D. ParmarFor Respondent: Shri Chaitanya Anjaria
Section 143(1)Section 143(2)Section 143(3)Section 147Section 148Section 292B

E R PER C.N. PRASAD (JM) 1. These two appeals are filed by the assessee challenging the order of the Learned Commissioner of Income Tax (Appeals)–40, Mumbai [hereinafter in short “Ld.CIT(A)”] dated 02.01.2018 for the A.Ys. 2009-10 and 2010-11 in sustaining the validity of assessment order and also the additions/disallowance made in the assessment towards bogus

ASGAR MOHAMMED HUSSAIN GHADIALI,MUMBAI vs. ITO 17(1)(2), MUMBAI

In the result, appeal of the assessee is partly allowed

ITA 1879/MUM/2017[2009-10]Status: DisposedITAT Mumbai26 Jul 2019AY 2009-10

Bench: Shri C.N. Prasad, Hon'Ble & Shri Manoj Kumar Aggarwal, Hon'Bleshri Asgar Mohammed Hussain Ghadiali V. Income Tax Officer – 17(1)(2) Gem Time Trading, 59 Nakhoda Street Aayakar, Mumbai New Vora’S Malo, 3Rd Floor, Room No. 24 Mumbai – 400 003 & M/S. Kagalwala & Associates Pan: Aappk 4042 B (Assessee) (Respondent) Assessee By : Shri Dr. K. Shivram & Shri Rahul K. Hakani Department By : Shri Satish Chandra Rajore

For Appellant: Shri Dr. K. Shivram &For Respondent: Shri Satish Chandra Rajore
Section 124Section 143(2)Section 143(3)Section 148Section 292B

E R PER C.N. PRASAD (JM) 1. This appeal is filed by the assessee against the order of the Learned Commissioner of Income Tax (Appeals) -28, Mumbai [hereinafter in short “Ld.CIT(A)”] dated 13.01.2017 for the A.Y. 2009-10. 2 Shri Asgar Mohammed Hussain Ghadiali 2. The assessee in its appeal raised various grounds of appeal on merits and also

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

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

ITA 216/MUM/2023[2012-13]Status: DisposedITAT Mumbai28 Apr 2023AY 2012-13

Bench: Shri Kuldip Singh () & Shri Om Prakash Kant () Assessment Year: 2012-13 Sai Prerana Co-Op Society Ltd., Ito-7(3)(2), 317, Puran Aasha Bldg. Gr. Fl. Room No. 126, 1St Floor, Narashi Natha Street, Katha Vs. Kautilya Bhavan, C-41 To C- Bazar Musjid Bunder (W), 43 Block, Bandra Kurla Mumbai-400 009. Complex, Bandra (East) Mumbai-400051. Pan No. Aadts 5638 M Appellant Respondent Assessee By : Ms. Ruby Srivastava & Mr. Bharat Kumar, Ca Revenue By : Mr. Milind S. Chavan, Dr Date Of Hearing : 27/04/2023 : Date Of Pronouncement 28/04/2023 Order

For Appellant: Ms. Ruby Srivastava &For Respondent: Mr. Milind S. Chavan, DR
Section 139(1)Section 14Section 143(3)Section 147Section 148Section 80P

22,880/-. Subsequently, the . Subsequently, the notice u/s 148 of the Act was u/s 148 of the Act was issued and case was reopened u/s 14 case was reopened u/s 147 of the Act on the ground that the assessee had claimed deduction u/s the Act on the ground that the assessee had claimed deduction u/s

THE TATA POWER COMPANY LTD,MUMBAI vs. PR CIT 2, MUMBAI

In the result, appeal is allowed, as indicated above

ITA 1307/MUM/2020[2010-11]Status: DisposedITAT Mumbai29 Jul 2021AY 2010-11

Bench: Shri Saktijit Dey () & Shri Rajesh Kumar ()

Section 115JSection 143(3)Section 144C(1)Section 147Section 263Section 80I

E R Per: Saktijit Dey (JM): Captioned appeal has been filed by the assessee calling into question the validity of the order dated 28-01-1010 passed by learned Principal Commissioner of Income Tax-2 (PCIT, hereinafter), Mumbai under section 263 of the Income-tax Act, 1961 for the assessment year 2010-11. 2. Briefly the facts are, the assessee

ITO 24(1)(2), MUMBAI vs. ANUSHREE V. KHETAN, MUMBAI

In the result, the issue stands remitted to the file of the assessing officer

ITA 4975/MUM/2016[2006-07]Status: DisposedITAT Mumbai01 Jun 2018AY 2006-07

Bench: Shri Shamim Yahya, Am & Shri Pawan Sing, Jm आयकर अपील सं./I.T.A. No. 4975/Mum/2016 ("नधा"रण वष" / Assessment Year: 2006-07) The Ito-24(1)(2) Smt. Anushree V. Khetan बनाम/ 2Nd Floor, Khetan Bhavan, 605, Piramal Chambers, Lalbaug, Mumbai-400 012 78, J. B. Nagar, Andheri (E), Vs. Mumbai-400 049 "थायी लेखा सं./जीआइआर सं./Pan/Gir No. Aocpk 8810 J (अपीलाथ" /Appellant) (""यथ" / Respondent) : अपीलाथ" क" ओर से / Appellant By : Shri Ram Tiwari ""यथ" क" ओर से/Respondent By : Shri Rakesh Joshi

For Appellant: Shri Ram TiwariFor Respondent: Shri Rakesh Joshi
Section 142(1)Section 143(3)Section 147Section 148Section 2(22)(e)

u/s. 2(22)(e) of the Act are satisfied. Hence, the entire amount of loans and advances given during FY 2005-06 needs to be taxed as "Deemed Dividend" in the hand of the recipient i.e. Ms. Anushree Khetan in AY 2006-07. AO also pointed that during the course of assessment proceedings for A.Y. 2005-06 appellant had mislead