RAJEEV BRIJBHUSHAN BHATNAGAR,MUMBAI vs. INCOME TAX OFFICER-28(2)(1), MUMBAI, VASHI

In the result, the appeal of the assessee is allowed

Bench: Shri Om Prakash Kant () & Ms. Kavitha Rajagopal () Assessment Year: 2010-11 Rajeev Brijbhushan Bhatnagar, Ito-28(2)(1), C/O Ca Himanshu Gandhi Tower No. 6, Vashi Railway Station Vs. Chartered Accountants 16Th Floor, Commercial Complex, Vashi, D Wing, Trade World Tower, Navi Mumbai-400703. Kamala Mills Compound, Lower Parel, Mumbai-400013. Pan No. Acfpb 2967 G Appellant Respondent

reassessment order passed u/s 147 r.w.s. 144 dated 20.12.2017, the assessee order passed u/s 147 r.w.s. 144 dated 20.12.2017 order passed u/s 147 r.w.s. 144 dated 20.12.2017 preferred appeal before the Ld. CIT(A). The assessee also preferred preferred appeal before the Ld. CIT(A). The assessee al preferred appeal before the Ld. CIT(A). The assessee al appeal against

ATUL SHAMJI BHARANI,MUMBAI vs. DCIT CC- 4(1), MUMBAI

In the result, appeal by the assessee for the

250\nof the Income Tax Act, 1961 (“the Act”) by the learned Commissioner of\nIncome Tax (Appeals)-52, Mumbai, [“learned CIT(A)”], for the assessment\nyears 2011-12 and 2013-14.\n2. Since both appeals pertain to the same assessee and involve similar\nissues that arise out of a similar factual matrix, therefore, these appeals were\nheard together

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 ()

147. This argument is devoid of merit. The concept of "full and true disclosure" presupposes the genuineness concept of "full and true disclosure" presupposes the genuineness concept of "full and true disclosure" presupposes the genuineness of the transaction disclosed. In the reasons recorded, the Assessing ansaction disclosed. In the reasons recorded, the Assessing ansaction disclosed. In the reasons recorded

ATUL SHAMJI BHARANI,MUMBAI vs. DCIT CC- 4(1), MUMBAI

In the result, appeal by the assessee for the

250\nof the Income Tax Act, 1961 (“the Act”) by the learned Commissioner of\nIncome Tax (Appeals)-52, Mumbai, [“learned CIT(A)”], for the assessment\nyears 2011-12 and 2013-14.\n2. Since both appeals pertain to the same assessee and involve similar\nissues that arise out of a similar factual matrix, therefore, these appeals were\nheard together

DCIT, CIRCLE 42(1)(1), INCOME TAX DEPARTMENT vs. GHANSHYAM RASIKLAL SHAH, MUMBAI

In the result, the appeal of the revenue bearing ITA No

Bench: Shrinarendra Kumar Billaiya & Shri Anikesh Banerjeedcit, Circle 42(1)(1), Mumbai Vs Ghanshyam Rasiklal Shah Room 732, 7Th Floor, B-1408, Shankar Park, Agrawal Kautilya Bhavan, Bkc, Bandra Residency, Shankar Lane, Kandivali East, Mumbai-400 051 West, Mumbai-400 067 Pan: Aafps1306Q Appellant Respondent

250 of the Income-tax Act, 1961 (in short, ‘the Act’) for A.Y. 2012-13, date of order 18/07/2024. The impugned order was emanated from the order of the Learned Deputy Commissioner of Income-tax- 33(1), Mumbai (in short, the Ld. AO) passed under section 143(3) read with section 147 of the Act, date of order 18/12/2019

KASHYAP KANIYALAL MEHTA,MUMBAI vs. DCIT CC-4(1), MUMBAI

In the result, appeals of the assessee are allowed

reassessment order holding that the Assessing Officer had not assumed valid jurisdiction in accordance with law. ―The Assessee/Appellant herein has preferred this appeal against the order dated 01.02.2023 impugned herein passed by Ld. Commissioner of Income Tax (Appeal) {in short ‗Ld. Commissioner)‘} u/s 250 r.w.s. 154 of the Income Tax Act 1961 (in short ‗the Act‘). 5 ITA No.6197-6203/Mum/2024 Kashyap

KASHYAP KANIYALAL MEHTA,MUMBAI vs. DCIT, CC-4(1), MUMBAI

In the result, appeals of the assessee are allowed

reassessment order holding that the Assessing Officer had not assumed valid jurisdiction in accordance with law. ―The Assessee/Appellant herein has preferred this appeal against the order dated 01.02.2023 impugned herein passed by Ld. Commissioner of Income Tax (Appeal) {in short ‗Ld. Commissioner)‘} u/s 250 r.w.s. 154 of the Income Tax Act 1961 (in short ‗the Act‘). 5 ITA No.6197-6203/Mum/2024 Kashyap

KASHYAP KANIYALAL MEHTA,MUMBAI vs. DCIT CC-4(1), MUMBAI

In the result, appeals of the assessee are allowed

reassessment order holding that the Assessing Officer had not assumed valid jurisdiction in accordance with law. ―The Assessee/Appellant herein has preferred this appeal against the order dated 01.02.2023 impugned herein passed by Ld. Commissioner of Income Tax (Appeal) {in short ‗Ld. Commissioner)‘} u/s 250 r.w.s. 154 of the Income Tax Act 1961 (in short ‗the Act‘). 5 ITA No.6197-6203/Mum/2024 Kashyap

KASHYAP KANIYALAL MEHTA,MUMBAI vs. DCIT CC-4(1), MUMBAI

In the result, appeals of the assessee are allowed

reassessment order holding that the Assessing Officer had not assumed valid jurisdiction in accordance with law. ―The Assessee/Appellant herein has preferred this appeal against the order dated 01.02.2023 impugned herein passed by Ld. Commissioner of Income Tax (Appeal) {in short ‗Ld. Commissioner)‘} u/s 250 r.w.s. 154 of the Income Tax Act 1961 (in short ‗the Act‘). 5 ITA No.6197-6203/Mum/2024 Kashyap

KASHYAP KANIYALAL MEHTA,MUMBAI vs. DCIT CC-4(1), MUMBAI

In the result, appeals of the assessee are allowed

reassessment order holding that the Assessing Officer had not assumed valid jurisdiction in accordance with law. ―The Assessee/Appellant herein has preferred this appeal against the order dated 01.02.2023 impugned herein passed by Ld. Commissioner of Income Tax (Appeal) {in short ‗Ld. Commissioner)‘} u/s 250 r.w.s. 154 of the Income Tax Act 1961 (in short ‗the Act‘). 5 ITA No.6197-6203/Mum/2024 Kashyap

KASHYAP KANIYALAL MEHTA,MUMBAI vs. DCIT CC-4(1), MUMBAI

In the result, appeals of the assessee are allowed

reassessment order holding that the Assessing Officer had not assumed valid jurisdiction in accordance with law. ―The Assessee/Appellant herein has preferred this appeal against the order dated 01.02.2023 impugned herein passed by Ld. Commissioner of Income Tax (Appeal) {in short ‗Ld. Commissioner)‘} u/s 250 r.w.s. 154 of the Income Tax Act 1961 (in short ‗the Act‘). 5 ITA No.6197-6203/Mum/2024 Kashyap

KASHYAP KANIYALAL MEHTA,MUMBAI vs. DCIT CC-4(1), MUMBAI

In the result, appeals of the assessee are allowed

reassessment order holding that the Assessing Officer had not assumed valid jurisdiction in accordance with law. ―The Assessee/Appellant herein has preferred this appeal against the order dated 01.02.2023 impugned herein passed by Ld. Commissioner of Income Tax (Appeal) {in short ‗Ld. Commissioner)‘} u/s 250 r.w.s. 154 of the Income Tax Act 1961 (in short ‗the Act‘). 5 ITA No.6197-6203/Mum/2024 Kashyap

JAYDEEP PROFILES PVT. LTD.,MUMBAI vs. ITO WD 6 (3)(2), MUMBAI

Bench: Shri Joginder Singh & Shri G. Manjunathaassessment Year: 2009-10 Income Tax Officer 6(3)(2), Jaydeep Profiles P. Ltd., R No.503, 5Th Floor, Aayakar 142/7 Lakdi Bunder Road, बनाम/ Bhavan, M.K.Road, Darukhana, Reay Road, Vs. Mumbai 400 020 Mumbai 400 086 (राज"व /Revenue) ("नधा"रती /Assessee) P.A. No. Aaacj8998B Assessment Year: 2009-10 Jaydeep Profiles P. Ltd., Income Tax Officer 6(3)(2), 142/7 Lakdi Bunder Road, R No.503, 5Th Floor, Aayakar बनाम/ Darukhana, Reay Road, Bhavan, M.K.Road, Vs. Mumbai 400 086 Mumbai 400 020 ("नधा"रती /Assessee) (राज"व /Revenue) P.A. No. Aaacj8998B 2 & 2698/Mum/2016

u/s 133A and no other material was found, in that situation, it was held that the such statement has no evidentiary value. 34 & 2698/Mum/2016 Jaydeep Profiles P.Ltd 4.28. In the case of Aradhna Estate Pvt. Ltd. vs DCIT (2018) 91 taxmann.com 119 (Gujarat), the Hon'ble High Court observed/held as under:- “In reasons recorded by the Assessing Officer for reopening

ITO 6(3)(2), MUMBAI vs. JAYDEEP PROFILES P.LTD, MUMBAI

Bench: Shri Joginder Singh & Shri G. Manjunathaassessment Year: 2009-10 Income Tax Officer 6(3)(2), Jaydeep Profiles P. Ltd., R No.503, 5Th Floor, Aayakar 142/7 Lakdi Bunder Road, बनाम/ Bhavan, M.K.Road, Darukhana, Reay Road, Vs. Mumbai 400 020 Mumbai 400 086 (राज"व /Revenue) ("नधा"रती /Assessee) P.A. No. Aaacj8998B Assessment Year: 2009-10 Jaydeep Profiles P. Ltd., Income Tax Officer 6(3)(2), 142/7 Lakdi Bunder Road, R No.503, 5Th Floor, Aayakar बनाम/ Darukhana, Reay Road, Bhavan, M.K.Road, Vs. Mumbai 400 086 Mumbai 400 020 ("नधा"रती /Assessee) (राज"व /Revenue) P.A. No. Aaacj8998B 2 & 2698/Mum/2016

u/s 133A and no other material was found, in that situation, it was held that the such statement has no evidentiary value. 34 & 2698/Mum/2016 Jaydeep Profiles P.Ltd 4.28. In the case of Aradhna Estate Pvt. Ltd. vs DCIT (2018) 91 taxmann.com 119 (Gujarat), the Hon'ble High Court observed/held as under:- “In reasons recorded by the Assessing Officer for reopening

SHRI DINESHKUMAR C. DOSHI,MUMBAI vs. INCOME TAX OFFICER 19(1)(4), MUMBAI

The appeals of the assessee are dismissed

Bench: Shri Joginder Singh

u/s 133A and no other material was found, in that situation, it was held that the such statement has no evidentiary value. 4.28. In the case of Aradhna Estate Pvt. Ltd. vs DCIT (2018) 91 taxmann.com 119 (Gujarat), the Hon'ble High Court observed/held as under:- “In reasons recorded by the Assessing Officer for reopening the assessment. He pointed

IDHASOFT LTD.,MUMBAI vs. DCIT - 15(2)(1), MUMBAI

Bench: Shri Joginder Singh & Shri N.K. Pradhanassessment Year: 2007-08 M/S Idhasoft Ltd. Dcit-15(2)(1), 3, Narayan Building, Room No.357, 3Rd Floor बनाम/ 23 L. N. Road, Dadar East, Aayakar Bhavan, Vs. Mumbai-400014 M. K. Road, Mumbai-400020 ("नधा"रती /Assessee) (राज"व /Revenue) P.A. No. Aabci6090G Assessment Year: 2007-08 Dcit-15(2)(1), M/S Idhasoft Ltd. Room No.357, 3Rd Floor 3, Narayan Building, बनाम/ Aayakar Bhavan, 23 L. N. Road, Dadar East, Vs. M. K. Road, Mumbai-400014 Mumbai-400020 (राज"व /Revenue) ("नधा"रती /Assessee) P.A. No. Aabci6090G

reassessment is within the period of limitation prescribed under the proviso to section 147. Explanation (1 ) to the said provision makes it clear that production of account books or other evidence from which the Assessing Officer could with due diligence discover material evidence would not necessarily amount to disclosure within the meaning of the proviso that stipulates an extended period

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

6. The power to reopen a completed assessment under section 147 of the Act has been bestowed on the Assessing officer, if he has reason to believe Act has been bestowed on the Assessing officer, if he has reason to believe Act has been bestowed on the Assessing officer, if he has reason to believe that any income chargeable

ITO-28(3)(1), MUMBAI, MUMBAI vs. SATYA PRAKASH SINGH, MUMBAI

In the result, the ground so taken by the assessee so far as it relates to challenging the order of the AO as passed beyond the period of limitation is hereby allowed

Bench: Justice (Retd.) Shri C.V. Bhadang & Shri Vikram Singh Yadav

250 or section 254 or section 260 or section 262 or section 263 or section 264 shall be made within the time specified in sub- section (3). (5A) Where the Transfer Pricing Officer gives effect to an order or direction under section 263 by an order under section 92CA and forwards such order to the Assessing Officer, the Assessing Officer