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

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:

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

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:

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

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:

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

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:

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

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

ADDL CIT R G 7(1), MUMBAI vs. NOVARTIS INDIA LTD ( FORMERLY KNOWN AS HINDUSTAN CIBA GIEGY LTD. ), MUMBAI

Bench: Shri Amit Shukla, Hon'Ble & Shri S. Rifaur Rahman, Hon'Blem/S. Novartis India Limited V. Asst. Commissioner Of Income –Tax - 7(2)(2) {Earlier Addl. Commissioner Of Income –Tax – 7(1)} 6Th& 7Th Floor 1St Floor, Aayakar Bhavan Inspire Bkc M.K. Road, Mumbai - 400020 “G” Block, Bkc Main Road Bandra Kurla Complex, Bandra (E) Mumbai – 400051 Pan: Aaach2914F (Appellant) (Respondent) Addl. Commissioner Of Income –Tax – 7(1) V. M/S. Novartis India Limited Room No. 622, Aayakar Bhavan {Earlier Known As Hindustan Ciba Giegy Ltd.,} Sandoz House, Dr. A.B. Road M.K. Road, Mumbai - 400020 Worli, Mumbai – 400018 Pan: Aaach2914F (Appellant) (Respondent) Co No.190/Mum/2011 [Arising Out Of Ita No.6772/Mum/2010 (A.Y. 2002-03)] M/S. Novartis India Limited V. Addl. Commissioner Of Income –Tax – 7(1)} Room No. 622, Aayakar Bhavan {Earlier Known As Hindustan Ciba Giegy Ltd.,} Sandoz House, Dr. A.B. Road M.K. Road, Mumbai - 400020 Worli, Mumbai – 400018 Pan: Aaach2914F (Appellant) (Respondent)

270A, section 271, section 271A,section 271J or section 272A; or (b) an order passed by an Assessing Officer under clause (c) of section 158BC, in respect of search initiated under section 132 or books of account, other documents or any assets requisitioned under section 132A, after the 30th day of June, 1995, but before the 1st day of January

EXIM TRAC,MUMBAI vs. MUM-C-(431)(91), MUMBAI

In the result the appeal filed by the assessee stands

Bench: Shri Om Prakash Kant () & Shri Sandeep Karhail () Assessment Year: 2019-20

b) proceedings. However, following the issuance of notice under Section 148, the However, following the issuance of notice under Section 148, the However, following the issuance of notice under Section 148, the Assessee filed a return of income withdrawing the said claim and Assessee filed a return of income withdrawing the said claim and Assessee filed a return of income

NILANJANA ARVINDER SINGH,MUMBAI vs. DCIT, MUMBAI

In the result, the appeal by the assessee for the assessment year 2014-

Bench: Shri Amarjit Singhshri Sandeep Singh Karhail

reassessment proceedings, which began on 01.06.2021, to issue a notice under Section 148 of the Act. The said notice was required to be accompanied by an order under Section 148A(d) of the Act. Thus, the AO was required to pass an order under Section 148A(d) of the Act within the said twenty-nine days notwithstanding the time stipulated

M/S G M BUILDERS,MUMBAI vs. PCIT(MUMBAI), OLD-ACIT CIRCLE-22(1), PIRAMAL CHAMBER, MUMBAI

In the result, the appeal by the assessee is allowed

Bench: Shri Amarjit Singhshri Sandeep Singh Karhailm/S. G M Builders, 115, Veena Beena Shipping Center, Turner Road, Bandra West, Mumbai - 400050 Pan – Aaafg1872G ……………. Appellant

u/s 143(3) read with section 147 of the Income Tax Act, 1961 for Asst. Year 2017-18dated 30.03.2022. From the facts of the case, it is ascertained that you had not filed the return of income for A.Y. 2017-18. The return was filed only after the notice u/s.148 was issued. In response thereto, you filed the return

ALRAMEEZ CONSTRUCTION PVT LTD ,MUMBAI vs. NATIONAL FACELESS APPEAL CENTRE , MUMBAI

In the result grounds of appeal raised by assessee is allowed

Bench: Shri Kuldip Singh & Shri Gagan Goyalm/S Alrameez Construction Pvt. Ltd. 707/708, 7Th Floor, Jms Business Centre Behram Baug, Oshiwara Link Road, Jogeshwari West, Mumbai-400 080 Pan: Aafca8078A ...... Appellant Vs. Cit/Nfac Delhi ..... Respondent

u/s 43CA r.w.s. 56 (2) (x) i.e. deeming sections. For ready reference we are reproducing herein below the provisions of section 270A as under:- [Penalty for under-reporting and misreporting of income. 270A. (1) The Assessing Officer or the Commissioner (Appeals) or the Principal Commissioner or Commissioner may, during the course of any proceedings under this Act, direct that

PANKAJ DHANDHARIA,MUMBAI vs. ACIT-22(1), MUMBAI

Appeal is dismissed

270A of the act, which is\npremature, does not require any adjudication at this stage, and\nin absence of any argument, same is dismissed.\n15. This leaves us with the two substantive issues of reopening of\nthe assessment and addition on the merits of the case.\n16. The learned authorized representative submitted a paper book\ncontaining 718 pages as factual

GATEGROUP INVESTMENTS SINGAPORE PTE LTD,SINGAPORE vs. INT TAX CIRCLE 2(3)(2), MUMBAI

Bench: Shri Gagan Goyal & Shri Raj Kumar Chauhangateway Investments Singapore Pte Ltd. ...... Appellant 1 Maritime Square, # 12-03 Harbour Front Centre Singapore-99 253 Pan No. : Aaecg1565B

270A read with section 274 of the Act. 2. The assessee has also filed additional grounds of appeal vide letter dated 19.08.2024 filed on 22.08.2024. The additional grounds are reproduced hereunder: 8. On the facts and circumstances of the case and in law, the learned AO has erred in issuing notice u/s. 148A (b) dated 1 June 2022, notice u/s

NILESH SHAMJI BHARANI ,MUMBAI vs. DCIT CENTRAL CIRCLE -4(1), MUMBAI

In the result, the appeals by the assessee for the

270A and section 271AAC(1) were\ninitiated for the assessment year 2017-18, and penalty proceedings under\nsection 271AAB(1A)(b) of the Act were initiated for the assessment year\n2018-19. The AO vide separate orders levied penalties under aforesaid\nsections for the assessment years 2012-13 to 2018-19. The learned CIT(A),\nvide separate impugned orders, upheld

NILESH SHAMJI BHARANI ,MUMBAI vs. DCIT, CENTRAL CIRCLE 4(1), MUMBAI

In the result, the appeals by the assessee for the

270A and section 271AAC(1) were\ninitiated for the assessment year 2017-18, and penalty proceedings under\nsection 271AAB(1A)(b) of the Act were initiated for the assessment year\n2018-19. The AO vide separate orders levied penalties under aforesaid\nsections for the assessment years 2012-13 to 2018-19. The learned CIT(A),\nvide separate impugned orders, upheld

JORSS BULLION PVT LTD,MUMBAI vs. DY COMMISSIONER OF INCOME TAX -CENTRAL CIRCLE 7(1), MUMBAI

Reassessment limitation effect of Section 149(1)(b) - period\nextended where alleged escaped income exceeds prescribed\nlimit Section 149 does not override provisions of section 147-\nnotice after four years failure to disclose material facts\nnecessary for assessment must exist.\"\n(ii) Novo Nordisk India P. Ltd. V/s. DCIT[2018] 95 taxmann.com\n225 Karnataka. The catch-note is reproduced

NILESH SHAMJI BHARANI ,MUMBAI vs. DCIT, CENTRAL CIRCLE -4(1), MUMBAI

In the result, the appeals by the assessee for the

270A and section 271AAC(1) were\ninitiated for the assessment year 2017-18, and penalty proceedings under\nsection 271AAB(1A)(b) of the Act were initiated for the assessment year\n2018-19. The AO vide separate orders levied penalties under aforesaid\nsections for the assessment years 2012-13 to 2018-19. The learned CIT(A),\nvide separate impugned orders, upheld

DCIT, CENTRAL CIRCLE 7(1), MUMBAI vs. JORSS BULLION PRIVATE LIMITED, MUMBAI

Reassessment limitation effect of Section 149(1)(b) - period\nextended where alleged escaped income exceeds prescribed\nlimit Section 149 does not override provisions of section 147-\nnotice after four years failure to disclose material facts\nnecessary for assessment must exist.\"\n(ii) Novo Nordisk India P. Ltd. V/s. DCIT[2018] 95 taxmann.com\n225 Karnataka. The catch-note is reproduced

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

In the result, the appeals by the assessee for the assessment years

Bench: Shri Sandeep Singh Karhailsmt. Renu Jauhri

270A and section 271AAC(1) were initiated for the assessment year 2017-18, and penalty proceedings under section 271AAB(1A)(b) of the Act were initiated for the assessment year 2018-19. The AO vide separate orders levied penalties under aforesaid sections for the assessment years 2012-13 to 2018-19. The learned CIT(A), vide separate impugned orders, upheld