RAVI NIRMAN NIGAM LIMITED,MUMBAI vs. CIRCLE -13(3)(1), MUMBAI

In the result, appeal of the assessee is allowed

Bench: Ms. Kavitha Rajagopal & Shri Girish Agrawal

section 143(3) r.w.s. 147 dated 24.12.2018. In the same reassessment, ld. Assessing Officer had al- leged that there are certain transactions of loan taken and repayment made, which were carried out by the assessee by means other than by way of account pay cheque/bank draft, therefore there is a violation u/s. 269SS and 269T of the Act. Ld. Assessing

RAVI NIRMAN NIGAM LIMITED,MUMBAI vs. CIRCLE 13(3)(1), MUMBAI

In the result, appeal of the assessee is allowed

Bench: Ms. Kavitha Rajagopal & Shri Girish Agrawal

section 143(3) r.w.s. 147 dated 24.12.2018. In the same reassessment, ld. Assessing Officer had al- leged that there are certain transactions of loan taken and repayment made, which were carried out by the assessee by means other than by way of account pay cheque/bank draft, therefore there is a violation u/s. 269SS and 269T of the Act. Ld. Assessing

RAVI NIRMAN NIGAM LIMITED,MUMBAI vs. CIRCLE 13(3)(1), MUMBAI

In the result, appeal of the assessee is allowed

Bench: Shri Satbeer Singh Godara (Jm) & Shri Girish Agrawal (Am)

section 271D & 271E penalty(ies),as the case may be, involving varying sums as under :- “2. All the three appeals relate to common issues in respect of imposition of penalty u/s. 271D and 271E for AY 2011-12 and AY 2010-11. Since, similar issue is involved in all the three appeals, we take them up together by passing

M/S SANJEEV CHIRANIA HUF,MUMBAI vs. INCOME TAX OFFICER, WARD-28(3)(1) , MUMBAI

In the result, the appeal of the assessee is allowed

Bench: Shri Om Prakash Kant () & Shri Sandeep Singh Karhail () Assessment Year: 2015-16 M/S Sanjeev Chirania Huf, Ito-28(3)(1), 301, Sona Chambers, 507/509 Tower No. 6, Vashi Railway Vs. Jss Road, Chira Bazar, Station Commercial Marine Lines – East, Complex, Vashi, Mumbai-400 002. Navi Mumbai-400703 Pan No. Aarhs 4527 D Appellant Respondent Assessee By : Ms. Ritu Kamalkishor, Ar Revenue By : Mr. Milind S. Chavan, Cit-Dr : Date Of Hearing 23/03/2023 : Date Of Pronouncement 31/03/2023 Order

reassessment u/s 147 of the Act was completed on 27.03.2022 wherein the total income was was completed on 27.03.2022 wherein the total inc was completed on 27.03.2022 wherein the total inc assessed at Rs.4,88,05,223/ assessed at Rs.4,88,05,223/-. In view of the assesse . In view of the assessed income, the Assessing Officer

ASST.COMMISSIONER OF INCOME TAX, BANDRA KURLA COMPLEX MUMBAI vs. DEVANG AJIT JAVERI , MUMBAI

In the result, appeal of the Revenue is dismissed on aforesaid terms

Bench: SHRI AMIT SHUKLA (Judicial Member), SHRI GIRISH AGRAWAL (Accountant Member)

271E of the Act and it was only the Joint Commissioner of Income- tax who could have done so. Therefore, for the purpose of limitation under section 275(1) (c), the relevant date should be the date on which notice in relation to the penalty proceedings were issued. In the present case, as the Additional Commissioner of Income-tax issued

DEVANG AJIT JHAVERI,MUMBAI vs. JCIT, RANGE 17(1), MUMBAI

In the result, appeal of the Revenue is dismissed on aforesaid terms

Bench: SHRI AMIT SHUKLA (Judicial Member), SHRI GIRISH AGRAWAL (Accountant Member)

271E of the Act and it was only the Joint Commissioner of Income- tax who could have done so. Therefore, for the purpose of limitation under section 275(1) (c), the relevant date should be the date on which notice in relation to the penalty proceedings were issued. In the present case, as the Additional Commissioner of Income-tax issued

SHYAM KUMAR SADASHIVAN PILLAI,MUMBAI vs. INCOME TAX OFFICER, CIRCLE 27(3)(1), NAVI MUMBAI

In the result, the appeal is allowed

Bench: Ms Padmavathy S, Am & Shri Raj Kumar Chauhan, Jm

reassessment proceedings and not filed even the basic details within the time allowed in the notices. 6. Conclusion drawn for Imposition of Penalty: 4 ITA No.897/Mum/2024 - Shyam Kumar Sadashivam Pillai 6.1 On considering the entirety of the facts and circumstances in this case and it becomes apparent that there was no reasonable cause on the part of the assessee

PREMJI BHURLAL GALA ,MUMBAI vs. ADDL CIT RANG 24(1), MUMBAI

In the result, Assessee’s appeal is allowed

Bench: Shri Narender Kumar Choudhry & Shri Bijayananda Prusethassessment Year: 2016-17 Premji Bhurlal Gala Addl. Cit Range 24(1), B-301, Water Ford, Cd Mumbai Barfiwala Road Juhu Fally Kautilya Bhavan, C-41 To C- Vs. Andheri West, Mumbai - 43, G Block, Bandra Kurla 400058 Complex, Bandra (E) Mumbai – 400051 (Appellant) (Respondent) Present For: Assessee By : Shri Vinod Kumar Bindal & Satish Kumar, Ld. A. Rs. Revenue By : Shri Virabhadra Mahajan, Sr. D.R. Date Of Hearing : 09.12.2025 Date Of Pronouncement : 28.01.2026 O R D E R Per : Narender Kumar Choudhry: This Appeal Has Been Preferred By The Assessee Against The Order Dated 23.09.2025, Impugned Herein, Passed By The Ld. Commissioner Of Income Tax (Appeals) (In Short Ld. Commissioner) U/S 250 Of The Income Tax Act, 1961 (In Short ‘The Act’) For The A.Y. 2016-17. 2. In The Instant Case, The Case Of The Assessee Was Reopened Under Section 147 Of The Act, On The Basis Of Search & Survey Action Under Section 132 Of The Act Carried Out In The Case Of M/S. Evergreen Enterprises, Wherein The Statement Of The Partner In M/S. Evergreen Enterprises, Mr. Nilesh Bharani Was Recorded Under Section 132(4) Of The Act, Unearthing An Undisclosed Activity, 2 Premji Bhurlal Gala

Section 271 (D) and 271 (E) of the Act and by observing and holding as under: 9. We have heard the rival contentions and perused the material on record. Admittedly, it is a fact on record that the reassessment proceedings, u/s. 147 of the Act in the course of which penalty proceedings u/s. 271D and 271E

RAVI NIRMAN NIGAM LTD.,MUMBAI vs. ACIT 13(3)(1), MUMBAI

In the result, both the appeal filed by the assessee are allowed

Bench: Shri Amarjit Singh, Hon'Ble & Shri S. Rifaur Rahman, Hon'Ble

271E without appreciating the fact that no addition has been made with respect to the reasons recorded (A.Ys: 2010-11 & 2011-12) M/s. Ravi Nirman Nigam Limited for reopening of assessment, as such, the reassessment order is bad in law and liable to be quashed. 6. Your appellant craves leave to add to, amend or N.A alter or delete

RAVI NIRMAN NIGAM LTD.,MUMBAI vs. DCIT, CIRCLE 13 (3)(1), MUMBAI

In the result, both the appeal filed by the assessee are allowed

Bench: Shri Amarjit Singh, Hon'Ble & Shri S. Rifaur Rahman, Hon'Ble

271E without appreciating the fact that no addition has been made with respect to the reasons recorded (A.Ys: 2010-11 & 2011-12) M/s. Ravi Nirman Nigam Limited for reopening of assessment, as such, the reassessment order is bad in law and liable to be quashed. 6. Your appellant craves leave to add to, amend or N.A alter or delete

ASST. COMMISSIONER OF INCOME TAX , BANDRA KURLA COMPLEX vs. DEVANG AJIT JHAVERI , MUMBAI

In the result, appeal of the Revenue is dismissed on\naforesaid terms

147\ntaxmann.com 220 (Delhi) wherein the Court has followed\nvarious other judgments to decide the precise issue of limitation\nin the case of penalty u/s 271D and 271T. The Hon'ble High\nCourt has even taken note of the contention of the Revenue\nwhich has also been raised before us that date of issuance of\nshow-cause notice should

DEVANG AJIT JHAVERI ,MUMBAI vs. JCIT, RANGE 17(1), MUMBAI

In the result, appeal of the Revenue is dismissed on\naforesaid terms

147\ntaxmann.com 220 (Delhi) wherein the Court has followed\nvarious other judgments to decide the precise issue of limitation\nin the case of penalty u/s 271D and 271T. The Hon'ble High\nCourt has even taken note of the contention of the Revenue\nwhich has also been raised before us that date of issuance of\nshow-cause notice should

DEPUTY COMMISSIONER OF INCOME TAX,CC-7(3), MUMBAI vs. M/S MAHAVIR BUILD ESTATE PVT LTD , MUMBAI

In the result, appeal preferred by the Revenue is dismissed

Reassessment proceedings were initiated for the Assessment Year 2009-10 and order under Section 143(3) read with Section 147 of the Act was passed on 30.03.2015 assessing total income of the Assessee at INR 4,36,970/- as against the returned loss of INR 17,69,197/-. During the assessment proceedings, the Assessing Officer had noticed that the Assessee