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

CROMPTON GREAVES LTD,MUMBAI vs. CIT -6, MUMBAI

In the result, the appeals filed by the assessee company in ITA no

Bench: Shri Shailendra Kumar Yadav & Shri Ramit Kochar"ी शैल" कुमार यादव, "या"यक सद"य एवं "ी "ी रिमत कोचर, लेखाकार सद"य के सम" । आयकर अपील सं./I.T.A. No. 1994/Mum/2013 ("नधा"रण वष" / Assessment Year : 2007-08) आयकर अपील सं./I.T.A. No. 2836/Mum/2014 ("नधा"रण वष" / Assessment Year : 2007-08) M/S Crompton Greaves बनाम/ Cit – 6,Mumbai, Ltd.,6Th Floor, C.G. House, 5Th Floor, V. Dr. A.B. Road, Worli, Aayakar Bhavan, Mumbai – 400 030. M.K. Road, Mumbai – 400 020. "थायी लेखा सं./Pan : Aaacc3840K .. (अपीलाथ" /Appellant) (""यथ" / Respondent) Assessee By Shri Pradeep N. Kapasi Revenue By : Shri C.W. Angolkar सुनवाई क" तार"ख /Date Of Hearing : 29-10-2015 घोषणा क" तार"ख /Date Of Pronouncement : 01-02-2016

147 [[except an order passed in pursuance of directions of the Dispute Resolution Panel [***] [or an order referred to in sub-section (12) of section 144BA]]] or section 150; [(ba) an order of assessment or reassessment under section 153A [[except an order passed in pursuance of directions of the Dispute Resolution Panel]] [***] [or an order referred to in sub-section

RAKESH JAIN AS THE LEGAL HEIR OF BHAWARLAL SHRILAL JAIN ,MUMBAI vs. ITO WARD -1 PALGHAR , THANE

In the result, all four appeals of the assessee stand allowed

Bench: Shri Saktijit Dey & Shri Makarand Vasant Mahadeokar1. Ita No. 7674/Mum/2025 (Assessment Year: 2013-14) 2. Ita No. 7675/Mum/2025 (Assessment Year: 2013-14) 3. Ita No. 7676/Mum/2025 (Assessment Year: 2013-14) & 4. Ita No. 7677/Mum/2025 (Assessment Year: 2013-14) Rakesh Jain As Legal Ito Ward-1, Heir Of Bhawarlal Shrilal Bidco Road, Jain, Vs. Palghar, Shop 5, Vaibhav Complex, Maharashtra – Irani Road, Malyan, 401 404 Dahanu Road, Thane – 401602, Maharashtra. Pan/Gir No. Abjpj5270F (Applicant) (Respondent) Assessee By Shri Suchek Anchaliya, Ld. Ar Revenue By Shri Annavaram Kosuri, Ld. Dr Date Of Hearing 05.02.2026 Date Of Pronouncement 09.02.2026 आदेश / Order Per Makarand Vasant Mahadeokar, Am: These Four Appeals Are Directed Against Separate Orders Passed By The Commissioner Of Income-Tax (Appeals), National Faceless Appeal Centre, Delhi [Hereinafter Referred To As “Cit(A)”], All Dated 26.09.2025 & 18.09.2025, For Assessment Year 2013– 14. Since The Issues Involved In All The Appeals Arise Out Of The Same Set Of Facts & Relate To Proceedings Initiated In The Name Of Late Shri Bhawarlal Shrilal Jain, These Appeals Were Heard Together & Are Being Disposed Of By This Common Order For The Sake Of Convenience & Brevity.

147 of the Act in the name of the dead person is bad in law and should be quashed. 5. On the facts and in the circumstances of the case in law, the Ld. CIT(A)/NFAC, erred in rejecting the condonation of the delay request of the appellant and in dismissing the appeal without going into the grounds

RAKESH JAIN AS THE LEGAL HEIR OF BHAWARLAL SHRILAL JAIN,MUMBAI vs. ITO WARD 1 PALGHAR, THANE

In the result, all four appeals of the assessee stand allowed

Bench: Shri Saktijit Dey & Shri Makarand Vasant Mahadeokar1. Ita No. 7674/Mum/2025 (Assessment Year: 2013-14) 2. Ita No. 7675/Mum/2025 (Assessment Year: 2013-14) 3. Ita No. 7676/Mum/2025 (Assessment Year: 2013-14) & 4. Ita No. 7677/Mum/2025 (Assessment Year: 2013-14) Rakesh Jain As Legal Ito Ward-1, Heir Of Bhawarlal Shrilal Bidco Road, Jain, Vs. Palghar, Shop 5, Vaibhav Complex, Maharashtra – Irani Road, Malyan, 401 404 Dahanu Road, Thane – 401602, Maharashtra. Pan/Gir No. Abjpj5270F (Applicant) (Respondent) Assessee By Shri Suchek Anchaliya, Ld. Ar Revenue By Shri Annavaram Kosuri, Ld. Dr Date Of Hearing 05.02.2026 Date Of Pronouncement 09.02.2026 आदेश / Order Per Makarand Vasant Mahadeokar, Am: These Four Appeals Are Directed Against Separate Orders Passed By The Commissioner Of Income-Tax (Appeals), National Faceless Appeal Centre, Delhi [Hereinafter Referred To As “Cit(A)”], All Dated 26.09.2025 & 18.09.2025, For Assessment Year 2013– 14. Since The Issues Involved In All The Appeals Arise Out Of The Same Set Of Facts & Relate To Proceedings Initiated In The Name Of Late Shri Bhawarlal Shrilal Jain, These Appeals Were Heard Together & Are Being Disposed Of By This Common Order For The Sake Of Convenience & Brevity.

147 of the Act in the name of the dead person is bad in law and should be quashed. 5. On the facts and in the circumstances of the case in law, the Ld. CIT(A)/NFAC, erred in rejecting the condonation of the delay request of the appellant and in dismissing the appeal without going into the grounds

RAKESH JAIN AS THE LEGAL HEIR OF BHAWARLAL SHRILAL JAIN ,MUMBAI vs. ITO WARD-1 PALGHAR , MUMBAI

In the result, all four appeals of the assessee stand allowed

Bench: Shri Saktijit Dey & Shri Makarand Vasant Mahadeokar1. Ita No. 7674/Mum/2025 (Assessment Year: 2013-14) 2. Ita No. 7675/Mum/2025 (Assessment Year: 2013-14) 3. Ita No. 7676/Mum/2025 (Assessment Year: 2013-14) & 4. Ita No. 7677/Mum/2025 (Assessment Year: 2013-14) Rakesh Jain As Legal Ito Ward-1, Heir Of Bhawarlal Shrilal Bidco Road, Jain, Vs. Palghar, Shop 5, Vaibhav Complex, Maharashtra – Irani Road, Malyan, 401 404 Dahanu Road, Thane – 401602, Maharashtra. Pan/Gir No. Abjpj5270F (Applicant) (Respondent) Assessee By Shri Suchek Anchaliya, Ld. Ar Revenue By Shri Annavaram Kosuri, Ld. Dr Date Of Hearing 05.02.2026 Date Of Pronouncement 09.02.2026 आदेश / Order Per Makarand Vasant Mahadeokar, Am: These Four Appeals Are Directed Against Separate Orders Passed By The Commissioner Of Income-Tax (Appeals), National Faceless Appeal Centre, Delhi [Hereinafter Referred To As “Cit(A)”], All Dated 26.09.2025 & 18.09.2025, For Assessment Year 2013– 14. Since The Issues Involved In All The Appeals Arise Out Of The Same Set Of Facts & Relate To Proceedings Initiated In The Name Of Late Shri Bhawarlal Shrilal Jain, These Appeals Were Heard Together & Are Being Disposed Of By This Common Order For The Sake Of Convenience & Brevity.

147 of the Act in the name of the dead person is bad in law and should be quashed. 5. On the facts and in the circumstances of the case in law, the Ld. CIT(A)/NFAC, erred in rejecting the condonation of the delay request of the appellant and in dismissing the appeal without going into the grounds

RAKESH JAIN AS THE LEGAL HEIR OF BHAWARLAL SHRILAL JAIN ,MUMBAI vs. ITO WARD 1, PALGHAR , THANE

In the result, all four appeals of the assessee stand allowed

Bench: Shri Saktijit Dey & Shri Makarand Vasant Mahadeokar1. Ita No. 7674/Mum/2025 (Assessment Year: 2013-14) 2. Ita No. 7675/Mum/2025 (Assessment Year: 2013-14) 3. Ita No. 7676/Mum/2025 (Assessment Year: 2013-14) & 4. Ita No. 7677/Mum/2025 (Assessment Year: 2013-14) Rakesh Jain As Legal Ito Ward-1, Heir Of Bhawarlal Shrilal Bidco Road, Jain, Vs. Palghar, Shop 5, Vaibhav Complex, Maharashtra – Irani Road, Malyan, 401 404 Dahanu Road, Thane – 401602, Maharashtra. Pan/Gir No. Abjpj5270F (Applicant) (Respondent) Assessee By Shri Suchek Anchaliya, Ld. Ar Revenue By Shri Annavaram Kosuri, Ld. Dr Date Of Hearing 05.02.2026 Date Of Pronouncement 09.02.2026 आदेश / Order Per Makarand Vasant Mahadeokar, Am: These Four Appeals Are Directed Against Separate Orders Passed By The Commissioner Of Income-Tax (Appeals), National Faceless Appeal Centre, Delhi [Hereinafter Referred To As “Cit(A)”], All Dated 26.09.2025 & 18.09.2025, For Assessment Year 2013– 14. Since The Issues Involved In All The Appeals Arise Out Of The Same Set Of Facts & Relate To Proceedings Initiated In The Name Of Late Shri Bhawarlal Shrilal Jain, These Appeals Were Heard Together & Are Being Disposed Of By This Common Order For The Sake Of Convenience & Brevity.

147 of the Act in the name of the dead person is bad in law and should be quashed. 5. On the facts and in the circumstances of the case in law, the Ld. CIT(A)/NFAC, erred in rejecting the condonation of the delay request of the appellant and in dismissing the appeal without going into the grounds

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

REKHA LAXMAN MANJIRAMANI ,MUMBAI vs. INCOME TAX OFFICER , WARD, 19(3)(1), MUMBAI

In the result, the appeal of the assessee is allowed for In the result, the appeal of the assessee is allowed for In the result, the appeal of the assessee is allowed for statistical purposes

Bench: Shri Om Prakash Kant () & Shri Sunil Kumar Singh () Assessment Year: 2011-12 Rekha Laxman Manjiramani, National Faceless Appeal Centre, 104, Lloyds Estates, G Wing Near Delhi, Income-Tax Officer-19(3)(1), Vs. Vidyalankar College, Piramal Chambers, Lalbaug, Mumbai-400037. Mumbai-400012. Pan No. Anhpm 5246 N Appellant Respondent

147 read with section 144 of the IT Act without appreciating the fact with section 144 of the IT Act without appreciating the fact with section 144 of the IT Act without appreciating the fact that the reopening notice was never served to the at the reopening notice was never served to the at the reopening notice was never served

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

APTIVAA MIDDLE EAST FZE,DUBAI, UNITED ARAB EMIRATES vs. DEPUTY COMMISSIONER OF INCOME TAX, CIRCLE 1(1)(2), INTERNATIONAL TAXATION, MUMBAI, MAHARASTRA

In the result of the file by the assessee stands partly allowed as indicated hereinabove

Bench: Smt. Beena Pillai () & Ms. Padmavathy S. ()

271F of the Act and section 271(1)(c) of the Act for the subject year as the same is bad in law.” Brief facts of the case are as under: 2. M/s. Aptivaa Middle East FZE Dubai, UAE (hereinafter referred to the assessee) is a 100% subsidiary of M/s. Aptivaa Consulting Solutions Pvt. Ltd (hereinafter referred to as Aptivaa

APTIVAA MIDDLE EAST FZE,DUBAI, UNITED ARAB EMIRATES vs. DEPUTY COMMISSIONER OF INCOME TAX, CIRCLE 1(1)(2), INTERNATIONAL TAXATION, MUMBAI, MAHARASTRA

In the result of the file by the assessee stands partly allowed as indicated hereinabove

Bench: Smt. Beena Pillai () & Ms. Padmavathy S. ()

271F of the Act and section 271(1)(c) of the Act for the subject year as the same is bad in law.” Brief facts of the case are as under: 2. M/s. Aptivaa Middle East FZE Dubai, UAE (hereinafter referred to the assessee) is a 100% subsidiary of M/s. Aptivaa Consulting Solutions Pvt. Ltd (hereinafter referred to as Aptivaa

APTIVAA MIDDLE EAST FZE,MUMBAI vs. DEPUTY COMMISSION OF INCOME TAX, CIRCLE 1(1)(2), INTERNATIONAL TAXATION, MUMBAI, MUMBAI

In the result of the file by the assessee stands partly allowed as indicated hereinabove

Bench: Smt. Beena Pillai () & Ms. Padmavathy S. ()

271F of the Act and section 271(1)(c) of the Act for the subject year as the same is bad in law.” Brief facts of the case are as under: 2. M/s. Aptivaa Middle East FZE Dubai, UAE (hereinafter referred to the assessee) is a 100% subsidiary of M/s. Aptivaa Consulting Solutions Pvt. Ltd (hereinafter referred to as Aptivaa

M/S MUMBADEVI VEYHICLES,MUMBAI vs. ITO WARD 41(4)(2), MUMBAI

In the result the appeal of the assessee is allowed

Bench: Shri Saktijit Dey & Shri Makarand Vasant Mahadeokarm/S. Mumbadevi Ito Ward 41(4)(2), Veyhicles Room No. 854B, 8Th Shop No. 18, Suyash Vs. Floor, Kautilya Shopping Centre, Nnp, A. Bhavan, Bkc, K. Vaidya Marg, Goregaon Bandra (East), (E), Mumbai-400 065 Mumbai-400 051 Pan/Gir No. Aaofm0851F (Applicant) (Respondent) Assessee By Ms. Dinkle Hariya & Ms. Sruti Kalyanikar, Ld. Ars Revenue By Shri Annavaram Kosuri, Ld. Dr Date Of Hearing 19.02.2026 Date Of Pronouncement 24.02.2026

147 and section 144B of the Act vide order dated 27.03.2022 determining the total income at Rs. 40,50,371/-, being the same 3 M/s. Mumbadevi Veyhicles income returned by the assessee in response to notice under section 148. 5. While completing the reassessment, the Assessing Officer initiated penalty proceedings under section 271(1)(c) of the Act for alleged

APTIVAA MIDDLE EAST FZE,DUBAI vs. DEPUTY COMMISSIONER OF INCOME TAX, CIRCLE 1(1)(2), INTERNATIONAL TAXATION , MUMBAI

The appeal of the assessee is allowed

Bench: Shri Amit Shukla, Jm & Ms Padmavathy S, Am

271F of the Act and section 271(1)(e) of the Act for the subject year as the same is bad in law.” 2. The assessee is a non-resident company incorporated as per the regulations of UAE and is registered with the RAK Investment Authority Free Zone, UAE on 01.04.2010. The assessee is the wholly owned subsidiary

JAIKISHIN OMPRAKASH PAHUJA,GHATKOPAR, MUMBAI vs. ITO WARD 2(2), KALYAN, KALYAN, MUMBAI

reassessment order u/s 147 r.w.s\n144B thereby making an addition of Rs. 11,04,732/- u/s 69\nr.w.s 115BBE in respect of purchase of equity shares\nthereby treating the same as unexplained investments for\nlack of documentary evidence\na. without appreciating the fact that the Appellant was\nnot required to maintain books of accounts and\ntherefore section

MILLENNIUM DEVELOPERS PRIVATE LIMITED,MUMBAI vs. PRINCIPLE COMMISSIONER OF INCOME TAX -3, MUMBAI

In the result the appeal filed by the assessee is allowed

Bench: Shri Amarjit Singh & Shri Raj Kumar Chauhanmillennium Developers Pvt. Ltd. Pcit-3, Ground Floor, Ceejay House, Vs. R. No. 612, 6Th Floor, Aayakar Shivsagar Estate, Dr. Annie Besant Bhavan, M. K. Road, Road, Worli, Mumbai – 400 018 Mumbai-400 020 Pan: Aabcm6404C (Appellant) (Respondent) Assessee Represented By : Shri B. V. Jhaveri, Ld. Ar Department Represented By : Shri Anurag Tripathi, Ld. Dr Date Of Conclusion Of Hearing : 18.10.2024 Date Of Pronouncement : 17.01.2025

reassessment order passed by the Assessing Officer dated 17th January 2022 is erroneous and prejudicial to the interest of the revenue, without appreciating the fact that mere adopting of one view out of two possible views based on the specific inquiries conducted by the Assessing Officer in respect of the issue under consideration cannot render the order so passed

MOHAMED IMRAN MOHAMED SIDDIQUE KHAN,MUMBAI vs. ITO WARD 26(2)(3), MUMBAI

The appeal is partly allowed in above terms

u/s. 271F for failing the file return were also initiated separately.\n3. Aggrieved by the assessment order, assessee preferred appeal before learned CIT(A), however assessee did not respond to the notices issued by the first appellate authority. Learned CIT(A) dismissed assessee's appeal for non prosecution.\n4. The appellant assessee has approached this tribunal on the following grounds

SUNIL SURESH RANE,DOMBIVLI vs. ITO WARD 42(3)(4), MUMBAI

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

Bench: Hon’Ble Shri Sandeep Gosain & Hon’Ble Shri Prabhash Shankarsunil Suresh Rane Vs. Ito Ward 42(3)(4) 301 Amrita, Apts, Rajaji Kautilya Bhawan C41- Path Lane 43, Avenue 3, Near No.4 Dombivli Videsh Bhavan, G Block Mumbai - 421201 Bkc, Gilban Area, Bkc, Bandra East Mumbai - 400051 Pan/Gir No. Abtpr2589P (Applicant) (Respondent) Assessee By Shri Aakash Parekh (Virtually Present) Revenue By Shri Brajendra Kumar (Sr. Dr) Date Of Hearing 12.02.2026 Date Of Pronouncement 10.03.2026 आदेश / Order Per Sandeep Gosain, Jm: The Present Appeal Has Been Filed By The Assessee Challenging The Impugned Order 29.09.2025 Passed U/S 250 Of The Income Tax Act, 1961 (‘The Act’), By The National Faceless Appeal Centre, Delhi (Nfac) For The Assessment Year 2016-17. The Following Grounds Are Reproduced Below: “1. Ground No. 1: Gross Violation Of Principles Of Natural Justice

147 r.w.s. 144 of the Act is bad in law inasmuch as there was no valid and proper sanction by the 4 prescribed authority under section 151 of the Act and hence the said order deserves to be quashed. 5.6. On the facts and in the circumstances of the case and without prejudice to any other grounds

SEEMA HEERA,MUMBAI vs. ASSISTANT COMMISSIONER OF INCOME TAX (OSD) (IT) - 2(2)(1), MUMBAI

In the result appeal of the assessee is allowed

Bench: Shri Pavan Kumar Gadale, Judicialmember & Shri Girish Agrawalassessment Year: 2010-11

147 dated 26.12.2017 is bad in law and without jurisdiction. 2. The reassessment proceeding initiated by issuing notice u/s 148 of the Act is bad in law. 2 Seema Heera, AY 2010-11 3. The Ld. CIT(A) erred in upholding the notice u/s 148 of the Act issued by the Ld. AO as no valid notice was served upon