DCIT 3.2.1, MUMBAI vs. THE NEW INDIA ASSURANCE CO LIMITED, MUMBAI

Accordingly, Ground No.1 to 4 raised by the Assessee are allowed

Bench: SHRI VIKRAM SINGH YADAV, ACCOUNTANT MEMBER SHRI RAHUL CHAUDHARY (Judicial Member)

u/s 148 is to be issued.” (Emphasis Supplied) 31. From the material on record it is apparent that the Assessing Officer had initiated reassessment proceedings for the Assessment Year 2012-2013 under Section 147 of the Act by issuance of notice under Section 148 of the Act on 30/03/2017. Thus, reassessment proceedings were initiated within a period of 4 years

THE NEW INDIA ASSURANCE CO LTD,MUMBAI vs. DEPUTY COMMISSIONER OF INCOME TAX, CIRCLE 3(2)(2), MUMBAI

Accordingly, Ground No.1 to 4 raised by the Assessee are allowed

Bench: SHRI VIKRAM SINGH YADAV , ACCOUNTANT MEMBER SHRI RAHUL CHAUDHARY (Judicial Member)

u/s 148 is to be issued.” (Emphasis Supplied) 31. From the material on record it is apparent that the Assessing Officer had initiated reassessment proceedings for the Assessment Year 2012-2013 under Section 147 of the Act by issuance of notice under Section 148 of the Act on 30/03/2017. Thus, reassessment proceedings were initiated within a period of 4 years

JAIN MACHINE TOOLS ,MUMBAI vs. INCOME TAX OFFICER, WARD 26(1)(7), MUMBAI

In the result, the appeal of the assessee is allowed

Bench: Shri Om Prakash Kant () & Shri Sunil Kumar Singh () Assessment Year: 2012-13 Jain Machine Tools, Ito, Ward 26(1)(7), 16, Meghal Industrial Estate, Room 625, 6Th Floor, Kautilya Vs. Devidayal Road, Mulund (West) Bhavan, C-41 To C-43, G Block, Mumbai-400080. Bandra Kurla Complex, Bandra (East), Mumbai-400051. Pan No. Aacfj 6163 H Appellant Respondent

section 147 of the Act, an assessment completed u/s 143(3) of the Act could be reopened beyond the completed u/s 143(3) of the Act could be reopened beyond the completed u/s 143(3) of the Act could be reopened beyond the period of four years from the end of the relevant assessment year iod of four years from

ITO 3(1)(4), MUMBAI vs. EVERLON SYNTHETICS P.LTD, MUMBAI

In the result, the appeal filed by the Revenue in ITA N0

Bench: Shri Saktijit Dey & Shri Ramit Kocharआयकर अपील सं./I.T.A. No. 6965/Mum/2013 ("नधा"रण वष" / Assessment Year : 2006-07) Income Tax Officer 3(1)(4), M/S Everlon Synthetics बनाम/ R. No. 666, Pvt. Ltd., V. Aayakar Bhawan,M.K. Road, 67, Regent Chambers, Mumbai – 400 020. 208 Nariman Point, Mumbai – 400 021 "थायी लेखा सं./Pan : Aaace0860H (अपीलाथ" /Appellant) .. (""यथ" / Respondent)

reassessment order was annulled by the learned CIT(A), thus, the learned CIT(A) held that the ground of appeals on merits has become academic, hence, the learned CIT(A) considered it not necessary to adjudicate the said grounds of appeal vide appellate orders dated 20-9-2013. 8. Aggrieved by the appellate orders dated

ICICI BANK LTD.,MUMBAI vs. THE DY CIT -2(3)(1), MUMBAI

In the result we hold that the learned principal

Bench: Shri Prashant Maharishi, Am & Shri Pavan Kumar Gadale, Jm Icici Bank Limited The Dy. Commissioner Of Icici Bank Towers, Income-Tax-2(3)(1), Aayakar Bhavan, 5 Th Floor, Bandra Kurla Complex, Vs. Bandra (East), Room No.552, Mumbai-400 051 M.K.Road, Mumbai-400 020 (Appellant) (Respondent) Pan No. Aaaci1195H Appellant By : Ms Arati Vissanji, Ar Respondent By : Shri Nikhil Chaudhary, Cit Dr Date Of Hearing: 13.01.2022 Date Of Pronouncement : 08.03.2022

45,836 was excluded from the total business income computed at Rs.7863,19,95,380 and the balance of Rs.5806,27,49,544 was considered as business income from long term finance eligible for deduction under section 36(1)(viii). 3.2 As per the show cause notice your Honour's first observation is that the lease income to be reduced

THE NEW INDIA ASSURANCE CO. LTD,MUMBAI vs. DEPUTY COMMISSIONER OF INCOME TAX, CIRCLE-3(2)(2), MUMBAI

45==\n\nassessment. Therefore, we hold that in the present case the\nmandatory preconditions for initiating reassessment proceedings\nfor the Assessment Year 2012-2013 within a period of 4 years\nfrom the end of the relevant previous year stood satisfied.\nAccordingly, we reject all the contentions raised by the Assessee\nchallenging the validity of the reassessment proceedings

MANOHAR MANAK ALLOYS P.LTD,MUMBAI vs. ACIT 4(2), MUMBAI

Appeal is allowed

reassessment order passed by ld. A.O. 147 r.w.s.143(3) holding wrongly the said assessment order erroneous as well as prejudicial to the interest of revenue. 2. That the ld. Principal CIT while setting aside the assessment order has erred in erroneously applying the concept of accrual system of accounting in the case by overlooking the concept of real income theory

ACIT, CIR-1(2)(1), MUMBAI vs. M/S. CHERYL ADVISORY PVT LTD., MUMBAI

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

Bench: Shri Om Prakash Kant () & Shri Narender Kumar Choudhry () Assessment Year: 2013-14

147 of the Act. The ground No. 1 of the appeal of The ground No. 1 of the appeal of the Revenue is accordingly allowed. the Revenue is accordingly allowed. 7. The ground No. 3 of the appeal relates to the validity of the The ground No. 3 of the appeal relates to the validity of the The ground

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

147 read with section 143(3) of the Act on 03.12.2019 on 03.12.2019, denied the deduction u/s 80P the deduction u/s 80P(2)(d) of the Act in respect of interest income of Rs.97,49,707/ Act in respect of interest income of Rs.97,49,707/- - earned by the assessee’s society from banks (co assessee’s society from banks

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

147 read with section 143(3) of the Act on 03.12.2019 on 03.12.2019, denied the deduction u/s 80P the deduction u/s 80P(2)(d) of the Act in respect of interest income of Rs.97,49,707/ Act in respect of interest income of Rs.97,49,707/- - earned by the assessee’s society from banks (co assessee’s society from banks

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

147 read with section 143(3) of the Act on 03.12.2019 on 03.12.2019, denied the deduction u/s 80P the deduction u/s 80P(2)(d) of the Act in respect of interest income of Rs.97,49,707/ Act in respect of interest income of Rs.97,49,707/- - earned by the assessee’s society from banks (co assessee’s society from banks

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

147 read with section 143(3) of the Act on 03.12.2019 on 03.12.2019, denied the deduction u/s 80P the deduction u/s 80P(2)(d) of the Act in respect of interest income of Rs.97,49,707/ Act in respect of interest income of Rs.97,49,707/- - earned by the assessee’s society from banks (co assessee’s society from banks

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

147 read with section 143(3) of the Act on 03.12.2019 on 03.12.2019, denied the deduction u/s 80P the deduction u/s 80P(2)(d) of the Act in respect of interest income of Rs.97,49,707/ Act in respect of interest income of Rs.97,49,707/- - earned by the assessee’s society from banks (co assessee’s society from banks

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

147 read with section 143(3) of the Act on 03.12.2019 on 03.12.2019, denied the deduction u/s 80P the deduction u/s 80P(2)(d) of the Act in respect of interest income of Rs.97,49,707/ Act in respect of interest income of Rs.97,49,707/- - earned by the assessee’s society from banks (co assessee’s society from banks

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

147 read with section 143(3) of the Act on 03.12.2019 on 03.12.2019, denied the deduction u/s 80P the deduction u/s 80P(2)(d) of the Act in respect of interest income of Rs.97,49,707/ Act in respect of interest income of Rs.97,49,707/- - earned by the assessee’s society from banks (co assessee’s society from banks

DCIT CIR 7(1), MUMBAI vs. SHETH FINANCIAL SERVICES P.LTD, MUMBAI

In the result, the appeal filed by the Revenue in ITA No

Bench: Shri C.N. Prasad & Shri Ramit Kocharआयकर अपील सं./I.T.A. No. 5406/Mum/2013 ("नधा"रण वष" / Assessment Year : 2005-06) D.C.I.T. Cir. 7(1), M/S Sheth Financial बनाम/ Room No. 622, Services P. Ltd., V. Aayakar Bhavan, (Formerly Known As P L M.K. Road, Research & Development Churchgate, Pvt. Ltd., Mumbai -400020. Sadhna House, 3 Rd Floor,, 570 P.B. Marg, Behind Mahindra Tower, Worli, Mumbai – 400 018. "थायी लेखा सं./Pan : Aabcp4312L .. (अपीलाथ" /Appellant) (""यथ" / Respondent)

147 of the Act is clearly applicable. The ld. CIT(A) observed that the assessee has filed full details during the original assessment proceedings u/s 143(3) read with Section 143(2) of the Act with respect to all the issues and there was no failure on the part of the assessee to disclose fully and truly all material facts

SAMBHAVANATH INFRABUILD FARMS (SUCCESSOR TO LODHA CONSTRUCTION P. LTD P. LTD.,MUMBAI vs. ASSTT. CIT, CENTRAL CIRCLE-7(3), MUMBAI

Bench: Shri C.N. Prasad, Hon'Ble & Shri S. Rifaur Rahman, Hon'Blesambhavnath Infrabuild & Farms Pvt. Ltd., V. Asst. Cit– Central Circle – 7(3) {Successor To Lodha Construction Pvt. Ltd.,} Room No. 655, 6Th Floor 412, 4Th Floor, 17G Vardhaman Chamber Aayakar Bhavan, M.K. Road Cawasji Patel Road, Horniman Circle Mumbai - 400020 Fort, Mumbai - 400001 Pan: Aalcs1394M (Appellant) (Respondent) Assessee By : Shri Anuj Kisnadwala Department By Shri B.K. Bagchi

reassessment proceedings by issue of notice u/s 148 and served the notice. The assessee was supplied with the reasons recorded u/s 148(2) of the Act, the same is given below: - "During the course of search proceedings at the residence of Shri Somanathan Nair at D-02, Vastu Shrusti CHS Ltd., Lodha Heritage, Bhopar Road, Desle Pada, Dombivaii (E), Thane

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

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

3. As per the records from Profit & Loss Alc, it was noticed that assessee received interest on FD of Rs 163,45,298/ that assessee received interest on FD of Rs 163,45,298/ that assessee received interest on FD of Rs 163,45,298/-. The FD's as seen from the Balance sheet were mainty with