DCIT-2(3)(1), MUMBAI vs. KOTAK MAHINDRA BANK LIMITED, MUMBAI

In the result the appeal filed by the assessee in ITA No

147 of the Act\ndeclared to be invalid. If our findings on this ground goes against the revenue,\nrest of the grounds will become infructuous and not required any adjudication\nfrom our side.\n21. We have gone through the order of AO alongwith reasons for reopening\nsupplied to the assessee, order of the Ld. CIT (A) and submissions of both

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

VII to the return, such deduction under Section 80P(2)(d) was the return, such deduction under Section 80P(2)(d) was the return, such deduction under Section 80P(2)(d) was bifurcated into dividend income of Rs.53,71,450 and interest bifurcated into dividend income of Rs.53,71,450 and interest bifurcated into dividend income of Rs.53

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

VII to the return, such deduction under Section 80P(2)(d) was the return, such deduction under Section 80P(2)(d) was the return, such deduction under Section 80P(2)(d) was bifurcated into dividend income of Rs.53,71,450 and interest bifurcated into dividend income of Rs.53,71,450 and interest bifurcated into dividend income of Rs.53

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

VII to the return, such deduction under Section 80P(2)(d) was the return, such deduction under Section 80P(2)(d) was the return, such deduction under Section 80P(2)(d) was bifurcated into dividend income of Rs.53,71,450 and interest bifurcated into dividend income of Rs.53,71,450 and interest bifurcated into dividend income of Rs.53

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

VII to the return, such deduction under Section 80P(2)(d) was the return, such deduction under Section 80P(2)(d) was the return, such deduction under Section 80P(2)(d) was bifurcated into dividend income of Rs.53,71,450 and interest bifurcated into dividend income of Rs.53,71,450 and interest bifurcated into dividend income of Rs.53

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

VII to the return, such deduction under Section 80P(2)(d) was the return, such deduction under Section 80P(2)(d) was the return, such deduction under Section 80P(2)(d) was bifurcated into dividend income of Rs.53,71,450 and interest bifurcated into dividend income of Rs.53,71,450 and interest bifurcated into dividend income of Rs.53

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

VII to the return, such deduction under Section 80P(2)(d) was the return, such deduction under Section 80P(2)(d) was the return, such deduction under Section 80P(2)(d) was bifurcated into dividend income of Rs.53,71,450 and interest bifurcated into dividend income of Rs.53,71,450 and interest bifurcated into dividend income of Rs.53

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

VII to the return, such deduction under Section 80P(2)(d) was the return, such deduction under Section 80P(2)(d) was the return, such deduction under Section 80P(2)(d) was bifurcated into dividend income of Rs.53,71,450 and interest bifurcated into dividend income of Rs.53,71,450 and interest bifurcated into dividend income of Rs.53

SWANSTON MULTIPLEX CINEMAS P.LTD,MUMBAI vs. ASST CIT CIR 11(1), MUMBAI

The appeal of the assessee is partly allowed

Bench: Shri Joginder Singh & Shri G. Manjunathaassessment Year: 2005-06 Swanston Multiplex Cinemas Acit, Private Limited, Circle-11(1), बनाम/ 9Th Floor, Viraj Towers, W.E. R. No.467, Vs. Highway Next To Andheri Aayakar Bhavan, Flyover Andheri (East), M. K. Road, Mumai-400093 Mumbai-400020 ("नधा"रती/Assessee) (राज"व /Revenue) Pan No.:-Aafcs6295K

147 and both the first appellate authority as well as the Tribunal accepted the contention of the assessee holding that so far as the reassessments related to assessment of unexplained trade credits, they were invalid. On appeal, it has been held that the reassessments were to be valid. In Honda Siel Power Products Ltd. v. Deputy

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

In the result, appeals of the assessee are allowed

147, albeit it can be roped in only u/s 153C. If on overall appreciation of the scheme of assessment / 93. reassessment of income after the income-tax searches on the assessee searched and also for the persons not searched based on detection of some incriminating information during the said searches conducted upto 31/03/2021, the following legal course of action

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

In the result, appeals of the assessee are allowed

147, albeit it can be roped in only u/s 153C. If on overall appreciation of the scheme of assessment / 93. reassessment of income after the income-tax searches on the assessee searched and also for the persons not searched based on detection of some incriminating information during the said searches conducted upto 31/03/2021, the following legal course of action

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

In the result, appeals of the assessee are allowed

147, albeit it can be roped in only u/s 153C. If on overall appreciation of the scheme of assessment / 93. reassessment of income after the income-tax searches on the assessee searched and also for the persons not searched based on detection of some incriminating information during the said searches conducted upto 31/03/2021, the following legal course of action

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

In the result, appeals of the assessee are allowed

147, albeit it can be roped in only u/s 153C. If on overall appreciation of the scheme of assessment / 93. reassessment of income after the income-tax searches on the assessee searched and also for the persons not searched based on detection of some incriminating information during the said searches conducted upto 31/03/2021, the following legal course of action

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

In the result, appeals of the assessee are allowed

147, albeit it can be roped in only u/s 153C. If on overall appreciation of the scheme of assessment / 93. reassessment of income after the income-tax searches on the assessee searched and also for the persons not searched based on detection of some incriminating information during the said searches conducted upto 31/03/2021, the following legal course of action

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

In the result, appeals of the assessee are allowed

147, albeit it can be roped in only u/s 153C. If on overall appreciation of the scheme of assessment / 93. reassessment of income after the income-tax searches on the assessee searched and also for the persons not searched based on detection of some incriminating information during the said searches conducted upto 31/03/2021, the following legal course of action

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

In the result, appeals of the assessee are allowed

147, albeit it can be roped in only u/s 153C. If on overall appreciation of the scheme of assessment / 93. reassessment of income after the income-tax searches on the assessee searched and also for the persons not searched based on detection of some incriminating information during the said searches conducted upto 31/03/2021, the following legal course of action

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

VII to the return, such deduction und the return, such deduction under Section 80P(2)(d) was er Section 80P(2)(d) was bifurcated into dividend income of Rs.53,71,450 and interest bifurcated into dividend income of Rs.53,71,450 and interest bifurcated into dividend income of Rs.53,71,450 and interest income of Rs.1,27,56,156. Further

DY CIT-1(3)(2), MUMBAI vs. MAHARASHTRA STATE CO-OPERATIVE BANK LIMITED, MUMBAI

In the result, the appeal of the In the result, the appeal of the assessee is allowed partly assessee is allowed partly whereas the appeal of the Revenue is dismissed

Bench: Shri Om Prakash Kant () & Shri Sandeep Singh Karhail () Assessment Year: 2013-14

vii) of the Act, M/s The Maharashtra State Co-op. Bank Ltd. M/s The Maharashtra State Co ITA Nos. 3878 & 3916/Mum/2019 (including opening (including opening credit balance of the provision of the bad credit balance of the provision of the bad debts created us 36(1)(viia) of the act, although, the opening debts created us 36(1)(viia