ACIT - 5(3)(1), MUMBAI vs. RISHABH DIAMOND PVT. LTD., MUMBAI

In the result, the appeal by the Revenue is dismissed, while the Cross\nObjection by the assessee is partly allowed

68 of the Act. The learned CIT(A), vide\nimpugned order, rejected various submissions of the assessee in respect of\nits challenge against the initiation of proceedings under section 147 of the\nAct, however concurred with the contention of the assessee that the AO had\nissued notice under section 148A

FOREVER FLOURISHING FIN & INV. PVT LTD,MUMBAI vs. DCIT-CC-3(4), MUMBAI, MUMBAI

In the result, appeal for the assessment year 2012

Bench: Shri Om Prakash Kant () & Ms. Kavitha Rajagopal ()

68 of the Act on merit. 5. Before us, the Ld. Counsel of the assessee challenging the Before us, the Ld. Counsel of the assessee challenging the Before us, the Ld. Counsel of the assessee challenging the validity of the reassessment referred to Ground No. 1(i) and validity of the reassessment referred to Ground No. 1(i) validity

FOREVER FLOURISHING FIN. & INV. PVT. LTD. ,MUMBAI vs. DCIT (CC)-3(4), MUMBAI, MUMBAI

In the result, appeal for the assessment year 2012

Bench: Shri Om Prakash Kant () & Ms. Kavitha Rajagopal ()

68 of the Act on merit. 5. Before us, the Ld. Counsel of the assessee challenging the Before us, the Ld. Counsel of the assessee challenging the Before us, the Ld. Counsel of the assessee challenging the validity of the reassessment referred to Ground No. 1(i) and validity of the reassessment referred to Ground No. 1(i) validity

ACIT-19(3), MUMBAI, MUMBAI vs. RISHABH AVNISH MODY, MUMBAI

In the result, cross objection filed by the assessee is allowed and appeal filed by the revenue is dismissed

148A(d) of the Act on 30.07.2022 concluding that it is a fit case for reopening and issuance of notice u/s. 148 of the Act. Accordingly, on the very same date i.e., 30.07.2022, the Assessing Officer issued a notice u/s. 148 of the Act after obtaining approval in terms of Section 151(i) of the Act from Principal Commissioner

AJAY MULTI PROJECTS PRIVATE LIMITED,MUMBAI vs. DCIT, CIRCLE 4(1)(1), MUMBAI, MUMBAI

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

Bench: Shri Sandeep Gosain, () & Shri Prabhash Shankar, ()

68 of the Act as unexplained money. 3. Aggrieved by the said addition, assessee preferred appeal, but the same was dismissed by Ld. CIT(A). 4. Aggrieved by the order of Ld. CIT(A) assessee has preferred the present appeal before us, on the grounds mentioned above. 5. At the very outset, Ld. AR recked up ground no. 5 which

CYRUS PATEL ,MUMBAI vs. INCOME TAX OFFICER WARD 23(2)(1), MUMBAI

In the result, the appeal is allowed

Bench: SHRI SANDEEP GOSAIN (Judicial Member), SHRI PRABHASH SHANKAR (Accountant Member)

68 of the Act in respect of sale proceeds of shares of Anuh Pharma Ltd. by wrongly treating the sale proceeds as unexplained cash credit. 4. The appellant respectfully submits that both the assessment unit and CIT (A) have erred in not appreciating the correct facts of the case and also the documentary evidences on record while considering the sale

INCOME TAX OFFICER-28(3)(1), MUMBAI, NAVI MUMBAI vs. VINOD BHANJI SHAH, VASHI, NAVI MUMBAI

In the result, the Cross Objection by the assessee is allowed, while the Revenue’s appeal is dismissed

Bench: Shri Sandeep Singh Karhailshri Bijayananda Pruseth

section 68 of the Act. (vi) Whether on the facts and in the circumstances of the case and in law, the Ld. CIT (A), NFAC has erred in deleting the disallowance of business expenses and interest without appreciating that the assessee failed to produce supporting bills, vouchers or documentary evidences to substantiate the genuineness of such expenses. (vii) Whether

RAMESH PURSHOTTAM MODI ,MUMBAI vs. INCOME TAX OFFICER CIRCLE 22(1), MUMBAI

In the result, the appeal of the assessee is allowed

Bench: Shri Saktijit Dey & Shri Makarand Vasant Mahadeokarramesh Purshottam Ito Circle 22(1) Modi Income Tax 303, Modi House, Linking Vs. Department, Road, Khar West, Piramal Chamber, Mumbai-400 052 Dr. Ss Rao Marg, Parel, Mumbai 0 400 012 Pan/Gir No. Aahpm2793F (Applicant) (Respondent) Assessee By Shri Ashwani Kumar A/W Ms. Deepali Aggarwal, Ld. Ars Revenue By Shri Umashankar Prasad, Ld. Dr Date Of Hearing 12.02.2026 Date Of Pronouncement 19.02.2026

148A suffer from violation of statutory mandate and principles of natural justice. On merits also, the addition under section 68

KALPANA RAMESH JAIN,MUMBAI vs. DEPUTY COMMISSIONER OF INCOME TAX- CENTRAL CIRCLE-4(3)(1), MUMBAI

In the result all the three appeals of the assessee are allowed

68", "Section 148A(b)", "Section 148A(d)", "Section 151", "Section 292BB"], "issues": "Whether the reassessment proceedings

ITO-23(3)(6).MUMBAI, MUMBAI vs. RAJESHWAR BULLION TRADING , MUMBAI

In the result, the appeal is dismissed

Bench: Shri Saktijit Dey & Shri Makarand Vasant Mahadeokarm/S. Rajeshwar Bullion Trading Income Tax Officer 2Nd Floor, 61/63, Ward 23(3)(6) Har Narayan Building, Vs. Mumbai Zaveri Bazar, Mumbai-400 002 Pan/Gir No. Aasfr 7707 D (Assessee) : (Revenue) & Income Tax Officer M/S. Rajeshwar Bullion Trading Ward 23(3)(6) 2Nd Floor, 61/63, Mumbai Vs. Har Narayan Building, Zaveri Bazar, Mumbai-400 002 Pan/Gir No. Aasfr 7707 D (Revenue) : (Assessee) Appellant By : Shri Dhran Gandhi Respondent By : Shri Annavaram Kosuri (Sr. Ar) Date Of Hearing : 16.02.2026 Date Of Pronouncement : 20.02.2026 O R D E R Per Saktijit Dey: The Captioned Appeals, One By The Assessee & The Other By The Revenue Arise Out Of Two Separate Orders Passed By National Faceless Appeal Centre (‘Nfac’ For Short), Delhi, Pertaining To The Very Same Assessment Year (A.Y. For Short) 2017-18. However, While Assessee’S Appeal Arises Out Of Original Assessment Proceeding, The Revenue’S Appeal Arises Out Of Reassessment Proceeding U/S. 147 Of The Act. M/S. Rajeshwar Bullion Trading 2. At The Outset, We Will Deal With Assessee’S Appeal, Being Ita No.5754/Mum/2025. In Ground Nos. 1 & 2, The Assessee Has Challenged The Decision Of Ld. First Appellate Authority In Remanding The Issue Back To The Assessing Officer (A.O. For Short) For De Novo Adjudication. Whereas, In Ground No. 3, The Assessee Has Challenged The Non-Adjudication Of The Ground Relating To The Applicability Of Section 115Bbe Of The Act. Since, The Issues Are Overlapping, We Will Deal With Them Concurrently.

68 of the Act. While doing so, he applied higher rate of tax in terms with section 115BBE of the Act. M/s. Rajeshwar Bullion Trading 4. Against the assessment order so passed, the assessee filed an appeal before ld. First appellate authority. 5. After considering the submissions of the assessee, in the context of the facts and materials

M/S. RAJESHWAR BULLION TRADING ,MUMBAI vs. ASST. CIT, CIRCLE 23(3), MUMBAI

In the result, the appeal is dismissed

Bench: Shri Saktijit Dey & Shri Makarand Vasant Mahadeokarm/S. Rajeshwar Bullion Trading Income Tax Officer 2Nd Floor, 61/63, Ward 23(3)(6) Har Narayan Building, Vs. Mumbai Zaveri Bazar, Mumbai-400 002 Pan/Gir No. Aasfr 7707 D (Assessee) : (Revenue) & Income Tax Officer M/S. Rajeshwar Bullion Trading Ward 23(3)(6) 2Nd Floor, 61/63, Mumbai Vs. Har Narayan Building, Zaveri Bazar, Mumbai-400 002 Pan/Gir No. Aasfr 7707 D (Revenue) : (Assessee) Appellant By : Shri Dhran Gandhi Respondent By : Shri Annavaram Kosuri (Sr. Ar) Date Of Hearing : 16.02.2026 Date Of Pronouncement : 20.02.2026 O R D E R Per Saktijit Dey: The Captioned Appeals, One By The Assessee & The Other By The Revenue Arise Out Of Two Separate Orders Passed By National Faceless Appeal Centre (‘Nfac’ For Short), Delhi, Pertaining To The Very Same Assessment Year (A.Y. For Short) 2017-18. However, While Assessee’S Appeal Arises Out Of Original Assessment Proceeding, The Revenue’S Appeal Arises Out Of Reassessment Proceeding U/S. 147 Of The Act. M/S. Rajeshwar Bullion Trading 2. At The Outset, We Will Deal With Assessee’S Appeal, Being Ita No.5754/Mum/2025. In Ground Nos. 1 & 2, The Assessee Has Challenged The Decision Of Ld. First Appellate Authority In Remanding The Issue Back To The Assessing Officer (A.O. For Short) For De Novo Adjudication. Whereas, In Ground No. 3, The Assessee Has Challenged The Non-Adjudication Of The Ground Relating To The Applicability Of Section 115Bbe Of The Act. Since, The Issues Are Overlapping, We Will Deal With Them Concurrently.

68 of the Act. While doing so, he applied higher rate of tax in terms with section 115BBE of the Act. M/s. Rajeshwar Bullion Trading 4. Against the assessment order so passed, the assessee filed an appeal before ld. First appellate authority. 5. After considering the submissions of the assessee, in the context of the facts and materials

INCOME TAX OFFICER (IT)-3(2)(1), KAUTILYA BHAWAN vs. SHAPOORJI PALLONJI MISTRY, MUMBAI

In the result, appeal filed by the Revenue is dismissed

Bench: Shri Amit Shukla & Shri Girish Agrawal

148A and 148, and/or in passing the impugned orders dated 30 July 2022 and/or 28th July 2023 under the said provisions. The actions are contrary to law, beyond the jurisdiction of the Assessing Officer, and the impugned orders are liable to be quashed. 2. erred in passing order under section 147 of the Act by reopening of original assessment

SAKSHI RATNESHCHAND JAIN,MUMBAI vs. INT TAX WARD 3(1)(1) , MUMBAI

In the result, the assessee’s appeal is allowed

Bench: SHRI OM PRAKASH KANT (Accountant Member), SHRI SUNIL KUMAR SINGH (Judicial Member)

section 148A of the Act were carried out and order u/s. 148A(d) of the Act was passed on 28.07.2022 after the approval of specified authority. Consequently, notice u/s. 148 of the Act was issued on 29.07.2022. Assessee filed return of income on 10.08.2022 in response thereof, declaring same total income of Rs. 2,64,520/- as declared earlier

SUMAN JAGANNATH SANKHE,MUMBAI vs. ITO WARD 41.4.4, KAUTILYA BHAVAN, MUMBAI

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

Bench: Smt. Beena Pillai ()

148A(b) are bad in law since the same are issued in violation of section 151A read with Notification No. 18 of 2022; g. The Notice under section 148 is void also because the same is issued without any Document Identification Number (DIN) as mandated by CBDT Circular No. 19 of 2019; h. In any case, there

SKA SALES PVT LTD,MUMBAI vs. INCOME TAX OFFICSR, WARD 13(2)(1), MUMBAI

68", "Section 69", "Section 69C", "Section 148", "Section 148A", "Section 149", "Section 151"], "issues

ACIT22(1), MUMBAI vs. SPR ASSOCIATES, MUMBAI

In the result, the appeal filed by the revenue stands dismissed and the cross-objection filed by assessee stands allowed

Bench: Smt. Beena Pillai () & Shri Arun Khodpia, ()

section 68 but on the ground that the receipt is taxable in the year of receipt as dividend income. 5. Whether on the facts and in the circumstances of the case and in law, the Ld. CIT(A) erred in relying on the assessee's explanation that the dividend was paid by the mutual fund out of capital funds

INCOME TAX OFFICER (INTERNATIONAL TAXATION) 3(2)(1), KAUTILYA BHAWAN MUMBAI vs. SHAPOORJI PALLONJI MISTRY, MUMBAI

In the result, both appeals by the Revenue are dismissed and the\ntwo Cross Objections of the assessee are allowed

sections": [ "147", "148", "148A", "149", "151", "143(3)", "68", "142(1)", "143(2)", "144C(1)", "144C(3)" ], "issues": "Whether

DCIT CENTRAL CIRCLE- 7(1), MUMBAI, MUMBAI vs. PRANAVKUMAR PRAFULCHANDRA VORA, GUJRAT

In the result, the appeal filed by the revenue is dismissed and cross-objection filed by assessee is partly allowed

Bench: Smt. Beena Pillai ()

68 operates independently of the profit and loss disclosure and the burden lies on the assessee to establish genuineness of entries, failing which they are deemed to be unexplained income of the assessee. 6. The appellant craves leave to add, amend, alter or withdraw any of the above grounds of appeal at or before the time of hearing