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

Section 151(i) of the Act from Principal Commissioner of Income Tax-19, Mumbai. Ultimately, the Assessing Officer completed the assessment u/s. 147 r.w.s. 144B of the Act making couple of additions u/s. 56 and 68

INCOME TAX OFFICER-12(3)(1), MUMBAI, MUMBAI vs. MANJU DIAMONDS PVT. LTD., MUMBAI

In the result, the appeal of the Revenue is allowed for statistical purposes whereas the application under Rule 27 of statistical purposes whereas the application under Rule 27

Bench: Shri Om Prakash Kant () & Shri Raj Kumar Chauhan () Assessment Year: 2017-18 Ito-12(3)(1), Manju Diamonds Pvt. Ltd., R.No. 145, 1St Floor, Aayakar 57/59, 1St Floor, Nagdevi Street, Vs. Bhavan, M.K. Road, Maszid Bunder, Mumbai-400020. Mumbai-400 003. Pan No. Aaecm 6609 G Appellant Respondent

68 153C. 69 [(1)] 70[Notwithstanding anything contained in [Notwithstanding anything contained in section 139, [Notwithstanding anything contained in section 147, section 148 section 148, section 149, section 151

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

DONA BUILDERS PVT LTD ,MUMBAI vs. DCIT, CIRCLE 1(3)(1), MUMBAI

Bench: Shri Om Prakash Kant () & Shri Raj Kumar Chauhan() Assessment Year: 2009-10 & Assessment Year: 2010-11 & Assessment Year: 2011-12 & Assessment Year: 2012-13 & Assessment Year: 2013-14 Dona Builders Pvt Ltd Dcit, Circle 1(3)(1), Mumbai 108, Shiv Aashish S.V. Road, Aayakar Bhavan, Mumbai- Vs. Andheri West, Mumbai- 400058 400020 Pan No. Aaacd 3116 F Appellant Respondent : Mr. Rajesh Shah Assessee By : Mr. Annavaram Kosuri, Sr-Dr A/W Revenue By Mr. Uma Shankar Prasad, Cit Dr : 06/11/2025 Date Of Hearing Date Of Pronouncement : 21/01/2026 Order Per Bench These Five Appeals By The Assessee Are Directed Against Separate Orders Passed By The Ld. Commissioner Of Income-Tax

151 of t 3. a) On the facts and circumstances of the case and in law, the a) On the facts and circumstances of the case and in law, the a) On the facts and circumstances of the case and in law, the learned CIT(A) learned CIT(A)-NFAC erred in confirming the addition of Rs NFAC erred

DONA BUILDERS PVT LTD,MUMBAI vs. DCIT, CIRCLE 1(3)(1), MUMBAI

Bench: Shri Om Prakash Kant () & Shri Raj Kumar Chauhan() Assessment Year: 2009-10 & Assessment Year: 2010-11 & Assessment Year: 2011-12 & Assessment Year: 2012-13 & Assessment Year: 2013-14 Dona Builders Pvt Ltd Dcit, Circle 1(3)(1), Mumbai 108, Shiv Aashish S.V. Road, Aayakar Bhavan, Mumbai- Vs. Andheri West, Mumbai- 400058 400020 Pan No. Aaacd 3116 F Appellant Respondent : Mr. Rajesh Shah Assessee By : Mr. Annavaram Kosuri, Sr-Dr A/W Revenue By Mr. Uma Shankar Prasad, Cit Dr : 06/11/2025 Date Of Hearing Date Of Pronouncement : 21/01/2026 Order Per Bench These Five Appeals By The Assessee Are Directed Against Separate Orders Passed By The Ld. Commissioner Of Income-Tax

151 of t 3. a) On the facts and circumstances of the case and in law, the a) On the facts and circumstances of the case and in law, the a) On the facts and circumstances of the case and in law, the learned CIT(A) learned CIT(A)-NFAC erred in confirming the addition of Rs NFAC erred

ARVIND VELJI GADA,MUMBAI vs. ITO WARD 41(1)(1), MUMBAI

In the result, both the appeals of the assessee and Revenue

Bench: Shri Om Prakash Kant () & Ms. Kavitha Rajagopal () Assessment Year: 2016-17 Arvind Velji Gada, Ito Ward 41(1)(1), 1704 12Th Floor, Bellezza Tower, Kautilya Bhavan, Avenue 3, Near Vs. 420, Bhavani Shankar Road, Videsh Bhavan, G Block Bkc, Dadar (West) Bandra Kurla Complex, Bandra Mumbai-400028. East, Mumbai-400051. Pan No. Aespg 4212 Q Appellant Respondent Assessment Year: 2016-17 Ito Ward 41(1)(1), Arvind Velji Gada, Kautilya Bhavan, Avenue 3, 1704 12Th Floor, Bellezza Tower, 420, Vs. Near Videsh Bhavan, G Block Bhavani Shankar Road, Dadar Bkc, Bandra Kurla Complex, (West) Bandra East, Mumbai-400028. Mumbai-400051. Pan No. Aespg 4212 Q Appellant Respondent

68 of the Act which was taxed of the Act which was taxed at special rate u/s 115JBE of the Act. special rate u/s 115JBE of the Act. On further appeal, the Ld. CIT(A) allowed part relief and therefore, On further appeal, the Ld. CIT(A) allowed part relief and therefore, On further appeal, the Ld. CIT(A) allowed

ITO WARD 41(1)(1), MUMBAI, KAUTILYA BHAVAN , BKC, MUMBAI vs. ARVIND VELJI GADA, MUMBAI

In the result, both the appeals of the assessee and Revenue

Bench: Shri Om Prakash Kant () & Ms. Kavitha Rajagopal () Assessment Year: 2016-17 Arvind Velji Gada, Ito Ward 41(1)(1), 1704 12Th Floor, Bellezza Tower, Kautilya Bhavan, Avenue 3, Near Vs. 420, Bhavani Shankar Road, Videsh Bhavan, G Block Bkc, Dadar (West) Bandra Kurla Complex, Bandra Mumbai-400028. East, Mumbai-400051. Pan No. Aespg 4212 Q Appellant Respondent Assessment Year: 2016-17 Ito Ward 41(1)(1), Arvind Velji Gada, Kautilya Bhavan, Avenue 3, 1704 12Th Floor, Bellezza Tower, 420, Vs. Near Videsh Bhavan, G Block Bhavani Shankar Road, Dadar Bkc, Bandra Kurla Complex, (West) Bandra East, Mumbai-400028. Mumbai-400051. Pan No. Aespg 4212 Q Appellant Respondent

68 of the Act which was taxed of the Act which was taxed at special rate u/s 115JBE of the Act. special rate u/s 115JBE of the Act. On further appeal, the Ld. CIT(A) allowed part relief and therefore, On further appeal, the Ld. CIT(A) allowed part relief and therefore, On further appeal, the Ld. CIT(A) allowed

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

68 of the Act in the order under section 147 of the Act without appreciating the facts of the case. CO. No. 153/MUM/2025 1. erred in filing appeals without complying with the regulations and with defect and filed multiple appeals with the same grounds as raised for the present appeal, which is wholly erroneous, arbitrary and contrary

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

RATAN N MOTWANI (HUF),MUMBAI vs. ITO WARD 23(3)(1), MUMBAI

In the result, assessee’s appeal is allowed

Bench: Smt. Beena Pillai & Smt.Renu Jauhri7 (A.Y.2017-18)

section 68 of the Act.” The Appellant craves leave to add, alter, amend, vary and/or withdraw any or all the above grounds of appeal. 3. Brief facts of the case are that the assessee HUF had filed return for A.Y. 2017-18 declaring income of Rs. 4,02,660/-. Subsequently, information was received by the ld. AO from Investigation

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, ()

section 147 to 151 have not been fulfilled. 3. The reopening of assessment is without proper application of mind and therefore, bad in law. 4. There is no reason to believe and the reasons recorded are merely on the basis of the information from the DDIT(Investigation). 5. The sanction u/s 151

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 ()

151 of the Act are not complied with in the present case since, as admitted by the Ld. AO himself, the sanction is obtained from the Principal Commissioner of Income Tax instead of the Chief Commissioner / Principal Chief Commissioner of Income Tax and therefore the entire proceeding is invalid and void ab initio; e. The impugned Notice under section

MARK FOODS,MUMBAI vs. INCOME TAX OFFICER-28(2)(1), MUMBAI

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

Bench: Shri Saktijit Dey & Shri Girish Agrawal

68 merely on surmises, conjecture and suspicion. 11. In the facts and circumstances of the case and in law, the Learned CIT(A) has erred in confirming addition of Rs. 81,75,025/-on account of alleged bogus purchase merely on surmises, conjecture and suspicion. 12. The appellant craves leave to add, alter, delete or modify

ITO(IT)-3(2)(1), 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

68 of the Act in the order under section 147 of the Act without appreciating\nthe facts of the case.\n\nCO. No. 153/MUM/2025\n\n1. erred in filing appeals without complying with the regulations and with defect\nand filed multiple appeals with the same grounds as raised for the present\nappeal, which is wholly erroneous, arbitrary and contrary

INCOME TAX OFFICER WARD 24(2)(1),MUMBAI, PIRAMAL CHAMBERS, LALBAUG vs. HOMEWELL REALTY LLP, ANDHERI, MUMBAI

In the result, the appeal of the Revenue is dismissed

151 of the Act?\n4. Brief facts of the case are that the assessee is a Firm and has\nfiled return for AY 2017-18 on 11.10.2017 declaring total income of Nil\nand the same was processed u/s 143(1) of the Act. Later, certain\ninformation was received by the AO from the Investigation wing of the\nDepartment whereby

ACIT CIRCLE-4(3)(1), MUMBAI, MUMBAI vs. JMP SECURITIES PVT LTD, MUMBAI

In the result, the cross objection by the assessee is allowed, while the Revenue’s appeal is dismissed

Bench: Ms. Padmavathy S & Shri. Sandeep Singh Karhail

68 of the Act. The learned CIT(A), vide impugned order, dismissed the grounds raised by the assessee challenging the initiation of reassessment proceedings under section 147 of the Act. 9. During the hearing, the learned Authorised Representative (“learned AR”) submitted that the reopening of assessment under section 147 of the Act, in the present case

DCIT CENTRAL CIRCLE- 7(1), MUMBAI, MUMBAI vs. BHAVIK 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 to establish the identity, creditworthiness or genuineness of the transaction during the assessment proceedings. 3. On the facts and in the circumstances of the case and in law, the Ld. CIT(A) erred in appreciating that the loss of Rs. 10,25,756/- was not a mere business loss but an instrument of an accommodation entry. The assessee

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