RAMESH AMRATLAL BRAHMBHATT ,MUMBAI vs. ITO WARD 34(3)(2), MUMBAI

In the result, the reassessment order dated 20

Bench: Shri Saktijit Dey & Shri Makarand Vasant Mahadeokarramesh Amratlal Ito Ward 34(3)(2), Brahmbhatt Kautilya Bhavan, 43 Rajnigandha, Vs. Bandra Kurla Gulmohar Cross Road No. Complex, Mumbai – 11, J V P D Scheme, 400 051 Juhu, Mumbai-400 049 Pan/Gir No. Aabpb7235R (Applicant) (Respondent) Assessee By Shri K. Gopal & Ms. Neha Paranjpe, Ld. Ars Revenue By Shri Annavaram Kosuri, Ld. Dr Date Of Hearing 23.02.2026 Date Of Pronouncement 25.02.2026

151A of the Act. Hence, the same is illegal and bad in law. 4. The notice dated 29.07.2022 issued under section 148 of the Act is barred by limitation as per the provisions of section 149 of the Act. Hence, the notice issued under section 148 of the Act and the entire reassessment proceedings conducted pursuant

ARHAM ANMOL PROJECTS PRIVATE LIMITED,VILLAGE VALSHIND, BHIWANDI vs. CIRCLE 1 KALYAN, KALYAN, THANE

In the result, the legal grounds challenging the validity of the assessment are dismissed

Bench: Shri Amit Shukla & Shri Makarand Vasant Mahadeokararham Anmol Projects Dcit Circle 1, Private Limited 2Nd Floor, Rani H. No. 1113, Ground Vs. Mansion, Murbad Floor, Arham Logiparc, Road, Kalyan Nh-3, Nashik Highway, (West), Thane, Village Valshind, Maharashtra – 421 Bhiwandi, Maharashtra – 301 421 302. Pan/Gir No. Aagca9644P (Applicant) (Respondent) Assessee By Shri Subhash Bains, Ld. Ar Revenue By Shri Surendra Mohan, Ld. Dr Date Of Hearing 28.01.2026 Date Of Pronouncement 26.03.2026

151A. The present issue concerns issuance of notice under section 143(2) and subsequent completion of assessment under section 144B. There is no finding in Hexaware that a notice validly issued by a competent Assessing Officer under section 143(2) becomes invalid merely because the assessment is completed by the Assessment Unit. 38. The Hon’ble Delhi

LEMAN DIVERSIFIED FUND ,MUMBAI vs. COMMISSIONER OF INCOME TAX (INT TAXATION) CIRCLE 3(1)(2), MUMABI

Bench: Smt Beena Pillai, Jm & Ms Padmavathy S, Am

68 of the Act does not survive. Since the facts pertaining to the year under consideration and the findings of the AO/DRP are identical we are of the view that our decision for AY 2013-14 is mutatis mutandis applicable for AY 2014-15 also. Accordingly we direct the AO to delete the addition made for AY 2014-15 also

LEMAN DIVERSIFIED FUND,MUMBAI vs. ASSSISTANT COMMISSIONER OF INCOME TAX (INT TAXATION)-CIRCLE 3(1)(2), MUMBAI

Bench: Smt Beena Pillai, Jm & Ms Padmavathy S, Am

68 of the Act does not survive. Since the facts pertaining to the year under consideration and the findings of the AO/DRP are identical we are of the view that our decision for AY 2013-14 is mutatis mutandis applicable for AY 2014-15 also. Accordingly we direct the AO to delete the addition made for AY 2014-15 also

DCIT, CENTRAL CIRCLE-8(1), MUMBAI, MUMBAI vs. E I RESORTS AND CLUBS PVT LTD, MUMBAI

3213/Mum/2025

Bench: SHRI AMIT SHUKLA (Judicial Member), SHRI ARUN KHODPIA (Accountant Member)

68 or 69A. He also drew our attention to Harish Textile Engineers Ltd. v. DCIT [(2015) 63 taxmann.com 66 (Bom)], and DCIT v. Padmashree Dr. D.Y. Patil University [(2024) 159 taxmann.com 353 (Mum Trib)], both reiterating that such scribbled records, unless validated through substantive inquiry, are mere dumb documents. The AR thus submitted that the legal landscape on this issue

DCIT, CENTRAL CIRCLE-8(1), MUMBAI, MUMBAI vs. EI RESORTS & CLUBS PVT LTD, MUMBAI

3213/Mum/2025

Bench: SHRI AMIT SHUKLA (Judicial Member), SHRI ARUN KHODPIA (Accountant Member)

68 or 69A. He also drew our attention to Harish Textile Engineers Ltd. v. DCIT [(2015) 63 taxmann.com 66 (Bom)], and DCIT v. Padmashree Dr. D.Y. Patil University [(2024) 159 taxmann.com 353 (Mum Trib)], both reiterating that such scribbled records, unless validated through substantive inquiry, are mere dumb documents. The AR thus submitted that the legal landscape on this issue

TARUN NANDKUMAR SEKSARIA ,MUMBAI vs. DEPUTY COMMISSIONER OF INCOME TAX CENTRAL CIRCLE -8(1), MUMBAI

68 or 69A. He also\ndrew our attention to Harish Textile Engineers Ltd. v. DCIT\n[(2015) 63 taxmann.com 66 (Bom)], and DCIT v.\nPadmashree Dr. D.Y. Patil University [(2024) 159\ntaxmann.com 353 (Mum Trib)], both reiterating that such\nscribbled records, unless validated through substantive\ninquiry, are mere dumb documents. The AR thus submitted\nthat the legal landscape on this

TARUN NANDKUMAR SEKSARIA,MUMBAI vs. DCIT CENTRAL CIRCLE 8(1), MUMBAI

68 or 69A. He also\ndrew our attention to Harish Textile Engineers Ltd. v. DCIT\n[(2015) 63 taxmann.com 66 (Bom)], and DCIT v.\nPadmashree Dr. D.Y. Patil University [(2024) 159\ntaxmann.com 353 (Mum Trib)], both reiterating that such\nscribbled records, unless validated through substantive\ninquiry, are mere dumb documents. The AR thus submitted\nthat the legal landscape on this

TARUN NANDKUMAR SEKSARIA ,MUMBAI vs. DEPUTY COMMISSIONER OF INCOME TAX CENTRAL CIRCLE -8(1), MUMBAI

68 or 69A. He also\ndrew our attention to Harish Textile Engineers Ltd. v. DCIT\n[(2015) 63 taxmann.com 66 (Bom)], and DCIT v.\nPadmashree Dr. D.Y. Patil University [(2024) 159\ntaxmann.com 353 (Mum Trib)], both reiterating that such\nscribbled records, unless validated through substantive\ninquiry, are mere dumb documents. The AR thus submitted\nthat the legal landscape on this

THE ESTATE INVESTMENT COMPANY PRIVATE LIMITED,MUMBAI vs. DCIT CENTRAL CIRCLE 8(1), MUMBAI

3012/Mum/2025

Bench: SHRI AMIT SHUKLA (Judicial Member), SHRI ARUN KHODPIA (Accountant Member)

68 or 69A. He also drew our attention to Harish Textile Engineers Ltd. v. DCIT [(2015) 63 taxmann.com 66 (Bom)], and DCIT v. Padmashree Dr. D.Y. Patil University [(2024) 159 taxmann.com 353 (Mum Trib)], both reiterating that such scribbled records, unless validated through substantive The Estate Investment Company Pvt. Ltd. and others inquiry, are mere dumb documents. The AR thus

THE ESTATE INVESTMENT COMPANY PRIVATE LIMITED,MUMBAI vs. DCIT CENTRAL CIRCLE 8(1), MUMBAI

68 or 69A. He also\ndrew our attention to Harish Textile Engineers Ltd. v. DCIT\n[(2015) 63 taxmann.com 66 (Bom)], and DCIT v.\nPadmashree Dr. D.Y. Patil University [(2024) 159\ntaxmann.com 353 (Mum Trib)], both reiterating that such\nscribbled records, unless validated through substantive\n\n26\nITA No.3012/Mum/2025 and others\nThe Estate Investment Company Pvt. Ltd. and others

THE ESTATE INVESTMENT COMPANY PRIVATE LIMITED,MUMBAI vs. DEPUTY COMMISSIONER OF INCOME TAX CENTRAL CIRCLE -8(1), MUMBAI

68 or 69A. He also\ndrew our attention to Harish Textile Engineers Ltd. v. DCIT\n[(2015) 63 taxmann.com 66 (Bom)], and DCIT v.\nPadmashree Dr. D.Y. Patil University [(2024) 159\ntaxmann.com 353 (Mum Trib)], both reiterating that such\nscribbled records, unless validated through substantive\n\n26\nITA No.3012/Mum/2025 and others\nThe Estate Investment Company Pvt. Ltd. and others

DCIT, CENTRAL CIRCLE-8(1), MUMBAI, MUMBAI vs. THE ESTATE INVESTMENT COMPANY PVT LTD, MUMBAI

68 or 69A. He also\ndrew our attention to Harish Textile Engineers Ltd. v. DCIT\n[(2015) 63 taxmann.com 66 (Bom)], and DCIT v.\nPadmashree Dr. D.Y. Patil University [(2024) 159\ntaxmann.com 353 (Mum Trib)], both reiterating that such\nscribbled records, unless validated through substantive\ninquiry, are mere dumb documents. The AR thus submitted\nthat the legal landscape on this

DCIT, CENTRAL CIRCLE-8(1), MUMBAI, MUMBAI vs. THE ESTATE INVESTMENT COMPANY PVT LTD, MUMBAI

68 or 69A. He also\ndrew our attention to Harish Textile Engineers Ltd. v. DCIT\n[(2015) 63 taxmann.com 66 (Bom)], and DCIT v.\nPadmashree Dr. D.Y. Patil University [(2024) 159\ntaxmann.com 353 (Mum Trib)], both reiterating that such\nscribbled records, unless validated through substantive\ninquiry, are mere dumb documents. The AR thus submitted\nthat the legal landscape on this

THE ESTATE INVESTMENT COMPANY PRIVATE LIMITED,MUMBAI vs. DCIT CENTRAL CIRCLE 8(1), MUMBAI

68 or 69A. He also\ndrew our attention to Harish Textile Engineers Ltd. v. DCIT\n[(2015) 63 taxmann.com 66 (Bom)], and DCIT v.\nPadmashree Dr. D.Y. Patil University [(2024) 159\ntaxmann.com 353 (Mum Trib)], both reiterating that such\nscribbled records, unless validated through substantive\n\n26\nITA No.3012/Mum/2025 and others\nThe Estate Investment Company Pvt. Ltd. and others\ninquiry

DCIT CENTRAL CIRCLE-8(1), MUMBAI, MUMBAI vs. THE ESTATE INVESTMENT COMPANY PRIVATE LIMITED, MUMBAI

68 or 69A. He also\ndrew our attention to Harish Textile Engineers Ltd. v. DCIT\n[(2015) 63 taxmann.com 66 (Bom)], and DCIT v.\nPadmashree Dr. D.Y. Patil University [(2024) 159\ntaxmann.com 353 (Mum Trib)], both reiterating that such\nscribbled records, unless validated through substantive\ninquiry, are mere dumb documents. The AR thus submitted\nthat the legal landscape on this

THE ESTATE INVESTMENT COMPANY PRIVATE LIMITED ,MUMBAI vs. DEPUTY COMMISSIONER OF INCOME TAX CENTRAL CIRCLE -8(1), MUMBAI

68 or 69A. He also\ndrew our attention to Harish Textile Engineers Ltd. v. DCIT\n[(2015) 63 taxmann.com 66 (Bom)], and DCIT v.\nPadmashree Dr. D.Y. Patil University [(2024) 159\ntaxmann.com 353 (Mum Trib)], both reiterating that such\nscribbled records, unless validated through substantive\n\n26\nITA No.3012/Mum/2025 and others\nThe Estate Investment Company Pvt. Ltd. and others

THE ESTATE INVESTMENT COMPANY PRIVATE LIMITED,MUMBAI vs. DEPUTY COMMISSIONER OF INCOME TAX CENTRAL CIRCLE -8(1), MUMBAI

68 or 69A. He also\ndrew our attention to Harish Textile Engineers Ltd. v. DCIT\n[(2015) 63 taxmann.com 66 (Bom)], and DCIT v.\nPadmashree Dr. D.Y. Patil University [(2024) 159\ntaxmann.com 353 (Mum Trib)], both reiterating that such\nscribbled records, unless validated through substantive\ninquiry, are mere dumb documents. The AR thus submitted\nthat the legal landscape on this

THE ESTATE INVESTMENT COMPANY PRIVATE LIMITED,MUMBAI vs. DCIT CENTRAL CIRCLE 8(1), MUMBAI

68 or 69A. He also drew our attention to Harish Textile Engineers Ltd. v. DCIT [(2015) 63 taxmann.com 66 (Bom)], and DCIT v. Padmashree Dr. D.Y. Patil University [(2024) 159 taxmann.com 353 (Mum Trib)], both reiterating that such scribbled records, unless validated through substantive\n\n26\nITA No.3012/Mum/2025 and others\nThe Estate Investment Company Pvt. Ltd. and others\ninquiry