DCIT CENTRAL CIRCLE-8(4), MUMBAI vs. M/S ROHAN DEVELOPERS PVT LTD, MUMBAI

In the result, all the appeals of the Revenue are dismissed and appeals of the assessee are allowed

Bench: Shri Rajesh Kumar & Shri Ravish Soodassessment Year: 2008-09 Assessment Year: 2010-11 Assessment Year: 2011-12 Assessment Year: 2012-13 Assessment Year: 2013-14 Assessment Year: 2013-14 Assessment Year: 2014-15 Assessment Year: 2014-15

245D(4) of the Act. Thus the Income Tax Settlement Commission accepted the settlement application by M/s. Riddhi Siddhi Bullion Ltd. without any addition on account of promissory notes upon being fully satisfied with the explanation of M/s. Riddhi Siddhi Bullion Ltd. that no unaccounted income has arisen from such seized pages. In view of these facts

ROHAN DEVELOPERS P.LTD,MUMBAI vs. DCIT CEN CIR 47, MUMBAI

In the result, all the appeals of the Revenue are dismissed and appeals of the assessee are allowed

Bench: Shri Rajesh Kumar & Shri Ravish Soodassessment Year: 2008-09 Assessment Year: 2010-11 Assessment Year: 2011-12 Assessment Year: 2012-13 Assessment Year: 2013-14 Assessment Year: 2013-14 Assessment Year: 2014-15 Assessment Year: 2014-15

245D(4) of the Act. Thus the Income Tax Settlement Commission accepted the settlement application by M/s. Riddhi Siddhi Bullion Ltd. without any addition on account of promissory notes upon being fully satisfied with the explanation of M/s. Riddhi Siddhi Bullion Ltd. that no unaccounted income has arisen from such seized pages. In view of these facts

ASSTT COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-6(1), MUMBAI vs. HELIOS MERCANTILE LIMITED, MUMBAI

245D (4) of the Act passed its order disposing of the\nassessee's application and has not accepted the terms of settlement of\nthe assessee group. Therefore, the terms of settlement were not\naccepted.\n05.\nThe assessee filed its return of income on 2/11/2018 in response to\nnotice under section 153A (1) of the act issued on 18/6/2018

SHRIVALLABH PITTE INDUSTRIES LTD ,MUMBAI vs. DY COMMISSIONER OF INCOME TAX,CENTRAL CIRLE -6(1) , MUMBAI

245D (4) of the Act passed its order disposing of the\nassessee's application and has not accepted the terms of settlement of\nthe assessee group. Therefore, the terms of settlement were not\naccepted.\n05.\nThe assessee filed its return of income on 2/11/2018 in response to\nnotice under section 153A (1) of the act issued on 18/6/2018

HEMENDRA RANCHOODDAS MERCHANT ,MUMBAI vs. DY CIT-CENTRAL CIRCLE-6(2), MUMBAI.

In the result, all the appeals of the assessee are allowed as partly for statistical purposes and appeal of the revenue except assessment year of 2005-06 are allowed for statistical purposes

Bench: Shri Om Prakash Kant () & Shri Sandeep Singh Karhail ()

245D was passed not providing for the terms of settlement.” 10.3.1 Under the second proviso below to Explantaion-1 to section 153, further period has been provided to the Assessing Officer for completion of assessment as under: “Provided further that where a proceeding before the Settlement Commission abates under section 245HA, the period of limitation available under this

DY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-6(2), MUMBAI. vs. HEMENDRA MERCHANT , MUMBAI

In the result, all the appeals of the assessee are allowed as partly for statistical purposes and appeal of the revenue except assessment year of 2005-06 are allowed for statistical purposes

Bench: Shri Om Prakash Kant () & Shri Sandeep Singh Karhail ()

245D was passed not providing for the terms of settlement.” 10.3.1 Under the second proviso below to Explantaion-1 to section 153, further period has been provided to the Assessing Officer for completion of assessment as under: “Provided further that where a proceeding before the Settlement Commission abates under section 245HA, the period of limitation available under this

DY COMMISSIONER OF INCOME TAX, , MUMBAI vs. HEMENDRA MERCHANT, MUMBAI

In the result, all the appeals of the assessee are allowed as partly for statistical purposes and appeal of the revenue except assessment year of 2005-06 are allowed for statistical purposes

Bench: Shri Om Prakash Kant () & Shri Sandeep Singh Karhail ()

245D was passed not providing for the terms of settlement.” 10.3.1 Under the second proviso below to Explantaion-1 to section 153, further period has been provided to the Assessing Officer for completion of assessment as under: “Provided further that where a proceeding before the Settlement Commission abates under section 245HA, the period of limitation available under this

DY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-6(2), MUMBAI vs. HEMENDRA MERCHANT , MUMBAI

In the result, all the appeals of the assessee are allowed as partly for statistical purposes and appeal of the revenue except assessment year of 2005-06 are allowed for statistical purposes

Bench: Shri Om Prakash Kant () & Shri Sandeep Singh Karhail ()

245D was passed not providing for the terms of settlement.” 10.3.1 Under the second proviso below to Explantaion-1 to section 153, further period has been provided to the Assessing Officer for completion of assessment as under: “Provided further that where a proceeding before the Settlement Commission abates under section 245HA, the period of limitation available under this

HEMENDRA RANCHOODDAS MERCHANT,MUMBAI vs. DY CIT CEN-CIRCLE 6(2). MUMBAI, MUMBAI

In the result, all the appeals of the assessee are allowed as partly for statistical purposes and appeal of the revenue except assessment year of 2005-06 are allowed for statistical purposes

Bench: Shri Om Prakash Kant () & Shri Sandeep Singh Karhail ()

245D was passed not providing for the terms of settlement.” 10.3.1 Under the second proviso below to Explantaion-1 to section 153, further period has been provided to the Assessing Officer for completion of assessment as under: “Provided further that where a proceeding before the Settlement Commission abates under section 245HA, the period of limitation available under this

DY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-6(2), MUMBAI vs. HEMENDRA MERCHANT, MUMBAI

In the result, all the appeals of the assessee are allowed as partly for statistical purposes and appeal of the revenue except assessment year of 2005-06 are allowed for statistical purposes

Bench: Shri Om Prakash Kant () & Shri Sandeep Singh Karhail ()

245D was passed not providing for the terms of settlement.” 10.3.1 Under the second proviso below to Explantaion-1 to section 153, further period has been provided to the Assessing Officer for completion of assessment as under: “Provided further that where a proceeding before the Settlement Commission abates under section 245HA, the period of limitation available under this

HEMENDRA RANCHOODDAS MERCHANT,MUMBAI vs. DY CIT CENTRAL CIRCLE-6(2), MUMBAI

In the result, all the appeals of the assessee are allowed as partly for statistical purposes and appeal of the revenue except assessment year of 2005-06 are allowed for statistical purposes

Bench: Shri Om Prakash Kant () & Shri Sandeep Singh Karhail ()

245D was passed not providing for the terms of settlement.” 10.3.1 Under the second proviso below to Explantaion-1 to section 153, further period has been provided to the Assessing Officer for completion of assessment as under: “Provided further that where a proceeding before the Settlement Commission abates under section 245HA, the period of limitation available under this

DY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-6(2), , MUMBAI vs. HEMENDRA MERCHANT , MUMBAI

In the result, all the appeals of the assessee are allowed as partly for statistical purposes and appeal of the revenue except assessment year of 2005-06 are allowed for statistical purposes

Bench: Shri Om Prakash Kant () & Shri Sandeep Singh Karhail ()

245D was passed not providing for the terms of settlement.” 10.3.1 Under the second proviso below to Explantaion-1 to section 153, further period has been provided to the Assessing Officer for completion of assessment as under: “Provided further that where a proceeding before the Settlement Commission abates under section 245HA, the period of limitation available under this

HEMENDRA RANCHOODDAS MERCHANT,MUMBAI vs. DY CIT, CENTRAL CIRCLE-6(2), MUMBAI

In the result, all the appeals of the assessee are allowed as partly for statistical purposes and appeal of the revenue except assessment year of 2005-06 are allowed for statistical purposes

Bench: Shri Om Prakash Kant () & Shri Sandeep Singh Karhail ()

245D was passed not providing for the terms of settlement.” 10.3.1 Under the second proviso below to Explantaion-1 to section 153, further period has been provided to the Assessing Officer for completion of assessment as under: “Provided further that where a proceeding before the Settlement Commission abates under section 245HA, the period of limitation available under this

DY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-6(2),, MUMBAI vs. HEMENDRA MERCHANT, MUMBAI

In the result, all the appeals of the assessee are allowed as partly for statistical purposes and appeal of the revenue except assessment year of 2005-06 are allowed for statistical purposes

Bench: Shri Om Prakash Kant () & Shri Sandeep Singh Karhail ()

245D was passed not providing for the terms of settlement.” 10.3.1 Under the second proviso below to Explantaion-1 to section 153, further period has been provided to the Assessing Officer for completion of assessment as under: “Provided further that where a proceeding before the Settlement Commission abates under section 245HA, the period of limitation available under this

HEMENDRA RANCHOODDAS MERCHANT ,MUMBAI vs. DY CIT-CENTRAL CIRCLE-6(2), MUMBAI.

In the result, all the appeals of the assessee are allowed as partly for statistical purposes and appeal of the revenue except assessment year of 2005-06 are allowed for statistical purposes

Bench: Shri Om Prakash Kant () & Shri Sandeep Singh Karhail ()

245D was passed not providing for the terms of settlement.” 10.3.1 Under the second proviso below to Explantaion-1 to section 153, further period has been provided to the Assessing Officer for completion of assessment as under: “Provided further that where a proceeding before the Settlement Commission abates under section 245HA, the period of limitation available under this

HEMENDRA RANCHOODDAS MERCHANT,MUMBAI vs. DY CIT-CENTRAL CIRCLE-6(2), MUMBAI

In the result, all the appeals of the assessee are allowed as partly for statistical purposes and appeal of the revenue except assessment year of 2005-06 are allowed for statistical purposes

Bench: Shri Om Prakash Kant () & Shri Sandeep Singh Karhail ()

245D was passed not providing for the terms of settlement.” 10.3.1 Under the second proviso below to Explantaion-1 to section 153, further period has been provided to the Assessing Officer for completion of assessment as under: “Provided further that where a proceeding before the Settlement Commission abates under section 245HA, the period of limitation available under this

DEPUTY COMMISSIONER OF INCOME TAX, CENTRE-CIRCLE-6(4), MUMBAI vs. SHRI RAJIV RATAN, NEW DELHI

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

Bench: Shri Aby T Varkey & Shri Amarjit Singhthe Dcit, Cc -6(4), Vs. Shri Rajiv Rattan Room No. 1925, 19 Th Floor, 60, 2 Nd Floor, Vasant Marg, Air India Building, Vasant Vihar, Nariman Point, New Delhi - 110057 Mumbai – 400021 स्थायी लेखा सं./जीआइआर सं./Pan/Gir No: Aespr3957D Appellant .. Respondent C.O. No. 126/Mum/2022 (A.Y.2011-12) Shri Rajiv Rattan Vs. The Dcit, Cc -6(4), 60, 2 Nd Floor, Vasant Marg, Room No. 1925, 19 Th Floor, Vasant Vihar, Air India Building, New Delhi - 110057 Nariman Point, Mumbai – 400021 स्थायी लेखा सं./जीआइआर सं./Pan/Gir No: Aespr3957D Appellant .. Respondent Appellant By : Smt. Riddhi Mishra Respondent By : Meet Shah

Section 245-1 of the Act the additions made in the assessment order are rightly been deleted by the Ld CIT(A) In this connection, Ld CIT(A) has referred the relevant portion of Settlement Commission's Order where a specific finding with reference to which the addition has been made. The relevant portion of the order

ASSTT COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-6(1), MUMBAI vs. HELIOS MERCANTILE LIMITED, MUMBAI

245D (4) of the Act passed its order disposing of the\nassessee's application and has not accepted the terms of settlement of\nthe assessee group. Therefore, the terms of settlement were not\naccepted.\n05.\nThe assessee filed its return of income on 2/11/2018 in response to\nnotice under section 153A (1) of the act issued on 18/6/2018