DCIT CC 7(4), MUMBAI vs. PODDAR RENAISSANCE REALITY PVT LTD (NOW KNOWN AS IMPERIAL RENAISSAICE RENIASANCE REALITY PVT. LTD), MUMBAI

In the result, the appeal of the In the result, the appeal of the Revenue is partly allowed

Bench: Shri Om Prakash Kant & Shri Sandeep Singh Karhaildcit, Cc-7(4), Mumbai V/S. Poddar Renaissance Reality Room No. 659, Aaykar बनाम Pvt. Ltd. (Now Known As Bhavan, M.K. Road, Imperial Renaissance Mumbai-400020 Renaissance Reality Pvt. Ltd.) 501/601, Aqua Marine, Carter Road, Mumbai-400050030 "थायी लेखा सं./जीआइआर सं./Pan/Gir No: Aagcp2657R Appellant/अपीलाथ" .. Respondent/"ितवादी

price of these two flats. Accordingly, from the said commission amount and rate, it Accordingly, from the said commission amount and rate, it was worked out that the was worked out that the total value of the flats so purchased was at Rs. 15,00,00,000/ total value of the flats so purchased

MACROTECH DEVELOPRS LTD,MUMBAI vs. DY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE 7(3), MUMBAI

The appeal is allowed

Bench: Shri Prashant Maharishi, Am & Shri Pavan Kumar Gadale, Jm

undisclosed income of Rs. 85,00,000/-. The tax was charged as prescribed in section 113 of the Act. Subsequently, a proviso was inserted u/s 113 by the Finance Act, 2002 w.e.f. 01 -06-2002 to provide for levy of surcharge at 10%. The A.O took the view that the said amendment was clarificatory in nature

MACROTECH DEVELOPERS LTD.(SUCCESSOR TO BELLISSIMO CROWN BUILDMART PVT LTD.,,MUMBAI vs. DCIT CENTRAL CIRCLE 7(3), MUMBAI

The appeal is allowed

Bench: Shri Prashant Maharishi, Am & Shri Pavan Kumar Gadale, Jm

undisclosed income of Rs. 85,00,000/-. The tax was charged as prescribed in section 113 of the Act. Subsequently, a proviso was inserted u/s 113 by the Finance Act, 2002 w.e.f. 01 -06-2002 to provide for levy of surcharge at 10%. The A.O took the view that the said amendment was clarificatory in nature

SWARAN NADHAN SALARIA,MUMBAI vs. DCIT, CENTRAL CIRCLE 1(2), MUMBAI

In the result all appeals of the assesses from AY 2014-15 to AY\n2020-21 are partly allowed

income represented by any addition made in conformity\nwith the arm's length price determined by the Transfer Pricing Officer, where the\nassessee had maintained information and documents as prescribed under\nsection 92D, declared the international transaction under Chapter X, and, disclosed all the material\nfacts relating to the transaction; and\n5. the amount of undisclosed

SWARAN NADHAN SALARIA,MUMBAI vs. DCIT, CENTRAL CIRCLE 1(2), MUMBAI

In the result all appeals of the assesses from AY 2014-15 to AY\n2020-21 are partly allowed

income represented by any addition\nmade in conformity with the arm's length price determined by the Transfer Pricing Officer, where the\nassessee had maintained information and documents as prescribed\nunder section 92D, declared the international transaction under\nChapter X, and, disclosed all the material facts relating to the transaction; and\n5. the amount of undisclosed

SHAILY PRINCE GOYAL,MUMBAI vs. INCOME TAX OFFICER-27(3)(1), NAVI MUMBAI

In the result, the appeal of the assessee Shri Yogesh Popatlal Thakkar in ITA No

undisclosed income and accordingly made addition under section 69 of the Income Tax Act, 1961. The Appeal filed by the Assessee was dismissed by CIT (A). 5 On further Appeal, the ITAT by the impugned order allowed the claim of the Assessee by recording that the purchase of shares during the year 1999-2000 and 2000-2001 were duly recorded

DCIT CC 3(4) CEN RG 3, MUMBAI vs. PATEL ENGINEERING LTD, MUMBAI

In the result, appeal filed by the assessee is dismissed

Bench: Shri Aby T. Varkey, Hon'Ble & Shri S. Rifaur Rahman, Hon’Ble

price and the book value of share, this ground is similar to Ground No. 4 of grounds of appeal raised by the revenue for the A.Y. 2006-07 and the decision taken therein shall apply mutatis-mutandis to the appeal for the A.Y. 2007-08. We order accordingly. 42. With regard to Ground No. 8 which is in respect

DCIT CC 3(4) CEN RG 3, MUMBAI vs. PATEL ENGINEERING LTD, MUMBAI

In the result, appeal filed by the assessee is dismissed

Bench: Shri Aby T. Varkey, Hon'Ble & Shri S. Rifaur Rahman, Hon’Ble

price and the book value of share, this ground is similar to Ground No. 4 of grounds of appeal raised by the revenue for the A.Y. 2006-07 and the decision taken therein shall apply mutatis-mutandis to the appeal for the A.Y. 2007-08. We order accordingly. 42. With regard to Ground No. 8 which is in respect

VRUSHALI SANJAY SHINDE,MUMBAI vs. DCIT, CC- 1, THANE

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

Bench: Shri Kuldip Singh, Hon'Ble & Shri S. Rifaur Rahman, Hon'Blevrushali Sanjay Shinde V. Dcit, Central Circle-1 282, Boundary Road B-101, Marigold, Prestige Residency G.B. Road, Kavesar, Thane- 400607 Civil Line, Meerut - 250001 Pan: Ajnps5211K (Appellant) (Respondent) Assessee Represented By : Shri Sankalp Malik Department Represented By : Shri Shanti Subramanian

Undisclosed Income 5,68,50,000/- 36 Y (to the extent 27.1-27.7 of Rs. 9,00,000) TOTAL ADDITIONS 28,29,44,370/- 12,95,43,07 27- 2. That a bare perusal of Para 21, 23, 24, 25, 26, 28, 30, 31, 32, 35 & 36 would show that all the additions (under dispute) are based solely

D G LAND DEVELOPERS PRIVATE LIMITED,MUMBAI vs. ASSISTANT COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE -4(4), MUMBAI, MUMBAI

In the result, the appeals of the assessee for assessment year

Bench: Shri Om Prakash Kant () & Shri Sunil Kumar Singh ()

price of some properties sold during the year, under section 43CA of the Act. under section 43CA of the Act. 6. The Ld. AO has erred in initiating penalty proceedings u/s 274 The Ld. AO has erred in initiating penalty proceedings u/s 274 The Ld. AO has erred in initiating penalty proceedings u/s 274 r.w.s 271AAB

D G LAND DEVELOPERS PRIVATE LIMITED,MUMBAI vs. ASSISTANT COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE -4(4), MUMBAI, MUMBAI

In the result, the appeals of the assessee for assessment year

Bench: Shri Om Prakash Kant () & Shri Sunil Kumar Singh ()

price of some properties sold during the year, under section 43CA of the Act. under section 43CA of the Act. 6. The Ld. AO has erred in initiating penalty proceedings u/s 274 The Ld. AO has erred in initiating penalty proceedings u/s 274 The Ld. AO has erred in initiating penalty proceedings u/s 274 r.w.s 271AAB

D G LAND DEVELOPERS PRIVATE LIMITED,MUMBAI vs. ASSISTANT COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE -4(4), MUMBAI, MUMBAI

In the result, the appeals of the assessee for assessment year

Bench: Shri Om Prakash Kant () & Shri Sunil Kumar Singh ()

price of some properties sold during the year, under section 43CA of the Act. under section 43CA of the Act. 6. The Ld. AO has erred in initiating penalty proceedings u/s 274 The Ld. AO has erred in initiating penalty proceedings u/s 274 The Ld. AO has erred in initiating penalty proceedings u/s 274 r.w.s 271AAB

GNP CONSULTANCY AND SOLUTIONS PVT LTD,NARIMAN POINT vs. DCIT CIRCLE-6(1), MUMBAI, NARIMAN POINT

Bench: Shri Prashant Maharishi, Am & Shri Rahul Chaudhary, Jm Gnp Consultancy & Dcit Solutions Private Limited Central Circle-6(1) Room No.1905, 19 Th Floor, Plot No.91, Shop No.1 Channel Classic Chs Sector Air India Building, Nariman Vs. Point 4 Kopar Khairne, Thane Mumbai-400 021 Mumbai-400 709 (Respondent) (Appellant) Pan No. Aadcg3716B Gnp Consultancy & Dcit Solutions Private Limited Central Circle-6(1) Plot No.91, Shop No.1 Room No.1905, 19 Th Floor, Channel Classic Chs Sector Air India Building, Nariman Vs. Point 4 Kopar Khairne, Thane Mumbai-400 021 Mumbai-400 709 (Appellant) (Respondent) Assessee By : Shri Nishit Gandhi, Advocate Revenue By : Shri Dr. Kishor Dhule, Cit Dr Date Of Hearing: 23.01.2024 Date Of Pronouncement : 20.03.2024

income at the rate of 70% of gross business receipts as additional income after claiming estimated expenses Page 69 of 108 ITA No. 3110 & 2547/Mum/2023 GNP Consultancy and Solutions Private Limited; A.Y. 21-22 deduction of 30% under section 132 (4) of the act. As per estimation made by the assessee it has presumed that all unaccounted expenditure incurred

SMT. USHA SATISH SALVI,MUMBAI vs. ASSISTANT COMMISSIONER OF INCOME TAX, MUMBAI

In the result, the appeals of the assessee for all the three years

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

undisclosed income for assessment years 2010 2010-11 to 2015-16. The assessee filed return of 16. The assessee filed return of income in respect of assessment years involved before us declaring income in respect of assessment years involved before us declaring income in respect of assessment years involved before us declaring total income as under: total income as under

SMT. USHA SATISH SALVI,MUMBAI vs. ASSISTANT COMMISSIONER OF INCOME TAX, MUMBAI

In the result, the appeals of the assessee for all the three years

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

undisclosed income for assessment years 2010 2010-11 to 2015-16. The assessee filed return of 16. The assessee filed return of income in respect of assessment years involved before us declaring income in respect of assessment years involved before us declaring income in respect of assessment years involved before us declaring total income as under: total income as under

THE DY. COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-5(1), MUMBAI vs. M/S SKYWAY INFRA PROJECTS PRIVATE LIMITED, MUMBAI

In the result, cross objections of the assessee are dismissed, cross objections of the assessee are dismissed, cross objections of the assessee are dismissed, whereas appeals of the revenue are par...

Bench: Shri Aby T Varkey () & Shri Om Prakash Kant () Assessment Year: 2013-14 & Assessment Year: 2014-15 & Assessment Year: 2015-16 & Assessment Year: 2016-17 & Assessment Year: 2017-18 & Assessment Year: 2018-19 & Assessment Year: 2019-20 & Assessment Year: 2020-21

undisclosed income of an Assessee has to be computed on the basis of undisclosed income of an Assessee has to be computed on the basis of undisclosed income of an Assessee has to be computed on the basis of evidence and material found during search. The statement recorded evidence and material found during search. The statement recorded evidence and material

DCIT, CENTRAL CIRCLE-3(2), MUMBAI vs. M/S VIRAJ PROFILES PRIVATE LIMITED, MUMBAI

In the result, all the appeals filed by the Revenue are dismissed

Bench: SHRI AMIT SHUKLA (Judicial Member), SHRI PRABHASH SHANKAR (Accountant Member)

Transfer Pricing Officer (TPO) noted that the assessee had not charged any commission for extending such guarantees. He was of the opinion that the transaction was an international transaction that required benchmarking, and accordingly determined the arm’s length commission at 1.5%. assessee’s income for the respective years. 6. In the first appellate stage, the learned CIT(A) examined

DCIT, CENTRAL CIRCLE-3(2), MUMBAI vs. VIRAJ PROFILES PRIVATE LIMITED, MUMBAI

In the result, all the appeals filed by the Revenue are dismissed

Bench: SHRI AMIT SHUKLA (Judicial Member), SHRI PRABHASH SHANKAR (Accountant Member)

Transfer Pricing Officer (TPO) noted that the assessee had not charged any commission for extending such guarantees. He was of the opinion that the transaction was an international transaction that required benchmarking, and accordingly determined the arm’s length commission at 1.5%. assessee’s income for the respective years. 6. In the first appellate stage, the learned CIT(A) examined