2019 (3) TMI 1467

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....itendra Jain I/by Mr. Atul Jasani for the Petitioners Mr. Sham Walve for the Respondents P.C.: 1. These petitions arise in common background. We may refer facts from Writ Petition (L) No. 810 of 2019.   2. The petitioner is a trust. The object of the trust is to acquire Non-Performing Assets ("NPAs" for short) by banks and recover dues from the defaulters. For the assessment year ....

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....19. Against this order, the petition has been filed. In other petitions, though figures are varying, the facts are common.   3. Learned counsel for the petitioner pointed out that the additions made by the Assessing Officer in the present set of assessment orders were made in hands of other similar trusts created under ARCIL. Such order of assessment was challenged before the CIT(A) and by....

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....mmissioner could be carried out. This Court in the case of UTI Mutual Fund Vs. ITO (2012) 345 ITR 71 (Bom) had observed that, "If the Assessing Officer has taken a view contrary to what has been held in the preceding previous years without there being a material change in facts or law, that is a relevant consideration in deciding the application for stay.". 5. In the present case, prima facie, ....