ASHOK NARAYAN SATAV,PUNE vs. INCOME TAX OFFICER. WARD 12(3), PUNE, PUNE

ITA 3355/PUN/2025Status: DisposedITAT Pune16 February 2026AY 2017-18Bench: DR.DIPAK P. RIPOTE (Accountant Member), SHRI VINAY BHAMORE (Judicial Member)6 pages
AI SummaryAllowed for statistical purpose

What did the Tribunal hold?

The Tribunal set aside the CIT(A)'s order and remanded the case for de novo adjudication. The CIT(A) was directed to obtain copies of the notices under sections 148A(b) and 148A(d) from the AO, provide the assessee with an opportunity, and decide all grounds of appeal on merits, including the maintainability of the reassessment notice issued after three years for an amount less than Rs. 50 lakhs.

What were the facts?

The assessee filed an ITR for A.Y. 2017-18. The Assessing Officer (AO) received information about an Rs. 8 lakh financial transaction and initiated reassessment proceedings by issuing notices under sections 148A(b) and 148. The assessee failed to comply, leading the AO to make an addition of Rs. 8 lakhs under section 69C as unexplained expenditure, passing an ex-parte assessment order under section 147 r.w.s 144. The CIT(A) dismissed the assessee's appeal without considering its merits, citing non-compliance with notices.

What were the issues?

1. Whether the addition of Rs. 8 lakhs under section 69C as unexplained expenditure was justified. 2. Whether the reassessment proceedings initiated under section 147/148 were maintainable, particularly regarding the time limit for issuing notice when income escaping assessment is less than Rs. 50 lakhs. 3. Whether the CIT(A) erred in dismissing the appeal without considering merits or following principles of natural justice.

Which sections of the Income-tax Act were involved?

Section 250,Section 147,Section 144,Section 139,Section 148A(b),Section 148A(d),Section 148,Section 69C,Section 115BBE,Section 251(1)(a)

AI-generated summary — verify with the full judgment below

Cases cited in this judgment(1)Show list

Detected automatically from the text. Citations are also linked where they appear in the judgment. The count shows how many other judgments on BharatTax rely on the same authority.

Income Tax Appellate Tribunal, PUNE BENCHES “SMC” :: PUNE

Before: DR.DIPAK P. RIPOTE & SHRI VINAY BHAMORE

For Appellant: Shri Deepak S Sasar
For Respondent: Shri Sadananda – JCIT(DR)
Hearing: 12/12/2026Pronounced: 16/02/2026

PER DR. DIPAK P. RIPOTE, AM: This is an appeal filed by the Assessee against the order of ld.Commissioner of Income Tax(Appeal)[NFAC], passed under section 250 of the Income Tax Act, 1961 for the A.Y.2017-18 dated 29.10.2025 emanating from the Assessment Order passed under section 147 r.w.s 144 of the I.T.Act, dated 10.05.2023. The Assessee has raised the following grounds of appeal :

“1. The Hon. Commissioner of Income Tax (Appeals), National Faceless Appeal Centre has wrongly confirmed the Addition made by ITA No.3355/PUN/2025 [A] the Ld. Assessing Officer amounting to Rs.8,00,000/- u/s. 69C a

The order continues below.

Read the full judgment

A free account opens 10 full judgments a month. Re-reading one you have already opened does not count again.

Create a free accountSign in

See plans and prices

The summary, the parties, the sections and the citations above are open to everyone and always will be. Only the text of the order and the PDF are metered.

More judgments on Section 147

All 49,210 judgments and leading authorities on Section 147 →

Recent GST High Court judgments

Search GST case law →