ITAT Pune Judgments — May 2026

SUNEETA RAMESH KORGAONKAR,MUMBAI vs ITO WARD-2, PANVEL, PANVEL

ITA 2752/PUN/2025[2020-21]Status: Disposed29 May 2026AY 2020-21Allowed

The Tribunal held that the reassessment proceedings were invalid as the AO relied on a tampered and 'dumb' document without clear evidence of cash payment by the assessee. Furthermore, the reasons for reopening were based on a chart prepared by an officer, not on specific seized documents, rendering the reopening bad in law.

MOHAMMAD SALIM AKBAR MIRZA,NASHIK vs ITO WARD-1 , MALEGAON

ITA 1889/PUN/2025[2017-18]Status: Disposed29 May 2026AY 2017-18Allowed

The Tribunal held that the Assessing Officer (AO) failed to discharge the onus of proving the source of cash deposits after the assessee provided affidavits. The AO made the addition without conducting further inquiries despite the affidavits.

INCOME TAX OFFICER EXEMPTIONS NANDED, NANDED vs ANUSAYA SHIKSHAN PRASARAK MANDAL PARBHANI, PARBHANI

ITA 405/PUN/2026[2020-21]Status: Disposed29 May 2026AY 2020-21Dismissed

The Tribunal held that the assessee is eligible for exemption under Section 10(23C)(iiiab) as it is an educational institution solely for education and not for profit. The Tribunal also found that the statutory requirements for this exemption were met, including the nature of the institution and its funding.

BIJI JOHNSON,PANVEL vs INCOME TAX OFFICER, PANVEL

ITA 3316/PUN/2025[2016-17]Status: Disposed29 May 2026AY 2016-17Remanded

The Tribunal found that the assessee had valid and sufficient reasons for the delay in filing the appeal before the CIT(A). Following the principles laid down by the Supreme Court, the Tribunal directed the CIT(A) to condone the delay and adjudicate the appeal afresh.

IMMANUEL MERCY MISSION ,NAVI MUMBAI vs THE CIT EXEMPTION , PUNE

ITA 1842/PUN/2026[2026-27]Status: Disposed29 May 2026AY 2026-27Remanded

The Tribunal held that substantial justice is more important than procedural delays and set aside the order of the CIT(E). The case was remanded to the CIT(E) for fresh adjudication, with an opportunity for the assessee to present relevant details.

YOG BUILDERS AND DEVELOPERS,NASHIK vs INCOME TAX OFFICER, WARD 1(1), NASHIK

ITA 646/PUN/2026[2015-16]Status: Disposed29 May 2026AY 2015-16Remanded

The Tribunal condoned the delay in filing the appeal due to reasonable cause and set aside the orders of the lower authorities. The matter was remanded to the Assessing Officer for fresh adjudication after providing the assessee with a reasonable opportunity of being heard.

IQBAL KHWAJA HUSSAIN SANGAM,PUNE vs ASSESSING OFFICER, PUNE

ITA 498/PUN/2026[2018-19]Status: Disposed29 May 2026AY 2018-19Remanded

The Tribunal found that the AO did not wait for the assessee's reply to the show cause notice and did not conduct independent inquiry. The Tribunal set aside the CIT(A)'s order to allow the assessee an opportunity to present all details.

UMESH KESHAV DESHPANDE,PUNE vs INCOME TAX OFFICER (IT) WARD 1, PUNE

ITA 652/PUN/2026[2014-15]Status: Disposed29 May 2026AY 2014-15Remanded

The Tribunal set aside the CIT(A)'s order, directing them to condone the delay and decide the appeal afresh on all grounds, including potential issues with the notice u/s 148 being time-barred. The assessee was permitted to raise additional grounds.

BIJI JOHNSON,PANVEL vs INCOME TAX OFFICER, PANVEL

ITA 3315/PUN/2025[2015-16]Status: Disposed29 May 2026AY 2015-16Remanded

The Tribunal found that the assessee had valid and sufficient reasons for the delay in filing the appeal before the CIT(A). Following the principles laid down by the Supreme Court, the Tribunal directed the CIT(A) to condone the delay and adjudicate the appeal afresh.

VIRAJ VILAS SHAH,NASHIK vs THE ASSISTANT COMMISSIONER OF INCOME TAX (ACIT), CENTRAL CIRCLE-1, NASHIK, NASHIK

ITA 3061/PUN/2025[2023-24]Status: Disposed27 May 2026AY 2023-24Partly Allowed

The Tribunal held that additions should not be made separately to entities within the group. Instead, a unified peak credit method should be applied to compute the income, with the entire peak addition to be made in the hands of the flagship company.

ACIT CC1 NASHIK, NASHIK vs VIRAJ VILAS SHAH, NASHIK

ITA 3295/PUN/2025[2017-18]Status: Disposed27 May 2026AY 2017-18Partly Allowed

The Tribunal held that additions should not be made separately to entities within the group. Instead, a unified peak credit method should be applied to compute the income, with the entire peak addition to be made in the hands of the flagship company.

ACIT CC1 NASHIK, NASHIK vs VILAS RASIKLAL SHAH, NASHIK

ITA 3286/PUN/2025[2017-18]Status: Disposed27 May 2026AY 2017-18Partly Allowed

The Tribunal held that while the additions were based on validly seized documents, the method of computation of income needed to be revised. Instead of separate additions, a unified peak credit method should be applied to avoid double taxation.

VIRAJ VILAS SHAH,NASHIK vs THE ASSISTANT COMMISSIONER OF INCOME TAX (ACIT), CENTRAL CIRCLE-1, NASHIK, NASHIK

ITA 3030/PUN/2025[2017-18]Status: Disposed27 May 2026AY 2017-18Partly Allowed

The Tribunal held that additions should not be made separately to entities within the group. Instead, a unified peak credit method should be applied to compute the income, with the entire peak addition to be made in the hands of the flagship company.

VIRAJ VILAS SHAH,NASHIK vs THE ASSISTANT COMMISSIONER OF INCOME TAX (ACIT), CENTRAL CIRCLE-1, NASHIK, NASHIK

ITA 3060/PUN/2025[2022-23]Status: Disposed27 May 2026AY 2022-23Partly Allowed

The Tribunal held that additions should not be made separately to entities within the group. Instead, a unified peak credit method should be applied to compute the income, with the entire peak addition to be made in the hands of the flagship company.

ACIT CC1 NASHIK, NASHIK vs VIRAJ ESTATES PRIVATE LIMITED, NASHIK

ITA 3291/PUN/2025[2020-21]Status: Disposed27 May 2026AY 2020-21Partly Allowed

The Tribunal held that additions sustained on a gross basis by the Assessing Officer and partly sustained by the CIT(A) should be deleted. Additions made under Section 69A were also directed to be deleted.

ACIT CC1 NASHIK, NASHIK vs VIRAJ ESTATES PRIVATE LIMITED, NASHIK

ITA 3292/PUN/2025[2022-23]Status: Disposed27 May 2026AY 2022-23Partly Allowed

The Tribunal held that additions sustained on a gross basis by the Assessing Officer and partly sustained by the CIT(A) should be deleted. Additions made under Section 69A were also directed to be deleted.

VIRAJ ESTATES PRIVATE LIMITED,NASHIK vs THE ASSISTANT COMMISSIONER OF INCOME TAX (ACIT), CENTRAL CIRCLE-1, NASHIK, NASHIK

ITA 3028/PUN/2025[2022-23]Status: Disposed27 May 2026AY 2022-23Partly Allowed

The Tribunal held that additions sustained on a gross basis by the Assessing Officer and partly sustained by the CIT(A) should be deleted. Additions made under Section 69A were also directed to be deleted.

ACIT,CC1,NASHIK, NASHIK vs RAJENDRA RASIKLAL SHAH, NASHIK

ITA 3301/PUN/2025[2022-23]Status: Disposed27 May 2026AY 2022-23Partly Allowed

The Tribunal held that while the premises might not be owned by the assessee, their possession and control by the group were accepted. However, it directed that additions should be made in the hands of the flagship company (M/s. Viraj Estates Pvt Ltd) using the unified peak credit method, not separately for each entity or individual.

ACIT,CC1,NASHIK, NASHIK vs RAJENDRA RASIKLAL SHAH, NASHIK

ITA 3300/PUN/2025[2020-21]Status: Disposed27 May 2026AY 2020-21Partly Allowed

The Tribunal held that while the premises might not be owned by the assessee, their possession and control by the group were accepted. However, it directed that additions should be made in the hands of the flagship company (M/s. Viraj Estates Pvt Ltd) using the unified peak credit method, not separately for each entity or individual.

VIRAJ ESTATES PRIVATE LIMITED,NASHIK vs ACIT, CENTRAL CIRCLE-1, NASHIK, NASHIK

ITA 3001/PUN/2025[2014-15]Status: Disposed27 May 2026AY 2014-15Partly Allowed

The Tribunal held that additions sustained on a gross basis by the Assessing Officer and partly sustained by the CIT(A) should be deleted. Additions made under Section 69A were also directed to be deleted.

VIRAJ ESTATES PRIVATE LIMITED,NASHIK vs THE ASSISTANT COMMISSIONER OF INCOME TAX (ACIT), CENTRAL CIRCLE-1, NASHIK

ITA 3015/PUN/2025[2020-21]Status: Disposed27 May 2026AY 2020-21Partly Allowed

The Tribunal held that additions sustained on a gross basis by the Assessing Officer and partly sustained by the CIT(A) should be deleted. Additions made under Section 69A were also directed to be deleted.

VIRAJ ESTATES PRIVATE LIMITED,NASHIK vs THE ASSISTANT COMMISSIONER OF INCOME TAX (ACIT), CENTRAL CIRCLE-1, NASHIK, NASHIK

ITA 3027/PUN/2025[2023-24]Status: Disposed27 May 2026AY 2023-24Partly Allowed

The Tribunal held that additions sustained on a gross basis by the Assessing Officer and partly sustained by the CIT(A) should be deleted. Additions made under Section 69A were also directed to be deleted.

ACIT CC1 NASHIK, NASHIK vs VIRAJ VILAS SHAH, NASHIK

ITA 3294/PUN/2025[2014-15]Status: Disposed27 May 2026AY 2014-15Partly Allowed

The Tribunal held that additions should not be made separately to entities within the group. Instead, a unified peak credit method should be applied to compute the income, with the entire peak addition to be made in the hands of the flagship company.

ACIT CC1 NASHIK, NASHIK vs VIRAJ ESTATES PRIVATE LIMITED, NASHIK

ITA 3293/PUN/2025[2023-24]Status: Disposed27 May 2026AY 2023-24Partly Allowed

The Tribunal held that additions sustained on a gross basis by the Assessing Officer and partly sustained by the CIT(A) should be deleted. Additions made under Section 69A were also directed to be deleted.

VILAS RASIKLAL SHAH,NASHIK vs THE ASSISTANT COMMISSIONER OF INCOME TAX (ACIT), CENTRAL CIRCLE-1, NASHIK, NASHIK

ITA 3033/PUN/2025[2017-18]Status: Disposed27 May 2026AY 2017-18Partly Allowed

The Tribunal held that the additions made on the basis of seized documents were valid, as possession and control of the premises were with the assessee's group. However, it directed that additions should be computed using a unified peak credit method, consolidating all entries from seized cash books.

ACIT CC1 NASHIK, NASHIK vs VILAS RASIKLAL SHAH, NASHIK

ITA 3287/PUN/2025[2022-23]Status: Disposed27 May 2026AY 2022-23Partly Allowed

The Tribunal held that while the additions were based on validly seized documents, the method of computation of income needed to be revised. Instead of separate additions, a unified peak credit method should be applied to avoid double taxation.

VIRAJ VILAS SHAH,NASHIK vs THE ASSISTANT COMMISSIONER OF INCOME TAX (ACIT), CENTRAL CIRCLE-1, NASHIK, NASHIK

ITA 3029/PUN/2025[2014-15]Status: Disposed27 May 2026AY 2014-15Partly Allowed

The Tribunal held that additions should not be made separately to entities within the group. Instead, a unified peak credit method should be applied to compute the income, with the entire peak addition to be made in the hands of the flagship company.

SHREEM ELECTRIC LIMITED,KOLHAPUR vs ACIT (CENTRAL CIRCLE), KOLHAPUR

ITA 2794/PUN/2025[2016-17]Status: Disposed27 May 2026AY 2016-17Allowed

The Tribunal set aside the CIT(A)'s order and restored the appeal to the CIT(A)'s file. The delay was condoned, and the CIT(A) was directed to decide the appeal on its merits after providing a reasonable opportunity to the assessee.

SHRI ARYA CHANAKYANAGARI SAHKARI PATSANSTHA MARYADIT,ICHALKARANJI vs INCOME TAX OFFICER, ICHALKARANJI

ITA 2528/PUN/2025[2022-23]Status: Disposed27 May 2026AY 2022-23Allowed

The tribunal held that disallowances related to business activity against which Chapter VI-A deductions are claimed result in enhanced profits, and deductions are admissible on these enhanced profits. Following CBDT Circular No. 37/2016, the tribunal directed the AO to allow the deduction.

VIRAJ VILAS SHAH,NASHIK vs THE ASSISTANT COMMISSIONER OF INCOME TAX (ACIT), CENTRAL CIRCLE-1, NASHIK, NASHIK

ITA 3031/PUN/2025[2020-21]Status: Disposed27 May 2026AY 2020-21Partly Allowed

The Tribunal held that additions should not be made separately to entities within the group. Instead, a unified peak credit method should be applied to compute the income, with the entire peak addition to be made in the hands of the flagship company.

ACIT CC1 NASHIK, NASHIK vs VIRAJ ESTATES PRIVATE LIMITED, NASHIK

ITA 3289/PUN/2025[2014-15]Status: Disposed27 May 2026AY 2014-15Partly Allowed

The Tribunal held that additions sustained on a gross basis by the Assessing Officer and partly sustained by the CIT(A) should be deleted. Additions made under Section 69A were also directed to be deleted.

RAJENDRA RASIKLAL SHAH,NASHIK vs THE ASSISTANT COMMISSIONER OF INCOME TAX (ACIT), CENTRAL CIRCLE-1, NASHIK, NASHIK

ITA 3014/PUN/2025[2017-18]Status: Disposed27 May 2026AY 2017-18Partly Allowed

The Tribunal held that while the premises might not be owned by the assessee, their possession and control by the group were accepted. However, it directed that additions should be made in the hands of the flagship company (M/s. Viraj Estates Pvt Ltd) using the unified peak credit method, not separately for each entity or individual.

VILAS RASIKLAL SHAH,NASHIK vs THE ASSISTANT COMMISSIONER OF INCOME TAX (ACIT), CENTRAL CIRCLE-1, NASHIK, NASHIK

ITA 3034/PUN/2025[2020-21]Status: Disposed27 May 2026AY 2020-21Partly Allowed

The Tribunal held that while the additions were based on validly seized documents, the method of computation of income needed to be revised. Instead of separate additions, a unified peak credit method should be applied to avoid double taxation.

ACIT CC1 NASHIK, NASHIK vs VIRAJ VILAS SHAH, NASHIK

ITA 3298/PUN/2025[2023-24]Status: Disposed27 May 2026AY 2023-24Partly Allowed

The Tribunal held that additions should not be made separately to entities within the group. Instead, a unified peak credit method should be applied to compute the income, with the entire peak addition to be made in the hands of the flagship company.

RAJENDRA RASIKLAL SHAH,NASHIK vs THE ASSISTANT COMMISSIONER OF INCOME TAX (ACIT), CENTRAL CIRCLE-1, NASHIK, NASHIK

ITA 3013/PUN/2025[2014-15]Status: Disposed27 May 2026AY 2014-15Partly Allowed

The Tribunal held that while the premises might not be owned by the assessee, their possession and control by the group were accepted. However, it directed that additions should be made in the hands of the flagship company (M/s. Viraj Estates Pvt Ltd) using the unified peak credit method, not separately for each entity or individual.

RAJENDRA RASIKLAL SHAH,NASHIK vs THE ASSISTANT COMMISSIONER OF INCOME TAX (ACIT), CENTRAL CIRCLE-1, NASHIK, NASHIK

ITA 3056/PUN/2025[2023-24]Status: Disposed27 May 2026AY 2023-24Partly Allowed

The Tribunal held that while the premises might not be owned by the assessee, their possession and control by the group were accepted. However, it directed that additions should be made in the hands of the flagship company (M/s. Viraj Estates Pvt Ltd) using the unified peak credit method, not separately for each entity or individual.

ACIT CC1 NASHIK, NASHIK vs VILAS RASIKLAL SHAH, NASHIK

ITA 3288/PUN/2025[2023-24]Status: Disposed27 May 2026AY 2023-24Partly Allowed

The Tribunal held that while the additions were based on validly seized documents, the method of computation of income needed to be revised. Instead of separate additions, a unified peak credit method should be applied to avoid double taxation.

ACIT CC1 NASHIK, NASHIK vs VIRAJ REALITY PVT.LTD., NASHIK

ITA 3284/PUN/2025[2020-21]Status: Disposed27 May 2026AY 2020-21Partly Allowed

The Tribunal held that the key persons of the assessee group had accepted possession and control of the premises and the seized documents during the search. However, for subsequent assessment years, it directed that additions should be made in the hands of the flagship company by applying a unified peak credit method to avoid double taxation.

ACIT CC1 NASHIK, NASHIK vs VIRAJ VILAS SHAH, NASHIK

ITA 3297/PUN/2025[2022-23]Status: Disposed27 May 2026AY 2022-23Partly Allowed

The Tribunal held that additions should not be made separately to entities within the group. Instead, a unified peak credit method should be applied to compute the income, with the entire peak addition to be made in the hands of the flagship company.

VILAS RASIKLAL SHAH,NASHIK vs THE ASSISTANT COMMISSIONER OF INCOME TAX (ACIT), CENTRAL CIRCLE-1, NASHIK, NASHIK

ITA 3059/PUN/2025[2022-23]Status: Disposed27 May 2026AY 2022-23Partly Allowed

The Tribunal held that while the additions were based on validly seized documents, the method of computation of income needed to be revised. Instead of separate additions, a unified peak credit method should be applied to avoid double taxation.

DY. COMMISSIONER OF INCOME TAX, CIRCLE-1(1), PUNE, PUNE vs BHATE & RAJE CONSTRUCTION CO PRIVATE LIMITED , PUNE

ITA 377/PUN/2026[2014-15]Status: Disposed27 May 2026AY 2014-15Partly Allowed

The Tribunal held that the penalty under Section 271AA was not maintainable as the AO did not specify which documents were not maintained by the assessee and the TPO had already accepted the transactions as Arm's Length. Similarly, the penalty under Section 271G was also held to be not maintainable, with the Tribunal finding no merit in the Revenue's appeal against the deletion of this penalty by the CIT(A).

ACIT CC1 NASHIK, NASHIK vs KARAN RAJENDRA SHAH, NASHIK

ITA 3305/PUN/2025[2023-24]Status: Disposed27 May 2026AY 2023-24Partly Allowed

The Tribunal held that the seized documents, even if found from third-party premises, were admissible as evidence because the assessee and group members accepted possession and control of these premises and deciphered the seized documents. However, additions based on these documents were to be made in the hands of the flagship company (Viraj Estates Pvt Ltd) using the peak credit method to avoid double taxation.

VILAS RASIKLAL SHAH,NASHIK vs THE ASSISTANT COMMISSIONER OF INCOME TAX (ACIT), CENTRAL CIRCLE-1, NASHIK, NASHIK

ITA 3058/PUN/2025[2023-24]Status: Disposed27 May 2026AY 2023-24Partly Allowed

The Tribunal held that while the additions were based on validly seized documents, the method of computation of income needed to be revised. Instead of separate additions, a unified peak credit method should be applied to avoid double taxation.

VIRAJ ESTATES PRIVATE LIMITED,NASHIK vs THE ASSISTANT COMMISSIONER OF INCOME TAX (ACIT), CENTRAL CIRCLE-1, NASHIK, NASHIK

ITA 3002/PUN/2025[2017-18]Status: Disposed27 May 2026AY 2017-18Partly Allowed

The Tribunal held that additions sustained on a gross basis by the Assessing Officer and partly sustained by the CIT(A) should be deleted. Additions made under Section 69A were also directed to be deleted.

ACIT CC1, NASHIK, NASHIK vs VILAS RASIKLAL SHAH, NASHIK

ITA 3285/PUN/2025[2014-15]Status: Disposed27 May 2026AY 2014-15Partly Allowed

The Tribunal held that while the additions were based on validly seized documents, the method of computation of income needed to be revised. Instead of separate additions, a unified peak credit method should be applied to avoid double taxation.

VILAS RASIKLAL SHAH,NASHIK vs THE ASSISTANT COMMISSIONER OF INCOME TAX (ACIT), CENTRAL CIRCLE-1, NASHIK, NASHIK

ITA 3032/PUN/2025[2014-15]Status: Disposed27 May 2026AY 2014-15Partly Allowed

The Tribunal held that while the additions were based on validly seized documents, the method of computation of income needed to be revised. Instead of separate additions, a unified peak credit method should be applied to avoid double taxation.

ACIT CC1 NASHIK, NASHIK vs VIRAJ VILAS SHAH, NASHIK

ITA 3296/PUN/2025[2020-21]Status: Disposed27 May 2026AY 2020-21Partly Allowed

The Tribunal held that additions should not be made separately to entities within the group. Instead, a unified peak credit method should be applied to compute the income, with the entire peak addition to be made in the hands of the flagship company.

VIKAS CHANDRAKANT PATIL,NASIK vs ACIT CIRCLE-1, NASHIK, NASHIK

ITA 1765/PUN/2025[2018-19]Status: Disposed27 May 2026AY 2018-19Remanded

The Tribunal noted that the assessee, a salaried individual, was likely not properly advised in framing the grounds of appeal. Considering substantial justice over procedural technicalities, the Tribunal set aside the CIT(A)'s order and remanded the case for de-novo adjudication.

HEMLATA KAMAL BHATIA,PUNE vs DCIT CIRCLE-7 , PUNE

ITA 2092/PUN/2025[2017-18]Status: Disposed27 May 2026AY 2017-18Allowed

The Tribunal held that issuing a notice under Section 143(2) is mandatory when an assessee's request to treat an earlier return as a response to a Section 148 notice is accepted. Failure to do so renders the reassessment order bad in law.

RAJENDRA RASIKLAL SHAH,NASHIK vs THE ASSISTANT COMMISSIONER OF INCOME TAX (ACIT), CENTRAL CIRCLE-1, NASHIK, NASHIK

ITA 3057/PUN/2025[2022-23]Status: Disposed27 May 2026AY 2022-23Partly Allowed

The Tribunal held that while the premises might not be owned by the assessee, their possession and control by the group were accepted. However, it directed that additions should be made in the hands of the flagship company (M/s. Viraj Estates Pvt Ltd) using the unified peak credit method, not separately for each entity or individual.