Rajesh Kourani v. Union of India

DINESH DATTATRAY SHINDE,RATNAGIRI vs. INCOME-TAX OFFICER,CIRCLE-1, KOLHAPUR

In the result, appeal of the Assessee is allowed

Bench: Dr.Dipak P. Ripote & Shri Vinay Bhamoreआयकर अपऩल सं. / Ita Nos.2285, 2286 & 2287/Pun/2025 निर्धारण वषा / Assessment Year: 2014-15(Q3, Q2 & Q4) Dinesh Dattatray Shinde, Vs The Income Tax Officer, 1756, Jutica, Teli Ali, Circle-1, Kolhapur. Ratnagiri – 415612. Pan: Klpdo1360C Appellant/ Assessee Respondent / Revenue Assessee By Shri Anup Bipin Shaha(Virtual) & Shri Rohit Rajeev Shah Revenue By Smt Neha Thakkar (Virtual) Date Of Hearing 21/01/2026 Date Of Pronouncement 23/01/2026 आदेश/ Order Per Bench : These Threeappeals Filed By The Assessee Against The Separate Orders Of Ld.Commissioner Of Income Tax(Appeal)[Nfac], Passed Under Section 250 Of The Income Tax Act, 1961 For A.Y.2014-15- Q3, Q2 & Q4 Respectively, All Dated 28.07.2025. For The Sake Of Convenience, These Three Appeals Were Heard Together & Are Being Disposed Of By This Common Order. We Treat Appeal For A.Y.2014-

…आयकर अपीलीय अधिकरण ”ए” न्यायपीठ पुणेमें। IN THE INCOME TAX APPELLATE TRIBUNAL PUNE BENCHES “A” :: PUNE BEFORE DR.DIPAK P. RIPOTE, ACCOUNTANT MEMBER AND SHRI VINAY BHAMORE, JUDICIAL MEMBER आयकर अपऩल सं. / ITA Nos.2285, 2286 & 2287/PUN/2025 निर्धारण वषा / Assessment Year: 2014-15(Q3, Q2 & Q4) Dinesh Dattatray Shinde, Vs The Income Tax Officer, 1756, Jutica, Teli Ali, Circle-1, Kolhapur. Ratnagiri – 415612. PAN: KLPDO1360C Appellant/ Assessee Respondent / Revenue Assessee by Shri Anup Bipin Shaha(Virtual) & Shri Rohit Rajeev Shah Revenue by Smt Neha Thakkar (Virtual) Date of hearing 21/01/2026 Date of pronouncement…

DINESH DATTATRAY SHINDE,RATNAGIRI vs. INCOME-TAX OFFICER, CIRCLE-1, KOLHAUR

In the result, appeal of the Assessee is allowed

Bench: Dr.Dipak P. Ripote & Shri Vinay Bhamoreआयकर अपऩल सं. / Ita Nos.2285, 2286 & 2287/Pun/2025 निर्धारण वषा / Assessment Year: 2014-15(Q3, Q2 & Q4) Dinesh Dattatray Shinde, Vs The Income Tax Officer, 1756, Jutica, Teli Ali, Circle-1, Kolhapur. Ratnagiri – 415612. Pan: Klpdo1360C Appellant/ Assessee Respondent / Revenue Assessee By Shri Anup Bipin Shaha(Virtual) & Shri Rohit Rajeev Shah Revenue By Smt Neha Thakkar (Virtual) Date Of Hearing 21/01/2026 Date Of Pronouncement 23/01/2026 आदेश/ Order Per Bench : These Threeappeals Filed By The Assessee Against The Separate Orders Of Ld.Commissioner Of Income Tax(Appeal)[Nfac], Passed Under Section 250 Of The Income Tax Act, 1961 For A.Y.2014-15- Q3, Q2 & Q4 Respectively, All Dated 28.07.2025. For The Sake Of Convenience, These Three Appeals Were Heard Together & Are Being Disposed Of By This Common Order. We Treat Appeal For A.Y.2014-

…आयकर अपीलीय अधिकरण ”ए” न्यायपीठ पुणेमें। IN THE INCOME TAX APPELLATE TRIBUNAL PUNE BENCHES “A” :: PUNE BEFORE DR.DIPAK P. RIPOTE, ACCOUNTANT MEMBER AND SHRI VINAY BHAMORE, JUDICIAL MEMBER आयकर अपऩल सं. / ITA Nos.2285, 2286 & 2287/PUN/2025 निर्धारण वषा / Assessment Year: 2014-15(Q3, Q2 & Q4) Dinesh Dattatray Shinde, Vs The Income Tax Officer, 1756, Jutica, Teli Ali, Circle-1, Kolhapur. Ratnagiri – 415612. PAN: KLPDO1360C Appellant/ Assessee Respondent / Revenue Assessee by Shri Anup Bipin Shaha(Virtual) & Shri Rohit Rajeev Shah Revenue by Smt Neha Thakkar (Virtual) Date of hearing 21/01/2026 Date of pronouncement…

DINESH DATTATRAY SHINDE,RATNAGIRI vs. INCOME-TAX OFFICER, CIRCLE -1, KOLHAPUR

In the result, appeal of the Assessee is allowed

Bench: Dr.Dipak P. Ripote & Shri Vinay Bhamoreआयकर अपऩल सं. / Ita Nos.2285, 2286 & 2287/Pun/2025 निर्धारण वषा / Assessment Year: 2014-15(Q3, Q2 & Q4) Dinesh Dattatray Shinde, Vs The Income Tax Officer, 1756, Jutica, Teli Ali, Circle-1, Kolhapur. Ratnagiri – 415612. Pan: Klpdo1360C Appellant/ Assessee Respondent / Revenue Assessee By Shri Anup Bipin Shaha(Virtual) & Shri Rohit Rajeev Shah Revenue By Smt Neha Thakkar (Virtual) Date Of Hearing 21/01/2026 Date Of Pronouncement 23/01/2026 आदेश/ Order Per Bench : These Threeappeals Filed By The Assessee Against The Separate Orders Of Ld.Commissioner Of Income Tax(Appeal)[Nfac], Passed Under Section 250 Of The Income Tax Act, 1961 For A.Y.2014-15- Q3, Q2 & Q4 Respectively, All Dated 28.07.2025. For The Sake Of Convenience, These Three Appeals Were Heard Together & Are Being Disposed Of By This Common Order. We Treat Appeal For A.Y.2014-

…आयकर अपीलीय अधिकरण ”ए” न्यायपीठ पुणेमें। IN THE INCOME TAX APPELLATE TRIBUNAL PUNE BENCHES “A” :: PUNE BEFORE DR.DIPAK P. RIPOTE, ACCOUNTANT MEMBER AND SHRI VINAY BHAMORE, JUDICIAL MEMBER आयकर अपऩल सं. / ITA Nos.2285, 2286 & 2287/PUN/2025 निर्धारण वषा / Assessment Year: 2014-15(Q3, Q2 & Q4) Dinesh Dattatray Shinde, Vs The Income Tax Officer, 1756, Jutica, Teli Ali, Circle-1, Kolhapur. Ratnagiri – 415612. PAN: KLPDO1360C Appellant/ Assessee Respondent / Revenue Assessee by Shri Anup Bipin Shaha(Virtual) & Shri Rohit Rajeev Shah Revenue by Smt Neha Thakkar (Virtual) Date of hearing 21/01/2026 Date of pronouncement…

CHATE TUTORIALS PVT LTD,AURANGABAD vs. ASSISTANT COMMISSIONER OF INCOME TAX, TDS CIRCLE, NASHIK, NASHIK

In the result, both the bunch of appeals filed by the respective assessee’s in ITA Nos

Bench: Dr.Manish Borad & Shri Vinay Bhamoreआयकर अपील सं. / Ita Nos.476 To 480/Pun/2024 Chate Tutorials Pvt. Ltd., Vs. Acit,Tds Circle, Chate House, Plot No.4, Nashik Near N-2 Cricket Stadium, Cidco, Aurangabad – 431 003 Maharashtra Tan : Nskco1565E Appellant Respondent

…ich is to delivered or cause to delivered on or after 1- 7-2012. [Para 7.1] That, with the above overview of section 234 E and on considering both the above views, it appears that the opinion expressed by the Gujarat High Court in Rajesh Kourani v. UOI [2017] 297 CTR 502 that section 234E by itself creates a liability and the liability to pay the late fee is not dependent on section 200A(1)(c) which only prescribes the recovery mechanism reflects the true intent and purpose of section 234E. Section 234E which provides for late fee is the substantive provision and the levy is not dependent on section 200A(1)(c) wh…

CHATE TUTORIALS PVT. LTD. ,AURANGABAD vs. LD. ASSISTANT COMMISSIONER OF INCOME TAX, TDS CIRCLE, NASHIK , NASHIK

In the result, both the bunch of appeals filed by the\nrespective assessee's in ITA Nos

…is to delivered or cause to delivered on or after 1-\n7-2012. [Para 7.1]\nThat, with the above overview of section 234 E and on considering both\nthe above views, it appears that the opinion expressed by the Gujarat\nHigh Court in Rajesh Kourani v. UOI [2017] 297 CTR 502 that section\n234E by itself creates a liability and the liability to pay the late fee is\nnot dependent on section 200A(1)(c) which only prescribes the recovery\nmechanism reflects the true intent and purpose of section 234E.\nSection 234E which provides for late fee is the substantive provision\nand the levy is not dependent on section 200A(1)(…

CHATE TUTORIALS PVT. LTD. ,AURANGABAD vs. LD. ASSISTANT COMMISSIONER OF INCOME TAX, TDS CIRCLE, NASHIK , NASHIK

In the result, both the bunch of appeals filed by the\nrespective assessee's in ITA Nos

…is to delivered or cause to delivered on or after 1-\n7-2012. [Para 7.1]\nThat, with the above overview of section 234 E and on considering both\nthe above views, it appears that the opinion expressed by the Gujarat\nHigh Court in Rajesh Kourani v. UOI [2017] 297 CTR 502 that section\n234E by itself creates a liability and the liability to pay the late fee is\nnot dependent on section 200A(1)(c) which only prescribes the recovery\nmechanism reflects the true intent and purpose of section 234E.\nSection 234E which provides for late fee is the substantive provision\nand the levy is not dependent on section 200A(1)(…

CHATE TUTORIALS PVT. LTD. AURANGABAD , AURANGABAD vs. LD. ASSISTANT COMMISSIONER OF INCOME TAX, TDS CIRCLE, NASHIK , NASHIK

In the result, both the bunch of appeals filed by the\nrespective assessee's in ITA Nos

…is to delivered or cause to delivered on or after 1-\n7-2012. [Para 7.1]\nThat, with the above overview of section 234 E and on considering both\nthe above views, it appears that the opinion expressed by the Gujarat\nHigh Court in Rajesh Kourani v. UOI [2017] 297 CTR 502 that section\n234E by itself creates a liability and the liability to pay the late fee is\nnot dependent on section 200A(1)(c) which only prescribes the recovery\nmechanism reflects the true intent and purpose of section 234E.\nSection 234E which provides for late fee is the substantive provision\nand the levy is not dependent on section 200A(1)(…

CHATE TUTORIALS PVT. LTD.,AURANGABAD vs. LD. ASSISTANT COMMISSIONER OF INCOME TAX, TDS CIRCLE, NASHIK, NASHIK

In the result, both the bunch of appeals filed by the respective assessee’s in ITA Nos

Bench: Dr.Manish Borad & Shri Vinay Bhamoreआयकर अपील सं. / Ita Nos.476 To 480/Pun/2024 Chate Tutorials Pvt. Ltd., Vs. Acit,Tds Circle, Chate House, Plot No.4, Nashik Near N-2 Cricket Stadium, Cidco, Aurangabad – 431 003 Maharashtra Tan : Nskco1565E Appellant Respondent

…ich is to delivered or cause to delivered on or after 1- 7-2012. [Para 7.1] That, with the above overview of section 234 E and on considering both the above views, it appears that the opinion expressed by the Gujarat High Court in Rajesh Kourani v. UOI [2017] 297 CTR 502 that section 234E by itself creates a liability and the liability to pay the late fee is not dependent on section 200A(1)(c) which only prescribes the recovery mechanism reflects the true intent and purpose of section 234E. Section 234E which provides for late fee is the substantive provision and the levy is not dependent on section 200A(1)(c) wh…

SHREE BHASKARACHARYA PRATISHTHAN,CHH SAMBHAJINAGAR vs. LD. DEPUTY COMMISSIONER OF INCOME TAX, CPC-TDS

In the result, both the bunch of appeals filed by the\nrespective assessee's in ITA Nos

…is to delivered or cause to delivered on or after 1-\n7-2012. [Para 7.1]\nThat, with the above overview of section 234 E and on considering both\nthe above views, it appears that the opinion expressed by the Gujarat\nHigh Court in Rajesh Kourani v. UOI [2017] 297 CTR 502 that section\n234E by itself creates a liability and the liability to pay the late fee is\nnot dependent on section 200A(1)(c) which only prescribes the recovery\nmechanism reflects the true intent and purpose of section 234E.\nSection 234E which provides for late fee is the substantive provision\nand the levy is not dependent on section 200A(1)(…

SHRI BHASKARACHARYA PRATISHTHAN,CHH SAMBHAJINAGAR vs. LD. DEPUTY COMMISSIONER OF INCOME TAX, CPC-TDS, CPC TDS

In the result, both the bunch of appeals filed by the\nrespective assessee's in ITA Nos

…is to delivered or cause to delivered on or after 1-\n7-2012. [Para 7.1]\nThat, with the above overview of section 234 E and on considering both\nthe above views, it appears that the opinion expressed by the Gujarat\nHigh Court in Rajesh Kourani v. UOI [2017] 297 CTR 502 that section\n234E by itself creates a liability and the liability to pay the late fee is\nnot dependent on section 200A(1)(c) which only prescribes the recovery\nmechanism reflects the true intent and purpose of section 234E.\nSection 234E which provides for late fee is the substantive provision\nand the levy is not dependent on section 200A(1)(…

SHREE BHASKARACHARYA PRATISHTHAN,CHH SAMBHAJINAGAR vs. LD. DEPUTY COMMISSIONER OF INCOME TAX, CPC-TDS

In the result, both the bunch of appeals filed by the\nrespective assessee's in ITA Nos

…is to delivered or cause to delivered on or after 1-\n7-2012. [Para 7.1]\nThat, with the above overview of section 234 E and on considering both\nthe above views, it appears that the opinion expressed by the Gujarat\nHigh Court in Rajesh Kourani v. UOI [2017] 297 CTR 502 that section\n234E by itself creates a liability and the liability to pay the late fee is\nnot dependent on section 200A(1)(c) which only prescribes the recovery\nmechanism reflects the true intent and purpose of section 234E.\nSection 234E which provides for late fee is the substantive provision\nand the levy is not dependent on section 200A(1)(…

SHRI BHASKARACHARYA PRATISHTHAN,CHH. SAMBHAJINAGAR vs. LD. DEPUTY COMMISSIONER OF INCOME TAX, CPC-TDS

In the result, both the bunch of appeals filed by the respective assessee’s in ITA Nos

Bench: Dr.Manish Borad & Shri Vinay Bhamoreआयकर अपील सं. / Ita Nos.476 To 480/Pun/2024 Chate Tutorials Pvt. Ltd., Vs. Acit,Tds Circle, Chate House, Plot No.4, Nashik Near N-2 Cricket Stadium, Cidco, Aurangabad – 431 003 Maharashtra Tan : Nskco1565E Appellant Respondent

…ich is to delivered or cause to delivered on or after 1- 7-2012. [Para 7.1] That, with the above overview of section 234 E and on considering both the above views, it appears that the opinion expressed by the Gujarat High Court in Rajesh Kourani v. UOI [2017] 297 CTR 502 that section 234E by itself creates a liability and the liability to pay the late fee is not dependent on section 200A(1)(c) which only prescribes the recovery mechanism reflects the true intent and purpose of section 234E. Section 234E which provides for late fee is the substantive provision and the levy is not dependent on section 200A(1)(c) wh…

SHRI BHASKARACHARYA PRATISHTHAN,CHH. SAMBHAJINAGAR vs. LD. DEPUTY COMMISSIONER OF INCOME TAX, CPC-TDS

In the result, both the bunch of appeals filed by the\nrespective assessee's in ITA Nos

…is to delivered or cause to delivered on or after 1-\n7-2012. [Para 7.1]\nThat, with the above overview of section 234 E and on considering both\nthe above views, it appears that the opinion expressed by the Gujarat\nHigh Court in Rajesh Kourani v. UOI [2017] 297 CTR 502 that section\n234E by itself creates a liability and the liability to pay the late fee is\nnot dependent on section 200A(1)(c) which only prescribes the recovery\nmechanism reflects the true intent and purpose of section 234E.\nSection 234E which provides for late fee is the substantive provision\nand the levy is not dependent on section 200A(1)(…

SHREE BHASKARACHARYA PRATISHTHAN,CHH SAMBHAJINAGAR vs. LD. DEPUTY COMMISSIONER OF INCOME TAX, GHAZIABAD

In the result, both the bunch of appeals filed by the respective assessee’s in ITA Nos

Bench: Dr.Manish Borad & Shri Vinay Bhamoreआयकर अपील सं. / Ita Nos.476 To 480/Pun/2024 Chate Tutorials Pvt. Ltd., Vs. Acit,Tds Circle, Chate House, Plot No.4, Nashik Near N-2 Cricket Stadium, Cidco, Aurangabad – 431 003 Maharashtra Tan : Nskco1565E Appellant Respondent

…ich is to delivered or cause to delivered on or after 1- 7-2012. [Para 7.1] That, with the above overview of section 234 E and on considering both the above views, it appears that the opinion expressed by the Gujarat High Court in Rajesh Kourani v. UOI [2017] 297 CTR 502 that section 234E by itself creates a liability and the liability to pay the late fee is not dependent on section 200A(1)(c) which only prescribes the recovery mechanism reflects the true intent and purpose of section 234E. Section 234E which provides for late fee is the substantive provision and the levy is not dependent on section 200A(1)(c) wh…

SHREE BHASKARACHARYA PRATISHTHAN,CHH SAMBHAJINAGAR vs. LD. DEPUTY COMMISSIONER OF INCOME TAX, CPC-TDS

In the result, both the bunch of appeals filed by the respective assessee’s in ITA Nos

Bench: Dr.Manish Borad & Shri Vinay Bhamoreआयकर अपील सं. / Ita Nos.476 To 480/Pun/2024 Chate Tutorials Pvt. Ltd., Vs. Acit,Tds Circle, Chate House, Plot No.4, Nashik Near N-2 Cricket Stadium, Cidco, Aurangabad – 431 003 Maharashtra Tan : Nskco1565E Appellant Respondent

…ich is to delivered or cause to delivered on or after 1- 7-2012. [Para 7.1] That, with the above overview of section 234 E and on considering both the above views, it appears that the opinion expressed by the Gujarat High Court in Rajesh Kourani v. UOI [2017] 297 CTR 502 that section 234E by itself creates a liability and the liability to pay the late fee is not dependent on section 200A(1)(c) which only prescribes the recovery mechanism reflects the true intent and purpose of section 234E. Section 234E which provides for late fee is the substantive provision and the levy is not dependent on section 200A(1)(c) wh…

SHRI BHASKARACHARYA PRATISHTHAN,CHH. SAMBHAJINAGAR vs. LD. DEPUTY COMMISSIONER OF INCOME TAX, CPC-TDS

In the result, both the bunch of appeals filed by the respective assessee’s in ITA Nos

Bench: Dr.Manish Borad & Shri Vinay Bhamoreआयकर अपील सं. / Ita Nos.476 To 480/Pun/2024 Chate Tutorials Pvt. Ltd., Vs. Acit,Tds Circle, Chate House, Plot No.4, Nashik Near N-2 Cricket Stadium, Cidco, Aurangabad – 431 003 Maharashtra Tan : Nskco1565E Appellant Respondent

…ich is to delivered or cause to delivered on or after 1- 7-2012. [Para 7.1] That, with the above overview of section 234 E and on considering both the above views, it appears that the opinion expressed by the Gujarat High Court in Rajesh Kourani v. UOI [2017] 297 CTR 502 that section 234E by itself creates a liability and the liability to pay the late fee is not dependent on section 200A(1)(c) which only prescribes the recovery mechanism reflects the true intent and purpose of section 234E. Section 234E which provides for late fee is the substantive provision and the levy is not dependent on section 200A(1)(c) wh…

SHREE BHASKARACHARYA PRATISHTHAN,CHH SAMBHAJINAGAR vs. LD. DEPUTY COMMISSIONER OF INCOME TAX CPC TDS, GHAZIABAD

In the result, both the bunch of appeals filed by the respective assessee’s in ITA Nos

Bench: Dr.Manish Borad & Shri Vinay Bhamoreआयकर अपील सं. / Ita Nos.476 To 480/Pun/2024 Chate Tutorials Pvt. Ltd., Vs. Acit,Tds Circle, Chate House, Plot No.4, Nashik Near N-2 Cricket Stadium, Cidco, Aurangabad – 431 003 Maharashtra Tan : Nskco1565E Appellant Respondent

…ich is to delivered or cause to delivered on or after 1- 7-2012. [Para 7.1] That, with the above overview of section 234 E and on considering both the above views, it appears that the opinion expressed by the Gujarat High Court in Rajesh Kourani v. UOI [2017] 297 CTR 502 that section 234E by itself creates a liability and the liability to pay the late fee is not dependent on section 200A(1)(c) which only prescribes the recovery mechanism reflects the true intent and purpose of section 234E. Section 234E which provides for late fee is the substantive provision and the levy is not dependent on section 200A(1)(c) wh…

SHREE BHASKARACHARYA PRATISHTHAN,CHH SAMBHAJINAGAR vs. LD. DEPUTY COMMISSIONER OF INCOME TAX, GHAZIABAD

In the result, both the bunch of appeals filed by the respective assessee’s in ITA Nos

Bench: Dr.Manish Borad & Shri Vinay Bhamoreआयकर अपील सं. / Ita Nos.476 To 480/Pun/2024 Chate Tutorials Pvt. Ltd., Vs. Acit,Tds Circle, Chate House, Plot No.4, Nashik Near N-2 Cricket Stadium, Cidco, Aurangabad – 431 003 Maharashtra Tan : Nskco1565E Appellant Respondent

…ich is to delivered or cause to delivered on or after 1- 7-2012. [Para 7.1] That, with the above overview of section 234 E and on considering both the above views, it appears that the opinion expressed by the Gujarat High Court in Rajesh Kourani v. UOI [2017] 297 CTR 502 that section 234E by itself creates a liability and the liability to pay the late fee is not dependent on section 200A(1)(c) which only prescribes the recovery mechanism reflects the true intent and purpose of section 234E. Section 234E which provides for late fee is the substantive provision and the levy is not dependent on section 200A(1)(c) wh…