LATITUDE INFRAVENTURES,NAGPUR vs. PCIT,NAGPUR-1, NAGPUR

In the result, appeal filed by the assessee for assessment year 2017–18

Bench: Shri V. Durga Rao & Shri K.M. Roy, Accountant, Member

reassessment u/s 147 had been passed. 4. Whether on the facts and circumstances, the learned CIT erred in neither making any enquiry on his own nor considering merits of case but simply directed the learned AO to make proper enquiry and further verification thereby, rendering the order passed u/s 263 bad in law which deserves to be set aside

LATITUDE INFRAVENTURES,NAGPUR vs. PCIT,NAGPUR-1, NAGPUR

In the result, appeal filed by the assessee for assessment year 2017–18

Bench: Shri V. Durga Rao & Shri K.M. Roy, Accountant, Member

reassessment u/s 147 had been passed. 4. Whether on the facts and circumstances, the learned CIT erred in neither making any enquiry on his own nor considering merits of case but simply directed the learned AO to make proper enquiry and further verification thereby, rendering the order passed u/s 263 bad in law which deserves to be set aside

ASHOKKUMAR GOKULCHAND SANANDA,BULDHANA vs. ASSISTANT COMMISIONER OF INCOME TAX AKOLA CIRCLE, AKOLA

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

Bench: Shri Pawan Singh & Shri Khettra Mohan Royashokkumar Gokulchand Acit, Akola Circle, Akola Sananda, Rana Traders, Vs Gandhi Chowk, Khamgaon, Dist. Buldhan, Khamgaon Pan : Adpps 755I L Assessee Respondent Assessee By : Shri K.P. Dewani, Adv Revenue By : Shri Surjit Kumar Saha, Sr. Dr Date Of Hearing : 20.02.2026 Date Of Pronouncement : 06.04.2026

deduction u/s 35(1)(ii) of I.T. Act 1961 as claimed and allowed in regular assessment proceedings. 9) The addition made by A.O. at Rs.1,50,000/- u/s 69C of I.T. Act 1961 is unjustified, unwarranted and bad in law. 10) The learned A.O. erred in making addition of Rs.1,50,000/- u/s 69C without there being any evidence

SHRI SUBHASHCHAND CHANDAK,NAGPUR vs. ASSISTANT COMMISSIONER OF INCOME TAX, CIRCLE-1, NAGPUR

In the result, appeal filed by the assessee is dismissed in limine

Bench: Shri V. Durga Rao & Shri K.M. Roy, Accountant, Member

reassessment u/s 147 is initiated, ceased to exist. 3. That, the Assessing Officer has erred, while giving effect to order of CIT (A), Nagpur, in not deducting

SUBHASHCHAND SUNDERLAL CHANKAK,NAGPUR vs. ASSISTANT COMMISSIONER OF INCOME TAX, CIRCLE-1, NAGPUR

In the result, appeal filed by the assessee is dismissed in limine

Bench: Shri V. Durga Rao & Shri K.M. Roy, Accountant, Member

reassessment u/s 147 is initiated, ceased to exist. 3. That, the Assessing Officer has erred, while giving effect to order of CIT (A), Nagpur, in not deducting

SHRI PRABODH SADASHIV SADAVARTE (HUF), NAGPUR vs. INCOME TAX OFFICER,WARD-1(4),, NAGPUR

In the result, the appeal of assessee is dismissed

Bench: Shri Inturi Rama Rao & Shri S.S. Viswanethra Ravi

reassessment proceedings u/s. 147 of the Act is not valid, before the CIT(A). The CIT(A) discussed the same in detail at para 8 of the impugned order. The CIT(A) held the AO rightly formed an opinion that there was no detailed examination of the issue u/s. 54B of the Act in the intimation proceedings. The relevant portion

PRABODH SADASHIV SADAVARTEM(HUF),NAGPUR vs. I.T.O.(TDS) WARD -1(4), NAGPUR

In the result, the appeal of assessee is dismissed

Bench: Shri Inturi Rama Rao & Shri S.S. Viswanethra Ravi

reassessment proceedings u/s. 147 of the Act is not valid, before the CIT(A). The CIT(A) discussed the same in detail at para 8 of the impugned order. The CIT(A) held the AO rightly formed an opinion that there was no detailed examination of the issue u/s. 54B of the Act in the intimation proceedings. The relevant portion

SUBHASHCHAND CHANDAK (HUF),NAGPUR vs. ASSISTANT COMMISSIONER OF INCOME TAX, CIRCLE-1, NAGPUR

In the result, appeal filed by the assessee is dismissed

Bench: Shri V. Durga Rao & Shri K.M. Roy, Accountant, Member

reassessment u/s 147 is initiated, ceased to exist. 4. That, the Assessing Officer has erred, while giving effect to order of CIT (A), Nagpur, in not deducting

THE AMRAVATI PEOPLE CO-OP BANK LTD ( NOW MERGED IN THE COSMOS CO-OP BANK LTD),AMARAVATI vs. D.C.I.T. AMRAVATI CIRCLE, AMARAVATI

Bench: Shri Ravish Sood & Shri Jamlappa D Battullआयकरअपीलसं. / Ita No. 309/Nag/2015 "नधा"रणवष" / Assessment Year : 2008-09 The Amravati Peoples Co-Op. Bank Limited (Now Merged In The Cosmos Co-Op. Bank Ltd.) C/O. Cosmos Co-Op Bank Ltd. Jawahar Road, Amravati-444601. Pan : Aaact5899B .......अपीलाथ" / Appellant बनाम / V/S. The Deputy Commissioner Of Income Tax, Amravati Circle, Amravati. ……""यथ" / Respondent Assessee By : Shri S.G. Gandhi, Ar Revenue By : Smt. Agnes P. Thomas, Dr सुनवाईक"तार"ख / Date Of Hearing : 18.02.2022 घोषणाक"तार"ख / Date Of Pronouncement : 09.05.2022

deduction u/s.80P of Rs.28,39,640/-. As per item No.25(a) of the audit report in Form No.3CD, the details given under the head "Details of brought forward loss or depreciation allowance, in the following manner, to the extent available" is as under:- Asst. Year Remarks S. Nature of Amount as Amount as No. loss/allowance ( returned (in assessed ( give rupees

INCOME TAX OFFICER, WARD-1, BHANDARA, FIRST FLOOR, GANGA MOTORS BUILDING, Z P CHOWK, BHANDARA Z vs. ZILLA PARISHAD SHASHKIYA KARMCHARI SAHKARI PAT SANSTHA MARYADIT, BHANDARA

In the result, appeal by the Revenue stands dismissed

Bench: Shri V. Durga Rao & Shri K.M. Roy, Accountant, Member

u/s 147 of the Act on change of opinion is not permissible even within 4 years. 6.2.7 Accordingly, I am of the considerate view that the initiation of the reassessment proceedings in the instant case beyond 4 years from the end of the relevant AY without tangible material evidence is bad in law. Accordingly, the reassessment order dated

VISHAL KISHORILAL JAIN,NAGPUR vs. DCIT/ACIT CIRCLE-4, NAGPUR

In the result, assessee’s appeal for A

Bench: Shri V. Durga Rao & Shri K.M. Roy, Accountant, Member

deduction for such assessment year and for which a prior notice under Section 148 would be required to be issued. Section 147 does not contemplate an eventuality which Section 153A or Section 153C contemplates, the basis of which is inter alia a search action under Section 132 being resorted as noted hereinabove. Thus, both these provisions are quite compartmentalized although

DY. C.I.T. CIR-.2, NAGPUR vs. SHRI GOVINDDAS GOVERDHAN DAGA, NAGPUR

Bench: Shri V. Durga Rao & Shri K.M. Roy, Accountant, Member

reassessment framed is bad in law. D) The A.O. has referred to the decision of Hon'ble Delhi High Court in the case of Acorus Unitech Wireless (P) Ltd. and it can be seen that in said decision objections filed were disposed by revenue authorities as is evident from para 3 of judgment. It is further seen from the reasons

DEPUTY COMMISSIONER OF INCOME TAX CIRCLE -2, NAGPUR vs. M/S SUNFLAG IRON & STEEL CO. LTD. , NAGPUR

In the result, appeal of the Revenue in ITA No

Bench: Shri Ravish Sood & Shri Jamlappa D Battullआयकरअपीलसं. / Ita Nos. 268 & 269/Nag/2018 "नधा"रणवष" / Assessment Years : 2010-11 & 2011-12 The Deputy Commissioner Of Income Tax, Circle-2, Nagpur. .......अपीलाथ" / Appellant बनाम / V/S. M/S. Sunflag Iron & Steel Co. Ltd. 33, Mount Road, Sadar, Nagpur-440 001 Pan : Aaccs3376C ……""यथ" / Respondent

147 its case could not have been reopened beyond a period of 4 years from the end of the assessment year. Accordingly, it was observed by the CIT(Appeals) that the notice u/s. 148 of the Act, dated 25.01.2017 was barred by limitation. Lastly, it was observed by the 6 DCIT, Circle-2 Vs. M/s. Sunflag Iron & Steel

DEPUTY COMMISSIONER OF INCOME TAX CIRCLE -2, NAGPUR vs. M/S SUNFLAG IRON & STEEL CO. LTD. , NAGPUR

In the result, appeal of the Revenue in ITA No

Bench: Shri Ravish Sood & Shri Jamlappa D Battullआयकरअपीलसं. / Ita Nos. 268 & 269/Nag/2018 "नधा"रणवष" / Assessment Years : 2010-11 & 2011-12 The Deputy Commissioner Of Income Tax, Circle-2, Nagpur. .......अपीलाथ" / Appellant बनाम / V/S. M/S. Sunflag Iron & Steel Co. Ltd. 33, Mount Road, Sadar, Nagpur-440 001 Pan : Aaccs3376C ……""यथ" / Respondent

147 its case could not have been reopened beyond a period of 4 years from the end of the assessment year. Accordingly, it was observed by the CIT(Appeals) that the notice u/s. 148 of the Act, dated 25.01.2017 was barred by limitation. Lastly, it was observed by the 6 DCIT, Circle-2 Vs. M/s. Sunflag Iron & Steel

THE AMRAVATI PEOPLE CO-OP BANK LTD ( NOW MERGED IN THE COSMOS CO-OP BANK LTD),AMARAVATI vs. D.C.I.T. AMRAVATI CIRCLE, AMARAVATI

In the result, the appeal of assessee is dismissed

Bench: Shri Inturi Rama Rao & Shri S.S. Viswanethra Ravi

reassessment proceedings vide para No. 10 of the assessment order, wherein, he clearly held that there was no loss available for A.Y. 2002-03 which was assessed u/s. 143(3) of the Act determining Nil income after allowing deduction u/s. 80P of the Act against the income for the year 3 ITA No. 308/NAG/2015, A.Y. 2007-08 under consideration. Further

CHANDRAKUMAR MADHUSUDANJI JAJODIA,THANE vs. ASSISTANT COMMISSIONER OF INCOME TAX, AMRAVATI CIRCLE

In the result, appeal filed by the assessee is allowed

Bench: Shri V. Durga Rao & Shri K.M. Roy, Accountant, Member

reassessment is general in nature and is not on specific transaction of assessee. Evidence placed on record is not found to be incorrect or false. Conclusion of escapement of income tantamount to mere change of opinion. Belief of escapement of income could not be derived on the basis of report of Investigation Wing being not specific to transaction of loan

SUNRISE STRUCTURALS & ENGINEERING PVT LTD,NAGPUR vs. ASSISTANT/ DEPUTY COMMISSIONER OF INCOME TAX CIRCLE-4 NAGPUR, NAGPUR

In the result, appeal filed by the assessee stands allowed

Bench: Shri Pawan Singh & Shri Khettra Mohan Roysunrise Structural & Acit/Dcit, Circle-4, Engineering P. Ltd., A10, Vs Nagpur Hingna Midc, Nagpur (Urban), Nagpur-440016 Pan : Aaccs 3220 M Assessee Respondent Assessee By : Shri K.P. Dewani, Advocate Revenue By : Shri Surjit Kumar Saha, Sr. Dr Date Of Hearing : 25.02.2026 Date Of Pronouncement : 10.04.2026 O R D E R

147 r.w.s. 144B of I.T. Act 1961 dated 06/02/2024 as placed in the paper book at page135 – 139 (Vol.- II). This further substantiates the authenticity and genuineness of the transactions under consideration. Sales of trading goods purchased are accepted. Business loss as shown in return is accepted and books of account are not rejected. Considering facts and evidence on record

ASSTT.COMMISSIONER OF INCOME TAX ,CIRCLE-4, NAGPUR vs. SHRI NANDLAL B MALOO, NAGPUR

In the result, assessee’s cross objection is partly allowed

Bench: Shri P.K. Bansal & Shri Amarjit Singh

147 are started the ITO has not only the jurisdiction but also the duty to complete the assessment denovo and what is true of assm is also rule of reassessment because reassessment is nothing but a fresh assessment. 8.1 As regards the issue whether the addition is justified it is necessary to recapitulate the facts of the case. The income