DATTU SAMPAT VANKHEDE,NAGPUR vs. PCIT-2, NAGPUR

In the result, appeal filed by the assessee is dismissed

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

147 the Pr. Commissioner of Income Tax-2, Nagpur has initiated proceedings U/s. 263 on the initiation of proposal by AO and accordingly passed the order U/s. 263 on 22/02/2021 by setting aside the order passed by AO on 12/10/2018 and order U/s 263 passed with a direction to reassess

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

u/s 147 was initiated, ceased to exist. 4. That, if the primary ground based on which reassessment u/s 147

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

u/s 147 was initiated, ceased to exist. 4. That, if the primary ground based on which reassessment u/s 147

A.C.I.T ,AKOLA CIRCLE, AKOLA vs. M/S LEBEN LABORATORIES PVT..LTD,, AKOLA

Bench: Shri D. Karunakara Rao, Am & Shri Vikas Awasthy, Jm

reassessment proceedings the deduction claimed by the assessee u/s. 80IB of the Act in respect of Unit Nos. III, IV and V were denied. Aggrieved against the assessment order dated 26-12-2008 passed u/s. 143(3) r.w.s. 147

M/S. LEBEN LABORATORIES PVT. LTD.,,AKOLA vs. ACIT, AKOLA CIRCLE, AKOLA, AKOLA

Bench: Shri D. Karunakara Rao, Am & Shri Vikas Awasthy, Jm

reassessment proceedings the deduction claimed by the assessee u/s. 80IB of the Act in respect of Unit Nos. III, IV and V were denied. Aggrieved against the assessment order dated 26-12-2008 passed u/s. 143(3) r.w.s. 147

NIRMALKUMAR AGRAWAL HUF,NAGPUR vs. INCOME TAX OFFICER, WARD-2, BHANDARA

In the result, assessee’s appeal stands allowed

Bench: Shri Narender Kumar Choudhry & Shri K.M. Roy, Accountant, Member

reassessment order dated 24.03.2023 passed by AO u/s 147 read with 5 Nirmalkumar Agrawal (HUF) ITA no.242/Nag./2025 section

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

u/s 147 was initiated, ceased to exist. 5. That, if the primary ground based on which reassessment u/s 147

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 valid under law in the facts and circumstances of the case

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 valid under law in the facts and circumstances of the case

DY. COMMISSIONER OF INCOME TAX, CIRCLE-3, NAGPUR, NAGPUR vs. VINODKUMAR RAJENDRALAL KOCHHAR, KAMPTEE

In the result, the appeal filed by the department is dismissed

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

u/s 147 of the Act and change of opinion is not permissible even within 4 years. “Reopening of an assessment on mere change of opinion without any tangible material is unsustainable - Assessing Officer deemed to have applied his mind if facts are on record and reopening under section 147 on change of opinion is not permissible even within 4 years

MITHILESH JAGDEO SINGH PAWAR,AMRAVATI vs. ITO WARD-5, AMRAVATI

Bench: Shri Narender Kumar Choudhryassessment Year: 2017-18 Mr. Mithilesh Jagdeo Singh Ito Ward-5 Pawar, Besides Dps, Vs. Ghatladki, Chandur Bazar, Saturna Road, Maharashtra - 444720. Maharashtra - 444605. Pan: Bpfpp6167L (Appellant) (Respondent) Present For: Assessee By : Ms. Mrudul Bhusari, Ld. Adv {Ld. Amicus Curie} Revenue By : Shri Surjit Kumar Saha, Ld. Sr. Dr Date Of Hearing : 26.06.2025 Date Of Pronouncement : 09.2025 O R D E R Per : Narender Kumar Choudhry:

reassessment proceedings u/s 147 of the Act are unsustainable which would entail the assessment order passed in consequence thereof

PRADEEP DATTATRAYA BANGINWAR,YAVATMAL vs. PRINCIPAL COMMISSIONER OF INCOME TAX-II, NAGPUR

In the result, appeal of the assessee is allowed in terms of our aforesaid observations

Bench: Shri Ravish Sood & Shri Jamlappa D Battullआयकर अपील सं. / Ita No. 28/Nag/2021 "नधा"रण वष" / Assessment Year : 2011-12 Pradeep Dattatraya Banginwar, At- Trimurti Sales, Datta Chowk, Yavatmal-445 001. Pan : Abcpb5111C .......अपीलाथ" / Appellant बनाम / V/S. The Pr. Commissioner Of Income Tax-Ii, Nagpur. ……""यथ" / Respondent Assessee By : Shri P.M. Gandhi, Ca Revenue By : Shri Vitthal Bhosale, Dr सुनवाई क" तार"ख / Date Of Hearing :17.02.2022 घोषणा क" तार"ख / Date Of Pronouncement : 06.04.2022

u/s. 147 r.w.s 143(3) of the Act, dated 01.12.2018 4 Pradeep Dattatraya Bangirwar Vs. Pr CIT-II accepted his returned income and did not make any addition as regards the issue on the basis of which his case was reopened by him. 3. After culmination of the reassessment

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

147 of the Act in the absence of any valid approval/sanction u/s.151 of the Act, therefore, the assessment framed by him u/s. 143(3) r.w.s.147 of the Act, dated 18.03.2014 cannot be sustained and is liable to be struck down on the said count itself. 6. Per contra, the Ld. Departmental Representative (for short ‘DR’) relied on the orders

MAMTA SANJAY DAND,BULDHANA vs. THE INCOME-TAX OFFICER, WARD 1, KHAMGAON, BULDHANA

In the result, appeal filed by the assessee stands allowed

Bench: Shri Pawan Singh & Shri Khettra Mohan Roymamta Sanjay Dand, Ito, Ward – 1, Khamgaon Akdo Jain Society, Vs Near Govind Nagar, At Post Malkhapur, Dist. Buldhana, Maharashtra-443101 Pan : Azgpd 6958 F Assessee Respondent Assessee By : Shri Sanjeev Mutha, Ca Revenue By : Shri Pankaj Kumar, Cit-Dr Date Of Hearing : 23.02.2026 Date Of Pronouncement : 07.04.2026

reassessment was already completed u/s 147. Reopening done beyond 4 years is invalid. Approval u/s. 151 was granted mechanically

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

reassessment u/s 139, 147, 148, 149, 151 & 153. 28. The language of explanation 2 to new Section 148 is akin

VAISHNAV YASHWANT ASHTANKAR,NAGPUR vs. THE PRINCIPAL COMMISSIONER OF INCOME TAX - NAGPUR 2, NAGPUR

In the result, appeal filed by the assessee is allowed

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

u/s 147 r.w.s. 144B for A.Y. 2016-17. 1. In addition, it is seen that the source of investment in the purchase of property i.e. Rs. 34,28,333/- (1/3rd of the purchase consideration of Rs. 1,02,85,000/-) had been claimed by the assessee during reassessment

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

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

147 of the I.T. Act, the AO is empowered to reopen the assessment, if he/she has reasons to believe that the income chargeable to tax has escaped assessment. In the present case, notice u/s 148 of the I.T. Act was issued and served to the assessee after following due procedure as provided by Income Tax Act and also copy

AXYKNO CAPITAL SERVICES LTD,,NAGPUR vs. DCIT CIRCLE 1, NAGPUR

In the result, both the appeals of the assessee are allowed

Bench: Shri Sandeep Gosain, Jm & Shri Arun Khodpia, Am

u/s 68 of I.T. Act. 3 ITA 178/NAG/ 2017 AXYKNO CAPITAL SERVICES LTD VS DCIT, CIRCLE- 1,NAGPUR 1. The Ld. AR of the Appellant, during the course of hearing reiterated the facts of the case and filed a detailed synopsis which can be summarized as under: a. The Appellant is a limited company engaged in activity of consulting