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. Therefore, due date for revision proceedings u/s 263 will be reckoned from date of intimation order passed u/s 143(1) and not from date of order passed u/s 147. Accordingly, following will be due date to pass order u/s 263: 10 Latitude Infraventures ITA no.349 & 350/Nag./2024 A.Y. 2016–17 & 2017–18 Due Date for passing order

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. Therefore, due date for revision proceedings u/s 263 will be reckoned from date of intimation order passed u/s 143(1) and not from date of order passed u/s 147. Accordingly, following will be due date to pass order u/s 263: 10 Latitude Infraventures ITA no.349 & 350/Nag./2024 A.Y. 2016–17 & 2017–18 Due Date for passing order

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

142(1) dated 13/07/2018 specifically had inquired into this issue of credits to capital account (which, incidentally, was the main issue for which computer-aided selection of case was made for limited scrutiny u/s 143(2) of the Act) by asking for relevant evidences and the documents. Upon being satisfied with the explanation of the appellant in response to this

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

Reassessment framed without providing reasons recorded for issue of notice u/s 148 is not in accordance with law and contrary to decision of Hon’ble Jurisdictional High Court in the case of CIT vs. Videsh Sanchar Nigam Ltd. reported at 340 ITR 66 (Bom.) and liable to be cancelled. 6) The addition made by A.O. at Rs.17

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 144B of the Act for A.Y. 2018-19 in the case of the assessee is set aside, with a direction to the Assessing Officer to pass a fresh Assessment Order denovo, after giving opportunity of being heard to the assessee

VINAY RAMSHARANDAS AGRAWAL,NAGPUR vs. PRINCIPAL COMMISSIONER OF INCOME TAX-II, NAGPUR

In the result, appeal by the assessee stands allowed

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

142(1) of Act, on 16/09/2019. In the aforesaid notice, the assessee was called upon to provide details regarding the source of income as mentioned in Para–1 of the said notice. At Para–4, the assessee was called upon to explain sale consideration of property reported in Schedule CG of the return of income at less than the sale

ADITI EXPRESS CARGO INDIA PRIVATE LIMITED THROUGH ITS ERSTWHILE DIRECTOR PRASHANT NATWARLAL LAKHANI,NAGPUR vs. DCIT ACIT CIRCLE-3, NAGPUR

In the result, all the captioned seven appeal are allowed for statistical purposes

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

147 r/w Faceless 5. 23/09/2024 144 Appeal A.Y. 2014–15 by Assessee Centre, Delhi National ITA no.559/Nag./2024 Faceless 6. 23/09/2024 271(1)(b) Appeal A.Y. 2014–15 by Assessee Centre, Delhi National ITA no.560/Nag./2024 Faceless 7. 23/09/2024 271(1)(c) Appeal A.Y. 2014–15 by Assessee Centre, Delhi We take up appeal in ITA no.498/Nag./2024

ADITI EXPRESS CARGO INDIA PRIVATE LIMITED THROUGH ITS ERSTWHILE DIRECTOR PRASHANT NATWARLAL LAKHANI,NAGPUR vs. DCIT ACIT CIRCLE-3, NAGPUR

In the result, all the captioned seven appeal are allowed for statistical purposes

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

147 r/w Faceless 5. 23/09/2024 144 Appeal A.Y. 2014–15 by Assessee Centre, Delhi National ITA no.559/Nag./2024 Faceless 6. 23/09/2024 271(1)(b) Appeal A.Y. 2014–15 by Assessee Centre, Delhi National ITA no.560/Nag./2024 Faceless 7. 23/09/2024 271(1)(c) Appeal A.Y. 2014–15 by Assessee Centre, Delhi We take up appeal in ITA no.498/Nag./2024

ADITI EXPRESS CARGO INDIA PRIVATE LIMITED,NAGPUR vs. DCIT ACIT CIRCLE -3, NAGPUR

In the result, all the captioned seven appeal are allowed for statistical purposes

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

147 r/w Faceless 5. 23/09/2024 144 Appeal A.Y. 2014–15 by Assessee Centre, Delhi National ITA no.559/Nag./2024 Faceless 6. 23/09/2024 271(1)(b) Appeal A.Y. 2014–15 by Assessee Centre, Delhi National ITA no.560/Nag./2024 Faceless 7. 23/09/2024 271(1)(c) Appeal A.Y. 2014–15 by Assessee Centre, Delhi We take up appeal in ITA no.498/Nag./2024

ADITI EXPRESS CARGO INDIA PRIVATE LIMITED,NAGPUR vs. DCIT ACIT CIRCLE -3, NAGPUR

In the result, all the captioned seven appeal are allowed for statistical purposes

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

147 r/w Faceless 5. 23/09/2024 144 Appeal A.Y. 2014–15 by Assessee Centre, Delhi National ITA no.559/Nag./2024 Faceless 6. 23/09/2024 271(1)(b) Appeal A.Y. 2014–15 by Assessee Centre, Delhi National ITA no.560/Nag./2024 Faceless 7. 23/09/2024 271(1)(c) Appeal A.Y. 2014–15 by Assessee Centre, Delhi We take up appeal in ITA no.498/Nag./2024

ADITI EXPRESS CARGO INDIA PRIVATE LIMITED THROUGH ITS ERSTWHILE DIRECTOR PRASHANT NATWARLAL LAKHANI,NAGPUR vs. DCITACIT CIRCLE-3 , NAGPUR

In the result, all the captioned seven appeal are allowed for statistical purposes

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

147 r/w Faceless 5. 23/09/2024 144 Appeal A.Y. 2014–15 by Assessee Centre, Delhi National ITA no.559/Nag./2024 Faceless 6. 23/09/2024 271(1)(b) Appeal A.Y. 2014–15 by Assessee Centre, Delhi National ITA no.560/Nag./2024 Faceless 7. 23/09/2024 271(1)(c) Appeal A.Y. 2014–15 by Assessee Centre, Delhi We take up appeal in ITA no.498/Nag./2024

ADITI EXPRESS CARGO INDIA PRIVATE LIMITED,NAGPUR vs. DCIT ACIT CIRCLE -3, , NAGPUR

In the result, all the captioned seven appeal are allowed for statistical purposes

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

147 r/w Faceless 5. 23/09/2024 144 Appeal A.Y. 2014–15 by Assessee Centre, Delhi National ITA no.559/Nag./2024 Faceless 6. 23/09/2024 271(1)(b) Appeal A.Y. 2014–15 by Assessee Centre, Delhi National ITA no.560/Nag./2024 Faceless 7. 23/09/2024 271(1)(c) Appeal A.Y. 2014–15 by Assessee Centre, Delhi We take up appeal in ITA no.498/Nag./2024

ADITI EXPRESS CARGO INDIA PRIVATE LIMITED,NAGPUR vs. DCIT ACIT CIRCLE -3, NAGPUR

In the result, all the captioned seven appeal are allowed for statistical purposes

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

147 r/w Faceless 5. 23/09/2024 144 Appeal A.Y. 2014–15 by Assessee Centre, Delhi National ITA no.559/Nag./2024 Faceless 6. 23/09/2024 271(1)(b) Appeal A.Y. 2014–15 by Assessee Centre, Delhi National ITA no.560/Nag./2024 Faceless 7. 23/09/2024 271(1)(c) Appeal A.Y. 2014–15 by Assessee Centre, Delhi We take up appeal in ITA no.498/Nag./2024

DAYAL COTSPIN LIMITED,AKOLA vs. ACIT, AKOLA CIRCLE, AKOLA

In the result, appeal filed by the assessee is allowed

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

142(1) of the Act during the regular assessment framed under section 143(3) of Act. All corporate shareholders were assessed to income tax and transactions of subscription of share capital were through proper banking channel. Regular assessment was framed under 3 Dayal Cotspin Ltd. section 143(3) of the Act, on 23/03/2015, by accepting share capital contribution and income

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

142(1) of the Act seeking certain details and documents from the assessee, in response to which the Vaishnav Yashwant Ashtankar A.Y. 2016–17 assessee furnished replies stating that he was owner of a gas agency under the name of M/s. Satyabama Indane Gas Agency and that he along with two other co–owners, had purchased a property for ` 1

ITO, WARD- 4,, CHANDRAPUR vs. M/S. K.S.R. TRANSPORT COMPANY,, CHANDRAPUR

Appeal is dismissed

Bench: Shri S.S.Godara & Dr. Dipak P. Ripoteआयकर अपील सं. / Ita No.364/Nag/2019 िनधा"रण वष" / Assessment Year : 2009-10 The Assistant M/S.Ksr Transport, Commissioner Of Income V Padoli Chadda Building, Tax, Chandrapur Circle, S Kosara Road, Chandrapur. Chandrapur. Pan: Aabfk3222D Appellant / Revenue Respondent / Assessee Cross Objection No.02/Nag/2020 (Arising Out Of Ita No.364/Nag/2019) िनधा"रण वष" / Assessment Year : 2009-10 M/S.Ksr Transport, The Assistant Padoli Chadda Building, V Commissioner Of Income Kosara Road, Chandrapur. S Tax, Chandrapur Circle, Pan: Aabfk3222D Chandrapur. Appellant / Assessee Respondent / Revenue Assessee By Shri Mukesh Agrawal – Ar Revenue By Shri Abhay Y. Marathe – Sr.Dr Date Of Hearing 30/11/2023 Date Of Pronouncement 09/01/2024 आदेश/ Order Per Dr. Dipak P. Ripote, Am: This Is An Appeal Filed By The Revenue Against The Order Of Ld.Cit(A)-2, Nagpur Dated 28.08.2019 Emanating From

reassessment proceedings afresh and upheld the addition made by the AO. ITA No.364/NAG/2019 & C.O.No.02/NAG/2020 M/s.K S R Transport Company (Cross Appeal) 6. Any other ground that may be raise during the proceedings.” 2. The assessee filed C.O.No.02/PUN/2020. The assessee has raised the ground of appeal as under : “1. That on the facts and in the circumstances

ASSISTANT COMMISSIONER OF INCOME TAX CHANDRAPUR CIRCLE , CHANDRAPUR vs. M/S CHADDA TRANSPORT , CHANDRAPUR

Appeal is dismissed

Bench: Shri S.S.Godara & Dr. Dipak P. Ripoteआयकर अपील सं. / Ita No.363/Nag/2019 िनधा"रण वष" / Assessment Year : 2009-10 The Assistant M/S.Chadda Transport, Commissioner Of V Kosara Road, Padoli, Income Tax, S Chandrapur, Chandrapur Circle, Maharashtra – 442401. Chandrapur. Pan: Aaafc8556F Appellant / Revenue Respondent / Assessee Cross Objection No.01/Nag/2020 (Arising Out Of Ita No.363/Nag/2019) िनधा"रण वष" / Assessment Year : 2009-10 M/S.Chadda Transport, The Assistant Kosara Road, Padoli, V Commissioner Of Income Chandrapur, S Tax, Maharashtra – 442401. Chandrapur Circle, Chandrapur. Pan: Aaafc8556F Appellant / Assessee Respondent / Revenue Assessee By Shri Mukesh Agrawal – Ar Revenue By Shri Abhay Y. Mrathe – Sr.Dr Date Of Hearing 30/11/2023 Date Of Pronouncement 27/12/2023 आदेश/ Order Per Dr. Dipak P. Ripote, Am:

reassessment proceedings afresh and upheld the addition made by the AO. 6. Any other ground that may be raise during the proceedings.” 2. The assessee filed C.O.No.01/PUN/2020. The assessee has raised the ground of appeal as under : ITA No.363/NAG/2019 & C.O.No.01/NAG/2020 M/s.Chadda Transport (Cross Appeal) “1. That on the facts and in the circumstances of the case the reopening

M/S MAHESHWARI COAL BENEFICATION & INFRASTRUCTURE P LTD.,BILASPUR vs. ACIT CENTRAL CIRCLE 1(1), NAGPUR

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

section 153D dated 29/09/2021 is in mechanical/routine manner without application of mind by Addl.CIT, which is merely a formality, an empty ritual and as such it leads to flagrant violation of the rules of law. 45. The third contention of the learned A.R. is that while granting such mechanical approval dated 29/09/2021 under section 153D for the assessment year

M/S MAHESHWARI COAL BENEFICATION & INFRASTRUCTURE P. LTD,BILASPUR vs. ACIT CENTRAL CIRCLE-1(1), NAGPUR

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

section 153D dated 29/09/2021 is in mechanical/routine manner without application of mind by Addl.CIT, which is merely a formality, an empty ritual and as such it leads to flagrant violation of the rules of law. 45. The third contention of the learned A.R. is that while granting such mechanical approval dated 29/09/2021 under section 153D for the assessment year