SHRI SANJAY DHANRAJ JAIN,NAGPUR vs. DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-1(3), NAGPUR

In the result, assessee' appeal for A

section 69 has held that in creating the legal fiction the phraseology employs the word \"may\" and not \"shall\". Thus the unsatisfactoriness of the explanation does not and need not automatically result in deeming the amount credited in the books as the income of the assessee as held by the Supreme Court in the case

SHRI SANJAY DHANRAJ JAIN,NAGPUR vs. DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-1(3), NAGPUR

u/s. 143(3) r.w.s. 153A is bad in law and\nwrong on facts and the learned CIT(A) erred in confirming the same.\n(2) That the learned CIT(A) erred in law and on facts in confirming the\naddition made by AO in the proceedings u/s 153A of the Income Tax Act,\n1961 in absence of incriminating document found

SHRI SANJAY DHANRAJ JAIN,NAGPUR vs. DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-1(3), NAGPUR

In the result, assessee' appeal for A

section 68 of the Income Tax Act,\n1961. Further, the AO did not find the explanation offered by the assessee\nsatisfactory and stated that the assessee has failed to discharge its onus\ntowards explaining the credit of Rs.15,00,000/-. We respectfully object to the\nabove observations and allegations made by the AO as the same are based on\nconjectures

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

234B and 234C of I.T. Act 1961 is unjustified, unwarranted and excessive. 9) Any other ground shall be prayed at the time of hearing.” 5. The assessee submitted the following submissions along with the paper book for consideration. 3.1 Ground No.1: Notice u/s 148 of I.T. Act 1961 is not in accordance with law:- A) Notice u/s 148A

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

234B and 234C of I.T. Act 1961 is unjustified, unwarranted and excessive. Any other ground that shall be prayed at the time of hearing.” 11. 3. Facts in Brief:- In this case, the assessee, for the year under consideration, filed its return of income on 29/09/2012, which was accepted by the Assessing Officer during the regular assessment framed under section

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

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 framed is liable to be cancelled. 2 Chandrakumar Madhusudanji Jajodia ITA no.399/Nag./2023 3. Assessment framed u/s 144 r.w.s. 147 of I.T. Act 1961 is bad in law in view of no notice u/s 143(2) of I.T. Act 1961 having been issued before framing assessment even though assessee has submitted return of income on 23/10/2018 in respect

SHRI SANJAY DHANRAJ JAIN,NAGPUR vs. DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-1(3), NAGPUR

In the result, assessee' appeal for A

section 69.\nFurther, we may point out that section 68 under which the addition has\nbeen made by the Assessing Officer reads as under:\n\"68. Where any sum is found credited in the books of an assessee\nmaintained for any previous year. and the assessee offers no\nexplanation about the nature and source thereof or the explanation\noffered

SHRI SANJAY DHANRAJ JAIN,NAGPUR vs. DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-1(3), NAGPUR

section 69.\nFurther, we may point out that section 68 under which the addition has\nbeen made by the Assessing Officer reads as under:\n\"68. Where any sum is found credited in the books of an assessee\nmaintained for any previous year. and the assessee offers no\nexplanation about the nature and source thereof or the explanation\noffered

SHRI SANJAY DHANRAJ JAIN,NAGPUR vs. DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-1(3), NAGPUR

section 69.\nFurther, we may point out that section 68 under which the addition has\nbeen made by the Assessing Officer reads as under:\n\"68. Where any sum is found credited in the books of an assessee\nmaintained for any previous year. and the assessee offers no\nexplanation about the nature and source thereof or the explanation\noffered

SIMA RAVISINGH KACHHAWAH,UMRER vs. ITO WARD 3(4), NAGPUR

In the result, appeal filed by the assessee is allowed for statistical purposes

Bench: Shripavan Kumar Gadalesima Ravisingh Kachhawah, Girad Road, Om Nagar Umrer, ……………. Appellant Nagpur- 441203 Maharastra, Pan – Aqmpk2899K V/S Income Tax Officer ……………. Respondent Ward–3(4), Nagpur Assessee By: Shri.D.P. Lohiya.Ar Revenue By :Shri Surjit Kumar Saha.Sr.Dr

147 read with Sections 144 and 144B of the Income Tax Act, 1961, on 15.03.2023, without due consideration of the facts and circumstances of the case, and in raising an arbitrary and excessive demand of Rs. 9,76,265/-, rendering the assessment order unjustified, unwarranted, and bad in law. 6. On the facts and circumstances of the case the learned

BHAWANA HARIRAM LAVHALE,AMRAVATI vs. INCOME TAX OFFICER WARD-3, AMRAVATI

In the result, assessee’s appeal for the assessment year 2013–14 is allowed for statistical purposes

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

234B and 234C of I.T. Act 1961. Without prejudice, levy of interest under section 234A, 234C and 234C of I.T. Act 1961 is unjustified, unwarranted and excessive. 13. Any other ground that shall be prayed at the time of hearing.” 5. Facts in brief:- The appellant is an individual and has not filed return of income for assessment year

BHAWANA HARIRAM LAVHALE,AMRAVATI vs. INCOME TAX OFFICER,WARD-3, AMRAVATI

In the result, assessee’s appeal for the assessment year 2013–14 is allowed for statistical purposes

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

234B and 234C of I.T. Act 1961. Without prejudice, levy of interest under section 234A, 234C and 234C of I.T. Act 1961 is unjustified, unwarranted and excessive. 13. Any other ground that shall be prayed at the time of hearing.” 5. Facts in brief:- The appellant is an individual and has not filed return of income for assessment year