JENNY ELTON VALES,DONA PAULA vs. ITO, WARD - 5, MARGAO

In the result, the appeal of assessee in ITA No

Bench: Shri S.S. Viswanethra Ravi

reopening of assessment made u/s. 143(3)/147 of the Act is valid and ground No. 1 raised by the assessee is dismissed. 13. Ground Nos. 2 and 3 raised by the assessee challenging the action of CIT(A) in confirming the addition made in the hands of the assessee in terms of operation of provisions

JENNY ELTON VALES,DONA PAULA vs. ITO, WARD - 5, MARGAO

In the result, the appeal of assessee in ITA No

Bench: Shri S.S. Viswanethra Ravi

reopening of assessment made u/s. 143(3)/147 of the Act is valid and ground No. 1 raised by the assessee is dismissed. 13. Ground Nos. 2 and 3 raised by the assessee challenging the action of CIT(A) in confirming the addition made in the hands of the assessee in terms of operation of provisions

INCOME TAX OFFICER, WARD 1(2), BELAGAVI vs. SH. GIRISH PRAKASH VERNEKAR, BELAGAVI

In the result, the appeal filed by the Revenue is dismissed and the cross objection

Bench: Shri Shamim Yahya, Am & Shri Ram Lal Negi, Jm

reopened assessments were getting time barred by 31-12-2016. But it appears that neither notice U/S 133[6] or Summons U/S 131 was issued to Rajesh Exports. Simultaneously appellant also by RPAD letter dated 9-12- 2016 requested Rajesh Exports to furnish the details in respect of alleged Cash Sales of Rs.4,37,07,261/-. However, there was absolutely

SONALI MAHENDRA NAIK GAUNEKAR,PANAJI vs. INCOME TAX OFFICER, WARD - 1(1), PANAJI

The appeal of the assessee is partly allowed for statistical purpose

Bench: Hon’Ble Shri Pavan Kumar Gadale & Shri G. D. Padmahshali

disallowance of indexed cost of acquisition made by the AO on the ground of alleged failure to furnish requisite documentary evidences either before the AO or during the appeal proceedings despite the fact that the same was duly provided. Failure to adhere to mandatory procedure for reopening of assessment

M/S SANKAMTAL HOTEL PRIVATE LTD.,BELAGAVI vs. THE ASST. COMMISSIONER OF INCOME TAX CIRCLE - 2 (1), BELAGAVI

In the result, the appeal of the assessee is allowed

Bench: Shri Chandra Mohan Garg & Shri Girish Agrawalassessment Year: 2008-09 M/S Sankamtal Hotel Acit, Circle-1, Pvt. Ltd. Belagavi S. Parthasarathi, Advocate, 3/1, Pranava Vs. Complex, 5Th Cross, Malleswaram, Bangalore- 560 003. Pan: Aadcs 5106 P (Appellant) (Respondent) Present For: Appellant By : Smt. Pratibha R., Advocate Respondent By : Shri Mayur Kamble, Sr. Dr Date Of Hearing : 14.06.2022 Date Of Pronouncement : 30.08.2022 O R D E R Per Girish Agrawal: This Appeal By The Assessee Is Arising Out Of The Order Of Ld. Cit(A), -Belagavi In Ita No.51/Bgm/2016-17 Dated 25.02.2018 Against The Assessment Order Passed By Acit, Circle-2(1), Belagavi U/S 143(3) Of The Income-Tax Act, 1961 (Hereinafter Referred To As The ‘Act’) Dated 14.03.2016 For A.Y. 2008-09. 2. There Is A Delay Of Five Days In Filing The Present Appeal For Which The Petition For Condonation Of Delay & Affidavit Are Placed On Record. From The Affidavit, We Note That The Assessee Was Out Of Station When The Appeal Memo Was Sent To Him By The Counsel For Its Signature & Therefore A Short Delay Of 5 Days Occurred. Considering The Petition & In The Interest Of Justice & Fair Play, We Find It Proper To Admit The Appeal & Proceed To Adjudicate Thereon.

reopening u/s. 147 of the Act prior to the commencement of assessment proceedings, the assessment as made was opposed to law and against the principles of natural justice and thus liable to be cancelled. 4. The Id. CIT(A) ought to have appreciated that the expenditures incurred towards change of flooring and bathroom fittings without changing the structure

ITO, WARD - 2(1), MANGALURU vs. M/S S. K & UDUPI DISTRICT CO-OPERATIVE FISH MARKETING FEDERATION LIMITED, MANGALURU

Bench: Hon’Ble Shri S. S. Godara & Shri G. D. Padmahshali(Through Virtual Hearing) आयकर अपऩल सं. / Ita No.38 To 43/Pan/2022 निर्धारण वषा / Assessment Year : 2012-13 To 2014-15 & 2016-17 To 2018-19

reopened by the Ld. AO u/s 147 of the Act after prior approval Ld. PCIT dt. 30/03/2019. 3.3 After considering the submission of the appellant, the Ld. AO culminated the assessment u/s 144 r.w.s. 147 of the Act on 26/12/2019 by disallowing

ITO, WARD - 2(1), MANGALURU vs. M/S S. K & UDUPI DISTRICT CO-OPERATIVE FISH MARKETING FEDERATION LIMITED, MANGALURU

Bench: Hon’Ble Shri S. S. Godara & Shri G. D. Padmahshali(Through Virtual Hearing) आयकर अपऩल सं. / Ita No.38 To 43/Pan/2022 निर्धारण वषा / Assessment Year : 2012-13 To 2014-15 & 2016-17 To 2018-19

reopened by the Ld. AO u/s 147 of the Act after prior approval Ld. PCIT dt. 30/03/2019. 3.3 After considering the submission of the appellant, the Ld. AO culminated the assessment u/s 144 r.w.s. 147 of the Act on 26/12/2019 by disallowing

ITO, WARD - 2(1), MANGALURU vs. M/S S. K & UDUPI DISTRICT CO-OPERATIVE FISH MARKETING FEDERATION LIMITED, MANGALURU

Bench: Hon’Ble Shri S. S. Godara & Shri G. D. Padmahshali(Through Virtual Hearing) आयकर अपऩल सं. / Ita No.38 To 43/Pan/2022 निर्धारण वषा / Assessment Year : 2012-13 To 2014-15 & 2016-17 To 2018-19

reopened by the Ld. AO u/s 147 of the Act after prior approval Ld. PCIT dt. 30/03/2019. 3.3 After considering the submission of the appellant, the Ld. AO culminated the assessment u/s 144 r.w.s. 147 of the Act on 26/12/2019 by disallowing

ITO, WARD - 2(1), MANGALURU vs. M/S S. K & UDUPI DISTRICT CO-OPERATIVE FISH MARKETING FEDERATION LIMITED, MANGALURU

Bench: Hon’Ble Shri S. S. Godara & Shri G. D. Padmahshali(Through Virtual Hearing) आयकर अपऩल सं. / Ita No.38 To 43/Pan/2022 निर्धारण वषा / Assessment Year : 2012-13 To 2014-15 & 2016-17 To 2018-19

reopened by the Ld. AO u/s 147 of the Act after prior approval Ld. PCIT dt. 30/03/2019. 3.3 After considering the submission of the appellant, the Ld. AO culminated the assessment u/s 144 r.w.s. 147 of the Act on 26/12/2019 by disallowing

ITO, WARD - 2(1), MANGALURU vs. M/S S. K & UDUPI DISTRICT CO-OPERATIVE FISH MARKETING FEDERATION LIMITED, MANGALURU

Bench: Hon’Ble Shri S. S. Godara & Shri G. D. Padmahshali(Through Virtual Hearing) आयकर अपऩल सं. / Ita No.38 To 43/Pan/2022 निर्धारण वषा / Assessment Year : 2012-13 To 2014-15 & 2016-17 To 2018-19

reopened by the Ld. AO u/s 147 of the Act after prior approval Ld. PCIT dt. 30/03/2019. 3.3 After considering the submission of the appellant, the Ld. AO culminated the assessment u/s 144 r.w.s. 147 of the Act on 26/12/2019 by disallowing

ITO, WARD - 2(1), MANGALURU vs. M/S S. K & UDUPI DISTRICT CO-OPERATIVE FISH MARKETING FEDERATION LIMITED, MANGALURU

Bench: Hon’Ble Shri S. S. Godara & Shri G. D. Padmahshali(Through Virtual Hearing) आयकर अपऩल सं. / Ita No.38 To 43/Pan/2022 निर्धारण वषा / Assessment Year : 2012-13 To 2014-15 & 2016-17 To 2018-19

reopened by the Ld. AO u/s 147 of the Act after prior approval Ld. PCIT dt. 30/03/2019. 3.3 After considering the submission of the appellant, the Ld. AO culminated the assessment u/s 144 r.w.s. 147 of the Act on 26/12/2019 by disallowing

DAMODAR MANGALJI & COMPANY LIMITED,PANAJI vs. THE JOINT COMMISSIONER OF INCOME TAX, RANGE - 1, PANAJI

Appeals stands DISMISSED

Bench: Hon’Ble Shri Pavan Kumar Gadale & Shri G. D. Padmahshaliita Nos. 034 & 035/Pan/2025 Assessment Year : 2011-12 & 2014-15 Damodar Mangalji & Company Ltd. Damodar Niwas, 1St Floor, Mc Road, Panaji, Goa-403001. Pan : Aaacd6880G . . . . . . . Appellant V/S Jt./Asstt. Commissioner Of Income Tax, Range-1/Circle-1(1), Goa. . . . . . . . Respondent Appearances Assessee By : Adv Rahul Sarda [‘Ld. Ar’] Revenue By : Mr M Satish [‘Ld. Dr’] Date Of Conclusive Hearing : 20/11/2025 Date Of Pronouncement : 18/12/2025 Order Per G. D. Padmahshali; The Captioned Twin Appeals Of Assessee Instituted U/S 253(1) Of The Income-Tax Act, 1961 [‘The Act’] Are Directed Against Separate Din & Order 1070138041(1) Dt. 08/11/2024 & 1070321994(1) Dt. 13/11/2024 Passed U/S 250 Of The Act By National Faceless Appeal Centre, Delhi [‘Ld. Nfac/Cit(A)’] Which Sprang From Assessment Orders Passed U/S 143(3) Of The Act Anent To Assessment Years 2011-12 & 2014-15 [‘Ay’].

disallowances. Finding appellant being indifferent, the Ld. NFAC vide para 4.5 advanced ex-parte on merits and upheld the disallowance/addition by a reasoned order. ITAT-Panaji Page 17 of 32 Damodar Mangalji & Company Ltd. Vs JCIT/ACIT ITA Nos.034 & 035/PAN/2025 AY: 2011-12 & 2014-15 20. The perusal of case record of impugned proceedings for AY 2014-15 revealed much alike

DAMODAR MANGALJI & COMPANY LIMITED,PANAJI vs. ASSISTANT COMMISSIONER OF INCOME TAX, CIRCLE - 1(1), PANAJI

Appeals stands DISMISSED

Bench: Hon’Ble Shri Pavan Kumar Gadale & Shri G. D. Padmahshaliita Nos. 034 & 035/Pan/2025 Assessment Year : 2011-12 & 2014-15 Damodar Mangalji & Company Ltd. Damodar Niwas, 1St Floor, Mc Road, Panaji, Goa-403001. Pan : Aaacd6880G . . . . . . . Appellant V/S Jt./Asstt. Commissioner Of Income Tax, Range-1/Circle-1(1), Goa. . . . . . . . Respondent Appearances Assessee By : Adv Rahul Sarda [‘Ld. Ar’] Revenue By : Mr M Satish [‘Ld. Dr’] Date Of Conclusive Hearing : 20/11/2025 Date Of Pronouncement : 18/12/2025 Order Per G. D. Padmahshali; The Captioned Twin Appeals Of Assessee Instituted U/S 253(1) Of The Income-Tax Act, 1961 [‘The Act’] Are Directed Against Separate Din & Order 1070138041(1) Dt. 08/11/2024 & 1070321994(1) Dt. 13/11/2024 Passed U/S 250 Of The Act By National Faceless Appeal Centre, Delhi [‘Ld. Nfac/Cit(A)’] Which Sprang From Assessment Orders Passed U/S 143(3) Of The Act Anent To Assessment Years 2011-12 & 2014-15 [‘Ay’].

disallowances. Finding appellant being indifferent, the Ld. NFAC vide para 4.5 advanced ex-parte on merits and upheld the disallowance/addition by a reasoned order. ITAT-Panaji Page 17 of 32 Damodar Mangalji & Company Ltd. Vs JCIT/ACIT ITA Nos.034 & 035/PAN/2025 AY: 2011-12 & 2014-15 20. The perusal of case record of impugned proceedings for AY 2014-15 revealed much alike

SALGAOCAR MINING INDUSTRIES PVT. LTD,PANAJI vs. DEPUTY COMMISSIONER OF INCOME TAX, CIRCLE - 1, MARGAO

The appeal of the assessee is PARTLY ALLOWED in aforestated terms

Bench: Hon’Ble Shri Pavan Kumar Gadale & Shri G. D. Padmahshaliassessment Years: 2006-2007 M/S Salgaocar Mining Industries Pvt Ltd. Salgaonkar Bhava, Altino, Panaji, Goa-403001. Pan: Aabcs8862N . . . . . . . Appellant V/S Dy. Commissioner Of Income Tax, Circle-1, Margao, Goa. . . . . . . . Respondent Represented Assessee By: Mr Sukhsagar Syal [‘Ld. Ar’] Revenue By: Ms Rijjula Uniyal [‘Ld. Dr’] Date Of Conclusive Hearing : 20/01/2026 Date Of Pronouncement : 29/01/2026 Order Per G. D. Padmahshali; This Assessee’S Appeal Filed U/S 253(1) Of The Income- Tax Act, 1961 [‘The Act’] Impugns The Order Dt. 20/03/2025 Passed U/S 250 Of The Act By Commissioner Of Income Tax(Appeals-2), Panaji [‘Ld. Cit(A)’] Which In Turn Dealt With Order Dt. 20/12/2011 Passed U/S 144 Of The Act By Dcit, Circle-1, Margao Goa [‘Ld. Ao’] Anent To Assessment Year 2006-07.[‘Ay’]

reopened u/147 of the Act to reassess the income escaped the assessment. For the non- compliance on the part of the assessee, the assessment u/s 144 r.w.s. 147 of the Act culminated by an order dt. 20/12/2011 wherein the Ld. AO made to additions owning to; (1) difference of business revenue/receipts of 87,62,350/- remained undisclosed in the return

MR. AGNELO SOCORRO JOAQUIM VIEGAS,PANAJI vs. INCOME TAX OFFICER, WARD - 1(5), PANAJI

Bench: Hon’Ble Shri Pavan Kumar Gadale & Shri G. D. Padmahshaliita Nos. 069/Pan/2025 & Sa 06/Pan/2025 Assessment Year : 2011-12 Agnelo Socorro Joaquim Viegas H. No. 373, Galliwaddo, Taleigao, Caranzalem, Goa-403002. Pan : Akapv9049C . . . . . . . Appellant V/S Income Tax Officer, Ward-1(5), Panaji, Goa. . . . . . . . Respondent Appearances Assessee By : Mr Vinesh Pikale [‘Ld. Ar’] Revenue By : Mr Sanket Deshmukh[‘Ld. Dr’] Date Of Conclusive Hearing : 21/08/2025 Date Of Pronouncement : 26/08/2025 Order Per G. D. Padmahshali; The Captioned Appeal Of The Assessee Impugns Din & Order No. Itba/Apl/S/250/2024-25/1073026397(1) Dt. 07/02/2025 Passed By Addl./Jt. Commissioner Of Income Tax, Appeals(2), Ahmedabad [‘Ld. Cit(A)’] U/S 250 Of The Income-Tax Act, 1961 [‘The Act’] Which In Turn Sprung Out Of Order Of Assessment Dt. 27/12/2018 Passed U/S 143(3) R.W.S. 147 Of The Act By The Income

reopening of assessee’s case u/s 147 of the Act. Pursuant to reassessment notice the appellant filed his return declaring income of ₹1,53,590/- and claimed that the said income was offered on presumptive taxation basis. The said return was subjected to scrutiny and the appellant was called upon to adduce documentary evidence in support of his claim