VIRUPAXAPPA SIDRAMAPPA BEMBALGI,BELAGAVI vs. INCOME TAX OFFICER, BELGAVU

Bench: Hon’Ble Shri Pavan Kumar Gadale & Shri G. D. Padmahshaliita Nos. 011/Pan/2025 Assessment Year : 2017-18 M/S Virupakaxappa Sidramappa Bembalgi 580, Saraf Katta, Shahapur, Belgaum-590003. Pan : Aadfv3936F . . . . . . . Appellant

disallowance of (i) total URD purchases of ₹1,61,75,480/- and (ii) Labour charges paid for ornamentation ₹3,86,340/- or Option- (B) addition of ₹45,29,674/- on account of estimation of gross profit @40% of estimated ad-hoc sales/turnover of ₹250Lakhs. Since the first option(A) will result into profit of more than the turnover

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’].

1) or 253(2) of the Act is required to be filed within two months from the end of the month in which order sought to be appealed is communicated to the assessee. In view thereof the present twin appeals are filed with a 19 days delay. Thus these appeals are filed beyond the statutory period of two month from

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’].

1) or 253(2) of the Act is required to be filed within two months from the end of the month in which order sought to be appealed is communicated to the assessee. In view thereof the present twin appeals are filed with a 19 days delay. Thus these appeals are filed beyond the statutory period of two month from

HERALD PUBLICATIONS PVT. LTD,PANAJI vs. NATIONAL FACELESS APPEAL CENTRE, ASSESSMENT UNIT, DELHI

Bench: Hon’Ble Shri Pavan Kumar Gadale & Shri G. D. Padmahshaliita Nos. 160/Pan/2025 Assessment Year : 2018-19 Herald Publication Pvt. Ltd. Ag-6, Campal Trade Centre, Opp. Taj Vivanta, H/H Mili, Panaji, Goa-403001 Pan : Aaach4580K . . . . . . . Appellant V/S National Faceless E-Asstt. Centre, Delhi. . . . . . . . Respondent

1) of the Act. Consequent to such disallowance & determination of income u/s 147 r.w.s. 144B of the Act, a penalty proceedings u/s 270A of the Act were initiated. The assessee choose to remain silent. In the absence of rebuttal, the penalty proceeding ceased by imposing penalty equal to 50% of tax sought to have evaded by an order dt. 26/09/2023

THE BRAHMALING MULTIPURPOSE CO-OP SOCIETY LTD,BELGAUM vs. INCOME TAX OFFICER, WARD -3, BELGAUM

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

Bench: SHRI PAVAN KUMAR GADALE (Judicial Member)

1) of the Act are issued calling for details in support of return of income filed. The assesse has filed the information of members of the society along with interest income on deposits with the cooperative banks, cooperative society and scheduled bank. The Assessing Officer (A.O) has dealt on the submissions/details of regular members and associate/nominal members and find that

M/S SHIRAGAO PRATHAMIK KRISHI PATTIN SAHAKARI BANK NIYAMIT,BELAGAVI vs. INCOME TAX OFFICER, WARD - 1(3), BELAGAVI

The appeals of the assessee are allowed

Bench: Shri Satbeer Singh Godara

section 80P(2)(d) deduction claim of Rs.9,35,731/- representing interest income derived from fixed deposits made with M/s. Belgavi District Cooperative Credit Bank, Belagavi for the reason that such receipts from cooperative societies is not eligible for the foregoing relief. 5. I have given my thoughtful consideration to vehement rival contentions and find no merit in the Revenue

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’]

disallowance of excess depreciation of 1,82,643/- . 2.4 Aggrieved assessee company preferred an appeal u/s 246A r.w.s. 249 of the Act before the Ld. CIT(A) on 25/01/2012 which was instituted for first appellate adjudication vide Appeal No : CIT(A)/PNJ/10310/2019-20 and dismissed by the Ld. CIT(A) by an order dt. 17/03/2025. ITAT-Panaji Page

BANDEKAR BROTHERS PRIVATE LIMITED,VASCO-DA-GAMA, GOA vs. ASSISTANT COMMISSIONER OF INCOME TAX, PANAJI, GOA

The appeal of the assessee is PARTLY ALLOWED in aforestated terms

Bench: Hon’Ble Shri Pavan Kumar Gadale & Shri G. D. Padmahshaliassessment Years: 2013-14 Bandekar Brothers Pvt. Ltd. Post Box No. 11, Suvarna Bandekar Bldg., Swatantra Path, Vasco-Da-Gama Goa-403802 Pan: Aaacb5502B . . . . . . . Appellant V/S Asstt. Commissioner Of Income Tax, Circle-2(1), Panaji, Goa. . . . . . . . Respondent Represented Assessee By: Mr Pramod & Mr Shriniwas Deshpande [‘Ld. Ar’] Revenue By: Mr M Satish & Mr Renga Rajan [‘Ld. Dr’] Date Of Conclusive Hearing : 12/01/2026 Date Of Pronouncement : 11/02/2026 Order Per G. D. Padmahshali; This Assessee’S Appeal Filed U/S 253(1) Of The Income-

35 of 39 M/s Bandekar Brothers Pvt. Ltd. Vs ACIT ITA No. 038/PAN/2025 AY: 2013-14 circulating commodity/inventory therefore brought in existence an asset falling within the ambarella of ‘capital asset’ of s/s 14 of section 2 of the Act and (c) the impugned sum of ₹16Crs paid by the appellant in the form of ‘stamp duty’ is in nature

SURAJDATTA SAGUN MORAJKAR,NERUL vs. ASST. COMMISSIONER OF INCOME TAX, CIRCLE-1(1), PANAJI GOA, PANAJI

Bench: Hon’Ble Shri Pavankumar Gadale & Shri G. D. Padmahshaliita Nos. 122/Pan/2024 Assessment Year : 2017-18 Surajdatta Sagun Morajkar C/O. Sun Estate Developers, Next To Sal De Goa, Bhatti Waddo, Bardez, Goa-403114 Pan : Aempm7614J . . . . . . . Appellant

section 5A of the Act was for the year under consideration engaged in the business of real estate development and construction in the name & style of ‘Sun Estate Developer’ and also a partner in M/s ‘SM Venture.’ The assessee filed his return of income on 30/03/2018 declaring total income at ₹4,47,72,090/- which was subjected to scrutiny

THE SHIRODA PROGRESSIVE URBAN MULTIPURPOSE COOPERATIVE SOCIETY LIMITED,PONDA vs. INCOME TAX OFFICER, PANAJI

In the result, the two appeals filed by the assessee are allowed for statistical purposes

Bench: Shri Pavan Kumar Gadalei T A. Nos.272 & 273/Pan/2025 (A.Y. 2018-19 & 2020-21 ) The Shiroda Progressive Urban Vs I T O, Multipurpose Cooperative National E Assessment . Society Limited, Centre, Shop.No.4, Opp: Police Station, Delhi. Shiroda Bhat, Ponda-403103.Goa Pan .No. Aabat7206P (अपीलार्थी/Appellant) (प्रत्यर्थी/Respondent)

35,940/- and passed the order u/sec143(3) r.w.s143(3A)&143(3B) of the Act dated 05.4.2021. 5. Aggrieved by the order u/sec 143(3) of the Act, the assessee has filed an appeal before the CIT(A), whereas the CIT(A) has considered the grounds of appeal, submissions of the assessee and findings

THE SHIRODA PROGRESSIVE URBAN MULTIPURPOSE COOPERATIVE SOCIETY LIMITED,PONDA vs. INCOME TAX OFFICER, PANAJI

In the result, the two appeals filed by the assessee are allowed for statistical purposes

Bench: Shri Pavan Kumar Gadalei T A. Nos.272 & 273/Pan/2025 (A.Y. 2018-19 & 2020-21 ) The Shiroda Progressive Urban Vs I T O, Multipurpose Cooperative National E Assessment . Society Limited, Centre, Shop.No.4, Opp: Police Station, Delhi. Shiroda Bhat, Ponda-403103.Goa Pan .No. Aabat7206P (अपीलार्थी/Appellant) (प्रत्यर्थी/Respondent)

35,940/- and passed the order u/sec143(3) r.w.s143(3A)&143(3B) of the Act dated 05.4.2021. 5. Aggrieved by the order u/sec 143(3) of the Act, the assessee has filed an appeal before the CIT(A), whereas the CIT(A) has considered the grounds of appeal, submissions of the assessee and findings

M/S SOVA,PANAJI vs. PR. COMMISSIONER OF INCOME TAX, PANAJI

The appeal of the assessee is PARTLY ALLOWED in aforestated terms

Bench: Hon’Ble Shri Pavan Kumar Gadale & Shri G. D. Padmahshaliassessment Years: 2018-19 M/S Sova Salgaocar Bhavan, Altinho, Panaji, Goa-403001. Pan: Aacfs8862Q . . . . . . . Appellant V/S Pr. Commissioner Of Income Tax, Panaji, Goa. . . . . . . . Respondent

35 u/s 246A of the Act. Same was perused and noted that the said appeal was filed by the assessee on 17/02/2024 which is much after passing of impugned order under challenge therefore former arguments advanced by the Ld. AR and plea of the appellant assessee without necessitating much deliberation thereon/therefor stands rejected at the very threshold. ITAT-Panaji Page

ASSISTANT COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE, PANAJI, PANAJI, GOA vs. BAGKIYA CONSTRUCTIONS PVT. LTD, GOA

The appeal of the Revenue is partly allowed in aforestated terms

Bench: Hon’Ble Shri Pavan Kumar Gadale & Shri G. D. Padmahshaliassessment Years: 2017-2018 Asstt. Commissioner Of Income Tax, Central Circle, Panaji, Goa. . . . . . . . Appellant V/S M/S Bagkiya Construction Pvt. Ltd. Sf-3, Building No.-3. Techno Cidade, Chogam Rd., Alto Porvorim, Goa-403521. Pan: Aaccb9382M . . . . . . . Respondent Represented Assessee By: None For The Respondent Revenue By: Mr Senthil Kumar [‘Ld. Dr’] Date Of Conclusive Hearing : 29/01/2026 Date Of Pronouncement : 27/02/2026 Order Per G. D. Padmahshali; This Revenue’S Appeal Filed U/S 253(2) Of The Income- Tax Act, 1961 [‘The Act’] Challenges The Order Dt. 29/05/2023 Passed U/S 250 Of The Act By Commissioner Of Income Tax(Appeals-2), Panaji [‘Ld. Cit(A)’] Which In Turn Wheeled From The Order Dt. 25/08/2021 Passed U/S 147 Of The Act By Acit, Central Circle, Panaji, Goa [‘Ld. Ao’] Anent To Assessment Year 2017-18.[‘Ay’]

section 133A of the Act. These IMs were confronted and various statements were recorded. As stated earlier hereinbefore statement of four employees E1 to E4 (as placed on record by the Revenue) were recorded who deposed confirming the transaction from the IMs confronted. The E2, Mr Arjunan in addition to confirming the bogus sub-contracting also deposed to have dealt

ASST. COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE, PANAJI vs. M/S SALITHO ORES PVT. LTD, PANAJI

In the result, appeal of the assessee is allowed

Bench: Shri Inturi Rama Rao & Shri Partha Sarathi Chaudhury(Through Virtual Hearing) M/S. Salitho Ores Pvt. Ltd., Vs Acit, Circle-1, Salgaocar Bhavan, Altinho, Margao Panaji, Goa. Pan: Aabcs 8859 F Appellant Respondent

disallowance made by the AO u/s. 43B of the Act amounting to Rs.5,85,17,297/- cannot be sustained and hence, is deleted. Ground No.2 is allowed.” 4. The Department in this ground substantially had contended that there has been a violation of Rule 46A(3) of the Income Tax Rules, 1962 by the ld. CIT(A) in admission

M/S SALITHO ORES PRIVATE LIMITED,PANAJI vs. ASST. COMMISSIONER OF INCOME TAX, CIRCLE - M1, MARGAO

In the result, appeal of the assessee is allowed

Bench: Shri Inturi Rama Rao & Shri Partha Sarathi Chaudhury(Through Virtual Hearing) M/S. Salitho Ores Pvt. Ltd., Vs Acit, Circle-1, Salgaocar Bhavan, Altinho, Margao Panaji, Goa. Pan: Aabcs 8859 F Appellant Respondent

disallowance made by the AO u/s. 43B of the Act amounting to Rs.5,85,17,297/- cannot be sustained and hence, is deleted. Ground No.2 is allowed.” 4. The Department in this ground substantially had contended that there has been a violation of Rule 46A(3) of the Income Tax Rules, 1962 by the ld. CIT(A) in admission

ASST. COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE, PANAJI vs. M/S SALITHO ORES PVT. LTD, PANAJI

In the result, appeal of the assessee is allowed

Bench: Shri Inturi Rama Rao & Shri Partha Sarathi Chaudhury(Through Virtual Hearing) M/S. Salitho Ores Pvt. Ltd., Vs Acit, Circle-1, Salgaocar Bhavan, Altinho, Margao Panaji, Goa. Pan: Aabcs 8859 F Appellant Respondent

disallowance made by the AO u/s. 43B of the Act amounting to Rs.5,85,17,297/- cannot be sustained and hence, is deleted. Ground No.2 is allowed.” 4. The Department in this ground substantially had contended that there has been a violation of Rule 46A(3) of the Income Tax Rules, 1962 by the ld. CIT(A) in admission

M/S R. S. SHETYE & BROS,PANAJI vs. ASSISTANT COMMISSIONER OF INCOME TAX, CIRCLE -1(1), PANAJI

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

Bench: Shri Pavan Kumar Gadale & Shri G D Padmahshalii T A. No.37/Pan/2023 (A.Y.2016-17) R.S.Shetye & Bros, Vs Acit 1(1), Flat.No.14, 1 St Floor, Aaykar Bhavan, . Trionara Apartments, Edc, Patto, New Muncipal Market, Panjim Panaji- Goa-403001. Goa-403001. Pan .No.Aabfr9785N (अपीलार्थी/Appellant) (प्रत्यर्थी/Respondent)

disallowance of community development and village welfare 7 ITA. No.37/PAN/2023 R.S.Shetye and Bros. expenses and this ground of appeal allowed in favour of the assessee. 7.On the second disputed issue, the Ld.AR mentioned that the expenses on stamp duty and registration charges of renewal of mining lease, paid as part payment towards second renewal of mining lease for the period

THE SANKHLI URBAN CO-OPERATIVE CREDIT SOCIETY LTD,SANKHLI vs. INCOME TAX OFFICER, WARD - 2(4), PANAJI

Bench: Hon’Ble Shri Pavan Kumar Gadale & Shri G. D. Padmahshaliita Nos. 058/Pan/2025 Assessment Year : 2014-15

1) of the Act. Subsequently the case of the assessee selected for scrutiny and consequential assessment was completed u/s 143(3) of the Act vide order dt. 21/10/2016 whereby two additions were made viz; (i) claim for deduction of ₹54,91,931/- u/s 80P of the Act was disallowed and (ii) ₹51,56,366/- was disallowed

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

35,791/-. 4. Aggrieved by aforestated assessment the assessee filed an appeal before Ld. NFAC on 23/04/2025, which came to be dismissed in absence of documentary evidence. Aggrieved thereby the assessee came in present appeal on following grounds; Not dealing with the submissions of the Appellant 1. The NFAC erred in not dealing with the submissions of the Appellant