M/S KAMAT REAL ESTATE DEVELOPERS,,PANAJI vs. THE ASSISTANT COMMISSIONER OF INCOME TAX, CIRCLE-1(1), PANAJI., PANAJI

In the result, appeal of the Assessee is allowed

Bench: Shri Chandra Mohan Garg & Shri Girish Agrawal

reassessment proceedings initiated u/s 147 of I.T. Act by the Assessing Officer were valid, although nothing had been recorded by the Assessing Officer in the reasons about any failure on the part of the Appellant Firm to disclose fully and truly all material facts necessary for the completion of 5 ITA.No.336/PAN./2018 M/s. Kamat Real Estate Developers, Panaji

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’]

reassessment proceedings were initiated calling upon the assessee to file return in response thereto within 30 days therefrom. The assessee filed a return in response thereto on 26/04/2021 declaring total income of ₹3,39,38,824/-which was subjected to scrutiny vide notice dt. 04/05/2021 issued u/s 143(2) of the Act. 3.4 From the verification & analysis of impounded

MARIA ESTIBEIRO,PANAJI vs. DCIT, CIRCLE - 1(1), PANAJI

The appeal stands ALLOWED

Bench: Hon’Ble Shri Pavan Kumar Gadale & Shri G. D. Padmahshaliassessment Year : 2012-13 Maria Estibeiro L/H Of Jacintodas Estibeiro 781, St. Marys Colony, Miramar, Goa. Pan:Aabpe2798N . . . . . . . Appellant V/S Dy. Commissioner Of Income Tax, Panaji, Goa. . . . . . . . Respondent Appearances Assessee By : Mr D E Robinson [‘Ld. Ar’] Revenue By : Mr Vimalraj Periyagounden [‘Ld. Dr’] Date Of Conclusive Hearing : 25/03/2025 Date Of Pronouncement : 24/04/2025 Order Per G. D. Padmahshali, Am; By This Appeal Captioned Appellant Impugns Din & Order No. 1060336601(1) Dt. 31/01/2024 Passed U/S 250 Of The Income-Tax Act, 1961 [‘The Act’] By The National Faceless Appeal Centre, Delhi [‘Nfac’] Which In Turn Arisen Out Of Order Of Assessment Passed U/S 147 R.W.S. 144 Of The Act For Assessment Year 2012- 13 [‘Ay’].

3. The learned Commissioner of Income Tax (Appeals) erred in holding that appellant who lawfully had no access to half share of assets of her spouse is bound to explain credits in the bank account of her deceased spouse. 4. The re-assessment order is not valid in law since all the requirements of provisions of section

M/S CHOWGULE AND COMPANY (SALT) PVT. LTD,MORMUGAO vs. THE ACIT, CIRCLE - 2, MARGAO

The appeal of the assessee is partly allowed in terms of aforesaid observation

Bench: Shri Ravish Sood & Shri Jamlappa D. Battullआयकर अपील सं. / Ita No. : 390/Pan/2017 करधििाारण वर्ा / Assessment Year : 2012-2013 M/S Chowgule & Company (Salt) Pvt Ltd., Chowgule House, Mormugao Harbour, Goa – 403803. Pan: Aabcc 5595 J . . . . . . . अपीलार्थी / Appellant बिाम / V/S Asstt. Commissioner Of Income Tax, Circle-2, Margao, Goa. . . . . . . . प्रत्यर्थी / Respondent द्वारा / Appearances Assessee By : Ms Hiral Sejpal Revenue By : Shri Sourabh Nayak सुनवाई की तारीख / Date Of Conclusive Hearing : 24/02/2022 घोषणा की तारीख / Date Of Pronouncement : 29/04/2022 आदेश / Order Per Jamlappa D Battull Am; The Present Appeal Filed By The Appellant Assessee Is Directed Against The Order Of Commissioner Of Income Tax- Appeals, Panaji-1 [For Short “Cit(A)”] Dt. 09/10/2017 Passed U/S 250 Of The Income-Tax Act, 1961 [For Short “The Act”], Which In Turn Tousled Out Of Order Of Assessment Of Assistant Commissioner Of Income Tax-Circle-2, Margoa [For Short “Ao”] Dt. 27/07/2014 Passed U/S 143(3) Of The Act, For The Assessment Year [For Short “Ay”] 2012-2013. Itat-Panaji Page 1 Of 23

3) The provisions of sub-section (2) shall also apply in relation to a case where an assessee claims that no expenditure has been incurred by him in relation to income which does not form part of the total income under this Act : Provided that nothing contained in this section shall empower the Assessing Officer either to reassess under section

MOUREEN CAMARA,PANAJI vs. ASSESSMENT CENTRE, INCOME TAX DEPARTMENT, DELHI

Bench: Hon’Ble Shri Pavan Kumar Gadale & Shri G. D. Padmahshaliita Nos. 200/Pan/2023 Assessment Year : 2016-17 Moureen Camara Lonic Apartment, 1St Floor, Albamar Road, Tiswadi, Panaji, Goa-403001. Pan : Abmpc9038M . . . . . . . Appellant V/S Income Tax Officer, Ward-1(5), Panaji. . . . . . . . Respondent Appearances Assessee By : Mr D E Robinson [‘Ld. Ar’] Revenue By : Ms Rijjula Uniyal [‘Ld. Dr’] Date Of Conclusive Hearing : 11/08/2025 Date Of Pronouncement : 26/08/2025 Order Per G. D. Padmahshali; Present Appeal Is Filed By The Assessee Challenging Din & Order No. Itba/Nfac/S/250/2023-24/1057640303(1) Dt. 02/11/2023 Passed By National Faceless Appeal Centre, Delhi [‘Ld. Cit(A)/Nfac’] U/S 250 Of The Income- Tax Act, 1961 [‘The Act’] Which In Turn Stemmed From Assessment Order Dt. 20/09/2021 Passed U/S 147 R.W.S.

3. The Learned Commissioner of Income Tax (Appeals) erred in confirming the addition of Rs.28,02,495/- being customs duty paid through bank as unexplained investment duly accounted in books. ITAT-Panaji Page 5 of 16 Moureen Camara Vs NFeAC ITA Nos.200/PAN/2023 AY: 2016-17 4. The learned commissioner of Income tax erred in holding that the transaction of purchase

SUNIL HANAMANT NAIKWAD,BELGAUM vs. INCOME TAX OFFICER, WARD - 2, BELAGAVI

The appeal is ALLOWED as above

Bench: Hon’Ble Shri Pavan Kumar Gadale & Shri G. D. Padmahshaliassessment Year : 2012-13 Sunil Hanmantsa Naikwad 1156, Saraf Galli, Shahapur, Belgaum Pan:Abeph0397N . . . . . . . Appellant V/S Income Tax Officer, Ward-2, Belgaum. . . . . . . . Respondent

reassessment of escaped income, and which he intends to taken into accounts, he would be required to issue a fresh notice under Section 148.’ (Emphasis supplied) 10. In the instant case, admittedly the Ld. AO neither made any addition in relation recorded reasons about share transactions undertaken by the appellant on MCX and nor established any nexus there between

SMT NEHA PRASANNA GHOTAGE,BELAGAVI vs. INCOME TAX OFFICER, WARD - 1, KARWAR

Appeals are DISMISSED

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

section 249 of the Act. ITAT-Panaji Page 6 of 22 Neha Prasanna Ghotage Vs ACIT, Belgaum ITA No. 259 to 268/PAN/2025 AY: 2006-07 to 2010-11 10. Alike in former cases, opportunities provided to showcase ‘sufficient cause’ behind such belated filings in these cases also went futile as no evidence and explanations were filed. In the event

SMT NEHA PRASANNA GHOTAGE,BELAGAVI vs. INCOME TAX OFFICER, WARD - 1, KARWAR

Appeals are DISMISSED

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

section 249 of the Act. ITAT-Panaji Page 6 of 22 Neha Prasanna Ghotage Vs ACIT, Belgaum ITA No. 259 to 268/PAN/2025 AY: 2006-07 to 2010-11 10. Alike in former cases, opportunities provided to showcase ‘sufficient cause’ behind such belated filings in these cases also went futile as no evidence and explanations were filed. In the event

SMT NEHA PRASANNA GHOTAGE,BELAGAVI vs. INCOME TAX OFFICER, WARD - 1, KARWAR

Appeals are DISMISSED

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

section 249 of the Act. ITAT-Panaji Page 6 of 22 Neha Prasanna Ghotage Vs ACIT, Belgaum ITA No. 259 to 268/PAN/2025 AY: 2006-07 to 2010-11 10. Alike in former cases, opportunities provided to showcase ‘sufficient cause’ behind such belated filings in these cases also went futile as no evidence and explanations were filed. In the event

SMT NEHA PRASANNA GHOTAGE,BELAGAVI vs. INCOME TAX OFFICER, WARD - 1, KARWAR

Appeals are DISMISSED

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

section 249 of the Act. ITAT-Panaji Page 6 of 22 Neha Prasanna Ghotage Vs ACIT, Belgaum ITA No. 259 to 268/PAN/2025 AY: 2006-07 to 2010-11 10. Alike in former cases, opportunities provided to showcase ‘sufficient cause’ behind such belated filings in these cases also went futile as no evidence and explanations were filed. In the event

SMT NEHA PRASANNA GHOTAGE,BELAGAVI vs. ASSISTANT COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE - 2, BELAGAVI

Appeals are DISMISSED

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

section 249 of the Act. ITAT-Panaji Page 6 of 22 Neha Prasanna Ghotage Vs ACIT, Belgaum ITA No. 259 to 268/PAN/2025 AY: 2006-07 to 2010-11 10. Alike in former cases, opportunities provided to showcase ‘sufficient cause’ behind such belated filings in these cases also went futile as no evidence and explanations were filed. In the event

SMT NEHA PRASANNA GHOTAGE,BELAGAVI vs. ASSISTANT COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE - 2, BELAGAVI

Appeals are DISMISSED

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

section 249 of the Act. ITAT-Panaji Page 6 of 22 Neha Prasanna Ghotage Vs ACIT, Belgaum ITA No. 259 to 268/PAN/2025 AY: 2006-07 to 2010-11 10. Alike in former cases, opportunities provided to showcase ‘sufficient cause’ behind such belated filings in these cases also went futile as no evidence and explanations were filed. In the event

SMT NEHA PRASANNA GHOTAGE,BELAGAVI vs. ASSISTANT COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE - 2, BELAGAVI

Appeals are DISMISSED

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

section 249 of the Act. ITAT-Panaji Page 6 of 22 Neha Prasanna Ghotage Vs ACIT, Belgaum ITA No. 259 to 268/PAN/2025 AY: 2006-07 to 2010-11 10. Alike in former cases, opportunities provided to showcase ‘sufficient cause’ behind such belated filings in these cases also went futile as no evidence and explanations were filed. In the event

SMT NEHA PRASANNA GHOTAGE,BELAGAVI vs. ASSISTANT COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE, 2, BELAGAVI

Appeals are DISMISSED

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

section 249 of the Act. ITAT-Panaji Page 6 of 22 Neha Prasanna Ghotage Vs ACIT, Belgaum ITA No. 259 to 268/PAN/2025 AY: 2006-07 to 2010-11 10. Alike in former cases, opportunities provided to showcase ‘sufficient cause’ behind such belated filings in these cases also went futile as no evidence and explanations were filed. In the event

SMT NEHA PRASANNA GHOTAGE,BELAGAVI vs. ASSISTANT COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE - 2, BELAGAVI

Appeals are DISMISSED

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

section 249 of the Act. ITAT-Panaji Page 6 of 22 Neha Prasanna Ghotage Vs ACIT, Belgaum ITA No. 259 to 268/PAN/2025 AY: 2006-07 to 2010-11 10. Alike in former cases, opportunities provided to showcase ‘sufficient cause’ behind such belated filings in these cases also went futile as no evidence and explanations were filed. In the event

SMT NEHA PRASANNA GHOTAGE,BELAGAVI vs. INCOME TAX OFFICER, WARD - 1, KARWAR

Appeals are DISMISSED

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

section 249 of the Act. ITAT-Panaji Page 6 of 22 Neha Prasanna Ghotage Vs ACIT, Belgaum ITA No. 259 to 268/PAN/2025 AY: 2006-07 to 2010-11 10. Alike in former cases, opportunities provided to showcase ‘sufficient cause’ behind such belated filings in these cases also went futile as no evidence and explanations were filed. In the event

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

reassessment order dt 24/09/2021 passed u/s 147 r.w.s. 143(3) of the Act which was set-aside u/s 263 of the Act. Whereas Ground No 1 & 2 alleges violation of principle of natural justice and hence seeks to turn down the impugned order as irregular. Since the ground no 3 is not within bounds

ASSISTANT COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE, BELAGAVI, BELAGAVI vs. M/S POTDAR BROTHERS, BELAGAVI

Appeals of the Revenue are PARTLY ALLOWED for statistical purposes in aforestated terms

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

reassessment by issue of notice u/s 148 and consequential assessment u/s 147 of the Act completed wherein a solitary addition of 30% of total payments made to karigars (artisan labours) during the year was made. 3.3 Aggrieved assessee filed an appeal u/s 246A of the Act before first appellate authority which was allowed vide para 4.9 to 4.12 which reads

ASSISTANT COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE, BELAGAVI, BELAGAVI vs. M/S POTDAR BROTHERS, BELAGAVI

Appeals of the Revenue are PARTLY ALLOWED for statistical purposes in aforestated terms

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

reassessment by issue of notice u/s 148 and consequential assessment u/s 147 of the Act completed wherein a solitary addition of 30% of total payments made to karigars (artisan labours) during the year was made. 3.3 Aggrieved assessee filed an appeal u/s 246A of the Act before first appellate authority which was allowed vide para 4.9 to 4.12 which reads