BHANDARI ASSOCIATES,PUNE vs. PR. COMMISSIONER OF INCOME TAX 2, PUNE, PUNE

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

Bench: Shri R. K. Panda & Ms. Astha Chandraassessment Year : 2018-19

revision by the Ld. PCIT is based on the internal audit objections for which a reply was also submitted by the assessee. He submitted that the reply filed to the audit objections has to be considered as part and parcel of record as per clause (b) of Explanation 1 to section 263 and merely on basis of audit objection, proceedings

M/S. LINGUANEXT TECHNOLOGIES PRIVATE LIMITED,,PUNE vs. PR. COMMISSIONER OF INCOME TAX -6,, PUNE

In the result, the appeal filed by the assessee stands allowed

revision order passed by the ld. PCIT in exercise of power vested u/s 263 of the Act. The provisions of section 263 provide that the Commissioner of Income Tax, on examination of the records, if he forms an opinion that the assessment order passed by the Assessing Officer is erroneous and prejudicial to the interest of the Revenue

BANSILAL RAMNATH AGARWAL CHARITABLE TRUST,PUNE vs. CIT (EXEMPTION), PUNE

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

Bench: Shri R. K. Panda & Ms. Astha Chandraassessment Year : 2020-21 Bansilal Ramnath Agarwal Charitable Trust Cit (Exemption), 251, Budhwar Peth, City Post Chowk, Vs. Pune Pune – 411002 Pan: Aaatb4383K (Appellant) (Respondent) Assessee By : Shri Kishor B Phadke Department By : Shri Amol Khairnar, Cit-Dr Date Of Hearing : 11-12-2025 Date Of Pronouncement : 28-01-2026 O R D E R Per R.K. Panda, V.P:

revision. 29. Referring to the decision of Hon’ble Delhi High Court in the case of CIT vs. Leisure Wear Exports Ltd. reported in (2012) 341 ITR 166 (Del), he submitted that the Hon’ble High Court in the said decision has held that where assessment order has been passed by the Assessing Officer after taking into account assessee

ASHISH NIRANJAN SHAH,,PUNE vs. PR. COMMISSIONER OF INCOME-TAX -4,, PUNE

In the result, appeal of the assessee is dismissed

Bench: Shri S.S.Godara & Dr. Dipak P. Ripoteआयकर अपील सं. / Ita No.697/Pun/2019 िनधा"रण वष" / Assessment Year : 2014-15 Ashish Niranjan Shah, The Pr.Cit-4, Pune. 39, Mantri Court, Dr.Ambedkar V Road, Next To Rto, Sangam, S Pune – 411001. Pan: Aidps 7682 K Appellant/ Assessee Respondent /Revenue Assessee By Shri Kishor B Phadke – Ar Revenue By Shri Keyur Patel, Irs – Cit-Dr Date Of Hearing 28/07/2023 Date Of Pronouncement 13/10/2023 आदेश/ Order Per Dr. Dipak P. Ripote, Am: This Appeal Filed By The Assessee Is Directed Against The Order Of Ld.Pr.Commissioner Of Income Tax-4, Pune Dated26.03.2019 Under Section 263 Of The Income Tax Act, 1961. The Assessee Has Raised The Following Grounds Of Appeal : “1. Learned Pr. Cit- 4, Pune Erred In Law & On Facts In Treating The Assessment Order U/S 143(3) Being Erroneous & Thereby Prejudicial To The Revenue U/S 263 Without Appreciating That, The Learned Ao Has Allowed Appellant'S Claim Of Business Loss Amounting To Rs.10,20,14,068/- Incurred On Account Of Default In Payment By Nsel, With Due Application Of Mind & Verification. The Learned Pr. Cit Erred In Holding That, Ao Has Not Carried Out Any Enquiry With Respect To Business Loss Claimed By The Appellant & Not Applied His Ashish Niranjan Shah [A]

TDS & L a/c. 6. Bank a/c details along with all banks statements in the following format :- 13 Ashish Niranjan Shah [A] Sr. No. Name of Branch A/c Type A/c No. the Bank 7. Details of Name, Permanent & Residential address of the assessee along with mobile number, telephone no. & email ids. 8. Evidences for deduction claimed under Chapter VIA viz. Purchase

DEPUTY COMMISSIONER OF INCOME TAX CIRCLE 12 PUNE, PUNE vs. JANATA GRAHAK MADHYAWARTI SAHKARI SANGH MARYADIT, PUNE

In the result, the appeal of the Revenue in ITA No

Bench: Shri R.K. Panda & Ms. Astha Chandra

revision order passed by the Ld. PCIT u/s 263 of the Act has allowed the appeal of the assessee holding that the assessment order is neither erroneous nor prejudicial to the interest of the revenue on the ground that the Ld. AO had allowed the deduction after considering the assessee’s submissions which indicates due application of mind

DEPUTY COMMISSIONER OF INCOME TAX CIRCLE-12 PUNE, PUNE vs. JANATA GRAHAK MADHYAWARTI SAHKARI SANGH MARYADIT, PUNE

In the result, the appeal of the Revenue in ITA No

Bench: Shri R.K. Panda & Ms. Astha Chandra

revision order passed by the Ld. PCIT u/s 263 of the Act has allowed the appeal of the assessee holding that the assessment order is neither erroneous nor prejudicial to the interest of the revenue on the ground that the Ld. AO had allowed the deduction after considering the assessee’s submissions which indicates due application of mind

DEPUTY COMMISSIONER OF INCOME TAX CIRCLE-12 PUNE, PUNE vs. JANATA GRAHAK MADHYAWARTI SAHKARI SANGH MARYADIT, PUNE

In the result, the appeal of the Revenue in ITA No

Bench: Shri R.K. Panda & Ms. Astha Chandra

revision order passed by the Ld. PCIT u/s 263 of the Act has allowed the appeal of the assessee holding that the assessment order is neither erroneous nor prejudicial to the interest of the revenue on the ground that the Ld. AO had allowed the deduction after considering the assessee’s submissions which indicates due application of mind

SACHIN RAMDAS MOHITE,,SATARA vs. PR. COMMISSIONER OF INCOME-TAX-3,, PUNE

Appeal is allowed in above terms

Bench: Shri S.S. Godara, Jm & Shri G.D. Padmahshali, Am

revision directions terming the corresponding regular assessment dated 28-03-2016 as an erroneous one causing prejudice to interest of the revenue, are in a narrow campus. 3. There is no dispute that the PCIT has invoked his revisional jurisdiction for the sole reason that the Assessing Officer had come across assessee’s cash deposit

ANAND CONSTRUWELL PRIVATE LIMITED,NASHIK vs. PRINCIPAL COMMISSIONER OF INCOME TAX, NASHIK -1, NASHIK

In the result, the appeal filed by the assessee is dismissed

Bench: Shri R. K. Panda & Shri Vinay Bhamoreआयकर अपील सं. / Ita No.955/Pun/2024 िनधा"रण वष" / Assessment Year: 2019-20 Anand Construwell Private Vs. Pcit-1, Nashik. Limited, Ramchandra Apartments, Makhmalabad Road, Panchvati, Nashik- 422003. Pan : Aafca7736H Appellant Respondent Assessee By : Shri Pramod S. Shingte Revenue By : Shri Keyur Patel Date Of Hearing : 05.09.2024 Date Of Pronouncement : 29.11.2024 आदेश / Order Per Vinay Bhamore, Jm: This Appeal Filed By The Assessee Is Directed Against The Order Dated 19.03.2024 Passed By Ld. Pcit-1, Nashik [‘Ld. Pcit’] For The Assessment Year 2019-20. 2. The Appellant Has Raised The Following Grounds Of Appeal :- “1. On The Basis Of The Facts & Circumstances Of The Case, The Order Passed U/S. 263 By The Principal Commissioner Of Income-Tax, Nashik May Please Be Quashed. 2. On The Basis Of The Facts & Circumstances Of The Case, The Principal Commissioner Of Income-Tax Is Not Justified In Invoking The Provisions Of Section 263 By Holding That Provisions Of Section 69C Are Applicable In The Present Case As The Assessee Was Not Able To Explain The Sources Of Expenditure

revision proceedings u/s 263 of the Act have been initiated on the ground that during the survey proceedings, assessee was not able to explain the source of expenditure of Rs.2,28,29,555/-, therefore, section 69C was squarely applicable and the same should have been taxed applying the provisions of section 115BBE of the Act. During the assessment proceedings

BANK OF MAHARASHRA,PUNE vs. THE PR. COMMISSIONER OF INCOME TAX, PUNE, PUNE

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

Bench: Shri R. K. Panda & Ms Astha Chandraassessment Year : 2018-19

TDS & Disallowance for such Default vii. Refund Claim viii. Business Loss ix. ICDS Compliance and Adjustment x. Disallowance u/s 40A(7) (Gratuity provision) xi. Expenses incurred for Earning Exempt Income xii. Excess Contribution to Provident Fund, Superannuation Fund or Gratuity Fund xiii. Capital Gains/Income on Sale of Property xiv. Business Expenses 3. The Assessing Officer completed the assessment u/s

SONAL SANDEEP SATAV,PUNE vs. PCIT, PUNE-2, PUNE

In the result, the appeal of the assessee is dismissed

Bench: Ms. Astha Chandra & Shree G.D. Padmahshali

revision proceedings before the Ld. PCIT : 5 ITA No.945/PUN/2024, AY 2018-19 3.7 Before the Ld. PCIT, challenging the validity of proceeding u/s 263 of the Act, the assessee submitted that the identity, genuineness and creditworthiness of the assessee’s husband, Mr. Sandeep Satav has been substantiated by production of above details/documents and hence the assessment order is neither erroneous

SHRI GANESH SERVA SEVA SANGHA SHRIPUR,SOLAPUR vs. CIT(E), PUNE, PUNE

In the result, the appeal of the assessee is dismissed

Bench: Dr.Manish Borad & Shri Vinay Bhamoreआयकर अपील सं. / Ita No.1230/Pun/2024 Assessment Year : 2016-17

revised is invalid and bad in law and therefore the order u/s 263 does not survive 2. On the facts and in the circumstances of the case theOrder u/s 263 passed by the Id. Pr. CIT is bad in law in as much as the same is not erroneous in so far as prejudicial to the interest of the revenue

BAJAJ FINANCE LIMITED,PUNE vs. PRINCIPAL COMMISSIONER OF INCOME TAX-3, PUNE, PUNE

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

Bench: Shri R. K. Panda & Shri Vinay Bhamoreassessment Year : 2019-20 Bajaj Finance Limited Pcit-3, Pune 3Rd Floor, Panchshil Tech Park, Vs. Viman Nagar, Pune – 411014 Pan: Aabcb1518L (Appellant) (Respondent) Assessee By : Shri Percy Pardiwalla Department By : Shri Amol Khairnar, Cit-Dr Date Of Hearing : 06-01-2026 Date Of Pronouncement : 29-01-2026

TDS in Revised Return iii. High Creditors/liabilities iv. Reduction of Income in Revised Return & Claim of Refund v. Refund Claim vi. Unsecured Loans vii. Expenses Incurred for Earning Exempt Income viii. Taxability of business liability written off u/s 41 or any other section ix. Foreign Outward Remittance x. Capital Gains/Income on Sale of Property xi. Deduction from Total Income under

PRABHAKAR MANJAJI THAKRE vs. PRINCIPOAL C.I.T.-1, NAGPUR

In the result, the appeal of the assessee is dismissed

Bench: Shri Inturi Rama Rao, Am & Shri Sonjoy Sarma, Jm Assessment Year : 2011-12

TDS. 5. The claim of deduction u/s. 54EC was made on account of STDR with SBI. The STDR with SBI is not a long term specified assessee within the meaning u/s. 54EC. The Assessing Officer did not notice this fact during the course of assessment proceedings and allowed the claim without application of mind. So the order of the Assessing

JAWAHAR LAL NEHRU PORT TRUST,NAVI MUMBAI vs. ACIT PANVEL, PANVEL

In the result, all the three appeals filed by the Revenue are dismissed and all the three appeals filed by the assessee are partly allowed

Bench: Shri R. K. Panda & Ms Astha Chandra

263 of the Act was passed by the Assessing Officer after considering the special audit report u/s 142(2A) of the Act on 27.12.2007 computing the total income at Rs.583,06,70,963/-. 4. The assessee had filed an application for registration u/s 12AA of the Act on 10.02.2006 which was rejected by the CIT-II, Thane. Aggrieved

DEPUTY COMMISSIONER OF INCOME-TAX vs. THE JAWAHARLAL NEHRU PORT TRUST,, RAIGAD

In the result, all the three appeals filed by the Revenue are dismissed and all the three appeals filed by the assessee are partly allowed

Bench: Shri R. K. Panda & Ms Astha Chandra

263 of the Act was passed by the Assessing Officer after considering the special audit report u/s 142(2A) of the Act on 27.12.2007 computing the total income at Rs.583,06,70,963/-. 4. The assessee had filed an application for registration u/s 12AA of the Act on 10.02.2006 which was rejected by the CIT-II, Thane. Aggrieved

DEPUTY COMMISSIONER OF INCOME-TAX vs. THE JAWAHARLAL NEHRU PORT TRUST,, RAIGAD

In the result, all the three appeals filed by the Revenue are dismissed and all the three appeals filed by the assessee are partly allowed

Bench: Shri R. K. Panda & Ms Astha Chandra

263 of the Act was passed by the Assessing Officer after considering the special audit report u/s 142(2A) of the Act on 27.12.2007 computing the total income at Rs.583,06,70,963/-. 4. The assessee had filed an application for registration u/s 12AA of the Act on 10.02.2006 which was rejected by the CIT-II, Thane. Aggrieved

JAWAHAR LAL NEHRU PORT TRUST,NAVI MUMBAI vs. ACIT PANVEL, PANVEL

In the result, all the three appeals filed by the Revenue are dismissed and all the three appeals filed by the assessee are partly allowed

Bench: Shri R. K. Panda & Ms Astha Chandra

263 of the Act was passed by the Assessing Officer after considering the special audit report u/s 142(2A) of the Act on 27.12.2007 computing the total income at Rs.583,06,70,963/-. 4. The assessee had filed an application for registration u/s 12AA of the Act on 10.02.2006 which was rejected by the CIT-II, Thane. Aggrieved