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41 results for “TDS”+ Section 131clear

Sorted by relevance

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Key Topics

Section 80I47Section 12A40Addition to Income31Section 143(3)24Section 10(20)24Section 1124Section 6819TDS18Deduction17Disallowance

DY COMMISSIONER OF INCOME TAX CIRCLE 5 PUNE, PUNE vs. DIPTI NARENDRA LULLA, PUNE

ITA 1065/PUN/2025[2018-19]Status: DisposedITAT Pune05 Dec 2025AY 2018-19
Section 143(2)

TDS\nwas not deducted for some persons / parties. The assessee has not furnished the\ncopy of Form 15G. Further, the assessee also could not substantiate with evidence\nto his satisfaction regarding the creditworthiness of persons / parties from whom\nsuch loans were taken. In view of the above, the Assessing Officer made addition\nof Rs.5,16,85,602/- to the total

ASSISTANT COMMISSIONER OF INCOME-TAX, CIRCLE - 2,, KOLHAPUR vs. UPPAL JITENDRA SHAH,, KOLHAPUR

In the result, the cross appeal of the Revenue in ITA

ITA 1893/PUN/2017[2012-13]Status: DisposedITAT Pune16 Jun 2022AY 2012-13

Bench: Shri Inturi Rama Rao & Shri S. S. Viswanethra Ravisl.

For Appellant: Shri Nikhil S. Pathak Shri Shivraj B. Morey &

Showing 1–20 of 41 · Page 1 of 3

15
Section 4013
Section 14A12
For Respondent:
Section 131(1)(d)Section 133(6)Section 143(3)Section 41(1)Section 68

TDS was also deducted thereon and therefore, there was no reason to hold that the loans taken from these 16 persons were non genuine. 5] The learned CIT(A) ought to have appreciated that simply because the notices u/s 131/ 133(6) could not be served on the above persons did not mean that the loans taken from them

UPPAL SHAH PROP-J K SUGARS,,KOLHAPUR vs. ASSISTANT COMMISSIONER OF INCOME-TAX, CIRCLE - 2,, KOLHAPUR

In the result, the cross appeal of the Revenue in ITA

ITA 1954/PUN/2017[2012-13]Status: DisposedITAT Pune16 Jun 2022AY 2012-13

Bench: Shri Inturi Rama Rao & Shri S. S. Viswanethra Ravisl.

For Appellant: Shri Nikhil S. PathakFor Respondent: Shri Shivraj B. Morey &
Section 131(1)(d)Section 133(6)Section 143(3)Section 41(1)Section 68

TDS was also deducted thereon and therefore, there was no reason to hold that the loans taken from these 16 persons were non genuine. 5] The learned CIT(A) ought to have appreciated that simply because the notices u/s 131/ 133(6) could not be served on the above persons did not mean that the loans taken from them

DEPUTY COMMISSIONER OF INCOME TAX, AURANGABAD vs. DHANANJAY BABRUVAN KENDER, BEED

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

ITA 1032/PUN/2024[2019-20]Status: DisposedITAT Pune09 Dec 2025AY 2019-20

Bench: Shri R. K. Panda & Ms. Astha Chandraassessment Year : 2019-20 Dcit, Aurangabad Dhananjay Babruvan Kender Bunglow No.69, Yogeshwari Nagari Vs. Ring Road, Ambajogai, Beed – 431517 Pan: Bwlpk1384D (Appellant) (Respondent) Assessee By : Shri Hari Krishan Department By : Shri Amol Khairnar, Cit-Dr Date Of Hearing : 27-11-2025 Date Of Pronouncement : 09-12-2025 O R D E R Per R.K. Panda, Vp:

For Appellant: Shri Hari KrishanFor Respondent: Shri Amol Khairnar, CIT-DR
Section 132Section 133ASection 142(1)Section 153ASection 69Section 69C

TDS of Rs.65,54,172/- was deducted. However, the assessee has offered receipts to the tune of Rs.10,44,63,302/-in return of income filed u/s 139 of the Act. 3. Whether on the facts and in the circumstances of the case and in law, the Ld.CIT (A) has erred in not taking cognizance of seized material seized during

KOTHARI AGRITECH PRIVATE LIMITED,SOLAPUR vs. DCIT CIRCLE 1, SOLAPUR, SOLAPUR

In the result, appeal of the Assessee is Partly Allowed

ITA 2354/PUN/2024[2015-16]Status: DisposedITAT Pune20 May 2025AY 2015-16

Bench: Dr.Dipak P. Ripote & Shri Vinay Bhamoreआयकर अपील सं. / Ita No.2354/Pun/2024 िनधा"रण वष" / Assessment Year: 2015-16 Kothari Agritech Private V The Dcit, Limited, S Circle-1, Solapur. 3Rd Floor, Sunplaza, 8516/11, Subhash Chowk, Murarji Peth, Solapur North, Jawaharlal Nehru Vastigrah S.O., Solapur – 413001. Maharashtra Pan: Aadck8017H Appellant/ Assessee Respondent / Revenue Assessee By Mr.Piyush Bafna – Ar Revenue By Shri Ramnath P Murkunde – Dr Date Of Hearing 24/04/2025 Date Of Pronouncement 20/05/2025 आदेश/ Order Per Dr. Dipak P. Ripote, Am: This Appeal Filed By The Assessee Is Against The Order Of Ld.Commissioner Of Income Tax(Appeals)[Nfac], Passed Under Section 250 Of The Income Tax Act, 1961; Dated 19.09.2024 For Assessment Year 2015-16. The Assessee Has Raised The Following Grounds Of Appeal :

Section 250

section 131 of the Act, or letter u/s.133(6) of the Act. However, neither Assessing Officer nor ld.CIT(A) had bothered to issue summons or 133(6) upon these persons. This explains that the AO or ld.CIT(A) has not bothered to carry any enquiry. It is also an admitted that TDS

DR. SUBHASH NATHMAL PALLOD,PUNE vs. DCIT, CIRCLE-3, PUNE

In the result, appeal of the assessee is allowed

ITA 73/PUN/2020[2015-16]Status: DisposedITAT Pune14 Jul 2022AY 2015-16

Bench: Shri S.S.Godara & Dr. Dipak P. Ripoteआयकरअपीलसं. / Ita No.73/Pun/2020 िनधा"रणवष" /Assessment Year: 2015-16 Dr.Subhash Nathmal Pallod, The Deputy Commissioner Of Sarala, 38, Vishwamitr Vs Income Tax, A Colony, Gulmohar Path, Circle-3, Pune. Erandwane, Pune – 411004. Pan: Aaupp 9286 B Appellant/ Assessee Respondent/ Revenue

Section 143(3)Section 37(1)

TDS has been duly deducted. Copy of the PAN Card of Mr.Kishore ITA No.73/PUN/2020 for A.Y.2015-16 Dr.Subhash Nathmal Pallod Vs. DCIT (A) Gangaram Aware was submitted by the assessee during the assessment proceedings. Thus, the assessee has submitted all the essential documents during the assessment proceedings to claim the expenditure as business expenditure. The AO has allowed the expenditure

VINAYAK HANUMANTRAO GHORPADE,PUNE vs. VAISHNAVI SATISH BANKAR, PUNE

In the result, appeal in ITA No

ITA 1438/PUN/2024[AY2019-20]Status: DisposedITAT Pune08 Dec 2025

Bench: Dr.Dipak P. Ripote & Shri Vinay Bhamoreआयकर अपऩल सं. / Ita Nos.1438 & 1439/Pun/2024 निर्धारण वषा / Assessment Years: 2019-20 & 2020-21 Vinayak Hanumantrao V Vaishnavi Satish Bankar, Ghorpade, S. Pune. F.No.7, Plot No.60/61, S.No.165/1B, Shivanjali, Near Central Circle-1(3), Pune. Mahadev Temple, Indira Nagar, Pune – 411033. Pan: Afdpg6919A Appellant/ Assessee Respondent / Revenue Assessee By Shri Pramod S Shingte Revenue By Shri Aviyogi Ambadkar –Addl.Cit Date Of Hearing 11/09/2025 Date Of Pronouncement 08/12/2025 आदेश/ Order Per Dr. Dipak P. Ripote, Am: These Two Appeals Filed By The Assessee Are Against The Common Order Of Ld.Commissioner Of Income Tax(Appeal), Pune-11 Passed Under Section 250 Of The Income Tax Act, 1961 For A.Y.2019-20 & 2020-21, Both Dated 02.05.2024 Emanating From Separate Assessment Order U/S.153A R.W.S 144 Of The I.T.Act, Both Dated 23.09.2021.For The Sake Of Convenience, These Two Appeals

Section 153ASection 250Section 43BSection 68Section 80C

TDS has been deducted on these consultancy charges. It has been specifically mentioned by the Assessing Officer and ld.CIT(A) that almost entire receipts of the Assessee are from Garware Technical Fibers Limited. The Assessee has claimed expenditure of Rs.5 lakhs as consultancy charges paid to SHAILJA ROOPCHAND. Though apparently, it is highly unlikely that a person doing consultancy

VINAYAK HANUMANTRAO GHORPADE,PUNE vs. INCOME TAX OFFICER, PUNE

In the result, appeal in ITA No

ITA 1439/PUN/2024[AY2020-21]Status: DisposedITAT Pune08 Dec 2025

Bench: Dr.Dipak P. Ripote & Shri Vinay Bhamoreआयकर अपऩल सं. / Ita Nos.1438 & 1439/Pun/2024 निर्धारण वषा / Assessment Years: 2019-20 & 2020-21 Vinayak Hanumantrao V Vaishnavi Satish Bankar, Ghorpade, S. Pune. F.No.7, Plot No.60/61, S.No.165/1B, Shivanjali, Near Central Circle-1(3), Pune. Mahadev Temple, Indira Nagar, Pune – 411033. Pan: Afdpg6919A Appellant/ Assessee Respondent / Revenue Assessee By Shri Pramod S Shingte Revenue By Shri Aviyogi Ambadkar –Addl.Cit Date Of Hearing 11/09/2025 Date Of Pronouncement 08/12/2025 आदेश/ Order Per Dr. Dipak P. Ripote, Am: These Two Appeals Filed By The Assessee Are Against The Common Order Of Ld.Commissioner Of Income Tax(Appeal), Pune-11 Passed Under Section 250 Of The Income Tax Act, 1961 For A.Y.2019-20 & 2020-21, Both Dated 02.05.2024 Emanating From Separate Assessment Order U/S.153A R.W.S 144 Of The I.T.Act, Both Dated 23.09.2021.For The Sake Of Convenience, These Two Appeals

Section 153ASection 250Section 43BSection 68Section 80C

TDS has been deducted on these consultancy charges. It has been specifically mentioned by the Assessing Officer and ld.CIT(A) that almost entire receipts of the Assessee are from Garware Technical Fibers Limited. The Assessee has claimed expenditure of Rs.5 lakhs as consultancy charges paid to SHAILJA ROOPCHAND. Though apparently, it is highly unlikely that a person doing consultancy

DILIP JAWAHARLAL VARYANI,PUNE vs. DCIT CIRCLE-8, PUNE

In the result, appeal of the assessee is partly allowed

ITA 643/PUN/2025[2011-12]Status: DisposedITAT Pune28 Oct 2025AY 2011-12

Bench: Dr.Dipak P. Ripote & Shri Vinay Bhamoreआयकरअपऩलसं. / Ita No.643/Pun/2025 निर्धारणवषा / Assessment Year:2011-12 Dilip Jawaharlal Varyani, V The Dy.Commissioner Of S.No.9/2B, Cts No.905, S Income Tax, Circle-8, Vaibhav Vihar, Near Vikram Pune. Vihar, Pimpri, Pune – 411017. Pan: Acapv0521H Appellant/ Assessee Respondent / Revenue Assessee By Shri Sarad Vaze, Ca – Ar Revenue By Shri Ramnath P Murkunde, Irs–Dr Date Of Hearing 12/08/2025 Date Of Pronouncement 28/10/2025 आदेश/ Order Per Dr. Dipak P. Ripote, Am: This Is An Appeal Filed By The Assessee Against The Order Of Ld.Commissioner Of Income Tax(Appeal)[Nfac], Delhi Passed Under Section 250 Of The Income Tax Act, 1961 Dated 19.06.2024 For The A.Y.2011-12 Emanating From The Assessment Order Under Section 143(3)Of The Income Tax Act, 1961, Dated 26.03.2014. The Assessee Has Raised The Following Grounds Of Appeal :

Section 143(3)Section 250Section 68

TDS was deducted. Submission of ld.DR : 4. Ld.Departmental Representative(ld.DR) for the Revenue relied on the order of the Assessing Officer and ld.CIT(A). Ld.DR vehemently submitted that ld.CIT(A) had given 13 opportunities, hence ld.CIT(A) had given sufficient opportunities. Ld.DR submitted that ld.AR’s request to set-aside the ld.CIT(A) order to ld.CIT

VIJAY TUKARAM RAUNDAL,PUNE vs. THE DEPUTY COMMISSIONER OF INCOME TAX , CENTRAL CIRCLE-1(2), PUNE

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

ITA 1634/PUN/2024[2013-14]Status: DisposedITAT Pune03 Sept 2025AY 2013-14
Section 115JSection 131Section 133ASection 271(1)(c)Section 80I

131(d) for examining the eligibility of the project ‘Teerth Towers'\nunder the provisions of section 80IB(10) of the Act. The Registered Valuer\nsubmitted his report on 02.03.2015 wherein he pointed out the following\ncontraventions of the conditions laid down in section 80IB(10) of the Act:\n“i) Sec. 80IB(10)(a) - Date of commencement and completion

KAPIL ALCOTECH LLP,AURANGABAD vs. DEPUTY COMMISSIONER OF INCOME TAX CIRCLE - 1, AURANGABAD

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

ITA 557/PUN/2024[2020-21]Status: DisposedITAT Pune09 Aug 2024AY 2020-21

Bench: Shri R. K. Panda & Ms Astha Chandraassessment Year : 2020-21

For Appellant: Shri K P DewaniFor Respondent: Shri Pankaj Kumar
Section 143(2)Section 143(3)Section 250Section 250(1)Section 68Section 69C

131 of the paper book, Volume-I. Proper TDS has been made and payments are through proper banking channel. The above sum was clubbed with ledger account considered by the Assessing Officer at Rs.4,85,058/- to report expenses in Profit and Loss Account at Rs.5,09,058/-. So far as the petty cash book is concerned, the payment

INCOME TAX OFFICER,WARD-7(1), PUNE, PUNE vs. HEMANT BAGAREDDY MOTADOO, PUNE

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

ITA 1897/PUN/2024[2013-14]Status: DisposedITAT Pune28 Jul 2025AY 2013-14

Bench: Shri R. K. Panda & Shri Vinay Bhamoreassessment Year : 2013-14

For Appellant: S/Shri B C Malakar & Yuvraj ChavanFor Respondent: Shri Ramnath P Murkunde
Section 143(2)Section 201Section 40Section 40A(3)Section 68

TDS on payment of security charges amounting to Rs.1,15,275/- paid to M/s. Shani Security & Allied Services. We find the provisions of section 40(a)(ia) of the Act as they stood at the relevant time read as under: “Amounts not deductible. 40. Notwithstanding anything to the contrary in sections 30 to 38, the following amounts shall

ASSISTANT COMMISSIONER OF INCOME-TAX, CIRCLE - 6,, PUNE vs. SHREE SADGURU ENTERPRISES,, PUNE

In the result, the appeal of Revenue is allowed for statistical purpose

ITA 2125/PUN/2017[2013-14]Status: DisposedITAT Pune30 Jul 2021AY 2013-14

Bench: Shri Inturi Rama Rao & Shri S.S. Viswanethra Ravi

For Appellant: Shri Swanand BarveFor Respondent: Shri Mahadevan A.M. Krishanan
Section 201Section 36(1)(iii)Section 40

TDS is permissible if the resident payee has furnished its return of income by taking into account such sum in the return of income and paid due taxes on such income. Before us, the ld. DR, Shri Mahadevan A.M. Krishanan vehemently argued that no evidences whatsoever filed before the AO regarding evidences claiming the payee filed return of income showing

RAMCHANDRAUDAYSINGHJADHAVRAO,PUNE vs. ACIT, CIRCLE-3, PUNE

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

ITA 1399/PUN/2024[2016-17]Status: DisposedITAT Pune24 Feb 2025AY 2016-17
Section 133ASection 139(1)Section 139(4)Section 143(1)Section 271(1)(c)Section 45(2)

section 271(1)(c) of the Act for which he levied the\npenalty on account of surrender of income of Rs.10.74 crores. We find the Ld.\nCIT(A) upheld the action of the Assessing Officer. It is the submission of the Ld.\nCounsel for the assessee that although the land was converted into stock in trade\nduring the financial year

VIJAY TUKARAM RAUNDAL,PUNE vs. THE DEPUTY COMMISSIONER OF INCOME TAX , CENTRAL CIRCLE-1(2), PUNE

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

ITA 1637/PUN/2024[2020-21]Status: DisposedITAT Pune03 Sept 2025AY 2020-21

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

For Appellant: Shri Mihir NaniwadekarFor Respondent: Shri Amit Bobde, CIT
Section 115JSection 131Section 133ASection 271(1)(c)Section 80I

131(d) for examining the eligibility of the project ‘Teerth Towers’ under the provisions of section 80IB(10) of the Act. The Registered Valuer submitted his report on 02.03.2015 wherein he pointed out the following contraventions of the conditions laid down in section 80IB(10) of the Act: “i) Sec. 80IB(10)(a) - Date of commencement and completion

VIJAY TUKARAM RAUNDAL,PUNE vs. THE DEPUTY COMMISSIONER OF INCOME TAX , CENTRAL CIRCLE-1(2), PUNE

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

ITA 1635/PUN/2024[2014-15]Status: DisposedITAT Pune03 Sept 2025AY 2014-15

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

For Appellant: Shri Mihir NaniwadekarFor Respondent: Shri Amit Bobde, CIT
Section 115JSection 131Section 133ASection 271(1)(c)Section 80I

131(d) for examining the eligibility of the project ‘Teerth Towers’ under the provisions of section 80IB(10) of the Act. The Registered Valuer submitted his report on 02.03.2015 wherein he pointed out the following contraventions of the conditions laid down in section 80IB(10) of the Act: “i) Sec. 80IB(10)(a) - Date of commencement and completion

VIJAY TUKARAM RAUNDAL,PUNE vs. THE DEPUTY COMMISSIONER OF INCOME TAX , CENTRAL CIRCLE-1(2), PUNE

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

ITA 1636/PUN/2024[2015-16]Status: DisposedITAT Pune03 Sept 2025AY 2015-16

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

For Appellant: Shri Mihir NaniwadekarFor Respondent: Shri Amit Bobde, CIT
Section 115JSection 131Section 133ASection 271(1)(c)Section 80I

131(d) for examining the eligibility of the project ‘Teerth Towers’ under the provisions of section 80IB(10) of the Act. The Registered Valuer submitted his report on 02.03.2015 wherein he pointed out the following contraventions of the conditions laid down in section 80IB(10) of the Act: “i) Sec. 80IB(10)(a) - Date of commencement and completion

SHRI MANOJ MADANLAL CHHAJED,PUNE vs. ASSISTANT COMMISSIONER OF INCOME TAX, CIRCLE -1(1)PUNE, PUNE

In the result, the appeal filed by the assessee in ITA

ITA 725/PUN/2022[2018-19]Status: DisposedITAT Pune28 Jun 2023AY 2018-19

Bench: Shri Inturi Rama Rao & Shri S. S. Viswanethra Raviआयकर अपील सं. / It(Ss)A Nos.91 To 96/Pun/2022 िनधा"रण वष" / Assessment Years : 2012-13 To 2017-18 Shri Manoj Madanlal Vs. Acit, Central Circle- Chhajed, 1(1), Pune. 601, A-8 Building, Karishma Housing Society, Near Sangam Press, Kothrud, Pune- 411029. Pan : Aalpc4991M Appellant Respondent आयकर अपील सं. / It(Ss)A Nos.97 & 98/Pun/2022 िनधा"रण वष" / Assessment Years : 2012-13 & 2015-16 Acit, Circle-1(1), Pune. Vs. Shri Manoj Madanlal Chhajed, 601, A-8 Building, Karishma Housing Society, Near Sangam Press, Kothrud, Pune- 411029. Pan : Aalpc4991M Appellant Respondent आयकर अपील सं. / Ita No.725/Pun/2022 िनधा"रण वष" / Assessment Year: 2018-19 Shri Manoj Madanlal Vs. Acit, Circle-1(1), Pune. Chhajed, 601, A-8 Building, Karishma Housing Society, Near Sangam Press, Kothrud, Pune- 411029. Pan : Aalpc4991M Appellant Respondent

For Appellant: Shri Ratan SamalFor Respondent: Shri Keyur Patel
Section 132(4)Section 139(1)

TDS. Thus, he submits that the appellant had discharged the onus lying upon it in terms of provisions of section 19 IT(SS)A Nos.91 to 96/PUN/2022 IT(SS)A Nos.97 & 98/PUN/2022 68 of the Act. In the circumstances, the AO was not justified in making the addition of unsecured loans. E. As regards, the addition made on account

PREM GRAIN INDUSTRIES PVT. LTD,JALGOAN vs. DCIT CIRCLE 1, JALGAON, JALGAON

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

ITA 2012/PUN/2025[2016-17]Status: PendingITAT Pune20 Nov 2025AY 2016-17

Bench: Shri R. K. Panda & Ms. Astha Chandraassessment Year : 2016-17 Prem Grain Industries Pvt. Ltd. Dcit, Circle – 1, Jalgaon E 2/1, Midc Area, Ahjantha Vs. Road, Jalgaon – 425003 Pan: Aadcp9598E (Appellant) (Respondent) Assessee By : Shri Suresh Anchaliya Department By : Shri S. Sadananda Singh, Jcit Date Of Hearing : 11-11-2025 Date Of Pronouncement : 20-11-2025 O R D E R Per R.K. Panda, Vp: This Appeal Filed By The Assessee Is Directed Against The Order Dated 22.07.2025 Of The Ld. Cit(A), Pune-12 Relating To Assessment Year 2016-17. 2. Facts Of The Case, In Brief, Are That The Assessee Is A Company & Filed Its Return Of Income On 01.09.2016 Declaring Total Income Of Rs.Nil. The Return Was Processed U/S 143(1) Of The Income Tax Act, 1961 (Hereinafter Referred To As ‘The Act’). The Case Was Selected For Limited Scrutiny Through Cass For The Following Issue: “Whether Unsecured Loans Are Genuine & From Disclosed Sources.”

For Appellant: Shri Suresh AnchaliyaFor Respondent: Shri S. Sadananda Singh, JCIT
Section 131Section 132Section 132(4)Section 133(6)Section 143(1)Section 143(2)Section 144Section 68

TDS thereon, bank statement etc to prove the identity and creditworthiness of the loan creditor and genuineness of the transaction. The director of Risa International Ltd, lender company has appeared before the Assessing Officer in response to the summons u/s 131 of the Act and has confirmed to have extended the loan of Rs.1,15,00,000/- out of collections

DHAVAL VINOD GADA,PUNE vs. DCIT CIRCLE-5, PUNE

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

ITA 1817/PUN/2025[2013-14]Status: DisposedITAT Pune03 Dec 2025AY 2013-14

Bench: Shri R. K. Panda & Ms. Astha Chandraassessment Year : 2013-14 Dhaval Vinod Gada Dcit, Circle – 5, Pune 101, New Timber Market, Vs. Bhawani Peth, Pune – 411042 Pan: Anjpg4733A (Appellant) (Respondent) Assessee By : Shri Nikhil S Pathak Department By : Shri A D Kulkarni Date Of Hearing : 26-11-2025 Date Of Pronouncement : 03-12-2025 O R D E R Per R.K. Panda, Vp:

For Appellant: Shri Nikhil S PathakFor Respondent: Shri A D Kulkarni
Section 131Section 133(6)Section 142(1)Section 143(2)Section 271(1)(c)Section 40A(2)(b)Section 68

TDS thereon, bank statement etc to prove the identity and creditworthiness of the loan creditor and genuineness of the transaction. The 10 director of Risa International Ltd, lender company has appeared before the Assessing Officer in response to the summons u/s 131 of the Act and has confirmed to have extended the loan of Rs.1