SATISH VISHNU THOMBARE, INCOME TAX OFFICER, WARD-1, AHMEDNAGAR, AHMEDNAGAR vs. VARSHA PRAFULLA ZENDE, AHMEDNAGAR

In the result, the appeal of the Revenue is dismissed

Bench: Shri R.K. Panda & Ms. Astha Chandraआयकर अपील सं. / Ita No.1656/Pun/2024 धििाारण वर्ा / Assessment Year : 2010-11 Satish Vishnu Thombare, Varsha Prafulla Zende, Income Tax Officer, Prop Of Bleach Chem Enterprises, Ward-1, Ahmednagar Vs. Industrial Estate, Shrirampur, Maharashtra-413709 Pan : Aabpz2541C अपीलार्थी / Appellant प्रत्यर्थी / Respondent Assessee By : Miss Shivani Shah (Virtual) Department By : Shri Akhilesh Srivastva Date Of Hearing : 06-08-2025 Date Of 29-10-2025 Pronouncement : आदेश / Order

section 151 of the Act. The relevant findings and observations of the Ld. CIT(A) is reproduced below : “6. Findings & Decision 6.1. I have carefully gone through the assessment order u/s 147 r.w.s.143(3), appellate order of CIT(A)-2, Pune, order of Hon‟ble ITAT, Pune, written submissions of the assessee and the documents furnished. 6.2. During the appellate

SUNAND CONSTRUCTIONS,PUNE vs. DCIT CENTRAL CIRCLE 2(2), PUNE, PUNE

In the result, both the appeals filed by the assessee are allowed

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

TDS. 17. We find Hon’ble Bombay High Court in the case of CIT vs. Jet Airways (I) Ltd. (supra) has held that after insertion of Explanation 3 to section 147

SUNANDA CONSTRUCTIONS,PUNE vs. DCIT, CENTRAL CIRCLE 2(2), PUNE, PUNE

In the result, both the appeals filed by the assessee are allowed

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

TDS. 17. We find Hon’ble Bombay High Court in the case of CIT vs. Jet Airways (I) Ltd. (supra) has held that after insertion of Explanation 3 to section 147

VAISHALI KESHAV KULKARNI,PUNE vs. ITO WARD 13(2), PUNE

In the result the Grounds Numbers 2, 3 and 4 raised by the assessee are allowed

147 read with section 144B of the Act, the appellant presents this appeal before Your Honor.\"\n5.1 Inspite of providing documentary evidence that assessee is not the owner of the impugned property, her father is owner and her father has paid entire tax, copy of the return of income filed by her father u/s.139(1), theld.CIT(A) has confirmed

M/S. SHARADA PAPER COMPANY,,PUNE vs. INCOME-TAX OFFICER, WARD - 11 (4),, PUNE

In the result, the appeal of the assessee is partly allowed

Bench: Shri S.S.Godara & Dr. Dipak P. Ripoteआयकरअपीलसं. / Ita No.1547/Pun/2019 िनधा"रणवष" / Assessment Year : 2007-08 M/S.Sharada Paper Company, The Income Tax Officer, 436/8, Narayan Peth, Vs Ward-11(4), Pune. Maharashtra – 411030. Pan: Aaffs 1470 H Appellant/ Assessee Respondent / Revenue Assessee By Shri Suhas Bora – Ar Revenue By Shri M.G.Jasnani – Dr Date Of Hearing 13/07/2022 Date Of Pronouncement 29/09/2022 आदेश/ Order Per Dr. Dipak P. Ripote, Am: This Appeal Filed By The Assessee Is Directed Against The Order Of Ld.Commissioner Of Income Tax(Appeals)-8, Pune For The Assessment Year 2007-08 Dated 18.07.2019 Arising Out Of Order Under Section 154 Of The Income Tax Act, 1961 Dated 25.03.2013. The Assessee Has Raised Following Grounds Of Appeal: “1. The Learned Commissioner Of Income Tax (Appeal -8) Has Erred In Confirming The Withdrawal Of Claim For The Carry Forward Of Loss For A.Y. 2003-04, A.Y. 2004-05, A.Y.2005-06 & A.Y.2006- 07 Without Verifying The Facts. 2. The Learned Commissioner Of Income Tax (Appeal -8) Has Erred In Confirming The Rectification Order Passed By The Assessing Officer Under Section 154 & Thereby Withdrawing Loss Allowed In The Assessment Made Under Section 143(3) Of Income Taxact,1961 Without Appreciating The Fact That This Is Not Mistake Apparent From Records & Hence Cannot Be Rectified Under 154 Of The Act.

TDS Certificates. Thus, it means assessee had filed return of income for A.Y. 2003-04 along with Audit Report. In the paper book, page no.64 to 83 is the Audit Report. The assessee had filed copies of the audit report before the ld.CIT(A) also. Similarly, the return of income for A.Y. 2004-05 (page 84 of the paper book

MRINALINI JAYANT PURANIK,PUNE vs. ITO, WARD-2(2), PUNE, PUNE

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

Bench: Shri R. K. Panda & Ms. Astha Chandraassessment Year : 2019-20 Mrinalini Jayant Puranik Ito, Ward 2(2), Pune Flat 14, Khagol Coop Society, Vs. S.No.38/1, Panchavati, Pashan, Pune – 411008 Pan: Almpp5163E (Appellant) (Respondent) Assessee By : Shri Suhas Kulkarni Department By : Shri A D Kulkarni Date Of Hearing : 26-11-2025 Date Of Pronouncement : 28-11-2025 O R D E R Per R.K. Panda, Vp:

TDS 2 statement the assessee has received various income to the tune of Rs.2,63,15,529/-, the Assessing Officer, after recording reasons, issued notice to reopen the assessment as per provisions of section 147

NATHARAM PANAJI CHOUDHARY,PUNE vs. I.T.O. WARD 8(1), PUNE, PUNE

In the result, the appeal of the assessee is allowed for statistical purposes

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

section 147 is permissible even if the Assessing officer gathers his reasons to believe from the very same record as has been the subject matter of the completed assessment proceedings. There might indeed be a presumption that the assessment proceedings have been regularly conducted, but there can be no presumption that even when the order of assessment is silent

NATHARAM PANAJI CHOUDHARY,PUNE vs. I.T.O. WARD 8(1), PUNE, PUNE

In the result, the appeal of the assessee is allowed for statistical purposes

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

section 147 is permissible even if the Assessing officer gathers his reasons to believe from the very same record as has been the subject matter of the completed assessment proceedings. There might indeed be a presumption that the assessment proceedings have been regularly conducted, but there can be no presumption that even when the order of assessment is silent

CHANDRAKANT VITHTHAL BHOPI,RAIGAD vs. ITO WARD 1 , PANVEL

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

Bench: Shri R. K. Panda & Ms. Astha Chandraassessment Year : 2016-17 Chandrakant Viththal Bhopi Ito, Ward-1, Panvel At Chinchpada, Post Panvel, Tal. Vs. Panvel, Dist. Raigad – 410206 Pan: Bjdpb7610L (Appellant) (Respondent) Assessee By : Shri Nikhil S Pathak & Ajinkya M Vaishampayan Department By : Shri Ramnath P Murkunde Date Of Hearing : 05-05-2025 Date Of Pronouncement : 07-05-2025 O R D E R

TDS Return - Other Interest Rs 2,60,05,088/- (Section 194A) 8 Ongoing through office records, it has been found that the assessee has NOT filed return of income for the A.Y. 2016-17 and therefore, the income earned out of the transaction as tabulated above had not been disclosed by the assessee pertaining to above mentioned transaction. In view

KALPANA VIJAY KADAM,PUNE vs. ITO, WARD 2(2), PUNE, PUNE

In the result, appeal of the assessee is Partly Allowed

Bench: Dr.Dipak P. Ripote & Shri Vinay Bhamoreआयकर अपील सं. / Ita No.841/Pun/2025 िनधा"रण वष" / Assessment Year: 2016-17 Kalpana Vijay Kadam, V The Income Tax Officer, Fi 13, Janki Heights, S.No.250, S. Ward-2(2), Pune. Baner D P Road, Aundh, Pune – 411007. Maharashtra. Pan: Axzpk4350P Appellant/ Assessee Respondent / Revenue Assessee By Shri Suhas P. Bora – Ar Revenue By Shri Manish Mehta – Addl.Cit(Dr) Date Of Hearing 15/05/2025 Date Of Pronouncement 23/05/2025 आदेश/ Order Per Dr. Dipak P. Ripote, Am: This Appeal Filed By The Assessee Is Directed Against The Order Of Ld.Commissioner Of Income Tax(Appeals)[Nfac], Under Section 250 Of The Income Tax Act, 1961 (Hereinafter Referred To As ‘The Act’), Dated 06.02.2025 For The A.Y.2016-17. The Assessee Has Raised The Following Grounds Of Appeal : “1. On The Facts & In Law, The Learned Commissioner Of Income Tax (Appeals) [Cit(A)] Erred In Passing An Ex-Parte Order Without Affording A Reasonable Opportunity To The Appellant. The Order Was Solely Based On The Observations Of The Assessing Officer (Ao) In The

147 read with sections 144 and 144B of the Income-tax Act, 1961 ("the Act"), is bad in law and void ab initio for the following reasons: i. The alleged escaped income is less than Rs. 50 lakhs, rendering the reassessment proceedings invalid. ii. The reopening was based on mere presumption and surmises, as it was initiated on borrowed satisfaction

MRS. SNEHAL SAMEER BHUJBAL,PUNE vs. ITO, WARD 13(2), PUNE, PUNE

Accordingly, Ground No.1 of the Assessee is allowed

Bench: Dr.Dipak P. Ripote & Shri Vinay Bhamoreआयकर अपील सं. / Ita No.1549/Pun/2025 िनधा"रण वष" / Assessment Year: 2018-19 Mrs. Snehal Sameer Bhujbal, V The Income Tax Officer, Sanswadi, Nagar Road, S Ward-13(2), Pune. Pune – 412208. Maharashtra. Pan: Blcpb5495C Appellant/ Assessee Respondent / Revenue Assessee By Shri Bhuvanesh Kankani – Ar Revenue By Shri Sandeep P Sathe – Jcit(Dr) Date Of Hearing 17/07/2025 Date Of Pronouncement 21/07/2025 आदेश/ Order Per Dr. Dipak P. Ripote, Am: This Is An Appeal Filed By Assessee Against The Order Of Ld.Commissioner Of Income Tax(Appeal)[Nfac],Passed Under Section 250 Of The Income Tax Act, 1961 For The A.Y.2018-19 Dated 16.05.2025, Emanating From Order U/S.147 R.W.S 144 Of The Income Tax Act, 1961, Dated 19.01.2024. The Assessee Has Raised Following Grounds Of Appeal : “1. On The Facts & Circumstances Prevailing In The Case & As Per Provisions & Scheme Of The Income-Tax Act, 1961 ('The Act') It Be Held

Section 147 of the Act. The said order u/s.148A(d) has been approved by ld.Pr.CCIT, Pune. We have already reproduced the Screenshot of the Insight Portal of Income Tax Department for ready reference. Thus, Assessing Officer has merely totalled the figures appearing in the Insight Portal without application of mind. Had the Assessing Officer analyzed the information appearing

DREAMS BELLE VUE,PUNE vs. ITO WARD 2 (1), PUNE

In the result, the appeal of the assessee is allowed for statistical\npurposes

TDS amounting to Rs.3,42,744\nought to be granted either to the Appellant AOP or, in the alternative,\nto the respective members who have duly offered the corresponding\nincome in their individual returns of income.\n4.\nThe Appellant craves to add/modify/amend/delete all / any of\ngrounds of appeal.\"\n4.\nBriefly stated the facts are that the assessee is an Association

DREAMS BELLE VUE,PUNE vs. ITO WARD-2(3), PUNE, PUNE

In the result, the appeal of the assessee is allowed for statistical\npurposes

TDS amounting to Rs.3,42,744\nought to be granted either to the Appellant AOP or, in the alternative,\nto the respective members who have duly offered the corresponding\nincome in their individual returns of income.\n4.\nThe Appellant craves to add/modify/amend/delete_all / any of\ngrounds of appeal.\"\n4.\nBriefly stated the facts are that the assessee is an Association

PADMAKAR VISHWAS DATE,BHOSARI vs. INCOME TAX E ASSESSMENT, PUNE

In the result, appeal of the assessee is dismissed

Bench: Shri S.S.Godara & Dr. Dipak P. Ripoteआयकर अपील सं. / Ita Nos.929, 930 & 931/Pun/2023 िनधा"रण वष" / Assessment Years : 2013-14, 2014-15 & 2015-16 Padmakar Vishwas Date, The Income Tax Officer S.No.218, Near Shri Krishn V –Tds(2), Pune. Mandir, Alandi Road, S Bhosari, Pune – 411038. Pan: Anhpd3804B Appellant/ Assessee Respondent /Revenue Assessee By None Revenue By Shri Sourabh Nayak – Addl.Cit(Dr) Date Of Hearing 15/02/2024 Date Of Pronouncement 16/02/2024 आदेश/ Order Per Dr. Dipak P. Ripote, Am: These Three Appeals Filed By The Assessee Are Against The Separate Orders Of Ld.Commissioner Of Income Tax(Appeals)[Nfac], Passed Under Section 250 Of The Income Tax Act, 1961 All Dated 26.06.2023. Since Issue Involved Is Same, All These Appeals Were Heard Together & Decided By This Consolidated Order. We Treat Appeal In Ita No.929/Pun/2023 For A.Y.2013-14

147 [except an order passed in pursuance of directions of the Dispute Resolution Panel or an order referred to in sub-section (12) of section 144BA] or section 150; (ba) an order of assessment or reassessment under section 153A [except an order passed in pursuance of directions of the Dispute Resolution Panel] or an order referred to in sub-section

PADMAKAR VISHWAS DATE,,BHOSARI vs. INCOME TAX E ASSESSMENT, PUNE

In the result, appeal of the assessee is dismissed

Bench: Shri S.S.Godara & Dr. Dipak P. Ripoteआयकर अपील सं. / Ita Nos.929, 930 & 931/Pun/2023 िनधा"रण वष" / Assessment Years : 2013-14, 2014-15 & 2015-16 Padmakar Vishwas Date, The Income Tax Officer S.No.218, Near Shri Krishn V –Tds(2), Pune. Mandir, Alandi Road, S Bhosari, Pune – 411038. Pan: Anhpd3804B Appellant/ Assessee Respondent /Revenue Assessee By None Revenue By Shri Sourabh Nayak – Addl.Cit(Dr) Date Of Hearing 15/02/2024 Date Of Pronouncement 16/02/2024 आदेश/ Order Per Dr. Dipak P. Ripote, Am: These Three Appeals Filed By The Assessee Are Against The Separate Orders Of Ld.Commissioner Of Income Tax(Appeals)[Nfac], Passed Under Section 250 Of The Income Tax Act, 1961 All Dated 26.06.2023. Since Issue Involved Is Same, All These Appeals Were Heard Together & Decided By This Consolidated Order. We Treat Appeal In Ita No.929/Pun/2023 For A.Y.2013-14

147 [except an order passed in pursuance of directions of the Dispute Resolution Panel or an order referred to in sub-section (12) of section 144BA] or section 150; (ba) an order of assessment or reassessment under section 153A [except an order passed in pursuance of directions of the Dispute Resolution Panel] or an order referred to in sub-section

PADMAKAR VISHWAS DATE,BHOSARI vs. INCOME TAX E ASSESSMENT , PUNE

In the result, appeal of the assessee is dismissed

Bench: Shri S.S.Godara & Dr. Dipak P. Ripoteआयकर अपील सं. / Ita Nos.929, 930 & 931/Pun/2023 िनधा"रण वष" / Assessment Years : 2013-14, 2014-15 & 2015-16 Padmakar Vishwas Date, The Income Tax Officer S.No.218, Near Shri Krishn V –Tds(2), Pune. Mandir, Alandi Road, S Bhosari, Pune – 411038. Pan: Anhpd3804B Appellant/ Assessee Respondent /Revenue Assessee By None Revenue By Shri Sourabh Nayak – Addl.Cit(Dr) Date Of Hearing 15/02/2024 Date Of Pronouncement 16/02/2024 आदेश/ Order Per Dr. Dipak P. Ripote, Am: These Three Appeals Filed By The Assessee Are Against The Separate Orders Of Ld.Commissioner Of Income Tax(Appeals)[Nfac], Passed Under Section 250 Of The Income Tax Act, 1961 All Dated 26.06.2023. Since Issue Involved Is Same, All These Appeals Were Heard Together & Decided By This Consolidated Order. We Treat Appeal In Ita No.929/Pun/2023 For A.Y.2013-14

147 [except an order passed in pursuance of directions of the Dispute Resolution Panel or an order referred to in sub-section (12) of section 144BA] or section 150; (ba) an order of assessment or reassessment under section 153A [except an order passed in pursuance of directions of the Dispute Resolution Panel] or an order referred to in sub-section

AUTOCOMP CORPORATION PANSE PRIVATE LIMITED ,PUNE vs. ASST. COMMISSIONER OF INCOME TAX, PUNE

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

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

147. The learned CITA failed to consider the submissions made against the aforesaid addition and failed to appreciate that- 4.1 The appellant had accumulated and capitalised the expenses incurred on tooling and dies at the behest and on behalf of the Customers of Rs.6,00,43,068/- under Capital Work in Progress (CWIP) in the General Ledger in the books

AUTOCOMP CORPORATION PANSE PRIVATE LIMITED ,PUNE vs. ASST. COMMISSIONER OF INCOME TAX, CIRCLE 1(1), PUNE

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

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

147. The learned CITA failed to consider the submissions made against the aforesaid addition and failed to appreciate that- 4.1 The appellant had accumulated and capitalised the expenses incurred on tooling and dies at the behest and on behalf of the Customers of Rs.6,00,43,068/- under Capital Work in Progress (CWIP) in the General Ledger in the books

PRESHIT KRISHAN MHATRE,RAIGARH vs. ASSESSING OFFICER, NATIONAL FACELESS ASSESSMENT CENTRE

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

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

TDS return other interest (section 194A) – Rs.34261/- 4. He therefore, reopened the case of the assessee after recording satisfaction as per the provisions of section 147