R&DE (ENGRS) EMPLOYEES CO-OP. CREDIT SOCIETY,PUNE vs. ITO, WARD 7(3), PUNE, PUNE

In the result, the appeal of the assessee is allowed

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

section 263 of the Act The Court held that every loss of tax cannot be said to be prejudicial to the interests of the Revenue. If two views are possible, and the AO has adopted one of those views, the order of assessment cannot be prejudicial to the interests of the Revenue. However, when the Assessing Officer does not apply

AHMEDNAGAR ZILLA GRAMSEVAKANCHI SAHAKAR PATSANSTHA MARYADIT,AHILYANAGAR vs. PCIT, PUNE-1, PUNE

In the result, the appeal of the assessee is allowed

capital gain / loss.\nNo Sale. Hence not applicable.\nii) Long Term Investment of Rs.1,23,11,263/-\nThis amount represent reserve fund saving account in ADCC bank. As per Maharashtra Co-\noperative Society Act, 1960 every co-operative society has to keep 25% of his current profit as\nreserve fund in District central co-operative bank. This amount represent cumulative

ASSISTANT COMMISSIONER OF INCOME-TAX vs. ENDURANCE TECHNOLOGIES PVT. LTD.,, AURANGABAD

Appeals are dismissed in above terms

Bench: Shri S.S.Godara, Jm & Shri Dr. Dipak P. Ripote, Am आयकर अपीऱ सं. / Ita No. 989/Pn/2015 ननधधारण वषा / Assessment Year : 2010-11

capital gain on sale of land Rs.2,15,37,986/-. Further, the remaining loss of ITA Nos. 2016 & 1694/PN/2017 A.Y. 2010-11 to 2012-13, Endurance Technologies Pvt. Ltd., Rs.43,72,19,080/- on sale of shares of Paioli Meccanica SPA, Italy is also allowed to carried forward. The A.O; is directed accordingly. Ground Nos.5 & 6 are allowed

DEPUTU COMMISSIONER OF INCOME-TAX vs. ENDURANCE TECHNOLOGIES PVT. LTD.,, AURANGABAD

Appeals are dismissed in above terms

Bench: Shri S.S.Godara, Jm & Shri Dr. Dipak P. Ripote, Am आयकर अपीऱ सं. / Ita No. 989/Pn/2015 ननधधारण वषा / Assessment Year : 2010-11

capital gain on sale of land Rs.2,15,37,986/-. Further, the remaining loss of ITA Nos. 2016 & 1694/PN/2017 A.Y. 2010-11 to 2012-13, Endurance Technologies Pvt. Ltd., Rs.43,72,19,080/- on sale of shares of Paioli Meccanica SPA, Italy is also allowed to carried forward. The A.O; is directed accordingly. Ground Nos.5 & 6 are allowed

DEPUTY COMMISSSIONER OF INCOME TAX, CIRCLE -1,, AURANGABAD vs. ENDURANCE TECHNOLOGIES PVT. LTD,, AURANGABAD

Appeals are dismissed in above terms

Bench: Shri S.S.Godara, Jm & Shri Dr. Dipak P. Ripote, Am आयकर अपीऱ सं. / Ita No. 989/Pn/2015 ननधधारण वषा / Assessment Year : 2010-11

capital gain on sale of land Rs.2,15,37,986/-. Further, the remaining loss of ITA Nos. 2016 & 1694/PN/2017 A.Y. 2010-11 to 2012-13, Endurance Technologies Pvt. Ltd., Rs.43,72,19,080/- on sale of shares of Paioli Meccanica SPA, Italy is also allowed to carried forward. The A.O; is directed accordingly. Ground Nos.5 & 6 are allowed

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:

gain. He referred to the decision of Hon'ble Gujarat High Court in the case of N. N. Desai Charitable Trust v. CIT reported in [(2000) 246 ITR 452 (Guj] wherein the Hon’ble High Court has held that when the transactions between a charitable trust and its related concerns are excessive and lack commercial prudence, the trust forfeits exemption

UJWAL FINE HOMES,PUNE vs. THE PRINCIPAL COMMISSIONER OF INCOME TAX -3, PUNE

In the result, appeal of the assessee is dismissed

Bench: Ms.Astha Chandra & Dr.Dipak P. Ripoteआयकर अपील सं. / Ita Nos.491/Pun/2024 िनधा"रण वष" / Assessment Year: 2018-19 Ujwal Fine Homes, V The Principal High Bliss, S No.23, Dhayri S Commissioner Of Income Narhe Road, Pune – 411041. Tax, Pune -3, Pune. Pan; Aabfu7293E Appellant/ Assessee Respondent / Revenue Assessee By Shri C.H.Naniwadekar – Ar Revenue By Shri Ajay Kumar Keshari – Cit(Dr) Date Of Hearing 21/11/2024 Date Of Pronouncement 28/11/2024 आदेश/ Order Per Dr. Dipak P. Ripote, Am: This Appeal Filed By The Assessee Directed Against The Order Of Ld.Principal Commissioner Of Income Tax, Pune-3, Pune U/Sec.263 Of The Income Tax Act, 1961; Dated 09.02.2024 For The A.Y.2018- 19. The Assessee Has Raised The Following Grounds Of Appeal : “1. In Issuing The Notice U/S 263 Of The Income-Tax Act, 1961 For Ay 2018-19

Section 263 of the ITAT Act. There was material before the ITAT to at least prima facie infer that there was under-invoicing and that this aspect of under-invoicing was not considered by the AO in making his assessment order. The CIT, in exercising its revisional jurisdiction, has not shut out any of the defences open

AVINASH DATTATRAY MULEY,PUNE vs. PCIT, PUNE, PUNE

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

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

2 to section 263 of the Act. He, therefore, issued a show cause notice to the assessee asking him to explain as to why the provisions of section 263 of the Act should not be invoked. Rejecting the various explanations given by the assessee, the Ld. PCIT held that the order passed by the Assessing Officer for the impugned assessment

SETH RAMDAS NATHUBHAI DHARMADAYA VISHWASTA NIDHI,,PUNE vs. INCOME-TAX OFFICER,(EXEMPTIONS) -1,, PUNE

Bench: Shri R.S. Syal & Shri Partha Sarathi Chaudhury"नधा"रण वष" / Assessment Year : 2011-12 Seth Ramdas Nathubhai Dharmadaya Vs. Ito Vishwasta Nidhi, (Exemptions)-1, C/O. Shah Khandelwal Jain & Pune Associates, Chartered Accountants, Level 3, Business Bay, Plot No.84, Wellesley Road, Near Rto, Pune 411 001 Pan : Aaatr6805N Appellant Respondent

263 ITR 13, the Hon’ble Andhra Pradesh High Court held that the finding of fact recorded by the AO and confirmed by the First Appellate Authority and the Tribunal to the effect that the assessee has violated the provisions of section 13(1)(c)(ii) r.w.s. 13(2)(b) and section 13(3)(c) gave rise to no question

RAJKAMAL STONE METAL WORKS,AMBEGAON KHURD, DIST. PUNE vs. ACIT CIRCLE 5 PUNE, PUNE

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

Bench: Shri R. K. Panda & Ms Astha Chandraassessment Year : 2017-18

2 The learned CIT (Appeals) failed to appreciate that the appellant firm has transferred only the amounts pertaining to the immovable properties sitting in the Balance Sheet of the assessee firm to its partners capital accounts without execution of any instruments in writing and hence there was no legal transfer of the impugned properties to the partners giving rise

JAYANT PROMOTERS LLP (EARLIER JAYANT PROMOTERS PVT.LTD),,PUNE vs. PR. COMMISSIONER OF INCOME-TAX -6,, PUNE

Appeal is dismissed

Bench: Shri S.S.Godara & Shri Inturi Rama Raoआयकर अपीलसं. / Ita No.1243/Pun/2018 िनधा"रणवष" / Assessment Year : 2015-16 Jayant Promoters Llp (Earlier The Principal Commissioner Jayant Promoters Pvt. Ltd.,), Vs Of Income Tax, Pune – 6. Khandelwal Jain & Associates, . Alankar Cinema Building, 1St Floor, Above United Bank, Punbe – 411001. Pan: Aaccj 1265 H Appellant/ Assessee Respondent /Revenue Assessee By Shri Sarvesh Khandelwal & R G Nahar – Ar Revenue By Shri Sunil Kumar – Dr Date Of Hearing 06/09/2022 Date Of Pronouncement 28/09/2022 आदेश/ Order Per S.S.Godara, Jm: This Assessee’S Appeal For Assessment Year 2015-16 Is Directed Against The Principle Commissioner Of Income Tax-6, Pune’S Order No.Pn/Pcit-6/263/2018-19 Dated 30/05/2018, In Proceedings U/S.263 Of The Income Tax Act, 1961 [In Short “The Act”].

2. It emerges at the outset that the assessee’s sole substantive ground pleaded in the instant appeal challenges correctness of the PCIT’s section 263 revision directions terming the corresponding ITA No.1243/PUN/2018 for A.Y. 2015-16 (A) regular assessment dated 11.03.2017 framed by the Assessing Officer as an erroneous one causing prejudice to interest of Revenue qua the sole

INCOME TAX OFFICER, WARD-1, JALNA, JALNA vs. ASHISH OMPRAKASH MANTRI, JALNA

In the result, all the appeals filed by the Revenue are dismissed

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

2. We enclose herewith ledger account of agriculture income for your record and perusal. 3. The details of capital gain on sale of plots is already filed along with computation of income for the year under assessment in our earlier submission. We enclose herewith Purchase and sale deeds of the said plots sold for your record and perusal

INCOME TAX OFFICER, WARD -1, JALNA, JALNA vs. PRAMILA OMPRAKASH MANTRI, JALNA

In the result, all the appeals filed by the Revenue are dismissed

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

2. We enclose herewith ledger account of agriculture income for your record and perusal. 3. The details of capital gain on sale of plots is already filed along with computation of income for the year under assessment in our earlier submission. We enclose herewith Purchase and sale deeds of the said plots sold for your record and perusal

INCOME TAX OFFICER, WARD-1, JALNA, JALNA vs. OMPRAKASH ASARAM MANTRI, JALNA

In the result, all the appeals filed by the Revenue are dismissed

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

2. We enclose herewith ledger account of agriculture income for your record and perusal. 3. The details of capital gain on sale of plots is already filed along with computation of income for the year under assessment in our earlier submission. We enclose herewith Purchase and sale deeds of the said plots sold for your record and perusal

INCOME TAX OFFICER, WARD-1, JALNA, JALNA vs. ATUL OMPRAKASH MANTRI, JALNA

In the result, all the appeals filed by the Revenue are dismissed

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

2. We enclose herewith ledger account of agriculture income for your record and perusal. 3. The details of capital gain on sale of plots is already filed along with computation of income for the year under assessment in our earlier submission. We enclose herewith Purchase and sale deeds of the said plots sold for your record and perusal

INCOME TAX OFFICER, WARD-1, JALNA, JALNA vs. OMPRAKASH ASARAM MANTRI, JALNA

In the result, all the appeals filed by the Revenue are dismissed

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

2. We enclose herewith ledger account of agriculture income for your record and perusal. 3. The details of capital gain on sale of plots is already filed along with computation of income for the year under assessment in our earlier submission. We enclose herewith Purchase and sale deeds of the said plots sold for your record and perusal

INCOME TAX OFFICER, WARD-1, JALNA, JALNA vs. PRAMILA OMPRAKASH MANTRI, JALNA

In the result, all the appeals filed by the Revenue are dismissed

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

2. We enclose herewith ledger account of agriculture income for your record and perusal. 3. The details of capital gain on sale of plots is already filed along with computation of income for the year under assessment in our earlier submission. We enclose herewith Purchase and sale deeds of the said plots sold for your record and perusal

INCOME TAX OFFICER, WARD-1, JALNA, JALNA vs. ATUL OMPRAKASH MANTRI, JALNA

In the result, all the appeals filed by the Revenue are dismissed

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

2. We enclose herewith ledger account of agriculture income for your record and perusal. 3. The details of capital gain on sale of plots is already filed along with computation of income for the year under assessment in our earlier submission. We enclose herewith Purchase and sale deeds of the said plots sold for your record and perusal

SANJAY AMRUTRAO SATAV (HUF),PUNE vs. INCOME-TAX OFFICER, WARD 12(4), PUNE

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

Bench: Shri Inturi Rama Rao & Shri S. S. Viswanethra Raviआयकर अपील सं. / Ita No.200/Pun/2021 िनधा"रण वष" / Assessment Year: 2016-17 Sanjay Amrutrao Satav Vs. Ito, Ward- 12(4), Pune. (Huf), Amrut Palace Bungalow, Gat No.12 Bhavadi Road Wagholi, Near Bhairavnath Mandir, Taluka Haveli, Pune- 412207. Pan : Aayhs1085F Appellant Respondent Assessee By : Smt. Pooja Rander Revenue By : Shri Sardar Singh Meena Date Of Hearing : 29.06.2022 Date Of Pronouncement : 30.06.2022 आदेश / Order Per Inturi Rama Rao, Am: This Is An Appeal Filed By The Assessee Directed Against The Order Of Ld. Pr. Commissioner Of Income Tax- 4, Pune [‘The Pr.Cit’] Dated 31.03.2021 Passed U/S 263 Of The Income Tax Act, 1961 For The Assessment Year 2016-17. 2. The Appellant Raised The Following Grounds Of Appeal :-

2] of the I.T. Act 1961, the capital gains on sale of impugned agriculture land introduced by the appellant as stock in trade of his business had become chargeable to income tax during previous year relevant to A.Y.2014-15 and hence in view of the amended provision of Section 54B w.e.f. 01/04/2013 the Capital Gains were rightly claimed as exempt