SAMEER SATISH SATPUTE,PUNE vs. INCOME TAX OFFICER, (IT) WARD 4, PUNE , B.O. BHAWAN, PUNE
In the result, the appeal of assessee is treated as allowed for statistical purpose
ITA 2933/PUN/2025[2022-23]Status: DisposedITAT Pune10 Apr 2026AY 2022-23
Bench: Shri R.K. Panda & Ms. Astha Chandraआयकर अपील सं. / Ita No.2933/Pun/2025 धििाारण वर्ा / Assessment Year : 2022-23 Sameer Satish Satpute, Ito, (It) Ward 4, Pune 39, Rakshak Society, Aundh, Pune-411027 Vs. Pan : Asops4608L अपीलार्थी / Appellant प्रत्यर्थी / Respondent Assessee By : Shri Kishor B Phadke Department By : Shri Harshit Bari Date Of Hearing : 25-02-2026 Date Of 10-04-2026 Pronouncement : आदेश / Order Per Astha Chandra, Jm : The Appeal Filed By The Assessee Is Directed Against The Order Dated 04.09.2025 Of The Ld. Commissioner Of Income Tax (Appeals), Pune-13 [“Cit(A)”] Pertaining To Assessment Year (“Ay”) 2022-23. 2. Briefly Stated, The Facts Of The Case Are That The Assessee Is A Non- Resident Individual. During Fy 2021-22 Relevant To Ay 2022-23 Under Consideration, The Taxable Income Of The Assessee In India Comprised Of : (I) Rental Income From House Property In Pune; (Ii) Capital Gains From Stocks & Mutual Funds; (Iii) Dividend Income; (Iv) Fixed Deposits & (V) Nro Account Interest & Pass Through Income From Two Funds. For Ay 2022- 23, The Assessee Filed His Return Of Income U/S 139(1) Of The Income Tax Act, 1961 (The “Act”) On 30.07.2022 Claiming Refund Of Rs.3,62,090/-. The Return Of The Assessee Was Processed By The Cpc, Bengaluru U/S 143(1) Of The Act Vide Intimation Order Dated 06.10.2023 Wherein The Ld. Cpc Assessed The Total Income Of The Assessee At Rs.5,37,30,540/- & Raised A Tax Demand Of Rs.35,68,200/-. On Going Through The Intimation, The Assessee Noticed That Though Gross Total Income Was Accepted, Income Adopted As Chargeable At Special Rate Was Incorrect. As Per The Order Of 2
For Appellant: Shri Kishor B PhadkeFor Respondent: Shri Harshit Bari
Section 115BSection 139(1)Section 143(1)Section 154
264,91,594 has been doubly taxed, which ought to be corrected. The Ld. CIT(A)/NFAC after considering the submissions of the assessee which are reproduced in para 8 of his impugned order dismissed the above ground raised by the assessee by observing as under:
“9. FINDINGS:-
During these appellate proceedings, the statement of facts, the grounds of appeal