PRASANNA SADASHIV SHETE,PUNE vs. THE DEPUTY COMMISSIONER OF INCOME TAX, CIRCLE-10, PUNE

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

Bench: Shri R. K. Panda & Shri Vinay Bhamoreassessment Year : 2012-13 Prasanna Sadashiv Shete Dcit, Circle 10, Pune 56/8, D-Ii, Midc Shete Industries, Vs. Chinchwad, Pune – 411019 Pan: Adbps4462Q (Appellant) (Respondent) Assessee By : Shri Suhas Bora Department By : Shri Arvind Desai, Addl Cit Dr Date Of Hearing : 27-03-2025 Date Of Pronouncement : 29-05-2025 O R D E R

section 27(3) of the Act is barred by limitation, it deserves to be rejected on this ground alone.” In Madhu Dadha vs. The Assistant Commissioner, Hon'ble Madras High Court in their decision dated 23.6.2009 in TC (A). No. 421 of 2009 while referring to the aforesaid decision of the Hon'ble Apex Court in P.K. RAMACHANDRAN v. State

SHREE BHASKARACHARYA PRATISHTHAN,CHH SAMBHAJINAGAR vs. LD. DEPUTY COMMISSIONER OF INCOME TAX, GHAZIABAD

In the result, both the bunch of appeals filed by the respective assessee’s in ITA Nos

Bench: Dr.Manish Borad & Shri Vinay Bhamoreआयकर अपील सं. / Ita Nos.476 To 480/Pun/2024 Chate Tutorials Pvt. Ltd., Vs. Acit,Tds Circle, Chate House, Plot No.4, Nashik Near N-2 Cricket Stadium, Cidco, Aurangabad – 431 003 Maharashtra Tan : Nskco1565E Appellant Respondent

5); and c. Dinesh T Tailor — [2010-TIOL-311-HC-MUM-IT] — (Para 11 and 12 on Page 21 and 22). 1.5 The assessee Appellant, additionally submitted that the distinction between tax, interest and fees canalso be made out from the fact that the charging section for tax, i.e. section 4 also mentions only income tax, TDS/TCS. For interest

SHREE BHASKARACHARYA PRATISHTHAN,CHH SAMBHAJINAGAR vs. LD. DEPUTY COMMISSIONER OF INCOME TAX, GHAZIABAD

In the result, both the bunch of appeals filed by the respective assessee’s in ITA Nos

Bench: Dr.Manish Borad & Shri Vinay Bhamoreआयकर अपील सं. / Ita Nos.476 To 480/Pun/2024 Chate Tutorials Pvt. Ltd., Vs. Acit,Tds Circle, Chate House, Plot No.4, Nashik Near N-2 Cricket Stadium, Cidco, Aurangabad – 431 003 Maharashtra Tan : Nskco1565E Appellant Respondent

5); and c. Dinesh T Tailor — [2010-TIOL-311-HC-MUM-IT] — (Para 11 and 12 on Page 21 and 22). 1.5 The assessee Appellant, additionally submitted that the distinction between tax, interest and fees canalso be made out from the fact that the charging section for tax, i.e. section 4 also mentions only income tax, TDS/TCS. For interest

CHATE TUTORIALS PVT LTD,AURANGABAD vs. ASSISTANT COMMISSIONER OF INCOME TAX, TDS CIRCLE, NASHIK, NASHIK

In the result, both the bunch of appeals filed by the respective assessee’s in ITA Nos

Bench: Dr.Manish Borad & Shri Vinay Bhamoreआयकर अपील सं. / Ita Nos.476 To 480/Pun/2024 Chate Tutorials Pvt. Ltd., Vs. Acit,Tds Circle, Chate House, Plot No.4, Nashik Near N-2 Cricket Stadium, Cidco, Aurangabad – 431 003 Maharashtra Tan : Nskco1565E Appellant Respondent

5); and c. Dinesh T Tailor — [2010-TIOL-311-HC-MUM-IT] — (Para 11 and 12 on Page 21 and 22). 1.5 The assessee Appellant, additionally submitted that the distinction between tax, interest and fees canalso be made out from the fact that the charging section for tax, i.e. section 4 also mentions only income tax, TDS/TCS. For interest

CHATE TUTORIALS PVT. LTD.,AURANGABAD vs. LD. ASSISTANT COMMISSIONER OF INCOME TAX, TDS CIRCLE, NASHIK, NASHIK

In the result, both the bunch of appeals filed by the respective assessee’s in ITA Nos

Bench: Dr.Manish Borad & Shri Vinay Bhamoreआयकर अपील सं. / Ita Nos.476 To 480/Pun/2024 Chate Tutorials Pvt. Ltd., Vs. Acit,Tds Circle, Chate House, Plot No.4, Nashik Near N-2 Cricket Stadium, Cidco, Aurangabad – 431 003 Maharashtra Tan : Nskco1565E Appellant Respondent

5); and c. Dinesh T Tailor — [2010-TIOL-311-HC-MUM-IT] — (Para 11 and 12 on Page 21 and 22). 1.5 The assessee Appellant, additionally submitted that the distinction between tax, interest and fees canalso be made out from the fact that the charging section for tax, i.e. section 4 also mentions only income tax, TDS/TCS. For interest

SHREE BHASKARACHARYA PRATISHTHAN,CHH SAMBHAJINAGAR vs. LD. DEPUTY COMMISSIONER OF INCOME TAX CPC TDS, GHAZIABAD

In the result, both the bunch of appeals filed by the respective assessee’s in ITA Nos

Bench: Dr.Manish Borad & Shri Vinay Bhamoreआयकर अपील सं. / Ita Nos.476 To 480/Pun/2024 Chate Tutorials Pvt. Ltd., Vs. Acit,Tds Circle, Chate House, Plot No.4, Nashik Near N-2 Cricket Stadium, Cidco, Aurangabad – 431 003 Maharashtra Tan : Nskco1565E Appellant Respondent

5); and c. Dinesh T Tailor — [2010-TIOL-311-HC-MUM-IT] — (Para 11 and 12 on Page 21 and 22). 1.5 The assessee Appellant, additionally submitted that the distinction between tax, interest and fees canalso be made out from the fact that the charging section for tax, i.e. section 4 also mentions only income tax, TDS/TCS. For interest

SHRI BHASKARACHARYA PRATISHTHAN,CHH. SAMBHAJINAGAR vs. LD. DEPUTY COMMISSIONER OF INCOME TAX, CPC-TDS

In the result, both the bunch of appeals filed by the respective assessee’s in ITA Nos

Bench: Dr.Manish Borad & Shri Vinay Bhamoreआयकर अपील सं. / Ita Nos.476 To 480/Pun/2024 Chate Tutorials Pvt. Ltd., Vs. Acit,Tds Circle, Chate House, Plot No.4, Nashik Near N-2 Cricket Stadium, Cidco, Aurangabad – 431 003 Maharashtra Tan : Nskco1565E Appellant Respondent

5); and c. Dinesh T Tailor — [2010-TIOL-311-HC-MUM-IT] — (Para 11 and 12 on Page 21 and 22). 1.5 The assessee Appellant, additionally submitted that the distinction between tax, interest and fees canalso be made out from the fact that the charging section for tax, i.e. section 4 also mentions only income tax, TDS/TCS. For interest

SHREE BHASKARACHARYA PRATISHTHAN,CHH SAMBHAJINAGAR vs. LD. DEPUTY COMMISSIONER OF INCOME TAX, CPC-TDS

In the result, both the bunch of appeals filed by the respective assessee’s in ITA Nos

Bench: Dr.Manish Borad & Shri Vinay Bhamoreआयकर अपील सं. / Ita Nos.476 To 480/Pun/2024 Chate Tutorials Pvt. Ltd., Vs. Acit,Tds Circle, Chate House, Plot No.4, Nashik Near N-2 Cricket Stadium, Cidco, Aurangabad – 431 003 Maharashtra Tan : Nskco1565E Appellant Respondent

5); and c. Dinesh T Tailor — [2010-TIOL-311-HC-MUM-IT] — (Para 11 and 12 on Page 21 and 22). 1.5 The assessee Appellant, additionally submitted that the distinction between tax, interest and fees canalso be made out from the fact that the charging section for tax, i.e. section 4 also mentions only income tax, TDS/TCS. For interest

SHRI BHASKARACHARYA PRATISHTHAN,CHH. SAMBHAJINAGAR vs. LD. DEPUTY COMMISSIONER OF INCOME TAX, CPC-TDS

In the result, both the bunch of appeals filed by the respective assessee’s in ITA Nos

Bench: Dr.Manish Borad & Shri Vinay Bhamoreआयकर अपील सं. / Ita Nos.476 To 480/Pun/2024 Chate Tutorials Pvt. Ltd., Vs. Acit,Tds Circle, Chate House, Plot No.4, Nashik Near N-2 Cricket Stadium, Cidco, Aurangabad – 431 003 Maharashtra Tan : Nskco1565E Appellant Respondent

5); and c. Dinesh T Tailor — [2010-TIOL-311-HC-MUM-IT] — (Para 11 and 12 on Page 21 and 22). 1.5 The assessee Appellant, additionally submitted that the distinction between tax, interest and fees canalso be made out from the fact that the charging section for tax, i.e. section 4 also mentions only income tax, TDS/TCS. For interest

WARVANDI VIVIDH KARYAKARI SEVASAHAKARI SOCIETY LTD.,AHMEDNAGAR vs. ITO, WARD 2,, AHMEDNAGAR

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

Bench: Shri S.S. Godara & Shri Inturi Rama Rao

condone the delay by holding that the appellant cannot sleep over the issue in filing the appeal for more than 120 days after the assessment order was passed. The ld. NFAC also referred to the statutory provisions of section 5

SHREE VINDHYA CAST COATERS LIMITED,JALGAON vs. DEPUTY COMMISSIONER OF INCOME TAX, CIRCLE-1, JALGAON

In the result, the appeals of assessee in ITA Nos

Bench: Ms. Astha Chandra & Shree Dr. Dipak P. Ripote

120-121]. Subsequently, an email communication was received from Income tax department on 27-02-2023 [Refer PB Page No. 63] whereby the password of the income tax portal was reset and the appellant was allowed to access the e-fling portal. Hence, from the period 07-12-2021 to 27-02-2023, the appellant could not file the appeal

SHREE VINDHYA CAST COATERS LIMITED,JALGAON vs. DEPUTY COMMISSIONER OF INCOME TAX, CIRCLE - 1, JALGAON

In the result, the appeals of assessee in ITA Nos

Bench: Ms. Astha Chandra & Shree Dr. Dipak P. Ripote

120-121]. Subsequently, an email communication was received from Income tax department on 27-02-2023 [Refer PB Page No. 63] whereby the password of the income tax portal was reset and the appellant was allowed to access the e-fling portal. Hence, from the period 07-12-2021 to 27-02-2023, the appellant could not file the appeal

SHREE VINDHYA CAST COATERS LIMITED,JALGAON vs. DEPUTY COMMISSIONER OF INCOME TAX, CIRCLE - 1, JALGAON

In the result, the appeals of assessee in ITA Nos

Bench: Ms. Astha Chandra & Shree Dr. Dipak P. Ripote

120-121]. Subsequently, an email communication was received from Income tax department on 27-02-2023 [Refer PB Page No. 63] whereby the password of the income tax portal was reset and the appellant was allowed to access the e-fling portal. Hence, from the period 07-12-2021 to 27-02-2023, the appellant could not file the appeal

SHREE VINDHYA CAST COATERS LIMITED,JALGAON vs. DEPUTY COMMISSIONER OF INCOME TAX, INCOME TAX OFFICE, B.J.MARKET

In the result, the appeals of assessee in ITA Nos

Bench: Ms. Astha Chandra & Shree Dr. Dipak P. Ripote

120-121]. Subsequently, an email communication was received from Income tax department on 27-02-2023 [Refer PB Page No. 63] whereby the password of the income tax portal was reset and the appellant was allowed to access the e-fling portal. Hence, from the period 07-12-2021 to 27-02-2023, the appellant could not file the appeal

SHREE BHASKARACHARYA PRATISHTHAN,CHH SAMBHAJINAGAR vs. LD. DEPUTY COMMISSIONER OF INCOME TAX, GHAZIABAD

In the result, both the bunch of appeals filed by the\nrespective assessee's in ITA Nos

condone the delay. The Court considering an\napplication under section 5 of the Limitation Act may also look\ninto the prima facie merits of an appeal. A liberal approach may\nbe adopted when some plausible cause for delay is shown.\nHon'ble Supreme Court in the case of Inder Singh Vs. State of\nMadhya Pradesh judgment dated 21.03.2025 (2025 INSC

SHREE BHASKARACHARYA PRATISHTHAN,CHH SAMBHAJINAGAR vs. LD. DEPUTY COMMISSIONER OF INCOME TAX, GHAZIABAD

In the result, both the bunch of appeals filed by the\nrespective assessee's in ITA Nos

condone the delay. The Court considering an\napplication under section 5 of the Limitation Act may also look\ninto the prima facie merits of an appeal. A liberal approach may\nbe adopted when some plausible cause for delay is shown.\nHon'ble Supreme Court in the case of Inder Singh Vs. State of\nMadhya Pradesh judgment dated 21.03.2025 (2025 INSC

CHATE TUTORIALS PVT. LTD. ,AURANGABAD vs. LD. ASSISTANT COMMISSIONER OF INCOME TAX, TDS CIRCLE, NASHIK , NASHIK

In the result, both the bunch of appeals filed by the\nrespective assessee's in ITA Nos

condone the delay. The Court considering an\napplication under section 5 of the Limitation Act may also look\ninto the prima facie merits of an appeal. A liberal approach may\nbe adopted when some plausible cause for delay is shown.\nHon'ble Supreme Court in the case of Inder Singh Vs. State of\nMadhya Pradesh judgment dated 21.03.2025 (2025 INSC

SHRI BHASKARACHARYA PRATISHTHAN,CHH. SAMBHAJINAGAR vs. LD. DEPUTY COMMISSIONER OF INCOME TAX, CPC-TDS

In the result, both the bunch of appeals filed by the\nrespective assessee's in ITA Nos

condone the delay. The Court considering an\napplication under section 5 of the Limitation Act may also look\ninto the prima facie merits of an appeal. A liberal approach may\nbe adopted when some plausible cause for delay is shown.\nHon'ble Supreme Court in the case of Inder Singh Vs. State of\nMadhya Pradesh judgment dated 21.03.2025 (2025 INSC

SHREE BHASKARACHARYA PRATISHTHAN,CHH SAMBHAJINAGAR vs. LD. DEPUTY COMMISSIONER OF INCOME TAX, CPC-TDS

In the result, both the bunch of appeals filed by the\nrespective assessee's in ITA Nos

condone the delay. The Court considering an\napplication under section 5 of the Limitation Act may also look\ninto the prima facie merits of an appeal. A liberal approach may\nbe adopted when some plausible cause for delay is shown.\nHon'ble Supreme Court in the case of Inder Singh Vs. State of\nMadhya Pradesh judgment dated 21.03.2025 (2025 INSC