DEPUTY COMMISSIONER OF INCOME-TAX vs. THE JAWAHARLAL NEHRU PORT TRUST,, RAIGAD

In the result, all the three appeals filed by the Revenue are dismissed and all the three appeals filed by the assessee are partly allowed

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

condone the delay for accepting the auditor’s report at a later date has only been given to the ITO and not thereafter, i.e., at the appellate stage. We find no merit in this submission. The CBDT by issuing the Circular dt. 9th Feb., 1978 has treated the provision regarding furnishing of auditor’s report along with the return

JAWAHAR LAL NEHRU PORT TRUST,NAVI MUMBAI vs. ACIT PANVEL, PANVEL

In the result, all the three appeals filed by the Revenue are dismissed and all the three appeals filed by the assessee are partly allowed

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

condone the delay for accepting the auditor’s report at a later date has only been given to the ITO and not thereafter, i.e., at the appellate stage. We find no merit in this submission. The CBDT by issuing the Circular dt. 9th Feb., 1978 has treated the provision regarding furnishing of auditor’s report along with the return

JAWAHAR LAL NEHRU PORT TRUST,NAVI MUMBAI vs. ACIT PANVEL, PANVEL

In the result, all the three appeals filed by the Revenue are dismissed and all the three appeals filed by the assessee are partly allowed

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

condone the delay for accepting the auditor’s report at a later date has only been given to the ITO and not thereafter, i.e., at the appellate stage. We find no merit in this submission. The CBDT by issuing the Circular dt. 9th Feb., 1978 has treated the provision regarding furnishing of auditor’s report along with the return

JAWAHAR LAL NEHRU PORT TRUST,NAVI MUMBAI vs. ACIT PANVEL, PANVEL

In the result, all the three appeals filed by the Revenue are dismissed and all the three appeals filed by the assessee are partly allowed

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

condone the delay for accepting the auditor’s report at a later date has only been given to the ITO and not thereafter, i.e., at the appellate stage. We find no merit in this submission. The CBDT by issuing the Circular dt. 9th Feb., 1978 has treated the provision regarding furnishing of auditor’s report along with the return

DEPUTY COMMISSIONER OF INCOME-TAX vs. THE JAWAHARLAL NEHRU PORT TRUST,, RAIGAD

In the result, all the three appeals filed by the Revenue are dismissed and all the three appeals filed by the assessee are partly allowed

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

condone the delay for accepting the auditor’s report at a later date has only been given to the ITO and not thereafter, i.e., at the appellate stage. We find no merit in this submission. The CBDT by issuing the Circular dt. 9th Feb., 1978 has treated the provision regarding furnishing of auditor’s report along with the return

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

condone the delay in filing the appeal, an empathetic humane view of the matter ought to have been adopted. 2. The learned CIT(A) erred in not deciding the appeal on merits further erred in not appreciating and considering all the issues emanating from the order of the AO passed under section 147 read with section 144B. It is prayed

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

condone the delay in filing the appeal, an empathetic humane view of the matter ought to have been adopted. 2. The learned CIT(A) erred in not deciding the appeal on merits further erred in not appreciating and considering all the issues emanating from the order of the AO passed under section 147 read with section 144B. It is prayed

APPASO SAMPATRAO MANE,PUNE vs. ITO WARD 7(1), PUNE

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

condoning the delay of 145 days in filing the appeal, despite the\nappellant being non resident and explained sufficient cause for the delay by way\nof an affidavit.\n1.2 The learned CIT(A) failed to appreciate the fact that the appellant, an NRI\nresiding in the USA since 2014, did not access his registered email provided to\nPAN Database, after

UNIVERSAL REALTY,PUNE, INDIA vs. INCOME TAX OFFICER, WARD 3(3), SWARGATE, PUNE

In the result, appeal of the assessee is dismissed

Bench: Dr.Manish Borad & Shri Vinay Bhamoreआयकर अपील सं. / Ita No.811/Pun/2025 Assessment Year : 2018-19

delay be condoned, and the Appeal should be taken up for hearing. 6) The Appellant craves leave to add, alter, amend, modify and or delete any or all of the grounds of appeal mentioned herein above.” 7 Universal Reality 10. From the above grounds of appeal, it is manifest that the only grievance of the assessee is that ld.CIT

SUYASH SOLUTIONS PVT.LTD,PUNE vs. DCIT CIRCLE-5, PUNE

Accordingly, the Appeal filed by the Assessee is dismissed

Bench: Ms.Astha Chandra & Dr.Dipak P. Ripoteआयकर अपऩल सं. / Ita No.576/Pun/2025 निर्धारण वषा / Assessment Year: 2010-11 Suyash Solutions Pvt. Ltd., V The Dy.Cit, S.No.145, Pune Saswad Road, S. Circle-5, Pune. Opp,.Navalakha Godown, Phursungi, Pune – 412308. Maharashtra. Pan: Aajcs7144M Appellant/ Assessee Respondent / Revenue Assessee By Shri Mihir C Naniwadekar & Shri B.D.Bhide – Ar’S Revenue By Shri Akhilesh Srivastva– Addl.Cit(Dr) Date Of Hearing 17/06/2025 Date Of Pronouncement 12/09/2025 आदेश/ Order Per Dr. Dipak P. Ripote, Am: This Appeal Is Filed By The Assessee Against The Order Of Ld.Addl./Joint Commissioner Of Income Tax(Appeal)-1, Gurugram Passed Under Section 250 Of The Income Tax Act, 1961 For A.Y.2010-11, Dated 22.01.2025 Emanating From Assessment Order U/S.143(1) Of The I.T.Act, Dated 23.02.2011. The Assessee Has Raised Following Grounds Of Appeal :

145, Pune Saswad Road, s. Circle-5, Pune. Opp,.Navalakha Godown, Phursungi, Pune – 412308. Maharashtra. PAN: AAJCS7144M Appellant/ Assessee Respondent / Revenue Assessee by Shri Mihir C Naniwadekar and Shri B.D.Bhide – AR’s Revenue by Shri Akhilesh Srivastva– Addl.CIT(DR) Date of hearing 17/06/2025 Date of pronouncement 12/09/2025 आदेश/ ORDER PER DR. DIPAK P. RIPOTE, AM: This appeal is filed

PUNE MATHADI HAMAL AND OTHER MANUAL WORKERS BOARD,PUNE vs. INCOME TAX OFFICER, WARD-5(1), PUNE, PUNE

In the result, appeal of the assessee is partly allowed

Bench: Shri S.S.Godara & Dr. Dipak P. Ripoteआयकर अपील सं. / Ita No.1012/Pun/2023 िनधा"रण वष" / Assessment Year : 2018-19 Pune Mathadihamal & Other The Income Tax Manual Workers Board, V Officer, Shramashakti Bhavan, S Ward-5(1), Pune. Coomercial Plot No.1, Market Yard, Pune – 411037. Pan: Aaalp0097L Appellant/ Assessee Respondent /Revenue Assessee By Shri Vipul Joshi – Ar Revenue By Shri Ajay Kumar Keshari & Shri Rajesh Gawali– Dr’S Date Of Hearing 17/04/2024 Date Of Pronouncement 27/06/2024 आदेश/ Order Per Dr. Dipak P. Ripote, Am: This Appeal Filed By The Assessee Is Against The Orders Of Ld.Commissionerof Income Tax(Appeals)[Nfac], Under Section 250 Of The Act Dated 14.07.2023 :

145 taxmann.com 278 (Amritsar - Trib.)] (iii) Alpha Educational Trust v. DCIT (Exemption) - [2023] 150 taxmann.com 20 (Chennai - Trib.) III. Proposition 3: If an Application for Registration is not disposed off within 6 months, then same isdeemed to be accepted/approved, in terms of section 12AA(2). Sardari Lai Oberoi memorial Charitable Trust v. ITO [2005] 3 SOT 229 (Delhi)] SambandhOrganisation

PRAKASHCHAND JAIN MULTI STATE CO.OPERATIVE CREDIT SOCIETY LTD.,JAMNER vs. ITO WARD 1(4), JALGAON, JALGAON

In the result, appeal of the assessee is allowed

Bench: Dr.Dipak P. Ripote & Shri Vinay Bhamoreआयकर अपील सं. / Ita Nos.1791, 1801 & 1802/Pun/2024 िनधा"रण वष" / Assessment Years: 2020-21, 2014-15 & 2018-19 The Prakashchand Jain Multi V The Income Tax Officer, State Co-Operative Credit S Ward-1(4), Jalgaon. Society Ltd., Mayur Complex, Bajrangpura Road, Jamner, Jalgaon – 424206. Pan: Aaaap4677K Appellant/ Assessee Respondent / Revenue Assessee By Shri Vinay Kawdia – Ar Revenue By Shri Arvind Desai – Addl.Cit(Dr) Date Of Hearing 18/11/2024 Date Of Pronouncement 21/11/2024 आदेश/ Order Per Dr. Dipak P. Ripote, Am: This Bunch Of Three Appeals Filed By The Assessee Directed Against The Separate Orders Of Ld.Commissioner Of Income Tax(Appeals)[Nfac] Under Section 250 Of The Income Tax Act, 1961 For A.Y.2020-21 Dated 10.07.2024, A.Y.2014-15 & A.Y.2018-19 Dated 09.07.2024 Respectively. Since The Issue Involved Is Common & Facts Are Identical, All The Three Appeals

section 80P(2)(a) of the Act. Ld.AR further submitted that there was a delay in filing appeal before the ld.CIT(A) of 145 days. Ld.AR submitted that an elaborate reasoning has been given by the Assessee in Form No.35 and requested the ld.CIT(A) to condone the delay. However, ld.CIT(A) dismissed the appeal without condoning the delay. Ld.AR

THE PRAKASHCHAND JAIN MULTI STATE CO OPERATIVE SOCIETY LTD.,JAMNER vs. ITO WARD 1(4), JALGAON, JALGAON

In the result, appeal of the assessee is allowed

Bench: Dr.Dipak P. Ripote & Shri Vinay Bhamoreआयकर अपील सं. / Ita Nos.1791, 1801 & 1802/Pun/2024 िनधा"रण वष" / Assessment Years: 2020-21, 2014-15 & 2018-19 The Prakashchand Jain Multi V The Income Tax Officer, State Co-Operative Credit S Ward-1(4), Jalgaon. Society Ltd., Mayur Complex, Bajrangpura Road, Jamner, Jalgaon – 424206. Pan: Aaaap4677K Appellant/ Assessee Respondent / Revenue Assessee By Shri Vinay Kawdia – Ar Revenue By Shri Arvind Desai – Addl.Cit(Dr) Date Of Hearing 18/11/2024 Date Of Pronouncement 21/11/2024 आदेश/ Order Per Dr. Dipak P. Ripote, Am: This Bunch Of Three Appeals Filed By The Assessee Directed Against The Separate Orders Of Ld.Commissioner Of Income Tax(Appeals)[Nfac] Under Section 250 Of The Income Tax Act, 1961 For A.Y.2020-21 Dated 10.07.2024, A.Y.2014-15 & A.Y.2018-19 Dated 09.07.2024 Respectively. Since The Issue Involved Is Common & Facts Are Identical, All The Three Appeals

section 80P(2)(a) of the Act. Ld.AR further submitted that there was a delay in filing appeal before the ld.CIT(A) of 145 days. Ld.AR submitted that an elaborate reasoning has been given by the Assessee in Form No.35 and requested the ld.CIT(A) to condone the delay. However, ld.CIT(A) dismissed the appeal without condoning the delay. Ld.AR

THE PRAKASHCHAND JAIN MULTI STATE CO OPERATIVE CREDIT SOCIETY LTD.,JAMNER vs. ITO WARD 1(4) JALGAON, JALGAON

In the result, appeal of the assessee is allowed

Bench: Dr.Dipak P. Ripote & Shri Vinay Bhamoreआयकर अपील सं. / Ita Nos.1791, 1801 & 1802/Pun/2024 िनधा"रण वष" / Assessment Years: 2020-21, 2014-15 & 2018-19 The Prakashchand Jain Multi V The Income Tax Officer, State Co-Operative Credit S Ward-1(4), Jalgaon. Society Ltd., Mayur Complex, Bajrangpura Road, Jamner, Jalgaon – 424206. Pan: Aaaap4677K Appellant/ Assessee Respondent / Revenue Assessee By Shri Vinay Kawdia – Ar Revenue By Shri Arvind Desai – Addl.Cit(Dr) Date Of Hearing 18/11/2024 Date Of Pronouncement 21/11/2024 आदेश/ Order Per Dr. Dipak P. Ripote, Am: This Bunch Of Three Appeals Filed By The Assessee Directed Against The Separate Orders Of Ld.Commissioner Of Income Tax(Appeals)[Nfac] Under Section 250 Of The Income Tax Act, 1961 For A.Y.2020-21 Dated 10.07.2024, A.Y.2014-15 & A.Y.2018-19 Dated 09.07.2024 Respectively. Since The Issue Involved Is Common & Facts Are Identical, All The Three Appeals

section 80P(2)(a) of the Act. Ld.AR further submitted that there was a delay in filing appeal before the ld.CIT(A) of 145 days. Ld.AR submitted that an elaborate reasoning has been given by the Assessee in Form No.35 and requested the ld.CIT(A) to condone the delay. However, ld.CIT(A) dismissed the appeal without condoning the delay. Ld.AR

TIRUMALA CONSTRUCTION ,NASHIK vs. ITO, WARD 2(4), , NASHIK

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

Bench: SHRI INTURI RAMA RAO (Accountant Member), SHRI VINAY BHAMORE (Judicial Member)

145 days. The appellant furnished an application along with an affidavit praying for condonation of delay in the circumstances mentioned therein. Ld. Sr. DR could not controvert the averments made in the 2 above affidavit. We are of the considered opinion that the reasons mentioned by the assessee constitute reasonable cause for not filing the appeal within prescribed time

RAJESH BABURAO SHINDE,PARBHANI vs. ITO, WARD- HINGOLI, HINGOLI

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

Bench: Shri R. K. Panda & Shri Vinay Bhamoreआयकर अपील सं. / Ita No.781/Pun/2025 िनधा"रण वष" / Assessment Year : 2015-16 Rajesh Baburao Shinde, Vs. Assessment Unit, Income Sayala Khating, Tq. Dist. Tax Department, Nfac, Parbhani- 431402. Delhi. Pan : Czcps6546Q Appellant Respondent Assessee By : Shri Shubham N. Rathi Revenue By : Shri Akhilesh Srivastva Date Of Hearing : 22.07.2025 Date Of Pronouncement 12.08.2025 : आदेश / Order Per Vinay Bhamore, Jm: This Appeal Filed By The Assessee Is Directed Against The Order Dated 18.07.2024 Passed By Ld. Cit(A)/Nfac For The Assessment Year 2015-16. 2. There Is Delay In Filing Of The Present Appeal. We Are Satisfied With The Reasons Mentioned In The Affidavit For Condonation That The Applicant Was Prevented By Sufficient Cause For Not Filing The Appeal Within The Prescribed Time Limit. After

condone the delay and proceed to adjudicate the appeal. 3. The assessee has raised the following grounds of appeal :- “1. THE CHALLENGE TO REASSESSMENT 1.1 The Learned Income Tax Officer, Ward Hingoli ['the Ld. JAO'] has erred in initiating the reassessment proceedings u/s 145 of the Income tax Act, 1961 ["the Act'] without serving notice under section

SAUMITRA KUMAR, LUCKNOW,UTTAR PRADESH vs. DCIT CIRCLE 12, PUNE, MAHARASHTRA

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

Bench: Shri R. K. Panda & Shri Vinay Bhamoreआयकर अपील सं. / Ita No.1520/Pun/2025 िनधा"रण वष" / Assessment Year : 2021-22 Saumitra Kumar, Vs. Dcit, Circle-12, Pune. Hig 111, Sector E, Aliganj, Lucknow- 226024. Pan : Bcmpk7370J Appellant Respondent Assessee By : Shri Naman Maloo (Virtual) Revenue By : Shri Amit Bobde Date Of Hearing : 23.07.2025 Date Of Pronouncement 14.08.2025 : आदेश / Order Per Vinay Bhamore, Jm: This Appeal Filed By The Assessee Is Directed Against The Order Dated 23.04.2025 Passed By Ld. Addl./Jcit(A), Indore [‘Ld. Cit(A)’] For The Assessment Year 2021-22. 2. The Assessee Has Raised The Following Grounds Of Appeal :- “1. In The Facts & Circumstances Of The Case, Ld. Cit(A) Has Erred In, Confirming The Action Of Ld. Ao(Cpc) In Disallowing The Credit Of Taxes Paid Outside India While Processing The Return Of Income (Foreign Tax Credit, "Ftc") Under Section 143(1) Of The Income Tax Act, 1961. Such Rejection Is Beyond The Purview Of Section 143(1). The Action Of The Ld. Cit(A) Is Illegal & Arbitrary & Against The Facts Of The Case. Relief May Please

condoning the delay in filing Form No. 67 by the PCIT under Section 119(2)(b), such Form No. 67 can't be taken into consideration and the relief u/s 90/90A cannot be allowed by the Appellate Authority even if other conditions are fulfilled. In view of the above, the appellant is not eligible for relief under section 90/90A