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

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

MANOHAR WAMAN PANDAGALE,PUNE vs. INCOME TAX OFFICER WARD 3(3), PUNE

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

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

condoning the delay without appreciating the facts and circumstances of the case. 2. The impugned notice u/s 148 dated 07.04.2022 is invalid and bad in law being issued by the Jurisdictional Assessing Officer as the same was not in accordance with Section 151A of the Act and consequently the impugned Assessment Order u/s 147 dt 24.02.2024 is invalid

VIJAYMALA VILAS KALOKHE,PUNE vs. ITO WARD-10(1), PUNE

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

Bench: Shri R.K. Panda & Ms. Astha Chandraआयकर अपील सं. / Ita No.1666/Pun/2025 धििाारण वर्ा / Assessment Year : 2013-14 Vijaymala Vilas Kalokhe, Ito, Ward-10(1), Pune Aditya Row House, Lane No. 2, Opp. Patel Garden, Sr. No. 8/2A, Vs. Juni Sangavi, Maharashtra-411027 Pan : Asepk8161G अपीलार्थी / Appellant प्रत्यर्थी / Respondent Assessee By : Shri Kishor B Phadke Department By : Shri Amit Bobde Date Of Hearing : 28-01-2026 Date Of 30-01-2026 Pronouncement : आदेश / Order Per Astha Chandra, Jm : The Appeal Filed By The Assessee Is Directed Against The Order Dated 17.06.2025 Of The Ld. Commissioner Of Income Tax (Appeals)/Nfac, Delhi [“Cit(A)/Nfac”] Pertaining To Assessment Year (“Ay”) 2013-14. 2. Briefly Stated The Facts Are That The Assessee Is An Individual. He Filed His Return Of Income For Ay 2013-14 Declaring Total Income Of Rs.2,21,050/-. The Case Of The Assessee Was Reopened U/S 147 Of The Income Tax Act, 1961 (The “Act”) After Following The Mandate Procedure As Laid Down Under The Relevant Provisions Of The Act. Accordingly, Statutory Notice U/S 142(1) Of The Act & Show Cause Letter(S) Were Issued To The Assessee From Time To Time. However, The Assessee Failed To File Any Response To The Said Notice(S) Which Constrained The Ld. Assessing Officer (“Ao”) To Pass An Ex-Parte Order U/S 144 Of The Act Based On The Material Available On Record. The Ld. Ao Proceeded To Complete The Assessment On Total Income Of Rs.2,66,70,989/-U/S 147 R.W.S. 144 Of The Act Thereby Making An Addition Of Rs.2,63,83,209/- On Account Of Undisclosed Long Term Capital Gain (Ltcg) By Observing As Under : “5.1. On-Going Through The Information Available On Record & In View Of The Order Passed U/S 148A(D) Of The Act Dated 21.07.2022, It Is Noticed That 2

section 149(1)(b) of the ITA, 1961. As such the appellant contends that, the present re- assessment proceedings are bad in law and ought to be quashed. 4. Learned CIT(A)-NFAC erred in law and in rejecting appellant's appeal, on account of the delay of 136 days in filing the appeal memo. Learned AO ought to have

KALPANA PRAKASH KALE,PUNE vs. ITO WARD 6(5), PUNE

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

Bench: Shri R. K. Panda & Ms. Astha Chandraassessment Year : 2015-16

condoning the delay when there was sufficient cause beyond the control of the assessee. 2. Whether on facts and in circumstances of the case, the impugned reassessment proceedings are valid in law which are initiated by issue of notice u/s 148 Jurisdictional Assessing Officer in contravention of the provisions of Section 151A. 3. Whether on facts and in circumstances

VIKAS DATTU DEOKAR,PUNE vs. ITO WARD 14(1), PUNE

In the result, appeal of the assessee is partly allowed

Bench: Dr.Dipak P. Ripote & Shri Vinay Bhamoreआयकर अपील सं. / Ita No.1012/Pun/2025 िनधा"रण वष" / Assessment Year: 2016-17 Vikas Dattu Deokar, V The Income Tax Officer, S.N.126/1, Plat No.18A, S Ward-14(1), Pune. Z Corner, Matoshri Niwas, Manjari Bk, Manjari Budruk, Po: Manjari Farm, Dist: Pune, Maharashtra – 412307. Pan: Aispd7124N Appellant/ Assessee Respondent / Revenue Assessee By Smt. Deepa Khare – Ar Revenue By Shri Eknath Abhang –Addl.Cit(Dr) Date Of Hearing 24/07/2025 Date Of Pronouncement 30/07/2025 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.2016-17 Dated 20.02.2025, Emanating From Order U/S.144 Of The Income Tax Act, 1961, Dated 17.05.2023. The Assessee Has Raised Following Grounds Of Appeal :

Section 149. 3. The ld CIT(A) erred in law and on facts in setting aside the addition of Rs.85000/- without deciding the legal issues regarding limitation and jurisdiction. 4. The appellant craves leave to add alter, modify or substitute any ground of appeal at the time of hearing.” Submission of ld.AR : 2. Ld.AR for the Assessee explained that Assessee

RAJENDRA VENKAT REDDY,PUNE vs. ASSISTANT COMMISSIONER OF INCOME TAX , CIRCLE 2, PUNE

In the result, appeal of the assessee is dismissed

Bench: The Ld. Cit(A) Which Is Evident From Para 5 Of His Order, Wherein A Total Of Eight Opportunities Were Provided To The Assessee But There Was Not A Single Appearance On Any Of The Given Date By The Assessee. The Ld. A.R Also Could

Section 5 of the Limitation Act. 6. It is also noticed in the case of State of West Bengal Vs. Administrator, Howrah 1972 AIR SC 749, that the Hon‟ble Apex Court held that expression “sufficient cause” should receive a liberal construction so as to advance substantial justice particularly when there is no motive behind the delay. The expression “sufficient

AMIT SURESH AGRAWAL,SATARA vs. ITO WARD-2, SATARA

In the result, appeal of the assessee is partly allowed

Bench: Dr.Dipak P. Ripote & Shri Vinay Bhamoreआयकर अपऩल सं. / Ita No.2225/Pun/2025 निर्धारण वषा / Assessment Year: 2016-17 Amit Suresh Agrawal, V The Income Tax Officer, Amit Trading Co, Plot No.35, S Ward-2, Satara. Satara – 415002. Maharashtra. Pan: Abgpa2925D Appellant/ Assessee Respondent / Revenue Assessee By Shri Suhas Kulkarni – Advocate Revenue By Shri Eknath Abhang – Add.Cit(Dr) Date Of Hearing 30/10/2025 Date Of Pronouncement 30/10/2025 आदेश/ Order Per Dr. Dipak P. Ripote, Am: This Appeal Filed By The 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.2016-17 Dated 02.04.2025 Emanating From The Assessment Order Passed Under Section 147 R.W.S 144B Of The Income Tax Act, 1961 Dated 10.05.2023. The Assessee Has Raised The Following Grounds Of Appeal :

149 of the Act, after the lapse of three years from the end of the Assessment Year, no notice can be issued unless the income chargeable to tax which has escaped assessment is likely to be Rs.50 lakhs or more. 6.1 Thus, it can be observed from the said order u/s.148A(d) that the income alleged to have escaped assessment

INCOME TAX OFFICER WARD 3, SATARA, INCOME TAX OFFICE SATARA vs. NANDKUMAR DATTATRAY KHOT, DAHIWADI MAN

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

Bench: Dr.Dipak P. Ripote & Shri Vinay Bhamoreआयकर अपील सं. /Ita No.1562/Pun/2024 िनधा"रण वष" / Assessment Year: 2015-16 The Income Tax Officer, V Nandkumar Dattatray Khot, Ward-3, Satara S Shri Agencies Dahiwadi, Dahiwadi, Man Satara. Maharashtra – 415508. Pan: Aatpk8947P Appellant/ Revenue Respondent/ Assessee Cross Objection No.11/Pun/2025 िनधा"रण वष" / Assessment Year: 2015-16 Nandkumar Dattatray Khot, V The Income Tax Officer, Shri Agencies Dahiwadi, S Ward-3, Satara. Dahiwadi, Man Satara. Maharashtra – 415508. Pan:Aatpk8947P Appellant/ Assessee Respondent /Revenue Assessee By Shri Suhas Kulkarni - Ar Shri Vidya Ratna Kishor – (Dr)(Virtual) Revenue By Date Of Hearing 25/03/2025 Date Of Pronouncement 24/04/2025 आदेश/ Order Per Dr. Dipak P. Ripote, Am: This Is An Appeal Filed By The Revenue Against The Order Of The Commissioner Of Income Tax (Appeal) (Nfac) Under Section 250 Of

149(1)(b) is read with Taxation and other Laws (Relxation and Amendment of Certain Provisions) Act, 2020, then all the notices issued between April 1, 2021 and June 30, 2021 pertaining to the assessment years 2013-2014. 2014-2015, 2015- 2016, 2016-2017, and 2017-2018 will be within the period of limitation as explained in the tabulation below

SOMNATH RAMDAS JADHAV,AHMEDNAGAR vs. ITO, WARD 2, AHMEDNAGAR, AHMEDNAGAR

Accordingly, the appeal in ITA No.1092/PUN/2025 for A.Y. 2013-14 involving the issue of penalty u/s 271(1)(c) of the Act is allowed

Bench: Shri Manish Borad & Shri Vinay Bhamore

delay in filing is condoned as per the principles of natural justice. 7.2 The appellant, instead of availing the opportunity to explain the sources for cash deposits, wanted to thrash the entire reassessment proceedings by challenging the assumption of jurisdiction in spite of knowing that it is not maintainable in accordance with law. This attitude of the appellant clearly demonstrated

SOMNATH RAMDAS JADHAV,AHMEDNAGAR vs. ITO WARD2, AHMEDNAGAR

Accordingly, the appeal in ITA No.1092/PUN/2025 for A.Y. 2013-14 involving the issue of penalty u/s 271(1)(c) of the Act is allowed

Bench: Shri Manish Borad & Shri Vinay Bhamore

delay in filing is condoned as per the principles of natural justice. 7.2 The appellant, instead of availing the opportunity to explain the sources for cash deposits, wanted to thrash the entire reassessment proceedings by challenging the assumption of jurisdiction in spite of knowing that it is not maintainable in accordance with law. This attitude of the appellant clearly demonstrated

SOMNATH RAMDAS JADHAV,AHMEDNAGAR vs. ITO, WARD 2, AHMEDNAGAR, AHMEDNAGAR

Accordingly, the appeal in ITA No.1092/PUN/2025 for A.Y. 2013-14 involving the issue of penalty u/s 271(1)(c) of the Act is allowed

Bench: Shri Manish Borad & Shri Vinay Bhamore

delay in filing is condoned as per the principles of natural justice. 7.2 The appellant, instead of availing the opportunity to explain the sources for cash deposits, wanted to thrash the entire reassessment proceedings by challenging the assumption of jurisdiction in spite of knowing that it is not maintainable in accordance with law. This attitude of the appellant clearly demonstrated

SOMNATH RAMDAS JADHAV,AHMEDNAGAR vs. ITO WARD 2, AHMEDNAGAR

Accordingly, the appeal in ITA No.1092/PUN/2025 for A.Y. 2013-14 involving the issue of penalty u/s 271(1)(c) of the Act is allowed

Bench: Shri Manish Borad & Shri Vinay Bhamore

delay in filing is condoned as per the principles of natural justice. 7.2 The appellant, instead of availing the opportunity to explain the sources for cash deposits, wanted to thrash the entire reassessment proceedings by challenging the assumption of jurisdiction in spite of knowing that it is not maintainable in accordance with law. This attitude of the appellant clearly demonstrated

SHAHBAZ MOHAMMED SHAFEEQUE,MALEGAON vs. INCOME TAX OFFICER, WARD - 1, MALEGAON

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

Bench: Ms.Astha Chandra & Dr.Dipak P. Ripoteआयकर अपऩल सं. / Ita No.2291/Pun/2025 निर्धारण वषा / Assessment Year: 2015-16 Shahbaz Mohammed V The Income Tax Officer, Shafeeque, S. Ward-1, Malegaon. House No.904, Lane No.2, Malegaon City S.O., Malegaon, Nashik, Malegaon – 423203. Maharashtra. Pan: Cfppm6844A Appellant/ Assessee Respondent / Revenue Assessee By Shri Sanket Joshi (Virtual) Revenue By Smt Saumya Pandey Jain-Addl.Cit Date Of Hearing 20/11/2025 Date Of Pronouncement 20/11/2025 आदेश/ Order Per Dr. Dipak P. Ripote, Am: In This Case, Appeal Has Been Filed By The Assessee Against The Order Of Ld.Commisioner Of Income Tax(Appeal)[Nfac] Passed Under Section 250 Of The Income Tax Act, 1961 For The A.Y.2015-16 Dated 28.02.2025. The Assessee Has Raised The Following Grounds Of Appeal :

condoned if the appellant has a just cause on merits. 2 ITA No.2291/PUN/2025 [A] 8] The appellant craves leave to add/ alter/ amend any of the grounds of appeal.” Findings & Analysis : 2. We have heard both the parties and perused the records. Ld.AR appeared virtually and submitted that ld.CIT(A) has not decided the legal grounds and hence appeal

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

delay is condoned.\nSubmission of ld.AR :\n2.\nLd.AR for the assessee submitted that CIT(A) has failed to appreciate the submission of the assessee. Ld.AR submitted Affidavit of the assessee.\n3\nITA No.540/PUN/2025 [A]\n2.1 Ld.AR pleaded that the Notice u/s.148 dated 13/04/2022 and the order is bad in Law.Ld.AR relied on the order of Hon'ble Supreme Court

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