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

condonation of delay was also wholly without any merit. [Para 18] It is now well settled that even though this Court exercising jurisdiction under article 226 of the Constitution has the power to declare a statute (or any provision thereof) as unconstitutional, it should exercise great restraint before exercising such a power. Really speaking, there is only one ground

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

condonation of delay was also wholly without any merit. [Para 18] It is now well settled that even though this Court exercising jurisdiction under article 226 of the Constitution has the power to declare a statute (or any provision thereof) as unconstitutional, it should exercise great restraint before exercising such a power. Really speaking, there is only one ground

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

condonation of delay was also wholly without any merit. [Para 18] It is now well settled that even though this Court exercising jurisdiction under article 226 of the Constitution has the power to declare a statute (or any provision thereof) as unconstitutional, it should exercise great restraint before exercising such a power. Really speaking, there is only one ground

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

condonation of delay was also wholly without any merit. [Para 18] It is now well settled that even though this Court exercising jurisdiction under article 226 of the Constitution has the power to declare a statute (or any provision thereof) as unconstitutional, it should exercise great restraint before exercising such a power. Really speaking, there is only one ground

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

condonation of delay was also wholly without any merit. [Para 18] It is now well settled that even though this Court exercising jurisdiction under article 226 of the Constitution has the power to declare a statute (or any provision thereof) as unconstitutional, it should exercise great restraint before exercising such a power. Really speaking, there is only one ground

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

condonation of delay was also wholly without any merit. [Para 18] It is now well settled that even though this Court exercising jurisdiction under article 226 of the Constitution has the power to declare a statute (or any provision thereof) as unconstitutional, it should exercise great restraint before exercising such a power. Really speaking, there is only one ground

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

condonation of delay was also\nwholly without any merit. [Para 18]\nIt is now well settled that even though this Court exercising jurisdiction\nunder article 226 of the Constitution has the power to declare a statute\n(or any provision thereof) as unconstitutional, it should exercise great\nrestraint before exercising such a power. Really speaking, there is only\none ground

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

condonation of delay was also\nwholly without any merit. [Para 18]\nIt is now well settled that even though this Court exercising jurisdiction\nunder article 226 of the Constitution has the power to declare a statute\n(or any provision thereof) as unconstitutional, it should exercise great\nrestraint before exercising such a power. Really speaking, there is only\none ground

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

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

condonation of delay was also\nwholly without any merit. [Para 18]\nIt is now well settled that even though this Court exercising jurisdiction\nunder article 226 of the Constitution has the power to declare a statute\n(or any provision thereof) as unconstitutional, it should exercise great\nrestraint before exercising such a power. Really speaking, there is only\none ground

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

condonation of delay was also\nwholly without any merit. [Para 18]\nIt is now well settled that even though this Court exercising jurisdiction\nunder article 226 of the Constitution has the power to declare a statute\n(or any provision thereof) as unconstitutional, it should exercise great\nrestraint before exercising such a power. Really speaking, there is only\none ground

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

condonation of delay was also\nwholly without any merit. [Para 18]\nIt is now well settled that even though this Court exercising jurisdiction\nunder article 226 of the Constitution has the power to declare a statute\n(or any provision thereof) as unconstitutional, it should exercise great\nrestraint before exercising such a power. Really speaking, there is only\none ground

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

condonation of delay was also\nwholly without any merit. [Para 18]\nIt is now well settled that even though this Court exercising jurisdiction\nunder article 226 of the Constitution has the power to declare a statute\n(or any provision thereof) as unconstitutional, it should exercise great\nrestraint before exercising such a power. Really speaking, there is only\none ground

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

condonation of delay was also\nwholly without any merit. [Para 18]\nIt is now well settled that even though this Court exercising jurisdiction\nunder article 226 of the Constitution has the power to declare a statute\n(or any provision thereof) as unconstitutional, it should exercise great\nrestraint before exercising such a power. Really speaking, there is only\none ground

CHATE TUTORIALS PVT. LTD. AURANGABAD , 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

condonation of delay was also\nwholly without any merit. [Para 18]\nIt is now well settled that even though this Court exercising jurisdiction\nunder article 226 of the Constitution has the power to declare a statute\n(or any provision thereof) as unconstitutional, it should exercise great\nrestraint before exercising such a power. Really speaking, there is only\none ground

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

condonation of delay was also\nwholly without any merit. [Para 18]\nIt is now well settled that even though this Court exercising jurisdiction\nunder article 226 of the Constitution has the power to declare a statute\n(or any provision thereof) as unconstitutional, it should exercise great\nrestraint before exercising such a power. Really speaking, there is only\none ground

UNUS ABDULGAFAR SHAIKH,PUNE vs. ITO WARD 14(3), PUNE, PUNE

In the result, appeal of the assessee in ITA No

Bench: Dr.Dipak P. Ripote & Shri Vinay Bhamoreआयकर अपील सं. / Ita Nos.652 To 655/Pun/2025 िनधा"रण वष" / Assessment Years: 2014-15 To 2017-18 Unusabdulgafar Shaikh, V The Income Tax Officer, Talwadiuruli Kanchan, Pune- S. Ward-14(3), Pune. Solapur Road, Haveli, Pune – 412202. Maharashtra. Pan: Aceps8721Q Appellant/ Assessee Respondent / Revenue Assessee By Shri Suhas Bora – Ar Revenue By Shri Vinod Pawar – Addl.Cit(Dr) Date Of Hearing 08/05/2025 Date Of Pronouncement 14/05/2025 आदेश/ Order Per Dr. Dipak P. Ripote, Am: These Four Appeals Filed By The Assessee Are Against The Separate Orders Of Ld.Commssioner Of Income Tax(Appeal)[Nfac] Passed Under Section 250 Of The Act, 1961, Respectively. For The Sake Of Convenience, These Four Appeals Were Heard Together & Are Being Disposed Of By This Common Order.We Treat Appeal In Ita No.652/Pun/2025 As “Lead Case”. The Assessee Has Raised The Following Grounds Of Appeal :

section 69A applies only when amounts are not recorded in books. Erroneous assumption of jurisdiction u/s 147 of the Act 5. The reassessment order u/s 147 r.w.s 144 r.w.s 144B is invalid. as reassessment based on a search action in a third-party case falls under Sec. 153C, not Sec. 147. Grounds on merits 6. The AO made the addition

UNUS ABDULGAFAR SHAIKH,PUNE vs. ITO WARD 14(3), PUNE, PUNE

In the result, appeal of the assessee in ITA No

Bench: Dr.Dipak P. Ripote & Shri Vinay Bhamoreआयकर अपील सं. / Ita Nos.652 To 655/Pun/2025 िनधा"रण वष" / Assessment Years: 2014-15 To 2017-18 Unusabdulgafar Shaikh, V The Income Tax Officer, Talwadiuruli Kanchan, Pune- S. Ward-14(3), Pune. Solapur Road, Haveli, Pune – 412202. Maharashtra. Pan: Aceps8721Q Appellant/ Assessee Respondent / Revenue Assessee By Shri Suhas Bora – Ar Revenue By Shri Vinod Pawar – Addl.Cit(Dr) Date Of Hearing 08/05/2025 Date Of Pronouncement 14/05/2025 आदेश/ Order Per Dr. Dipak P. Ripote, Am: These Four Appeals Filed By The Assessee Are Against The Separate Orders Of Ld.Commssioner Of Income Tax(Appeal)[Nfac] Passed Under Section 250 Of The Act, 1961, Respectively. For The Sake Of Convenience, These Four Appeals Were Heard Together & Are Being Disposed Of By This Common Order.We Treat Appeal In Ita No.652/Pun/2025 As “Lead Case”. The Assessee Has Raised The Following Grounds Of Appeal :

section 69A applies only when amounts are not recorded in books. Erroneous assumption of jurisdiction u/s 147 of the Act 5. The reassessment order u/s 147 r.w.s 144 r.w.s 144B is invalid. as reassessment based on a search action in a third-party case falls under Sec. 153C, not Sec. 147. Grounds on merits 6. The AO made the addition

UNUS ABDULGAFAR SHAIKH,PUNE vs. ITO WARD 14(3), PUNE, PUNE

In the result, appeal of the assessee in ITA No

Bench: Dr.Dipak P. Ripote & Shri Vinay Bhamoreआयकर अपील सं. / Ita Nos.652 To 655/Pun/2025 िनधा"रण वष" / Assessment Years: 2014-15 To 2017-18 Unusabdulgafar Shaikh, V The Income Tax Officer, Talwadiuruli Kanchan, Pune- S. Ward-14(3), Pune. Solapur Road, Haveli, Pune – 412202. Maharashtra. Pan: Aceps8721Q Appellant/ Assessee Respondent / Revenue Assessee By Shri Suhas Bora – Ar Revenue By Shri Vinod Pawar – Addl.Cit(Dr) Date Of Hearing 08/05/2025 Date Of Pronouncement 14/05/2025 आदेश/ Order Per Dr. Dipak P. Ripote, Am: These Four Appeals Filed By The Assessee Are Against The Separate Orders Of Ld.Commssioner Of Income Tax(Appeal)[Nfac] Passed Under Section 250 Of The Act, 1961, Respectively. For The Sake Of Convenience, These Four Appeals Were Heard Together & Are Being Disposed Of By This Common Order.We Treat Appeal In Ita No.652/Pun/2025 As “Lead Case”. The Assessee Has Raised The Following Grounds Of Appeal :

section 69A applies only when amounts are not recorded in books. Erroneous assumption of jurisdiction u/s 147 of the Act 5. The reassessment order u/s 147 r.w.s 144 r.w.s 144B is invalid. as reassessment based on a search action in a third-party case falls under Sec. 153C, not Sec. 147. Grounds on merits 6. The AO made the addition