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26 results for “disallowance”+ Section 148Aclear

Sorted by relevance

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Key Topics

Section 14870Section 148A47Section 14738Section 80P24Addition to Income23Section 80P(2)(a)22Section 143(2)16Disallowance16Section 139(1)14Section 250

M/S. ARTHBHARTI NAGARI SAHAKARI PATSANSTHA MARYADIT,LATUR vs. ITO, WARD-1, LATUR, LATUR

In the result, appeal of the Assessee is Partly Allowed

ITA 1848/PUN/2024[2018-19]Status: DisposedITAT Pune10 Feb 2025AY 2018-19

Bench: Dr.Dipak P. Ripote & Shri Vinay Bhamoreआयकर अपील सं. / Ita No.1848/Pun/2024 िनधा"रण वष" / Assessment Year: 2018-19 M/S.Arthbharti Nagari Sahakari V The Income Tax Officer, Patsanstha Maryadit, S Ward-1, Latur. Adarsh Colony, Old Ausa Road, Latur – 413512. Pan: Aabaa2265P Appellant/ Assessee Respondent / Revenue Assessee By Shri Bhuvanesh Kankani – Ar Revenue By Shri Manoj Tripathi - Dr Date Of Hearing 12/12/2024 Date Of Pronouncement 10/02/2025 आदेश/ Order Per Dr. Dipak P. Ripote, Am: This Is An Appeal Filed By The Assessee Against The Order Of Ld.Commissioner Of Income Tax(Appeals)[Nfac] For Assessment Year 2018-19Dated 24.07.2024 Passed U/Sec.250 Of The Income Tax Act, 1961. The Assessee Has Raised The Following Grounds Of Appeal : “1. Without Prejudice To Other Grounds & On The Facts & Circumstances Prevailing In The Case & As Per Provisions & Scheme Of The Income-Tax Act, 1961 ('The Act') It Be Held That The Assessment Proceedings So Completed Are Invalid Since The Addition Is Made On An Issue Different Than That For Which Case Was Re-Opened. Since, The Issue Of Re-Opening Did Not Survive The Assessment Proceedings Becomes Void-Ab-Initio. Accordingly, The Assessment Proceedings So Initiated & Completed Be Kindly Annulled & Appellant Be Granted Just & Proper Relief In This Respect.

Section 139(1)Section 147Section 148Section 148ASection 151

Showing 1–20 of 26 · Page 1 of 2

10
Deduction10
Reassessment5
Section 151A
Section 250
Section 80P

section 148A of the Act. Accordingly, the Assessment Proceedings u/s 147 of the Act so initiated on the basis of improper proceedings u/s 1484 of the Act be kindly annulled and Appellant be granted just and proper relief in this respect. 5. Without prejudice to other grounds and on the facts and circumstances prevailing in the case

DEPUTY COMMISSIONER OF INCOME TAX, JALGAON vs. TARADEVI RATANLAL BAFNA, JALGAON

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

ITA 499/PUN/2025[2018-19]Status: DisposedITAT Pune24 Oct 2025AY 2018-19

Bench: Shri R. K. Panda & Ms. Astha Chandraassessment Year : 2018-19

For Appellant: S/Shri Suchek Anchaliya and Tushar NagoriFor Respondent: Shri Amit Bobde, CIT
Section 10(38)Section 139(1)Section 143(3)Section 147Section 148Section 148ASection 68Section 69C

148A(d) and thereafter issued notice u/s 148 of the Act on 07.04.2022. The assessee in response to the same filed the return of income u/s 148 declaring total income of Rs.93,17,87,280/-. The Assessing Officer completed the assessment u/s 147 r.w.s. 144B of the Act on 30.03.2024 determining the total income of Rs.94,40,61,296/- wherein

SANCHIT KANTILAL GANORE,BHAGUR vs. ITO WARD 1(1), NASHIK, NASHIK

In the result, appeal of the assessee is partly allowed

ITA 1767/PUN/2025[2017-18]Status: DisposedITAT Pune19 Sept 2025AY 2017-18

Bench: Dr.Dipak P. Ripote & Shri Vinay Bhamoreआयकर अपऩल सं. / Ita No.1767/Pun/2025 निर्धारण वषा / Assessment Year: 2017-18 Sanchit Kantilal Ganore, V The Income Tax Officer, 21, Main Road, Bhagur, S. Ward-1(1), Nashik. Nashik - 422502. Pan: Aprpg4907J Appellant/ Assessee Respondent / Revenue Assessee By Shri Piyush Bafna Revenue By Shri Aviyogi Ambadkar– Add.Cit(Dr) Date Of Hearing 09/09/2025 Date Of Pronouncement 19/09/2025 आदेश/ Order Per Dr. Dipak P. Ripote, Am: This Appeal Is 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 A.Y.2017-18, Dated 29.05.2025 Emanating From Assessment Order U/S.147 R.W.S 144 Of The I.T.Act, Dated 21.05.2023. The Assessee Has Raised Following Grounds Of Appeal : “1. On The Facts & In The Circumstances Of The Case & In Law & Without Prejudice To Other Grounds, Ld. Nfac Has Erred In Passing A

Section 147Section 148Section 149Section 151Section 250

disallowance of deduction of Rs 96,408/- claimed under section 80C by Ld. NaFAC without appreciating the valid submission filed by the Appellant and hence, the same is bad in law and thus, the impugned addition may please be deleted. OTHER GROUNDS: 17. On the facts and in the circumstances of the case and in law and without prejudice

LIQUIDHUB ANALYTICS PVT. LTD. (NOW MERGED WITH CAPGEMINI TECHNOLOGY SERVICES INDIA LTD),PUNE vs. NFAC, PUNE

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

ITA 1952/PUN/2024[2020-21]Status: DisposedITAT Pune25 Mar 2025AY 2020-21

Bench: Shri R. K. Panda & Shri Vinay Bhamoreassessment Year : 2020-21

For Appellant: Shri Nikhil PathakFor Respondent: Smt Nilu Jaggi, CIT
Section 143Section 143(3)Section 144C(1)

disallowance under section 36(1)(va) of the Act 13 The Ld. AO erred in initiating penalty proceedings under Section 270A of the Act on arbitrary premise that there is under-reporting of income done by the Appellant The above grounds are without prejudice to each other The appellant craves leave to alter, amend or withdraw

KALAVATHI DEVI SHARMA,HYDERABAD vs. ITO, WARD-1, NANDED, NANDED

In the result, appeal of the assessee is dismissed

ITA 1519/PUN/2024[2016-17]Status: DisposedITAT Pune14 Jul 2025AY 2016-17

Bench: Dr.Manish Borad

For Appellant: NoneFor Respondent: Shri S. Sadananda Singh, JCIT
Section 10(38)Section 147Section 148Section 148ASection 149Section 250Section 68

148A. In this case, the same has been complied by the AO in compliance to Hon'ble Apex Court's decision in the case of Ashish Agarwal Vs. UOI. In view of the above discussion, this argument of the appellant is therefore rejected and Ground No. 3 is hereby dismissed. 8. The ground No. 4 raised by the appellant

ASSISTANT COMMISSIONER OF INCOME TAX CIRCLE 12, PUNE vs. VARUN JAIN, PUNE

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

ITA 2720/PUN/2024[2018]Status: DisposedITAT Pune07 May 2025

Bench: Dr.Dipak P. Ripote & Shri Vinay Bhamorecross Objection No.14/Pun/2025 (Arising Out Of Ita No.2720/Pun/2024) िनधा"रण वष" / Assessment Year: 2018-19 Varun Jain, The Acit, P-024, Forest County, Kharadi, V Circle-12, Pune. Pune – 411014. S. Maharashtra. Pan:Aexpj0171J Appellant/ Assessee Respondent / Revenue आयकर अपील सं. / Ita No.2720/Pun/2024 िनधा"रण वष" / Assessment Year: 2018-19 The Acit, Varun Jain, Circle-12, Pune. Vs. P-024, Forest County, Kharadi, Pune – 411014. Maharashtra. Pan:Aexpj0171J Appellant / Revenue Respondent / Assessee Assessee By Shri Fenil Bhatt – Ar(Virtual) Revenue By Shri Abhinay Kumbhar - Dr Date Of Hearing 05/05/2025 Date Of Pronouncement 07/05/2025 आदेश/ Order Per Dr. Dipak P. Ripote, Am: In This Case, Revenue Has Filed An Appeal Against The Order Of Ld.Commissioner Of Income Tax(Appeal)[Nfac] Passed Under C.O.No.14/Pun/2025 [A] & Ita No.2720/Pun/2024 [R]

Section 10(35)Section 133ASection 143(3)Section 144BSection 147Section 148ASection 250Section 253(4)

148A(a) seeking certain details regarding the subject transaction. 4.1 in response to the letter issued, the assessee has submitted that during the year he had purchased mutual fund through JM Financial Asset management Ltd. under the scheme "JM Equity Annual dividend option of Rs. 13,80,00,000/- on which the assessee received dividend income

MAHATMA PHULE GRAMIN BIGARSHETI SAHAKAR PAT SANSTHA LTD,KOLHAPUR vs. PCIT-1, PUNE, PUNE

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

ITA 1049/PUN/2025[2018-19]Status: DisposedITAT Pune09 Jan 2026AY 2018-19

Bench: Shri R. K. Panda & Ms. Astha Chandraassessment Year : 2018-19 Mahatma Phule Gramin Bigarsheti Pcit-1, Pune Sahakar Pat Sanstha Vs. A/P Hattiwade, Ajara, Kolhapur – 416505 Pan: Aaaam2608K (Appellant) (Respondent) Assessee By : None (Written Submission Filed) Department By : Shri Amol Khairnar, Cit-Dr Date Of Hearing : 09-12-2025 Date Of Pronouncement : 09-01-2026 O R D E R

For Appellant: None (written submission filed)For Respondent: Shri Amol Khairnar, CIT-DR
Section 139(1)Section 139(4)Section 147Section 148Section 263Section 80ASection 80PSection 80P(2)(a)Section 80P(2)(c)Section 80P(2)(d)

disallowance of deduction under section 80P, without appreciating that compliance under section 80AC is not mandatory and it is discretionary and further, by implication, AO had accepted one of the views in case of debatable issue. 3. The assessee craves leave to amend, alter or delete any of the above grounds of appeal. It is prayed that the above claims

ANANDA GORAKHANATH PAWAR,SATARA vs. ASSESSING OFFICER, WARD 3, SATARA, SATARA

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

ITA 1796/PUN/2025[2018-19]Status: DisposedITAT Pune28 Aug 2025AY 2018-19

Bench: Shri R. K. Panda & Shri Vinay Bhamoreआयकर अपील सं. / Ita No.1796/Pun/2025 िनधा"रण वष" / Assessment Year : 2018-19 Ananda Gorakhanath Pawar, Vs. Ito, Ward-3, Satara. At Post Ambawade, Khatav, Satara- 415506. Pan : Blhpp6081R Appellant Respondent Assessee By Shri R. C. Doshi : Revenue By : Shri Milind Debaje Date Of Hearing : 28.08.2025 Date Of Pronouncement : 28.08.2025 आदेश / Order Per Vinay Bhamore, Jm: This Appeal Filed By The Assessee Is Directed Against The Order Dated 30.06.2025 Passed By Ld. Cit(A)/Nfac For The Assessment Year 2018-19. 2. The Appellant Has Filed The Following Grounds Of Appeal :- “1. The Learned Cit Has Erred Both On Facts & In Law In Dismissing The Appeal Of The Appellant By Refusing To Condone The Delay Of 26 Days On Grounds Of Period Of Limitation, Notwithstanding The Fact That Appellant Has Submitted The Application & Explained The Reasons For Delay.

For Respondent: Shri Milind Debaje
Section 143(2)Section 144BSection 147Section 148Section 148ASection 151ASection 184ASection 4

Disallowed genuine deductions claimed under chapter VIA amounting to INR 25,200 • Creditors amounting to INR 3,10,110 added to income despite making addition w.r.t. purchase of milk • Citing credits in current accounts amounting to INR 11,54,361 as unexplained income. Contentions of the Appellant The learned AO has issued the notice under section 148A

DEPUTY COMMISSIONER OF INCOME TAX CIRCLE 7 PUNE, PUNE vs. KOLTE PATIL INTEGRATED TOWNSHIPS LIMITED, PUNE

In the result, both the appeals filed by the Revenue are dismissed

ITA 2011/PUN/2024[2016-17]Status: DisposedITAT Pune10 Mar 2025AY 2016-17
Section 143(3)Section 147Section 148Section 148ASection 151

disallowance of interest expenditure. He held that the reopening was beyond\nthe provisions of section 149. He accordingly submitted that the order of the Ld.\nCIT(A) / NFAC on this issue also being in accordance with law has to be accepted\nand the grounds raised by the Revenue on this issue have to be dismissed.\n17. The Ld. Counsel

KUMAR URBAN DEVELOPMENT PVT. LTD (SUCCESSOR KUMAR HOUSING CORPORATION PVT LTD),PUNE vs. DCIT CIRCLE 14, PUNE

ITA 2874/PUN/2024[2014-15]Status: DisposedITAT Pune18 Aug 2025AY 2014-15
For Appellant: Shri Nikhil S PathakFor Respondent: Shri Ramnath P Murkunde
Section 143(2)Section 32Section 36(1)(iii)

disallowance was consequently restricted.", "result": "Allowed", "sections": [ "143(2)", "142(1)", "36(1)(iii)", "32", "68", "80IA", "41(1)", "139", "170A", "148", "148A

M/S GIRIRAJ ENTERPRISES,PUNE vs. DCIT, CENTRAL CIRCLE 1(1), PUNE, PUNE

In the result, the appeal filed by the assessee is allowed and the appeals filed by the Revenue are dismissed

ITA 427/PUN/2024[2015-16]Status: DisposedITAT Pune17 Oct 2024AY 2015-16

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

For Appellant: Shri Nikhil S PathakFor Respondent: Shri Amol Khairnar, CIT-DR
Section 10(35)Section 132Section 133ASection 143(1)Section 143(2)Section 153A

disallowed / taxed accordingly as per computation as under: Particulars Amount (in Rs.) Redeemed Value of MF on 29.01.2015 8,99,93,198/- Add: Dividend Received 2,06,68,835/- Business Loss claimed 1,00,06,802/- 10 IT(SS)A Nos.23 to 25/PUN/2024 Total Receipts 12,06,68,835/- Less: Initial Investment Cost 10,00,00,000/- Income earned

DEPUTY COMMISSIONER OF INCOME TAX CIRCLE-7 PUNE, PUNE vs. KOLTE PATIL INTEGRATED TOWNSHIPS LIMITED, PUNE

In the result, both the appeals filed by the Revenue are dismissed

ITA 2023/PUN/2024[2014-15]Status: DisposedITAT Pune10 Mar 2025AY 2014-15
Section 143(3)Section 147Section 148Section 148ASection 151

section 148 prior to 31-\n03-2021) as notice u/s 148A(b) and directed to provide the information and\nmaterial relied upon by the revenue to the assessee for issue of such notice, within\n30 days from the date of order passed by Hon'ble Supreme Court of India i.e. 04-\n05-2022 and to provide two weeks time

KAMAL NAGARI SAHAKARI PATSANSTHA LTD.,ALIBAG vs. ITO, WARD-3, PANVEL, PANVEL

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

ITA 391/PUN/2025[2014-15]Status: DisposedITAT Pune26 Aug 2025AY 2014-15

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

For Appellant: Shri Ajinkya VaishampayanFor Respondent: Shri Ramnath P Murkunde
Section 143(3)Section 144Section 148Section 148ASection 149(1)(b)Section 56Section 57Section 80P(2)(a)Section 80P(2)(d)

148A(d) of the Act. While completing the original assessment u/s 143(3) of the Act, the Ld. AO accepted and allowed the deduction u/s 80P(2)(a)(i) as business income. During re-assessment proceedings, the Ld AO rejected the assessee’s contention that the assessee is eligible for deduction under section

KAMAL NAGARI SAHAKARI PATSANSTHA LTD.,RAIGAD vs. ITO WARD-3, PANVEL, PANVEL

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

ITA 390/PUN/2025[2013-14]Status: DisposedITAT Pune26 Aug 2025AY 2013-14

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

For Appellant: Shri Ajinkya VaishampayanFor Respondent: Shri Ramnath P Murkunde
Section 143(3)Section 144Section 148Section 148ASection 149(1)(b)Section 56Section 57Section 80P(2)(a)Section 80P(2)(d)

148A(d) of the Act. While completing the original assessment u/s 143(3) of the Act, the Ld. AO accepted and allowed the deduction u/s 80P(2)(a)(i) as business income. During re-assessment proceedings, the Ld AO rejected the assessee’s contention that the assessee is eligible for deduction under section

KUMAR URBAN DEVELOPMENT PVT. LTD (SUCCESSOR KUMAR HOUSING CORPN. PVT LTD),PUNE vs. DCIT CIRCLE 14, PUNE

In the result, both the appeals filed by the assessee are allowed and the appeal filed by the Revenue is dismissed

ITA 2875/PUN/2024[2013-14]Status: DisposedITAT Pune18 Aug 2025AY 2013-14

Bench: Shri R. K. Panda & Ms. Astha Chandraassessment Year : 2013-14

For Appellant: Shri Nikhil S PathakFor Respondent: Shri Ramnath P Murkunde
Section 143(2)Section 32Section 36(1)(iii)

disallowance of depreciation of Rs.10,74,599/-. However, since the assessee is not in appeal before us on these two issues, we are not concerned with the same. 9. So far as the addition of trade advances from customers of Rs.26,90,56,640/- is concerned, the Ld. CIT(A) / NFAC gave part relief to the assessee by observing

DY COMMISSIONER OF INCOME TAX CIRCLE 7 PUNE, PUNE vs. KUMAR HOUSING CORPORATION PRIVATE LIMITED, PUNE

In the result, both the appeals filed by the assessee are allowed and the appeal filed by the Revenue is dismissed

ITA 341/PUN/2025[2013-14]Status: DisposedITAT Pune18 Aug 2025AY 2013-14

Bench: Shri R. K. Panda & Ms. Astha Chandraassessment Year : 2013-14

For Appellant: Shri Nikhil S PathakFor Respondent: Shri Ramnath P Murkunde
Section 143(2)Section 32Section 36(1)(iii)

disallowance of depreciation of Rs.10,74,599/-. However, since the assessee is not in appeal before us on these two issues, we are not concerned with the same. 9. So far as the addition of trade advances from customers of Rs.26,90,56,640/- is concerned, the Ld. CIT(A) / NFAC gave part relief to the assessee by observing

KESARINATH RAM GAIKWAD,RAIGAD vs. ITO, WARD-1, PANVEL, PANVEL

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

ITA 2139/PUN/2025[2017-18]Status: DisposedITAT Pune28 Jan 2026AY 2017-18
For Respondent: Shri Basavaraj Hiremath
Section 10(37)Section 148Section 148ASection 151Section 151A

Section 148A with effect from 01.04.2021 and the directions issued by the hon'ble Supreme Court in the judgment of Union of India vs Ashish Agarwal bearing Civil Appeal no, 3005/2022; 4 12. BECAUSE, the notice issued u/s 148 dated 26.07.2022 is void ab initio and without jurisdiction as though the notice makes a reference to an alleged order

SHRI VARDHAMAN NAGRI SAHAKARI PATSANSTHA LTD.,PACHORA vs. ITO WARD 1(4), JALGAON, JALGAON

In the result, appeal of the assessee is partly allowed

ITA 2451/PUN/2025[2015-16]Status: DisposedITAT Pune16 Dec 2025AY 2015-16

Bench: Dr.Dipak P. Ripote & Shri Vinay Bhamoreआयकर अपऩल सं. / Ita No.2451/Pun/2025 निर्धारण वषा / Assessment Year: 2015-16 Shri Vardhaman Nagri V The Income Tax Sahakari Patsanstha Ltd., S Officer, 1061, Shivaji Chowk, Ward-1(4), Pune. Bhadgaon Road, Pachora, Maharashtra – 424201. Pan: Aacas3361F Appellant/ Assessee Respondent / Revenue Assessee By Shri Vinay Kawdia – (Virtual Hearing) Revenue By Shri Sandeep Sathe - Dr Date Of Hearing 08/12/2025 Date Of Pronouncement 30/12/2025 आदेश/ Order Per Dr. Dipak P. Ripote, Am: This Is An 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.2015-16 Dated 22.10.2025 Emanating From The Assessment Order Passed Under Section 147 R.W.S 144B Of The Act, Dated 18.03.2024. The Assessee Has Raised The Following Grounds Of Appeal :

Section 139(1)Section 147Section 148Section 148ASection 149Section 151ASection 250Section 80P

148A(b) is bad in law and liable to be quashed. 3) On the facts and circumstances of the case and in law, notice u/s. 148 Dt. 05.04.2022 issued by ITO, Ward 1(4), Jalgaon is bad law and void-ab-initio for want of jurisdiction in view of Section 151A read with CBDT Notification

SWA SAINIK N L BALKAWADE NAGARI SAHAKARI PATSANSTHA LTD,PUNE vs. ITO WARD 2(1), NASHIK

ITA 1526/PUN/2025[2015-16]Status: DisposedITAT Pune14 Jul 2025AY 2015-16
Section 147Section 148Section 149Section 151ASection 250Section 80P(2)(d)

148A in issued beyond three years from the relevant assessment Year in respect of income likely to be escaped is below Rs 50 Lakhs. Since the proceedings have been taken beyond the permitted time limit, the assessment Order is null void.\n3. Whether impugned Assessment Order u/s 147 are time barred in view of the proviso to Section

ACIT, CIRCLE-1, NASHIK, NASHIK vs. TAPARIA TOOLS LIMITED, NASHIK

In the result, both the appeal of the Revenue as well as Cross Objection of the assessee are allowed for statistical purposes as per the terms indicated above

ITA 1337/PUN/2025[2017-18]Status: DisposedITAT Pune10 Dec 2025AY 2017-18

Bench: Dr.Manish Borad & Shri Vinay Bhamoreआयकर अपील सं. / Ita No.1337/Pun/2025 Assessment Year : 2017-18

For Appellant: Shri Amit BobdeFor Respondent: Shri Viral Shah
Section 142(1)Section 147Section 148Section 37(1)

148A(d) order that seller has borne the transportation charges. The only bill furnished with respect to assessee was of meagre Rs.300/-. (d) The physical verification of the two warehouses and two corporate offices led to the following conclusions : (1) The M/s Sharp King Trading has only 2 one room warehouses, which are currently empty and do not have