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16 results for “disallowance”+ Section 153C(2)clear

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Key Topics

Section 14818Section 153C14Section 143(3)12Section 14711Section 269S9Section 153A8Addition to Income8Section 143(1)7Section 148A7Disallowance

INCOME TAX OFFICER, PUNE vs. SAGAR CONSTRUCTION COMPANY, PUNE

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

ITA 1812/PUN/2025[2017-18]Status: DisposedITAT Pune08 Jan 2026AY 2017-18

Bench: Shri R. K. Panda & Ms. Astha Chandraassessment Year : 2017-18

For Appellant: Shri Suhas Bora and Riya OswalFor Respondent: Shri S. Sadananda Singh, JCIT
Section 142(1)Section 143(1)Section 147Section 148Section 269SSection 37Section 68

2) of the Act in response to which the assessee submitted its reply. The assessee also filed objections against the reopening of assessment u/s 147 on 16.02.2022. The Assessing Officer disposed of the objections on 07.03.2022 as per the directions of Hon’ble Supreme Court in the case of GKN Driveshafts (India) Ltd vs ITO reported

4
Penalty3
Search & Seizure3

ASST. COMMISSIONER OF INCOME TAX, PANVEL CIRCLE PANVEL vs. OUTABOX MEDIA SOLUTIONS LLP, GHATKOPAR MUMBAI

In the result, the appeal filed by the Revenue is partly allowed

ITA 177/PUN/2024[2017-18]Status: DisposedITAT Pune07 Nov 2024AY 2017-18

Bench: Shri R. K. Panda & Ms Astha Chandraassessment Year : 2017-18

For Appellant: Shri Gunjan H KakkadFor Respondent: Shri Ramnath P Murkunde
Section 142(1)Section 143(2)

153C or after the completion of the assessment, whichever is earlier. (4) Subject to the provisions of sub-section (3), where an assessee calls in question the jurisdiction of an Assessing Officer, then the Assessing Officer shall, if not satisfied with the correctness of the claim, refer the matter for determination under sub-section (2) before the assessment is made

WOCKHARDT LIMITED,AURANGABAD vs. THE ASSISTANT COMMISSIONER OF INCOME TAX CENTRAL CIRCLE 2(1), PUNE

In the result, the appeal of the assessee is partly allowed

ITA 836/PUN/2025[2018-19]Status: DisposedITAT Pune10 Nov 2025AY 2018-19

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

For Appellant: Shri Manthan ShahFor Respondent: Shri Amit Bobde
Section 127Section 132Section 132(4)Section 143(2)Section 153C

2)/142(1) of the Act along with questionnaire were issued and served upon the assessee calling for various details, in response to which the assessee submitted its reply from time to time. Dissatisfied with the submissions of the assessee, the Ld. AO proceeded to pass the order u/s 153C of the Act on 30.03.2023 making disallowance in respect

WOCKHARDT LIMITED,AURANGABAD vs. THE ASSISTANT COMMISSIONER OF INCOME TAX CENTRAL CIRCLE 2(1), PUNE

In the result, the appeal of the assessee is partly allowed

ITA 837/PUN/2025[2016-17]Status: DisposedITAT Pune10 Nov 2025AY 2016-17

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

For Appellant: Shri Manthan ShahFor Respondent: Shri Amit Bobde
Section 127Section 132Section 132(4)Section 143(2)Section 153C

2)/142(1) of the Act along with questionnaire were issued and served upon the assessee calling for various details, in response to which the assessee submitted its reply from time to time. Dissatisfied with the submissions of the assessee, the Ld. AO proceeded to pass the order u/s 153C of the Act on 30.03.2023 making disallowance in respect

WOCKHARDT LIMITED,AURANGABAD vs. THE ASSISTANT COMMISSIONER OF INCOME TAX CENTRAL CIRCLE-2(1), PUNE

In the result, the appeal of the assessee is partly allowed

ITA 835/PUN/2025[2017-18]Status: DisposedITAT Pune10 Nov 2025AY 2017-18
For Appellant: \nDepartment by
Section 127Section 132Section 153C

153C of the Act, statutory notice(s) u/s\n143(2)/142(1) of the Act along with questionnaire were issued and served\nupon the assessee calling for various details, in response to which the\nassessee submitted its reply from time to time. Dissatisfied with the\nsubmissions of the assessee, the Ld. AO proceeded to pass the order u/s\n153C

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

153C, as the case may be, as they stood immediately before the\ncommencement of the Finance Act, 2021. As per the old provisions of section\n148, the case of the assessee could not have been reopened beyond four years from\nthe end of the relevant assessment year since there was no allegation of any failure\non the part

SHAKEEL ABDUL AZEEZ MOHAMMAD,JALGAON vs. ITO, WARD 1(1), JALGAON, JALGAON

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

ITA 1115/PUN/2025[2016-17]Status: DisposedITAT Pune21 Jul 2025AY 2016-17

Bench: Dr.Dipak P. Ripote & Shri Vinay Bhamoreआयकर अपीलसं. / Ita No.1115/Pun/2025 िनधा"रण वष" / Assessment Year: 2016-17 Shakeel Abdul Azeez V The Income Tax Officer, Mohammad, S Ward-1(1), Jalgaon. Kachchi Chawl, Indira Nagar, Shahu Nagar, Jalgaon-425001. Maharashtra. Pan: Byfpm1596K Appellant/ Assessee Respondent / Revenue Assessee By Shri Vinay V Kawdia – Ar(Virtual) Revenue By Shri Sandeep P Sathe – Jcit(Dr) Date Of Hearing 17/07/2025 Date Of Pronouncement 21/07/2025

Section 144Section 147Section 148Section 153CSection 250Section 69A

153C is bad in law and the resultant order under section 144 r w s 147 is liable to be quashed. 2) Under the facts and circumstances of the case and in law the learned CIT(A). NFAC has erred in confirming the addition of Rs. 44,04,041/- made by AO u/s 69A of the act by treating

SHRI MANOJ MADANLAL CHHAJED,PUNE vs. THE ASSISTANT COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-1(1), PUNE

ITA 1178/PUN/2023[2011-12]Status: DisposedITAT Pune19 Feb 2025AY 2011-12
Section 132Section 132(1)Section 142(1)Section 143(1)Section 143(2)Section 143(3)Section 147Section 148

2% on the amount of accommodation entry\ntaken of Rs.10,42,46,373/-, which comes to Rs.20,84,927/-. The same is also\nrequired to be added to the total income of the assessee.\n6.4 Interest Expenditure claimed thereon:\nFurther, it was also observed that the assessee has claimed interest expenditure on\nthese accommodation loan entries in its ITR returns

MANOJ MADANLAL CHHAJED,PUNE vs. THE ASSISTANT COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-1(1), PUNE

ITA 2017/PUN/2024[2011-12]Status: DisposedITAT Pune19 Feb 2025AY 2011-12
Section 132Section 132(1)Section 142(1)Section 143(1)Section 143(2)Section 143(3)Section 147Section 148

2% on the amount of accommodation entry\ntaken of Rs.10,42,46,373/-, which comes to Rs.20,84,927/-. The same is also\nrequired to be added to the total income of the assessee.\n6.4 Interest Expenditure claimed thereon:\nFurther, it was also observed that the assessee has claimed interest expenditure on\nthese accommodation loan entries in its ITR returns

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

2), Mumbai and others [2024] 162 taxmann.com 225?\n5.\nWhether on the facts and circumstances of the case and in law, the CIT(A)\nhas erred in granting relief to the assessee by deleting addition amounting\nto Rs.15,11,87,548/- while relying on the judgment of Hon'ble Bombay\nHigh Court in the case of Lokhandwala Construction Industries

SHAMKANT KESHAV KOTKAR (PROP. NANDAN BUILDERS),PUNE vs. PR. COMMISSIONER OF INCOME TAX (CENTRAL), PUNE

In the result, appeal of the assessee is allowed

ITA 1358/PUN/2025[2017-18]Status: DisposedITAT Pune31 Dec 2025AY 2017-18

Bench: SHRI VINAY BHAMORE (Judicial Member)

Section 132Section 142(1)Section 143(3)Section 153Section 153ASection 153CSection 26Section 263Section 40

disallowed interest on TDS of Rs.1,189/- and added Rs.1,189/- to the returned income. Ld.AR submitted that A.Y.2017-18 was unabated assessment. Therefore, addition could have been made only based on incriminating documents. Since there were no incriminating documents for A.Y.2017-18, Assessing Officer has not made any addition. Pr.CIT issued notice u/s.263 of the Act, alleging that there was document

DY. COMMISSIONER OF INCOME TAX (EXEMPTIONS), CIRCLE, PUNE, SWARGATE, PUNE vs. SHREE CHANAKYA EDUCATION SOCIETY, AUNDH ,PUNE

In the result, both the appeals filed by the Revenue and the Cross Objection filed by the assessee are dismissed

ITA 2155/PUN/2024[2014-2015]Status: DisposedITAT Pune11 Aug 2025AY 2014-2015

Bench: Shri R. K. Panda & Ms Astha Chandraassessment Year : 2014-15

For Appellant: S/Shri Neelesh Khandelwal &For Respondent: Shri Ramnath P Murkunde
Section 12ASection 143(1)Section 147Section 271(1)(c)

disallowed, the Respondent had an excess application of Rs.5,79,77,998/- for the relevant Assessment Year. Therefore, even by doing so, there will be no income chargeable to tax for AY 2014-15. Just and proper relief be granted to the respondent in this respect. 3. The appellant prays to be allowed to add, amend, modify, rectify, delete

DY. COMMISSIONER OF INCOME TAX (EXEMPTIONS), CIRCLE, PUNE, SWARGATE, PUNE vs. SHREE CHANAKYA EDUCATION SOCIETY, AUNDH, PUNE

In the result, both the appeals filed by the Revenue and the Cross Objection filed by the assessee are dismissed

ITA 2170/PUN/2024[2014-15]Status: DisposedITAT Pune11 Aug 2025AY 2014-15

Bench: Shri R. K. Panda & Ms Astha Chandraassessment Year : 2014-15

For Appellant: S/Shri Neelesh Khandelwal &For Respondent: Shri Ramnath P Murkunde
Section 12ASection 143(1)Section 147Section 271(1)(c)

disallowed, the Respondent had an excess application of Rs.5,79,77,998/- for the relevant Assessment Year. Therefore, even by doing so, there will be no income chargeable to tax for AY 2014-15. Just and proper relief be granted to the respondent in this respect. 3. The appellant prays to be allowed to add, amend, modify, rectify, delete

MCM DEVELOPERS,AURANGABAD vs. DCIT. CENTRAL CIRCLE-1, AURANGABAD, AURANGABAD

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

ITA 362/PUN/2025[2018-2019]Status: DisposedITAT Pune17 Sept 2025AY 2018-2019

Bench: SHRI MANISH BORAD (Accountant Member), SHRI VINAY BHAMORE (Judicial Member)

For Appellant: Shri Pramod ShingteFor Respondent: Shri Amol Khairnar
Section 143(3)Section 153ASection 153CSection 154Section 269SSection 270ASection 271DSection 40A(3)

2 complete application of mind by Learned Assessing Officer as well as by Learned Joint CIT who also initiated penalty proceedings under section 271DA therefore order passed under section 154 is bad in law and deserves to be struck down. Your appellant prays for deletion of entire addition. Your appellant craves for to add, alter amend, modify, delete

DY COMMISSIONER OF INCOME-TAX, SANGLI CIRCLE,, SANGLI vs. ANAND DEVELOPERS, SANGLI

In the result, the appeal filed by the assessee in ITA

ITA 67/PUN/2021[2014-15]Status: DisposedITAT Pune20 Jun 2023AY 2014-15
For Appellant: Shri Kishor B. PhadkeFor Respondent: Shri Keyur Patel &
Section 143(3)Section 42

disallowances, an appeal was filed before the ld. CIT(A) contesting inter alia that the profits of Rs.3,58,69,978/- on sale of immovable property had not accrued to the appellant. The Assessing Officer ought not to have made addition of Rs.8,47,00,000/- being the alleged receipt of on-money on sale of the said property

ANAND DEVELOPERS,SANGLI vs. INCOME-TAX OFFICER, WARD 2(1), SANGLI

In the result, the appeal filed by the assessee in ITA

ITA 458/PUN/2020[2014-15]Status: DisposedITAT Pune20 Jun 2023AY 2014-15
For Appellant: Shri Kishor B. PhadkeFor Respondent: Shri Keyur Patel &
Section 143(3)Section 42

disallowances, an appeal was filed before the ld. CIT(A) contesting inter alia that the profits of Rs.3,58,69,978/- on sale of immovable property had not accrued to the appellant. The Assessing Officer ought not to have made addition of Rs.8,47,00,000/- being the alleged receipt of on-money on sale of the said property