M/S. ANGELICA PROPERTIES PRIVATE LTD.,,PUNE vs. DEPUTY COMMISSIONER INCOME-TAX,,

The appeals of the assessee are partly allowed

Bench: Shri S.S.Viswanethra Ravi, Hon’Ble Jm & Dr. Dipak P. Ripote, Hon’Ble Am आयकरअपीलसं. / Ita No: 403/Pun/2015 िनधा"रणवष" / Assessment Year : 2010-11 Vason Engineers Ltd., Theadditional Commissioner Of (Formerly Angelica Properties Pvt. Vs Income Tax, Range1, Pune. Ltd.,) 301, Phoenix, Opp.Residency Club, Bund Garden Road, Pune – 411037. Pan: Aafca 8644 J Appellant/ Assessee Respondent /Revenue आयकरअपीलसं. / Ita No: 1738/Pun/2016 िनधा"रणवष" / Assessment Year : 2011-12 Angelica Properties Pvt. Ltd., The Deputy Commissioner Of Opp. Grand Hyatt Hotel, Vs Income Tax, Circle-1(1), Pune. Vimannagar, Puune – 411 014. Pan: Aafca 8644 J Appellant/ Assessee Respondent /Revenue Assessee By Shri Dharmesh Shah – Ar Revenue By Shri Naveen Gupta – Dr Date Of Hearing 24/06/2022 Date Of Pronouncement 22/09/2022 आदेश/ Order Per Dr. Dipak P. Ripote, Am: These Two Appeals Filed By The Assessee Are Directed Against The Separate Orders Of Ld.Commissioner Of Income Tax(Appeals)-1, Pune Dated 30.01.2015 & 09.06.2016 For The Assessment Years 2010-11 & 2011-12 Respectively. 2. The Assessee In Ita No.403/Pun/2015 For The A.Y.2010-11 Has Raised Following Grounds Of Appeal: “1. The Ld. Cit(A) Has Erred In Law & In Facts Enhancing The Income From Sale Of ‘Matrix It Building’ By Changing The Head Of Income From Capital Gains To Business Income Without Complying With The Principles Of Natural Justice & Without Giving Any Opportunity Of Hearing.

disallowances to the extent of 50% of wage expenses claimed by appellant in profit and loss account and 50% of sundry creditors appearing in balance sheet of the assessee. The Hon’ble Court took a view that the power of Commissioner (Appeals) cannot be restricted on the ground of new source of income, as Section 251

SATYAM TRANSFORMERS PRIVATE LIMITED,AURANGABAD vs. ITO WARD 2(3), AURANGABAD

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.1239/Pun/2025 धििाारण वर्ा / Assessment Year : 2015-16 Satyam Transformers Private Limited, Ito, Ward-2(3), Sharadanand, Opposite Telephone Office, Aurangabad Ajabnagar, Aurangabad-431001 Vs. Pan : Aakcs4648D अपीलार्थी / Appellant प्रत्यर्थी / Respondent Assessee By : Shri Shubham N. Rathi Department By : Shri Akhilesh Srivastva Date Of Hearing : 04-08-2025 Date Of 27-10-2025 Pronouncement : आदेश / Order

disallowance of index cost of acquisition is bad in law and therefore deserves to be allowed.” 6. The Ld. AR submitted that the assessee’s application under the Direct Tax Vivad Se Vishwas Act, 2020 (“DTVSV Act, 2020”) has been rejected by the Income Tax Department. Admittedly, there was a lapse on the part of the assessee to inform

DEPUTY COMMISSIONER OF INCOME TAX, CIRCLE-8, PUNE, PUNE vs. SANDVIK COROMANT INDIA PVT LTD, PUNE

In the result, appeal filed by the Revenue in ITA

Bench: Shri S.S.Godara & Dr. Dipak P. Ripoteआयकरअपीलसं. / Ita No.1072/Pun/2023 िनधा"रणवष" / Assessment Year : 2018-19 The Dy.Commissioner Of Sandvik Coromant India Pvt. Income Tax, Circle-8, Vs Ltd., Pune. Mumbai Pune Road, Dapodi, Pune – 411012. Pan: Aaccs6638K Appellant/ Revenue Respondent /Assessee Cross Objection No.7/Pun/2024 िनधा"रणवष" / Assessment Year : 2018-19 Sandvik Coromant India The Dy.Commissioner Of Pvt. Ltd., Vs Income Tax, Circle-8, Pune. Mumbai Pune Road, Dapodi, Pune – 411012. Pan: Aaccs6638K Appellant/ Assessee Respondent / Revenue Assessee By Shri Nikhil Patakh – Ar Revenue By Shri Ajay Kumar Keshari – Dr Date Of Hearing 15/04/2024 Date Of Pronouncement 07/05/2024 आदेश/ Order Per Dr. Dipak P. Ripote, Am: This Appeal Ita 1072/Pn/2023 Filed By The Revenue & Cross Objection Co No.7/Pun/2024 Filed By The Assessee Are Directed Against The Order Of Ld.Commissioner Of Income Tax(Appeal)[Nfac] U/S.250 Of The Act, For A.Y.2018-19

Section 251 of the Income Tax Act, 1961, which mandates that in an appeal against an order of assessment, the CIT(A) may confirm, reduce, enhance or annul the assessment. 3. On the facts and circumstances of the case and in law, the ld.CIT(A) erred in not disposing the same in the manner as provided in Sec.251

SURESH CHUNNILAL SHARMA,,PARBHANI vs. INCOME-TAX OFFICER, WARD - PARBHANI,, PARBHANI

In the result, the appeal is partly allowed for statistical

Bench: Shri R.S. Syalआयकर अपील सं. / Ita No.1883/Pun/2018 िनधा"रण वष" / Assessment Year : 2013-14

251 ITR 640 (Cal.) have confirmed the disallowance where the payment was made in cash exceeding the stipulated amount notwithstanding the genuineness of the transaction. 13. Let me consider the judgment of the Hon’ble jurisdictional High Court in Madhav Govind Dulshete (supra) a little more elaborately. The assessee therein was engaged in the business of sale of Kerosene which

KRUSHI SADHNA VIVIDH KARYAKARI SAHAKARI VIKAS SEVA SANSTHA MARYADIT,KURUNDWAD SHIROL ,KOLHAPUR vs. INCOME TAX OFFICER, ICHALKARANJI

In the result the ground number 1 raised by the Assessee is allowed

Bench: DR.DIPAK P. RIPOTE (Accountant Member), SHRI VINAY BHAMORE (Judicial Member)

section 250 of the Income tax Act 1961 for A.Y.2015-16. The Assessee has raised the following grounds of appeal : “1. On the facts and circumstances of the case and in law the CIT(A), NFAC erred in, sou motu, making addition of business income of the appellant society, holding the society not being eligible for deduction u/s 80P in respect

PINNAC PARIJAAT CO.OP. HSG. SOCIETY LTD,PUNE vs. ITO WARD 2(2), PUNE

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

Bench: Dr.Dipak P. Ripote & Shri Vinay Bhamoreआयकर अपील सं. / Ita No.531/Pun/2025 िनधा"रण वष" / Assessment Year: 2020-21 Pinnac Parijaat Co. Op. V The Income Tax Officer, Housing Society Limited, S Ward-2(2), Pune. S.No.35, Hissa No.1,3,4,5,11,12, Karve Nagar, Pune – 411052. Pan: Aadap9430D Appellant/ Assessee Respondent / Revenue Assessee By None Revenue By Shri Harish Bist – Addl.Cit(Dr) Date Of Hearing 03/04/2025 Date Of Pronouncement 09/04/2025 आदेश/ Order Per Dr. Dipak P. Ripote, Am: This Appeal Filed By The Assessee Is Against The Order Of Ld.Commissioner Of Income Tax(Appeals)/[Nfac], Passed Under Section 250 Of The Income Tax Act, 1961, On 24.12.2024 For Assessment Year 2020-21. The Assessee Has Raised The Following Grounds Of Appeal : “1. The Learned Cit(A) Erred In Law & On Facts In Confirming The Total Income Of The Appellant At Rs. 3,13,990/-Instead Of 1,01,830/-

disallowing assessee’s claim for deduction under section 80P(2)(d) of the Act. Assessee claimed that since no specific reason was mentioned in the order under section 143(1) for ITA No.531/PUN/2025 [A] denying the claim of Assessee for deduction u/s.80P(2)(d) of the Act, assessee filed a rectification application under section

SALASAR WAREHOUSING PRIVATE LIMITED,PUNE vs. INOCME TAX OFFICER, WARD-6(1), PUNE, PUNE

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

Bench: Shri Partha Sarathi Chaudhuryand Dr. Dipak P. Ripoteआयकर अपील सं. / Ita No.59/Pun/2023 िनधा"रण वष" / Assessment Year : 2020-21 Salasar Warehousing Private The Income Tax Officer, Limited, V Ward-6(1), Pune. F-2,Warehouse, Sr.No.20/2A, S Near Mundhwa Bridge, Kharadi, Pune – 411014. Pan: Aamcs4834C Appellant/ Assessee Respondent /Revenue Assessee By Shri Sarvesh Kandelwal – Ar Revenue By Shri M.G.Jasnani – Dr Date Of Hearing 27/09/2023 Date Of Pronouncement 30/11/2023

Section 251(2) of the Act which requires the CIT(A) to apply his mind to all the issues which arise from the impugned order before him whether or not the same has been raised by the appellant before him. Accordingly, the law does not empower the CIT(A) to dismiss the appeal for non- prosecution as is evident from

C R JAISWAL AND K B JAISWAL,VILLAGE KINGAON vs. INCOME TAX OFFICER, WARD -2(5), JALGAON

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

Bench: Shri S.S.Godara & Dr. Dipak P. Ripoteआयकर अपील सं. / Ita No.732/Pun/2023 िनधा"रण वष" / Assessment Year : 2016-17 C R Jaiswal & K B Jaiswal, The Income Tax Officer, Retail Country Liquor Shop, V Jalgaon. Village Kingaon, Taluka S Yawal – 425503 Maharashtra. Pan: Aaefc 8278 J Appellant / Assessee Respondent / Revenue Assessee By Shri Pramod Shingte – Ar Revenue By Shri Ramnath P Murkunde – Dr Date Of Hearing 12/09/2023 Date Of Pronouncement 14/09/2023 आदेश/ Order Per Dr. Dipak P. Ripote, Am: This Is An Appeal Filed By The Assessee Directed Against The Order Of Ld.Commissioner Of Income Tax(Appeal)[Nfac] Under Section 250 Of The Income Tax Act, 1961 Dated 21.04.2023 Emanating From Assessment Order Under Section 143(3) Dated 29.11.2018 For A.Y.2016-17. The Grounds Of Appeal Raised By The Assessee As Under : C.R.Jaiswal & K.B.Jaiswal [A]

disallowance can only be made when the payments are genuine. In the present case the payments were genuine and supported by ledger abstract duly confirmed by the seller J K Wines which was sent by the seller to the learned AO. Hence it is requested to direct the learned CIT [Appeals] to drop the initiation of penalty proceedings against

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

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

disallowing the deduction claimed u/s 80P(2)(d) at Rs. 1,33,53,021/- . 4. Aggrieved, the assessee filed an appeal before the Ld. CIT(A)/NFAC. There was non-compliance of notices of hearing. By applying the amended provisions of section 251

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

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

disallowing the deduction claimed u/s 80P(2)(d) at Rs. 1,33,53,021/- . 4. Aggrieved, the assessee filed an appeal before the Ld. CIT(A)/NFAC. There was non-compliance of notices of hearing. By applying the amended provisions of section 251

BHIMASHANKAR SSK LTD,PUNE vs. ACIT- CIRCLE-8, PUNE, PUNE

Bench: Shri R.K.Panda & Shri Vinay Bhamoreआयकर अपील सं. / Ita No.1147/Pun/2024 िनधा"रण वष" / Assessment Year:2012-13 Bhimashankar Ssk Ltd., V The Acit, A/P. Pargaon, Tal.Ambegaon, S Circle-8, Pune. Dist-Pune – 412406. Pan: Aaaab0949G Appellant/ Assessee Respondent / Revenue Assessee By Shri Hanmant Dattatry Dhavle – Ar Revenue By Shri Amol Khairnar – Cit(Dr) Date Of Hearing 18/12/2024 Date Of Pronouncement 11/03/2025 आदेश/ Order Per Vinay Bhamore, Jm: This Appeal Filed By The Assessee Is Against The Order Of Ld.Commissioner Of Income Tax(Appeals)[Nfac] Passed Under Section 250 Of The Income Tax Act, 1961; Dated 23.03.2024 For Assessment Year 2012-13. The Assessee Has Raised The Following Grounds Of Appeal : “1. On The Fact & In The Circumstance Of The Case & In Law Of The Learned Nfac –Commissioner Of Income Tax(Appeals) Delhi, Has Erred In Disallowing & Adding Back An Amount Of Rs.42,23,17,760/- On Account F Excess Cane Price Paid Farmers.

Section 251(2) of the Act which requires the CIT(A) to apply his mind to all the issues which arise from the impugned order before him whether or not ITA No.1147/PUN/2024 [A] the same has been raised by the appellant before him. Accordingly, the law does not empower the CIT(A) to dismiss the appeal for non- prosecution

V.R. SUKHWANI PROJECTS,PUNE vs. INCOME TAX OFFICER - CIRCLE 2, PUNE, PUNE

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

Bench: Dr.Dipak P. Ripote & Shri Vinay Bhamoreआयकर अपऩल सं. / Ita No.1750/Pun/2025 निर्धारण वषा / Assessment Year: 2022-23 V.R.Sukhwani Projects, V The Income Tax Officer, Office No.B-1205, S Circle-2, Pune Amar Business Zone, Baner, Pune – 411045 Pan: Aaqfv3888H Appellant/ Assessee Respondent / Revenue Assessee By Miss Sailee Gujarathi – Ar Revenue By Shri Aviyogi Ambadkar– Addl.Cit(Dr) Date Of Hearing 09/09/2025 Date Of Pronouncement 25/09/2025 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.2022-23 Dated 22.01.2025 Emanating From The Assessment Order Passed Under Section 144 Of The Income Tax Act, 1961 Dated 04.03.2024. The Assessee Has Raised The Following Grounds Of Appeal :

disallowed assessee’s claim under section 80IBA of Rs.1,53,39,381/-. Aggrieved by the 2 ITA No.1750/PUN/2025 [A] Assessment Order, Assessee filed appeal before ld.CIT(A). The Paragraph 6 and 7 of the ld.CIT(A)’s order is reproduced as under : “6. Decision: 04-03-2024, 6.1 Appeal has been filed against the order u/s 144, dated passed

BILIDEVALAYA LAKSHMI NARASIMHA MURTHY,SINDHUDURG vs. INCOME TAX OFFICE, KUDAL

Appeal of the assessee is allowed for statistical purpose

Bench: Shri Satbeer Singh Godara & Dr. Dipak P. Ripoteआयकर अपील सं. / Ita No.701/Pun/2024 निर्धारण वर्ा / Assessment Year: 2020-21 Bilidevalaya Lakshmi Narasimha Murthy, Vs The Income Tax Officer, S-7 Vinayak Apartment, Vaishyawada, Kudal Sawantwadi, Maharashtra-416510 Pan : Acgpb9237N Appellant/ Assessee Respondent / Revenue Assessee By None Revenue By Shri Ramnath P. Murkunde Date Of Hearing 26/08/2024 Date Of Pronouncement 28/08/2024 आदेश/ Order Per Dr. Dipak P. Ripote, Am: This Appeal Filed By The Assessee Against The Order Of Ld. Commissioner Of Income Tax(Appeals) [Nfac], Passed Under Section 250 Of The Income Tax Act, 1961 Dated 01.03.2024 For The A.Y. 2020-21. 2. The Assessee Has Raised The Following Grounds Of Appeal : “1. On The Facts & Circumstances Of The Case & In Law The Ld. Cit(A), Nfac, Erred In Confirming The Addition Made By The Ao Of Rs.1,35,52,006/- (Sundry Creditors Rs.41,42,506 & Unsecured Loans Bilidevalaya Lakshmi Narasimha Murthy

disallowances made by the AO under section 68 of the Income Tax Act, 1961, and the subsequent taxation at special rates under section 115BBE. The action of the AO appears to be in line in the circumstances of the case as described above.” Unquote. 5.2 Thus, the ld. CIT(A) has dismissed the appeal without adjudicating the grounds, which

GOVIND MILK AND MILK PRODUCTS PVT. LTD. ,PHALTAN vs. INCOME TAX OFFICER, WARD-3, SATARA, SATARA

Bench: Shri Partha Sarathi Chaudhury & Dr. Dipak P. Ripoteआयकर अपील सं. / Ita No.848/Pun/2023 िनधा"रण वष" / Assessment Year : 2016-17 Govind Milk & Milk Products The Income Tax Pvt. Ltd., V Officer, Ward-3, Ganesh Sheri, Pune Pandharpur S Satara. Road, At Post Kolki, Phaltan, Satara, Maharashtra. Pan: Aaacg7588A Appellant/ Assessee Respondent /Revenue Assessee By None. Revenue By Shri R.Y.Balawade – Addl.Cit Date Of Hearing 13/03/2024 Date Of Pronouncement 26/03/2024 आदेश/ Order Per Dr. Dipak P. Ripote, Am: This Appeal Filed By The Assessee Against The Order Of Ld.Commissioner Of Income Tax(Appeals)[Nfac], Passed Under Section 250 Of The Income Tax Act, 1961 Dated 25.05.2023. The Assessee For A.Y.2019-20 Has Raised The Following Grounds Of Appeal : “1. The Ld Cit(A) Erred In Passing Her Order Ex-Parte Without Allowing Appellant Reasonable Opportunity Of Being Heard. 2. The Ld Cit(A) Erred In Upholding The Disallowance Of Rs.43,51,377/- Under Section 40(A)(Ia) Made By The Ld Ao Without Govind Milk & Milk Products Pvt. Ltd., [A]

disallowance of Rs. 13,08,300/- out of expenses made in adhoc manner though the appellant had maintained reasonable records of expenses and the books of account were audited. 5. The above grounds of appeal are without prejudice to one another. 6. The appellant craves leave to furnish Additional Evidence which may be relevant to the above Grounds of Appeal

NINAD ARUN DIWAKAR,NASHIK vs. ITO, ACIT CIRCLE 1, NASHIK, NASHIK

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

Bench: Ms.Astha Chandra & Dr.Dipak P. Ripoteआयकर अपऩल सं. / Ita No.1318/Pun/2025 निर्धारण वषा / Assessment Year: 2022-23 Ninad Arun Diwakar, V The Income Tax Officer, Plot No.F-98, Midc, S Acti Circle-1, Nashik. Satpur Nashik – 422007. Pan: Ahepd7516M Appellant/ Assessee Respondent / Revenue Assessee By Ca Sarang Gudhate Revenue By Shri Ajay Kumar Keshari Date Of Hearing 15/09/2025 Date Of Pronouncement 17/09/2025 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], Delhi Passed Under Section 250 Of The Income Tax Act, 1961 Dated 24.03.2025 For The A.Y.2022-23 Emanating From The Assessment Order Under Section 143(3) Of The Income Tax Act, 1961, Dated 05.03.2024. The Assessee Has Raised The Following Grounds Of Appeal :

disallowing the deduction of Rs.7,97,15,590/- out of the deposit of Rs. 8,00,00,000/- with State Bank of India Nilambar Circle Branch Account No. 41108893383 in Capital Gains Account Scheme, 1988 as per Provision of the Section 54F (4) against the Long Term Capital Gain. ii) That Ld. Assessing officer erred in law and on facts

MYVISHWA TECHNOLOGIES PVT. LTD.,PUNE vs. DYCIT CIRCLE-7, PUNE

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

Bench: Ms.Astha Chandra, Judicialmember & Dr.Dipak P. Ripoteआयकर अपील सं. / Ita No.942/Pun/2025 िनधा"रण वष" / Assessment Year: 2018-19 Myvishwa Technologies Pvt. V The Dy.Commissioner Of Ltd., S Income Tax, Circle-7, Flat No.16, Sawali, Pan Mala, Pune. Off Sinhgad Road, Pune- 411030. Maharashtra. Pan: Aafcm9656E Appellant/ Assessee Respondent / Revenue Assessee By Shri Mahavir Jain – Ar Revenue By Shri Rajesh Haladkar – Addl.Cit(Dr) Date Of Hearing 26/06/2025 Date Of Pronouncement 27/06/2025 आदेश/ Order Per Dr. Dipak P. Ripote, Am: This Appeal Filed By The Assessee Is Directed Against The Order Of Ld.Commissioner Of Income Tax(Appeals)[Nfac] Passed Under Section 250 Of The Income Tax Act, 1961, Dated 07.02.2025 Emanating From The Assessment Order Passed U/S.143(3) Of The Income Tax Act, 1961, For A.Y.2018-19 Dated 24.02.2021. The Assessee Has Raised Following Grounds Of Appeal :

disallowance of depreciation of Rs. 32,04,890/- claimed @ 12.5% (1/2 of 25%) on 'Intangible Asset' u/s. 32 of the Income Tax Act without appreciating that the cost capitalized as Intangible assets in the books was covered as "Intangible Assets" as defined explanation 3 to section 32(1) of the Act. 3.1] The Ld. AO/CIT(A) further erred in upholding

MR. GIRISH KISANDAS MEHTA,PUNE vs. ITO WARD 9 (3), PUNE

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

Bench: Shri R. K. Panda & Shri Vinay Bhamoreआयकर अपील सं. / Ita No.1259/Pun/2025 िनधा"रण वष" / Assessment Year : 2018-19 Mr. Girish Kisandas Mehta, Vs. Ito, Ward-9(3), Pune. Mehta Niwas Bhairavnath Nagar, Kusgaon, Lonavala, Maval, Pune- 410401. Pan : Akepm3983A Appellant Respondent Assessee By : Shri Bhuvanesh Kankani Revenue By Smt. N. C. Shilpa : Date Of Hearing : 17.11.2025 Date Of Pronouncement : 29.12.2025 आदेश / Order Per Vinay Bhamore, Jm: This Appeal Filed By The Assessee Is Directed Against The Order Dated 17.03.2025 Passed By Ld. Cit(A)/Nfac For The Assessment Year 2018-19. 2. The Appellant Has Raised The Following Grounds Of Appeal :- “1. 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 Initiated U/S 147 Of The Act Are Invalid Since The Requisite Approval/Sanction U/S 151(Ii) Of The Act Is Not Taken. Accordingly, The Assessment Proceedings So Initiated Be Kindly Annulled & Appellant Be Granted Just & Proper Relief In This Respect.

disallowance of deduction claimed u/s 80C of the IT Act. 4 4. Being aggrieved with the above assessment order, the assessee preferred an appeal before Ld. CIT(A)/NFAC raising only grounds on merits. Since the assessee remained absent, Ld. CIT(A)/NFAC dismissed the appeal filed by the assessee. 5. It is the above ex-parte order passed

PRAVIN PRAKASHCHAND MEHTA,PUNE vs. INCOME TAX OFFICER, WARD 8(3), PUNE, PUNE

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

Bench: Ms.Astha Chandra & Dr.Dipak P. Ripoteआयकर अपऩल सं. / Ita No.475/Pun/2024 निर्धारण वषा / Assessment Year: 2016-17 Pravin Prakashchand Mehta, V The Income Tax Officer, B 10, Pati Regency, S Ward-8(3), Pune. Erandwane, Pune – 411004. Pan: Aavpm4448H Appellant/ Assessee Respondent / Revenue Assessee By Ms Sampada Ingale (Virtual) On Behalf Of Shri Suhas P. Bora – Ar Revenue By Shri Sandeep P Sathe – Jcit Date Of Hearing 06/10/2025 Date Of Pronouncement 31/10/2025 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 A.Y.2016-17 Dated 11.01.2024 Emanating From The Assessment Order Under Section 143(1) Of The Income Tax Act, 1961 Dated 08.03.2017. The Grounds Of Appeal Raised By The Assessee Are As Under :

disallowance of set off of loss is bad in law in the light of the fact that the appellant has made application u/s 119(2) to the Pr. CCIT, to extend the due date for filing of return of income for A.Y. 2016-17 due to genuine hardships preventing the appellant from filing the return of income in time