ALLIED RESOURCE MANAGEMENT SERVICES ASPIRE PRIVATE LIMITED,PUNE vs. DEPUTY COMMISSIONER OF INCOME-TAX, CPC), BANGALORE

Bench: Hon’Ble Shri S. S. Godara & Shri G. D. Padmahshaliasstt. Assessee’S Departmental Sr

36(1)(va) obliging to all earlier years as well for the assessments completed u/s 143(3) of the Act, however, accentuated the fact that the instant batch of appeals involves the disallowance made u/s 143(1) ITAT-Pune Page 11 of 24 M/s Kothari Agritech Pvt. Ltd & Others ITA No. 320/PUN/2022 & Others of the Act. It was argued that

M/S KOTHARI AGRITECH P LTD,SOLAPUR vs. ASSISTANT DIRECTOR OF INCOME-TAX, CPC, BENGALURU

Bench: Hon’Ble Shri S. S. Godara & Shri G. D. Padmahshaliasstt. Assessee’S Departmental Sr

36(1)(va) obliging to all earlier years as well for the assessments completed u/s 143(3) of the Act, however, accentuated the fact that the instant batch of appeals involves the disallowance made u/s 143(1) ITAT-Pune Page 11 of 24 M/s Kothari Agritech Pvt. Ltd & Others ITA No. 320/PUN/2022 & Others of the Act. It was argued that

MR HARISCHANDRA DHARAMNATH PANDEY,NASHIK vs. ADDITIONAL DIRECTOR OF INCOME TAX (CPC), BENGALURU, BENGALURU

Bench: Hon’Ble Shri S. S. Godara & Shri G. D. Padmahshaliasstt. Assessee’S Departmental Sr

36(1)(va) obliging to all earlier years as well for the assessments completed u/s 143(3) of the Act, however, accentuated the fact that the instant batch of appeals involves the disallowance made u/s 143(1) ITAT-Pune Page 11 of 24 M/s Kothari Agritech Pvt. Ltd & Others ITA No. 320/PUN/2022 & Others of the Act. It was argued that

DWARKADHISH SAKHAR KARKHANA LTD,,NASHIK vs. ASSISTANT DIRECTOR OF INCOME TAX, CPC, BENGALURU

Bench: Hon’Ble Shri S. S. Godara & Shri G. D. Padmahshaliasstt. Assessee’S Departmental Sr

36(1)(va) obliging to all earlier years as well for the assessments completed u/s 143(3) of the Act, however, accentuated the fact that the instant batch of appeals involves the disallowance made u/s 143(1) ITAT-Pune Page 11 of 24 M/s Kothari Agritech Pvt. Ltd & Others ITA No. 320/PUN/2022 & Others of the Act. It was argued that

CLOVER INFOTECH P LTD,PUNE vs. DEPUTY COMMISSIONER OF INCOME-TAX, CPC, BENGALURU

Bench: Hon’Ble Shri S. S. Godara & Shri G. D. Padmahshaliasstt. Assessee’S Departmental Sr

36(1)(va) obliging to all earlier years as well for the assessments completed u/s 143(3) of the Act, however, accentuated the fact that the instant batch of appeals involves the disallowance made u/s 143(1) ITAT-Pune Page 11 of 24 M/s Kothari Agritech Pvt. Ltd & Others ITA No. 320/PUN/2022 & Others of the Act. It was argued that

ALLIED RESOURCE MANAGEMENT SERVICES ASPIRE PRIVATE LIMITED,PUNE vs. ASST. DIRECTOR OF INCOME TAX, (CPC), BANGALORE

Bench: Hon’Ble Shri S. S. Godara & Shri G. D. Padmahshaliasstt. Assessee’S Departmental Sr

36(1)(va) obliging to all earlier years as well for the assessments completed u/s 143(3) of the Act, however, accentuated the fact that the instant batch of appeals involves the disallowance made u/s 143(1) ITAT-Pune Page 11 of 24 M/s Kothari Agritech Pvt. Ltd & Others ITA No. 320/PUN/2022 & Others of the Act. It was argued that

GOVINDSINGH BALRAJSINGH JADOUN,NASHIK vs. ASSISTANTDIRECTOR OF INCOME-TAX, CPC, BANGALORE

Bench: Hon’Ble Shri S. S. Godara & Shri G. D. Padmahshaliasstt. Assessee’S Departmental Sr

36(1)(va) obliging to all earlier years as well for the assessments completed u/s 143(3) of the Act, however, accentuated the fact that the instant batch of appeals involves the disallowance made u/s 143(1) ITAT-Pune Page 11 of 24 M/s Kothari Agritech Pvt. Ltd & Others ITA No. 320/PUN/2022 & Others of the Act. It was argued that

MR MADAN SITARAM KARANDE,ICHALKARANJI vs. ASSISTANT DIRECTOR OF INCOME-TAX, CPC, BENGALURU

Bench: Hon’Ble Shri S. S. Godara & Shri G. D. Padmahshaliasstt. Assessee’S Departmental Sr

36(1)(va) obliging to all earlier years as well for the assessments completed u/s 143(3) of the Act, however, accentuated the fact that the instant batch of appeals involves the disallowance made u/s 143(1) ITAT-Pune Page 11 of 24 M/s Kothari Agritech Pvt. Ltd & Others ITA No. 320/PUN/2022 & Others of the Act. It was argued that

MR HARISCHANDRA DHARAMNATH PANDEY,NASHIK vs. ADDITIONAL DIRECTOR OF INCOME TAX (CPC), BENGALURU, BENGALURU

Bench: Hon’Ble Shri S. S. Godara & Shri G. D. Padmahshaliasstt. Assessee’S Departmental Sr

36(1)(va) obliging to all earlier years as well for the assessments completed u/s 143(3) of the Act, however, accentuated the fact that the instant batch of appeals involves the disallowance made u/s 143(1) ITAT-Pune Page 11 of 24 M/s Kothari Agritech Pvt. Ltd & Others ITA No. 320/PUN/2022 & Others of the Act. It was argued that

GLOBEFLEX RESEARCH I P LTD., ,PUNE vs. ASSISTANT DIRECTOR OF INCOME-TAX, CPC, BENGALURU

Bench: Hon’Ble Shri S. S. Godara & Shri G. D. Padmahshaliasstt. Assessee’S Departmental Sr

36(1)(va) obliging to all earlier years as well for the assessments completed u/s 143(3) of the Act, however, accentuated the fact that the instant batch of appeals involves the disallowance made u/s 143(1) ITAT-Pune Page 11 of 24 M/s Kothari Agritech Pvt. Ltd & Others ITA No. 320/PUN/2022 & Others of the Act. It was argued that

HILARY VAZ,PUNE vs. DCIT, CPC,BENGALORE, BENGALORE

Bench: Hon’Ble Shri S. S. Godara & Shri G. D. Padmahshaliasstt. Assessee’S Departmental Sr

36(1)(va) obliging to all earlier years as well for the assessments completed u/s 143(3) of the Act, however, accentuated the fact that the instant batch of appeals involves the disallowance made u/s 143(1) ITAT-Pune Page 11 of 24 M/s Kothari Agritech Pvt. Ltd & Others ITA No. 320/PUN/2022 & Others of the Act. It was argued that

DEPUTY COMMISSIONER OF INCOME-TAX,, PUNE vs. M/S. SECO TOOLS INDIA PVT. LTD.,, PUNE

In the result, the Cross Objections of assessee are allowed and appeals of Revenue are dismissed

Bench: Ms. Sushma Chowla, Jm & Shri Anil Chaturvedi, Am आयकर अपीऱ सं. / Ita Nos.812 & 813/Pun/2017 यििाारण वषा / Assessment Years : 2002-03 & 2003-04

36(1)(iii) of the Income-tax Act, 1961, on the facts and circumstances of the case, and in law, the Ld. CIT(A) has erred in confirming the action of the Learned Assessing Officer [„Ld.AO‟] in reopening the assessment proceedings without any „reason to believe‟ as required by the provisions of section 147. It is prayed that the reassessment

M/S. SHIVAMM INDUSTRIES,PUNE vs. THE DEPUTY COMMISSIONER OF INCOME TAX, CIRCLE-8, PUNE

In the result, appeal of the Assessee is Dismissed

Bench: Shri S.S.Godara & Dr. Dipak P. Ripoteआयकरअपीलसं. / Ita No.393/Pun/2023 िनधा"रणवष" / Assessment Year : 2013-14 M/S.Shivamm Industries, The Dy.Commissioner Of Plot 76, Arihant Heights, Sector Vs Income Tax, Circle-8, No.25, Pradhikaran Nigdi, Pune. Pune – 411044. Pan: Aaefs 0458 A Appellant/ Assessee Respondent /Revenue Assessee By None. Revenue By Shri M.G.Jasnani – Dr Date Of Hearing 15/05/2023 Date Of Pronouncement 26/05/2023 आदेश/ Order Per Dr. Dipak P. Ripote, Am: This Is An Appeal Filed By The Assessee I.E. Shivamm Industries For A.Y. 2013-14 Against The Order Of Ld.Commissioner Of Income Of Tax(Appeals)[Nfac] Dated 21.03.2023 Emanating From Assessing Officer’S Order Under Section 154 Of The Act Dated 22.03.2021. The Ground Of Appeal Are As Under : “1. The Order Dated 21/03/2023 Bearing No.Itba/Nfac/S/250/2022-23/1051048828[L] Passed Under Section 250 Of Income Tax Act, 1961 By The Hon’Ble Cit[Appeals], National Faceless Appeal Centre [Nfac], Delhi, Is Excessive, M/S.Shivamm Industries [A]

36(1). 12 M/s.Shivamm Industries [A] 11. The second issue we need to consider is can AO invoke provisions of section 154? 11.1 We have already held that the law declared by the Hon’ble Supreme Court is applicable from the date of inception of the relevant section. Therefore, now it is a legal fiction that when the AO invoked

DEEPAK EKNATH FULAMBRIKAR,JALNA vs. INCOME-TAX OFFICER WARD -1, JALNA

In the result, all appeals of different assessees are dismissed

Bench: Shri Inturi Rama Rao & Shri Partha Sarathi Chaudhury

V. Deshpande 4. Shri Shri C.H. Naniwadekar 5. Mrs. J.R. Chandekar 6. Shri Abhay Avchat 7 & 8 : None 9 & 10 : Shri Sanket Joshi 11. Shri S.N. Puranik Respondents : Shri Ramnath P. Murkunde Date of Hearing : 29-11-2022 Date of Pronouncement : 29-11-2022 ORDER PER PARTHA SARATHI CHAUDHURY, JUDICIAL MEMBER These appeals preferred by different assessees emanates from respective

MANJUSHA ANIL LODHA L/H OF LATE SHRI ANIL BANSILAL LODHA,NASHIK vs. DEPUTY COMMISSIONER OF INCOME-TAX, CPC, BENGALURU

In the result, all appeals of different assessees are dismissed

Bench: Shri Inturi Rama Rao & Shri Partha Sarathi Chaudhury

V. Deshpande 4. Shri Shri C.H. Naniwadekar 5. Mrs. J.R. Chandekar 6. Shri Abhay Avchat 7 & 8 : None 9 & 10 : Shri Sanket Joshi 11. Shri S.N. Puranik Respondents : Shri Ramnath P. Murkunde Date of Hearing : 29-11-2022 Date of Pronouncement : 29-11-2022 ORDER PER PARTHA SARATHI CHAUDHURY, JUDICIAL MEMBER These appeals preferred by different assessees emanates from respective

ARUN POPAT KUSALKAR,PUNE vs. DEPUTY COMMISSIONER OF INCOME-TAX, CPC, BANGALURU

In the result, all appeals of different assessees are dismissed

Bench: Shri Inturi Rama Rao & Shri Partha Sarathi Chaudhury

V. Deshpande 4. Shri Shri C.H. Naniwadekar 5. Mrs. J.R. Chandekar 6. Shri Abhay Avchat 7 & 8 : None 9 & 10 : Shri Sanket Joshi 11. Shri S.N. Puranik Respondents : Shri Ramnath P. Murkunde Date of Hearing : 29-11-2022 Date of Pronouncement : 29-11-2022 ORDER PER PARTHA SARATHI CHAUDHURY, JUDICIAL MEMBER These appeals preferred by different assessees emanates from respective

JAMUNA INFRAPROJECTS P LTD,NASHIK vs. ASSISTANT COMMISSIONER OF INCOME-TAX, CIRCLE -1, NASHIK

In the result, all appeals of different assessees are dismissed

Bench: Shri Inturi Rama Rao & Shri Partha Sarathi Chaudhury

V. Deshpande 4. Shri Shri C.H. Naniwadekar 5. Mrs. J.R. Chandekar 6. Shri Abhay Avchat 7 & 8 : None 9 & 10 : Shri Sanket Joshi 11. Shri S.N. Puranik Respondents : Shri Ramnath P. Murkunde Date of Hearing : 29-11-2022 Date of Pronouncement : 29-11-2022 ORDER PER PARTHA SARATHI CHAUDHURY, JUDICIAL MEMBER These appeals preferred by different assessees emanates from respective

ANUJA SANJAY MAHAJAN,KOLHAPUR vs. DEPUTY COMMISSIONER OF INCOME-TAX, CPC, , BENGALURU

In the result, all appeals of different assessees are dismissed

Bench: Shri Inturi Rama Rao & Shri Partha Sarathi Chaudhury

V. Deshpande 4. Shri Shri C.H. Naniwadekar 5. Mrs. J.R. Chandekar 6. Shri Abhay Avchat 7 & 8 : None 9 & 10 : Shri Sanket Joshi 11. Shri S.N. Puranik Respondents : Shri Ramnath P. Murkunde Date of Hearing : 29-11-2022 Date of Pronouncement : 29-11-2022 ORDER PER PARTHA SARATHI CHAUDHURY, JUDICIAL MEMBER These appeals preferred by different assessees emanates from respective

MILLENNIUM ENGINEERS AND CONTRACTORS LTD,PUNE vs. DEPUTY COMMISSIONER OF INCOME-TAX, CENTRAL CIRCLE 1(3), , PUNE

In the result, all appeals of different assessees are dismissed

Bench: Shri Inturi Rama Rao & Shri Partha Sarathi Chaudhury

V. Deshpande 4. Shri Shri C.H. Naniwadekar 5. Mrs. J.R. Chandekar 6. Shri Abhay Avchat 7 & 8 : None 9 & 10 : Shri Sanket Joshi 11. Shri S.N. Puranik Respondents : Shri Ramnath P. Murkunde Date of Hearing : 29-11-2022 Date of Pronouncement : 29-11-2022 ORDER PER PARTHA SARATHI CHAUDHURY, JUDICIAL MEMBER These appeals preferred by different assessees emanates from respective