AUTOCOMP CORPORATION PANSE PRIVATE LIMITED ,PUNE vs. ASST. COMMISSIONER OF INCOME TAX, CIRCLE 1(1), PUNE

In the result, both the appeals filed by the assessee are allowed for statistical purposes

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

condone the delay in filing the appeal, an empathetic humane view of the matter ought to have been adopted. 2. The learned CIT(A) erred in not deciding the appeal on merits further erred in not appreciating and considering all the issues emanating from the order of the AO passed under section 147 read with section 144B. It is prayed

AUTOCOMP CORPORATION PANSE PRIVATE LIMITED ,PUNE vs. ASST. COMMISSIONER OF INCOME TAX, PUNE

In the result, both the appeals filed by the assessee are allowed for statistical purposes

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

condone the delay in filing the appeal, an empathetic humane view of the matter ought to have been adopted. 2. The learned CIT(A) erred in not deciding the appeal on merits further erred in not appreciating and considering all the issues emanating from the order of the AO passed under section 147 read with section 144B. It is prayed

DEPUTY COMMISSIONER OF INCOME-TAX vs. THE JAWAHARLAL NEHRU PORT TRUST,, RAIGAD

In the result, all the three appeals filed by the Revenue are dismissed and all the three appeals filed by the assessee are partly allowed

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

condone the delay for 'accepting the auditor's report at a later date has only been given to the Income-tax Officer and not thereafter, i.e., at the appellate stage. We find no merit in this submission. The Central Board of Direct Taxes by issuing the circular dated February 9, 1978, has treated the provisions regarding furnishing of the auditor

DEPUTY COMMISSIONER OF INCOME-TAX vs. THE JAWAHARLAL NEHRU PORT TRUST,, RAIGAD

In the result, all the three appeals filed by the Revenue are dismissed and all the three appeals filed by the assessee are partly allowed

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

condone the delay for 'accepting the auditor's report at a later date has only been given to the Income-tax Officer and not thereafter, i.e., at the appellate stage. We find no merit in this submission. The Central Board of Direct Taxes by issuing the circular dated February 9, 1978, has treated the provisions regarding furnishing of the auditor

JAWAHAR LAL NEHRU PORT TRUST,NAVI MUMBAI vs. ACIT PANVEL, PANVEL

In the result, all the three appeals filed by the Revenue are dismissed and all the three appeals filed by the assessee are partly allowed

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

condone the delay for 'accepting the auditor's report at a later date has only been given to the Income-tax Officer and not thereafter, i.e., at the appellate stage. We find no merit in this submission. The Central Board of Direct Taxes by issuing the circular dated February 9, 1978, has treated the provisions regarding furnishing of the auditor

JAWAHAR LAL NEHRU PORT TRUST,NAVI MUMBAI vs. ACIT PANVEL, PANVEL

In the result, all the three appeals filed by the Revenue are dismissed and all the three appeals filed by the assessee are partly allowed

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

condone the delay for 'accepting the auditor's report at a later date has only been given to the Income-tax Officer and not thereafter, i.e., at the appellate stage. We find no merit in this submission. The Central Board of Direct Taxes by issuing the circular dated February 9, 1978, has treated the provisions regarding furnishing of the auditor

JAWAHAR LAL NEHRU PORT TRUST,NAVI MUMBAI vs. ACIT PANVEL, PANVEL

In the result, all the three appeals filed by the Revenue are dismissed and all the three appeals filed by the assessee are partly allowed

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

condone the delay for 'accepting the auditor's report at a later date has only been given to the Income-tax Officer and not thereafter, i.e., at the appellate stage. We find no merit in this submission. The Central Board of Direct Taxes by issuing the circular dated February 9, 1978, has treated the provisions regarding furnishing of the auditor

DEPUTY COMMISSIONER OF INCOME-TAX vs. THE JAWAHARLAL NEHRU PORT TRUST,, RAIGAD

In the result, all the three appeals filed by the Revenue are dismissed and all the three appeals filed by the assessee are partly allowed

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

condone the delay for 'accepting the auditor's report at a later date has only been given to the Income-tax Officer and not thereafter, i.e., at the appellate stage. We find no merit in this submission. The Central Board of Direct Taxes by issuing the circular dated February 9, 1978, has treated the provisions regarding furnishing of the auditor

VIJAYMALA VILAS KALOKHE,PUNE vs. ITO WARD-10(1), PUNE

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.1666/Pun/2025 धििाारण वर्ा / Assessment Year : 2013-14 Vijaymala Vilas Kalokhe, Ito, Ward-10(1), Pune Aditya Row House, Lane No. 2, Opp. Patel Garden, Sr. No. 8/2A, Vs. Juni Sangavi, Maharashtra-411027 Pan : Asepk8161G अपीलार्थी / Appellant प्रत्यर्थी / Respondent Assessee By : Shri Kishor B Phadke Department By : Shri Amit Bobde Date Of Hearing : 28-01-2026 Date Of 30-01-2026 Pronouncement : आदेश / Order Per Astha Chandra, Jm : The Appeal Filed By The Assessee Is Directed Against The Order Dated 17.06.2025 Of The Ld. Commissioner Of Income Tax (Appeals)/Nfac, Delhi [“Cit(A)/Nfac”] Pertaining To Assessment Year (“Ay”) 2013-14. 2. Briefly Stated The Facts Are That The Assessee Is An Individual. He Filed His Return Of Income For Ay 2013-14 Declaring Total Income Of Rs.2,21,050/-. The Case Of The Assessee Was Reopened U/S 147 Of The Income Tax Act, 1961 (The “Act”) After Following The Mandate Procedure As Laid Down Under The Relevant Provisions Of The Act. Accordingly, Statutory Notice U/S 142(1) Of The Act & Show Cause Letter(S) Were Issued To The Assessee From Time To Time. However, The Assessee Failed To File Any Response To The Said Notice(S) Which Constrained The Ld. Assessing Officer (“Ao”) To Pass An Ex-Parte Order U/S 144 Of The Act Based On The Material Available On Record. The Ld. Ao Proceeded To Complete The Assessment On Total Income Of Rs.2,66,70,989/-U/S 147 R.W.S. 144 Of The Act Thereby Making An Addition Of Rs.2,63,83,209/- On Account Of Undisclosed Long Term Capital Gain (Ltcg) By Observing As Under : “5.1. On-Going Through The Information Available On Record & In View Of The Order Passed U/S 148A(D) Of The Act Dated 21.07.2022, It Is Noticed That 2

condoned the genuine delay of 136 days 3 ITA No.1666/PUN/2025, AY 2013-14 caused as the appellant was completely unaware of the present proceeding, and the present situation is simply a fall-out of a communication gap. 5. The learned AO and CIT(A), NAFC erred in law in issuing an order u/s 147 r.w.s 144 r.wis

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 :

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 solely based on information from the insight portal and bank statements, without corroborative evidence. 7. Without prejudice if at all addition is warranted, it should be based on peak credit theory rather than

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 :

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 solely based on information from the insight portal and bank statements, without corroborative evidence. 7. Without prejudice if at all addition is warranted, it should be based on peak credit theory rather than

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 :

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 solely based on information from the insight portal and bank statements, without corroborative evidence. 7. Without prejudice if at all addition is warranted, it should be based on peak credit theory rather than

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 :

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 solely based on information from the insight portal and bank statements, without corroborative evidence. 7. Without prejudice if at all addition is warranted, it should be based on peak credit theory rather than

KALPANA PRAKASH KALE,PUNE vs. ITO WARD 6(5), PUNE

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

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

condoning the delay when there was sufficient cause beyond the control of the assessee. 2. Whether on facts and in circumstances of the case, the impugned reassessment

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

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.

delay to filing the Appeal should not be condoned especially when he had dealt with all the issues in Appellate Order. 3. The learned CIT has erred both in facts and in law in not dealing with other issues on merits. 4. The Assessment order passed u/s 147 r.w.s

DILIPCHAND SOBHAGCHAND CHOPDA,LATUR vs. ITO, WARD-1, LATUR, LATUR

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

Bench: Shri Rama Kanta Panda, Vice- & Ms. Astha Chandra

reassessment order ex-parte on account of assessee’s failure to comply with the statutory notice(s)/ letter issued by him from time to time. The Ld. CIT(A) has not condoned the delay

MANJU MADHUSUDAN DHOOT L/H OF LATE MADHUSUDAN DHOOT,AHMEDNAGAR vs. ITO WARD 1, AHMEDNAGAR

In the result, both the appeals of the assessee are partly allowed

Bench: Dr.Manish Boradआयकर अपील सं. / Ita Nos.1919 & 1920/Pun/2024 "नधा"रण वष" / Assessment Years : 2007-08 & 2009-10

condone the delay in filing the instant appeals and proceed for adjudication on merits. 6. I first take up the appeal for A.Y. 2007-08. Grounds of appeal raised by assessee in ITA No.1919/PUN/2024 read as under: “The following grounds are taken without prejudice to each other - On facts and in law, 1] The Ld. CIT(A) erred in holding

MANJU MADHUSUDAN DHOOT, L/H OF LATE MADHUSUDAN DHOOT,AHMEDNAGAR vs. ITO, WARD 1, AHMEDNAGAR

In the result, both the appeals of the assessee are partly allowed

Bench: Dr.Manish Boradआयकर अपील सं. / Ita Nos.1919 & 1920/Pun/2024 "नधा"रण वष" / Assessment Years : 2007-08 & 2009-10

condone the delay in filing the instant appeals and proceed for adjudication on merits. 6. I first take up the appeal for A.Y. 2007-08. Grounds of appeal raised by assessee in ITA No.1919/PUN/2024 read as under: “The following grounds are taken without prejudice to each other - On facts and in law, 1] The Ld. CIT(A) erred in holding

ULKA MADHUKAR SHINDE,PANVEL vs. ASSISTANT COMMISSIONER OF INCOME TAX PANVEL, PANVEL

In the result, the appeal of the assessee is allowed for statistical\npurposes

condone the delay in filing of the appeal and\nadmit the same for adjudication.\n3. The assessee has raised the following grounds of appeal :\n“1.\nThe Ld AO relied on the information of AIR regarding cash deposit of\nRs.11,00,000/- in ShyamraoVithal Co-op Bank Ltd. Mumbai, but has\nno tangible reliable material of the same