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664 results for “reassessment”+ Section 10(1)clear

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Key Topics

Section 148194Section 147117Addition to Income73Section 25051Reassessment50Section 143(3)43Section 148A37Section 6829Section 270A28Reopening of Assessment

DEPUTY DIRECTOR OF INCOME-TAX,, PUNE vs. SANDVIK A B.,, PUNE

ITA 623/PUN/2014[2005-06]Status: DisposedITAT Pune05 Jun 2018AY 2005-06

Bench: Ms. Sushma Chowla, Jm & Shri D. Karunakara Rao, Am आयकर अपीऱ सं. / Ita No.608/Pun/2014 यििाारण वषा / Assessment Year :2006-07

For Appellant: S/Shri Nikhil Pathak & S. SrinivasFor Respondent: S/Shri Rajeev Kumar, CIT & Ajay Modi, JCIT
Section 143(3)Section 144C(13)Section 148Section 151(2)

10. The assessee is in appeal against the said exercise of jurisdiction by the Assessing Officer under section 147 of the Act. The first plea which has been raised by the assessee is that in the absence of any tangible material for reason to believe that there is escapement of income, the action adopted by the Assessing Officer was without

DEPUTY DIRECTOR OF INCOME-TAX vs. SANDVIK A B.,, PUNE

Showing 1–20 of 664 · Page 1 of 34

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Section 15127
Deduction24
ITA 608/PUN/2014[2006-07]Status: DisposedITAT Pune05 Jun 2018AY 2006-07

Bench: Ms. Sushma Chowla, Jm & Shri D. Karunakara Rao, Am आयकर अपीऱ सं. / Ita No.608/Pun/2014 यििाारण वषा / Assessment Year :2006-07

For Appellant: S/Shri Nikhil Pathak & S. SrinivasFor Respondent: S/Shri Rajeev Kumar, CIT & Ajay Modi, JCIT
Section 143(3)Section 144C(13)Section 148Section 151(2)

10. The assessee is in appeal against the said exercise of jurisdiction by the Assessing Officer under section 147 of the Act. The first plea which has been raised by the assessee is that in the absence of any tangible material for reason to believe that there is escapement of income, the action adopted by the Assessing Officer was without

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

ITA 813/PUN/2017[2003-04]Status: DisposedITAT Pune01 Aug 2019AY 2003-04

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

For Appellant: Shri Nikhil PathakFor Respondent: Shri Sudhendu Das
Section 143(1)Section 143(3)Section 147Section 148Section 36(1)(iii)

reassessment proceedings initiated are invalid and void and hence be quashed. 3. The learned Departmental Representative for the Revenue fairly pointed out ‘yes’ that the issue raised in Cross Objections is against reopening of assessment under section 147 of the Act. 4. The learned Authorized Representative for the assessee took us through factual aspects of the case and pointed

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

10. Aggrieved with such order of the Ld. CIT(A) / NFAC the Revenue is in appeal before the Tribunal by raising the following grounds: 1. Whether on the facts and circumstances of the case and in law, the Hon'ble CIT(A) was justified in deleting the addition of Rs.1,61,00,000/- made on account of unsecured loan

JOSHI WADEWALE SHEWALWADI,,PUNE vs. DEPUTY COMMISSIONER OF INCOME-TAX,,

In the result, appeals in the case of Mrs

ITA 100/PUN/2016[2010-11]Status: DisposedITAT Pune27 Mar 2018AY 2010-11

Bench: Ms. Sushma Chowla, Jm & Shri D. Karunakara Rao, Am आयकर अपीऱ सं. / Ita Nos.95 & 96/Pun/2016 यििाारण वषा / Assessment Years : 2009-10 & 2010-11

For Appellant: S/Shri Nikhil Pathak /For Respondent: Shri Hitendra Ninawe
Section 250Section 271(1)(c)

10 I confirm that these are seized from my residence at 64 & 65, Durga Apartments, Mahalaxmi Nagar, Bibwewadi, Pune. These pages are the daily receipt and expenses account from different outlets. The total made on these pages represent the gross sales on that day of that outlet. ‗Ghari‘, ‗Cash‘ represent the net amount of cash handed over

MRS. VASUNDHARA SHAILESH JOSHI,,PUNE vs. DEPUTY COMMISSIONER OF INCOME-TAX,,

In the result, appeals in the case of Mrs

ITA 96/PUN/2016[2010-11]Status: DisposedITAT Pune27 Mar 2018AY 2010-11

Bench: Ms. Sushma Chowla, Jm & Shri D. Karunakara Rao, Am आयकर अपीऱ सं. / Ita Nos.95 & 96/Pun/2016 यििाारण वषा / Assessment Years : 2009-10 & 2010-11

For Appellant: S/Shri Nikhil Pathak /For Respondent: Shri Hitendra Ninawe
Section 250Section 271(1)(c)

10 I confirm that these are seized from my residence at 64 & 65, Durga Apartments, Mahalaxmi Nagar, Bibwewadi, Pune. These pages are the daily receipt and expenses account from different outlets. The total made on these pages represent the gross sales on that day of that outlet. ‗Ghari‘, ‗Cash‘ represent the net amount of cash handed over

JOSHI WADEWALE SHEWALWADI,,PUNE vs. DEPUTY COMMISSIONER OF INCOME-TAX,,

In the result, appeals in the case of Mrs

ITA 99/PUN/2016[2009-10]Status: DisposedITAT Pune27 Mar 2018AY 2009-10

Bench: Ms. Sushma Chowla, Jm & Shri D. Karunakara Rao, Am आयकर अपीऱ सं. / Ita Nos.95 & 96/Pun/2016 यििाारण वषा / Assessment Years : 2009-10 & 2010-11

For Appellant: S/Shri Nikhil Pathak /For Respondent: Shri Hitendra Ninawe
Section 250Section 271(1)(c)

10 I confirm that these are seized from my residence at 64 & 65, Durga Apartments, Mahalaxmi Nagar, Bibwewadi, Pune. These pages are the daily receipt and expenses account from different outlets. The total made on these pages represent the gross sales on that day of that outlet. ‗Ghari‘, ‗Cash‘ represent the net amount of cash handed over

MRS. VASUNDHARA SHAILESH JOSHI,,PUNE vs. DEPUTY COMMISSIONER OF INCOME-TAX,,

In the result, appeals in the case of Mrs

ITA 95/PUN/2016[2009-10]Status: DisposedITAT Pune27 Mar 2018AY 2009-10

Bench: Ms. Sushma Chowla, Jm & Shri D. Karunakara Rao, Am आयकर अपीऱ सं. / Ita Nos.95 & 96/Pun/2016 यििाारण वषा / Assessment Years : 2009-10 & 2010-11

For Appellant: S/Shri Nikhil Pathak /For Respondent: Shri Hitendra Ninawe
Section 250Section 271(1)(c)

10 I confirm that these are seized from my residence at 64 & 65, Durga Apartments, Mahalaxmi Nagar, Bibwewadi, Pune. These pages are the daily receipt and expenses account from different outlets. The total made on these pages represent the gross sales on that day of that outlet. ‗Ghari‘, ‗Cash‘ represent the net amount of cash handed over

JOSHI WADEWALE PRABHAT CINEMA,,PUNE vs. DEPUTY COMMISSIONER OF INCOME-TAX,,

In the result, appeals in the case of Mrs

ITA 102/PUN/2016[2010-11]Status: DisposedITAT Pune27 Mar 2018AY 2010-11

Bench: Ms. Sushma Chowla, Jm & Shri D. Karunakara Rao, Am आयकर अपीऱ सं. / Ita Nos.95 & 96/Pun/2016 यििाारण वषा / Assessment Years : 2009-10 & 2010-11

For Appellant: S/Shri Nikhil Pathak /For Respondent: Shri Hitendra Ninawe
Section 250Section 271(1)(c)

10 I confirm that these are seized from my residence at 64 & 65, Durga Apartments, Mahalaxmi Nagar, Bibwewadi, Pune. These pages are the daily receipt and expenses account from different outlets. The total made on these pages represent the gross sales on that day of that outlet. ‗Ghari‘, ‗Cash‘ represent the net amount of cash handed over

JOSHI WADEWALE HADAPSAR,,PUNE vs. DEPUTY COMMISSIONER OF INCOME-TAX,,

In the result, appeals in the case of Mrs

ITA 105/PUN/2016[2010-11]Status: DisposedITAT Pune27 Mar 2018AY 2010-11

Bench: Ms. Sushma Chowla, Jm & Shri D. Karunakara Rao, Am आयकर अपीऱ सं. / Ita Nos.95 & 96/Pun/2016 यििाारण वषा / Assessment Years : 2009-10 & 2010-11

For Appellant: S/Shri Nikhil Pathak /For Respondent: Shri Hitendra Ninawe
Section 250Section 271(1)(c)

10 I confirm that these are seized from my residence at 64 & 65, Durga Apartments, Mahalaxmi Nagar, Bibwewadi, Pune. These pages are the daily receipt and expenses account from different outlets. The total made on these pages represent the gross sales on that day of that outlet. ‗Ghari‘, ‗Cash‘ represent the net amount of cash handed over

CAPGEMINI TECHNOLOGY SERVICES INDIA LIMITED ( SUCCESSOR OF ARICENT TECHNOLOGIES HOLDINGS LIMITED),PUNE vs. ASSISTANT COMMISSIONER OF INCOME TAX, CIRCLE 1(1), PUNE, PUNE

In the result, the appeal of the assessee is allowed

ITA 1260/PUN/2025[2020-21]Status: DisposedITAT Pune24 Nov 2025AY 2020-21

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

For Appellant: Shri Vyomesh PathakFor Respondent: Shri Vidya Ratna Kishore
Section 143(3)Section 154Section 155(18)Section 270ASection 270A(2)Section 270A(6)(a)Section 270A(7)Section 270A(8)Section 270A(9)

reassessment, referred to in clause (a) of sub-section (1), in a case where an order under sub- section (4) has been made accepting the application." 20. Sub-section (18) of Section 155 of the Income Tax Act is inserted vide Finance Act, 2022 w.e.f. 01.04.2022. The above referred provisions provide that deduction of any surcharge, cess, which

SACHIN MOHANLAL CHORDIA,PUNE vs. INCOME TAX OFFICER WARD 5(1), PUNE

Appeal of the assessee is partly allowed as we do not intend to adjudicate other grounds raised by the assessee

ITA 3281/PUN/2025[2017-18]Status: DisposedITAT Pune30 Mar 2026AY 2017-18

Bench: Ms. Astha Chandra & Dr. Dipak P. Ripoteआयकर अपील सं. / Ita Nos.3280 & 3281/Pun/2025 िनधा"रण वष" / Assessment Years: 2016-17 & 2017-18 Sachin Mohanlal Chordia, V The Income Tax Officer, B-101, Isha Emerald, S. Ward-5(1), Pune. Bibwewdi, Kondhwa Road, Marketyard, Pune- 411037. Pan: Aanpc8554C Appellant Respondent Assessee By Shri Abhilash Hiran Revenue By Shri Amit Bobade & Shri Sanjay Dhivare (Virtual) Date Of Hearing 05/03/2026 Date Of Pronouncement 30/03/2026 आदेश/ Order Per Bench : These Are Two Appeals Filed By Assessee Against The Separate Orders Of Commissioner Of Income Tax (Appeal) (Nfac) U/S 250 Of The Income Tax Act 1961 For Ay 2016-17, 2017-18 Passed On 22/10/2025 Emanating From Separate Assessment Orders U/S 147 Rws 144 Dated 11/05/2023 & 23/05/2023. 2. The Grounds Of Appeal Raised By The Assessee Are As Under:

Section 139Section 147Section 148Section 148ASection 151Section 151oSection 250

reassessment notices are to be dealt with as under: (i) AY 2013-14, AY 2014-15 and AY 2015- 16: Fresh notice under section 148 of the Act can be issued in these cases, with the approval of the specified authority, only if the case falls under clause (b) of sub-section (1) of section 149 as amended

SACHIN MOHANLAL CHORDIA,PUNE vs. INCOME TAX OFFICER WARD 5(1), PUNE

Appeal of the assessee is partly allowed as we do not intend to adjudicate other grounds raised by the assessee

ITA 3280/PUN/2025[2017-18]Status: DisposedITAT Pune30 Mar 2026AY 2017-18

Bench: Ms. Astha Chandra & Dr. Dipak P. Ripoteआयकर अपील सं. / Ita Nos.3280 & 3281/Pun/2025 िनधा"रण वष" / Assessment Years: 2016-17 & 2017-18 Sachin Mohanlal Chordia, V The Income Tax Officer, B-101, Isha Emerald, S. Ward-5(1), Pune. Bibwewdi, Kondhwa Road, Marketyard, Pune- 411037. Pan: Aanpc8554C Appellant Respondent Assessee By Shri Abhilash Hiran Revenue By Shri Amit Bobade & Shri Sanjay Dhivare (Virtual) Date Of Hearing 05/03/2026 Date Of Pronouncement 30/03/2026 आदेश/ Order Per Bench : These Are Two Appeals Filed By Assessee Against The Separate Orders Of Commissioner Of Income Tax (Appeal) (Nfac) U/S 250 Of The Income Tax Act 1961 For Ay 2016-17, 2017-18 Passed On 22/10/2025 Emanating From Separate Assessment Orders U/S 147 Rws 144 Dated 11/05/2023 & 23/05/2023. 2. The Grounds Of Appeal Raised By The Assessee Are As Under:

Section 139Section 147Section 148Section 148ASection 151Section 151oSection 250

reassessment notices are to be dealt with as under: (i) AY 2013-14, AY 2014-15 and AY 2015- 16: Fresh notice under section 148 of the Act can be issued in these cases, with the approval of the specified authority, only if the case falls under clause (b) of sub-section (1) of section 149 as amended

M/S. VIKRAM DEVELOPERS & PROMOTERS,,PUNE vs. DEPUTY COMMISSIONER OF INCOME TAX,,

In the result, the appeal of the assessee in ITA No

ITA 2795/PUN/2016[2012-13]Status: DisposedITAT Pune14 Nov 2019AY 2012-13

Bench: Shri D. Karunakara Rao, Am & Shri Partha Sarathi Chaudhury, Jm आयकर अपील सं. / Ita Nos.2795 & 2796/Pun/2016 िनधा"रण वष" / Assessment Years : 2012-13 & 2013-14 M/S. Vikram Developers & Promoters, 19, Shrikrishna Heights, Ganeshkhind Road, Shivaji Nagar, Pune-411005. .......अपीलाथ" / Appellant Pan : Aagfv4298R बनाम / V/S. Dcit, Central Circle-2(1), ……""यथ" / Respondent Pune. Assessee By : Shri Kishor Phadke Revenue By : Shri Milind Chahure सुनवाई क" तारीख / Date Of Hearing : 17.10.2019 घोषणा क" तारीख / Date Of Pronouncement : 14.11.2019 आदेश / Order Per D. Karunakara Rao, Am: There Are Two Appeals Under Consideration Filed By The Assessee Against The Common Orders Of The Cit(A)-12, Pune Dated 08.09.2016 For The Assessment Years 2012-13 & 2013-14 Respectively. Preliminary Issue - Condonation Of Delay – Both Appeals 2. Before Us, At The Outset, Ld. Counsel For The Assessee Submitted That The Both The Appeals Could Not Be Filed In Time & The Said Appeals Were Filed With The Delay Of 01 Day. In This Regard, Ld. Counsel For The Assessee Submitted That The Delay Is Unintentional & Prayed For Condoning The Same. 3. After Hearing Both The Sides & Considering The Smallness Of Delay In Filing Of Both The Appeals, We Condone The Delay & Proceed To Adjudicate The Appeals Of The Assessee In The Following Paragraphs. 4. The Facts & Grounds Are Common In Both The Appeals, Therefore, Both The Appeals Were Heard Together & Are Being Disposed Of By This Composite Order. Accordingly, The Appeal-Wise Adjudication Is Taken Up In The Following Paragraphs.

For Appellant: Shri Kishor PhadkeFor Respondent: Shri Milind Chahure
Section 132Section 68Section 80I

reassessment is required to be made in accordance with section 153A of the Act. Thus, when the amended provisions of section 153C (1) of the Act have been brought into force with effect from 1st June, 2015, it has to be construed that such amended provisions would apply to a search initiated under section 132 or in relation to books

VIKRAM DEVELOPERS & PROMOTERS,,PUNE vs. DEPUTY COMMISSIONER OF INCOME TAX,,

In the result, the appeal of the assessee in ITA No

ITA 2796/PUN/2016[2013-14]Status: DisposedITAT Pune14 Nov 2019AY 2013-14

Bench: Shri D. Karunakara Rao, Am & Shri Partha Sarathi Chaudhury, Jm आयकर अपील सं. / Ita Nos.2795 & 2796/Pun/2016 िनधा"रण वष" / Assessment Years : 2012-13 & 2013-14 M/S. Vikram Developers & Promoters, 19, Shrikrishna Heights, Ganeshkhind Road, Shivaji Nagar, Pune-411005. .......अपीलाथ" / Appellant Pan : Aagfv4298R बनाम / V/S. Dcit, Central Circle-2(1), ……""यथ" / Respondent Pune. Assessee By : Shri Kishor Phadke Revenue By : Shri Milind Chahure सुनवाई क" तारीख / Date Of Hearing : 17.10.2019 घोषणा क" तारीख / Date Of Pronouncement : 14.11.2019 आदेश / Order Per D. Karunakara Rao, Am: There Are Two Appeals Under Consideration Filed By The Assessee Against The Common Orders Of The Cit(A)-12, Pune Dated 08.09.2016 For The Assessment Years 2012-13 & 2013-14 Respectively. Preliminary Issue - Condonation Of Delay – Both Appeals 2. Before Us, At The Outset, Ld. Counsel For The Assessee Submitted That The Both The Appeals Could Not Be Filed In Time & The Said Appeals Were Filed With The Delay Of 01 Day. In This Regard, Ld. Counsel For The Assessee Submitted That The Delay Is Unintentional & Prayed For Condoning The Same. 3. After Hearing Both The Sides & Considering The Smallness Of Delay In Filing Of Both The Appeals, We Condone The Delay & Proceed To Adjudicate The Appeals Of The Assessee In The Following Paragraphs. 4. The Facts & Grounds Are Common In Both The Appeals, Therefore, Both The Appeals Were Heard Together & Are Being Disposed Of By This Composite Order. Accordingly, The Appeal-Wise Adjudication Is Taken Up In The Following Paragraphs.

For Appellant: Shri Kishor PhadkeFor Respondent: Shri Milind Chahure
Section 132Section 68Section 80I

reassessment is required to be made in accordance with section 153A of the Act. Thus, when the amended provisions of section 153C (1) of the Act have been brought into force with effect from 1st June, 2015, it has to be construed that such amended provisions would apply to a search initiated under section 132 or in relation to books

ANANT MATE,,PUNE vs. DEPUTY COMMISSIONER OF INCOME-TAX,,

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

ITA 1674/PUN/2015[2005-06]Status: DisposedITAT Pune28 Feb 2018AY 2005-06

Bench: Ms. Sushma Chowla, Jm & Shri Anil Chaturvedi, Am आयकर अपीऱ सं. / Ita Nos.1674 To 1678/Pun/2015 यििाारण वषा / Assessment Years : 2005-06 To 2008-09 & 2010-11

For Respondent: Shri Ajay Modi, JCIT
Section 132Section 139Section 139(5)Section 153ASection 271(1)(c)

reassessment proceeding u/s 153A. 3. On the facts and circumstances of the case and in law, the CIT (A) erred in considering the original return filed before search for levy of penalty abated or non-est. 4. On the facts and circumstances of the case and in law, the CIT (A) erred in holding that inadvertent mistakes can only

KIRLOSKAR BROTHERS LIMITED,,PUNE vs. DCIT, CIRCLE 11(1),, PUNE

In the result, the appeal of the assessee for A

ITA 2611/PUN/2012[2002-03]Status: DisposedITAT Pune19 Sept 2018AY 2002-03

Bench: Shri D. Karunakara Rao, Am & Shri Vikas Awasthy, Jm आयकर अपील सं आयकर अपील सं. / Ita Nos. 2611 & 2612/Pun/2012 आयकर अपील सं आयकर अपील सं िनधा"रण वष" िनधा"रण वष" / Assessment Years : 2002-03 & 2003-04 िनधा"रण वष" िनधा"रण वष"

For Appellant: Shri Sharad ShahFor Respondent: Shri Mukesh Jha
Section 271(1)(c)Section 37(1)

reassessment proceedings is the additional legal issue raised in particular for adjudication vide the appeal ITA No.2612/PUN/2012. 2. Assessee raised various grounds originally. However, during the proceedings before us, assessee filed concise grounds and the said grounds for A.Y. 2002-03 are as under : “Ground of appeal No.1: The Ld. AO erred in CIT(A) erred in confirming the levy

KIRLOSKAR BROTHERS LIMITED,,PUNE vs. DCIT, RANGE 11(1),, PUNE

In the result, the appeal of the assessee for A

ITA 2612/PUN/2012[2003-04]Status: DisposedITAT Pune19 Sept 2018AY 2003-04

Bench: Shri D. Karunakara Rao, Am & Shri Vikas Awasthy, Jm आयकर अपील सं आयकर अपील सं. / Ita Nos. 2611 & 2612/Pun/2012 आयकर अपील सं आयकर अपील सं िनधा"रण वष" िनधा"रण वष" / Assessment Years : 2002-03 & 2003-04 िनधा"रण वष" िनधा"रण वष"

For Appellant: Shri Sharad ShahFor Respondent: Shri Mukesh Jha
Section 271(1)(c)Section 37(1)

reassessment proceedings is the additional legal issue raised in particular for adjudication vide the appeal ITA No.2612/PUN/2012. 2. Assessee raised various grounds originally. However, during the proceedings before us, assessee filed concise grounds and the said grounds for A.Y. 2002-03 are as under : “Ground of appeal No.1: The Ld. AO erred in CIT(A) erred in confirming the levy

DEPUTY COMMISSIONER OF INCOME TAX, NASHIK vs. CHAKRADHAR CONTRACTORS AND ENGINEERS PRIVATE LIMITED, JALGAON

In the result, both the appeals of the Revenue are

ITA 1939/PUN/2024[2020-21]Status: DisposedITAT Pune26 Dec 2024AY 2020-21

Bench: Shri Rama Kanta Panda & Shri Vinay Bhamore

For Appellant: Shri Sanket M JoshiFor Respondent: Shri Amol Khairnar, CIT-DR
Section 131Section 143Section 143(1)(a)Section 143(2)Section 270ASection 270A(3)(i)Section 270A(6)(a)Section 270A(9)

10 ITA.Nos.1939 & 1940/PUN./2024 C = the total income assessed as per the provisions contained in section 115JB or section 115JC; D = the total income that would have been chargeable had the total income assessed as per the provisions contained in section 115JB or section 115JC been reduced by the amount of under- reported income: Provided further that where

DEPUTY COMMISSIONER OF INCOME TAX, NASHIK vs. CHAKRAHAR CONTRACTORS AND ENGINEERS PRIVATE LIMITED, JALGAON

In the result, both the appeals of the Revenue are

ITA 1940/PUN/2024[2021-22]Status: DisposedITAT Pune26 Dec 2024AY 2021-22

Bench: Shri Rama Kanta Panda & Shri Vinay Bhamore

For Appellant: Shri Sanket M JoshiFor Respondent: Shri Amol Khairnar, CIT-DR
Section 131Section 143Section 143(1)(a)Section 143(2)Section 270ASection 270A(3)(i)Section 270A(6)(a)Section 270A(9)

10 ITA.Nos.1939 & 1940/PUN./2024 C = the total income assessed as per the provisions contained in section 115JB or section 115JC; D = the total income that would have been chargeable had the total income assessed as per the provisions contained in section 115JB or section 115JC been reduced by the amount of under- reported income: Provided further that where