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

reassessment proceedings even the income which has escaped assessment has to be computed in accordance with the provisions of the Act which will include section 11 as is in the present case. It will not be correct to say that while computing income under section 148 the entire gross receipts are to be taxed. Further, it is not the case

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

reassessment proceedings even the income which has escaped assessment has to be computed in accordance with the provisions of the Act which will include section 11 as is in the present case. It will not be correct to say that while computing income under section 148 the entire gross receipts are to be taxed. Further, it is not the case

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

reassessment proceedings even the income which has escaped assessment has to be computed in accordance with the provisions of the Act which will include section 11 as is in the present case. It will not be correct to say that while computing income under section 148 the entire gross receipts are to be taxed. Further, it is not the case

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

reassessment proceedings even the income which has escaped assessment has to be computed in accordance with the provisions of the Act which will include section 11 as is in the present case. It will not be correct to say that while computing income under section 148 the entire gross receipts are to be taxed. Further, it is not the case

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

reassessment proceedings even the income which has escaped assessment has to be computed in accordance with the provisions of the Act which will include section 11 as is in the present case. It will not be correct to say that while computing income under section 148 the entire gross receipts are to be taxed. Further, it is not the case

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

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

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

ASHOK DHANRAJ CHORDIA ,PUNE vs. PCIT, PUNE-1, PUNE

10 of the paper book filed by the Revenue, he\nsubmitted that fourth entry of Rs.25 lakh also appears in the name of A.Lodha and\nnot in the name of the assesse. Referring to page 11 of the paper book filed by the\nRevenue, he submitted that fifth and sixth entries of Rs.10 lakh and Rs.15 lakh also\nappear

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

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

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

PADMAKAR VISHWAS DATE,BHOSARI vs. INCOME TAX E ASSESSMENT , PUNE

In the result, appeal of the assessee is dismissed

Bench: Shri S.S.Godara & Dr. Dipak P. Ripoteआयकर अपील सं. / Ita Nos.929, 930 & 931/Pun/2023 िनधा"रण वष" / Assessment Years : 2013-14, 2014-15 & 2015-16 Padmakar Vishwas Date, The Income Tax Officer S.No.218, Near Shri Krishn V –Tds(2), Pune. Mandir, Alandi Road, S Bhosari, Pune – 411038. Pan: Anhpd3804B Appellant/ Assessee Respondent /Revenue Assessee By None Revenue By Shri Sourabh Nayak – Addl.Cit(Dr) Date Of Hearing 15/02/2024 Date Of Pronouncement 16/02/2024 आदेश/ Order Per Dr. Dipak P. Ripote, Am: These Three Appeals Filed By The Assessee Are Against The Separate Orders Of Ld.Commissioner Of Income Tax(Appeals)[Nfac], Passed Under Section 250 Of The Income Tax Act, 1961 All Dated 26.06.2023. Since Issue Involved Is Same, All These Appeals Were Heard Together & Decided By This Consolidated Order. We Treat Appeal In Ita No.929/Pun/2023 For A.Y.2013-14

reassessment under section 153A [except an order passed in pursuance of directions of the Dispute Resolution Panel] or an order referred to in sub-section (12) of section 144BA; (bb) an order made under sub-section (3) of section 92CD; (c) an order made under section 154 or section 155 having the effect of enhancing the assessment or reducing

PADMAKAR VISHWAS DATE,,BHOSARI vs. INCOME TAX E ASSESSMENT, PUNE

In the result, appeal of the assessee is dismissed

Bench: Shri S.S.Godara & Dr. Dipak P. Ripoteआयकर अपील सं. / Ita Nos.929, 930 & 931/Pun/2023 िनधा"रण वष" / Assessment Years : 2013-14, 2014-15 & 2015-16 Padmakar Vishwas Date, The Income Tax Officer S.No.218, Near Shri Krishn V –Tds(2), Pune. Mandir, Alandi Road, S Bhosari, Pune – 411038. Pan: Anhpd3804B Appellant/ Assessee Respondent /Revenue Assessee By None Revenue By Shri Sourabh Nayak – Addl.Cit(Dr) Date Of Hearing 15/02/2024 Date Of Pronouncement 16/02/2024 आदेश/ Order Per Dr. Dipak P. Ripote, Am: These Three Appeals Filed By The Assessee Are Against The Separate Orders Of Ld.Commissioner Of Income Tax(Appeals)[Nfac], Passed Under Section 250 Of The Income Tax Act, 1961 All Dated 26.06.2023. Since Issue Involved Is Same, All These Appeals Were Heard Together & Decided By This Consolidated Order. We Treat Appeal In Ita No.929/Pun/2023 For A.Y.2013-14

reassessment under section 153A [except an order passed in pursuance of directions of the Dispute Resolution Panel] or an order referred to in sub-section (12) of section 144BA; (bb) an order made under sub-section (3) of section 92CD; (c) an order made under section 154 or section 155 having the effect of enhancing the assessment or reducing

PADMAKAR VISHWAS DATE,BHOSARI vs. INCOME TAX E ASSESSMENT, PUNE

In the result, appeal of the assessee is dismissed

Bench: Shri S.S.Godara & Dr. Dipak P. Ripoteआयकर अपील सं. / Ita Nos.929, 930 & 931/Pun/2023 िनधा"रण वष" / Assessment Years : 2013-14, 2014-15 & 2015-16 Padmakar Vishwas Date, The Income Tax Officer S.No.218, Near Shri Krishn V –Tds(2), Pune. Mandir, Alandi Road, S Bhosari, Pune – 411038. Pan: Anhpd3804B Appellant/ Assessee Respondent /Revenue Assessee By None Revenue By Shri Sourabh Nayak – Addl.Cit(Dr) Date Of Hearing 15/02/2024 Date Of Pronouncement 16/02/2024 आदेश/ Order Per Dr. Dipak P. Ripote, Am: These Three Appeals Filed By The Assessee Are Against The Separate Orders Of Ld.Commissioner Of Income Tax(Appeals)[Nfac], Passed Under Section 250 Of The Income Tax Act, 1961 All Dated 26.06.2023. Since Issue Involved Is Same, All These Appeals Were Heard Together & Decided By This Consolidated Order. We Treat Appeal In Ita No.929/Pun/2023 For A.Y.2013-14

reassessment under section 153A [except an order passed in pursuance of directions of the Dispute Resolution Panel] or an order referred to in sub-section (12) of section 144BA; (bb) an order made under sub-section (3) of section 92CD; (c) an order made under section 154 or section 155 having the effect of enhancing the assessment or reducing

DCIT CIRCLE 1 NASHIK, NASHIK vs. SHREE SAI PROPERTIES, NASHIK

In the result, appeal of the Revenue is dismissed

Bench: Dr. Manish Borad & Shri Vinay Bhamore

10 ITA.No.987/PUN./2025 (M/s. Shree Sai Properties) 3.3 It is to humbly submit that, the non obstante clause, kicks-in only on the AO assuming the jurisdiction under Section 153C of the Act, to make an assessment/ reassessment. The non obstante provisions cannot come into play, if the AO does not take recourse to provision of Section 153C

PUSHPADEVI SHIVLAL RATHI ,JALNA vs. ITO WARD-1, JALNA

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

Bench: Dr.Manish Boradआयकर अपील सं. / Ita No.1995/Pun/2024 "नधा"रण वष" / Assessment Years : 2017-18

10. Also further, it was held that the Income-tax Act read with TOLA extended the time limit for issuing reassessment notices under section 148, which fell for completion from 20 March 2020 to 31 March 2021, till 30 June 2021. All the reassessment notices under challenge in the 5 Pushpadevi Shivlal Rathi present appeals were issued from 1 April

PUNE MATHADI HAMAL AND OTHER MANUAL WORKERS BOARD,PUNE vs. INCOME TAX OFFICER, WARD-5(1), PUNE, PUNE

In the result, appeal of the assessee is partly allowed

Bench: Shri S.S.Godara & Dr. Dipak P. Ripoteआयकर अपील सं. / Ita No.1012/Pun/2023 िनधा"रण वष" / Assessment Year : 2018-19 Pune Mathadihamal & Other The Income Tax Manual Workers Board, V Officer, Shramashakti Bhavan, S Ward-5(1), Pune. Coomercial Plot No.1, Market Yard, Pune – 411037. Pan: Aaalp0097L Appellant/ Assessee Respondent /Revenue Assessee By Shri Vipul Joshi – Ar Revenue By Shri Ajay Kumar Keshari & Shri Rajesh Gawali– Dr’S Date Of Hearing 17/04/2024 Date Of Pronouncement 27/06/2024 आदेश/ Order Per Dr. Dipak P. Ripote, Am: This Appeal Filed By The Assessee Is Against The Orders Of Ld.Commissionerof Income Tax(Appeals)[Nfac], Under Section 250 Of The Act Dated 14.07.2023 :

10. The Supreme Court in Radhasoami Satsang v. CIT [1992] 60 Taxman 248/193 ITR 321 has held that even though principles of res judicata do not apply to income tax proceedings, but where a fundamental aspect permeating through the different Assessment Years has been found as the fact one way or the other and the parties have allowed the position

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

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:

10. On perusal of the order dated 18.08.2022, passed under Section 148A(d) of the Act we find that the aforesaid order was passed after taking approval from Principal Commissioner of Income Tax (Respondent No.2). Since the aforesaid order was passed, as well as the notice under section 148 was issued, after the expiry of three years from

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

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:

10. On perusal of the order dated 18.08.2022, passed under Section 148A(d) of the Act we find that the aforesaid order was passed after taking approval from Principal Commissioner of Income Tax (Respondent No.2). Since the aforesaid order was passed, as well as the notice under section 148 was issued, after the expiry of three years from

RAJDEEP BUILDCON PVT LTD, AHMEDNAGAR,AHMEDNAGAR vs. DY. COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE 1(2), PUNE, PUNE

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

Bench: SHRI R. K. PANDA (Vice President), SHRI VINAY BHAMORE (Judicial Member)

10. The appellant has also submitted that all its investments are in SPV entities formed for the purpose of executing the infrastructure projects. The Ld Assessing Officer made the addition only on the ground that this is a closed year and that if the Assessing Officer cannot make any additions in the absence of incriminating material, then the same principle

RAJDEEP BUILDCOM PRIVATE LIMITED,AHMEDNAGAR vs. DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE - 1(2), PUNE, PUNE

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

Bench: SHRI R. K. PANDA (Vice President), SHRI VINAY BHAMORE (Judicial Member)

10. The appellant has also submitted that all its investments are in SPV entities formed for the purpose of executing the infrastructure projects. The Ld Assessing Officer made the addition only on the ground that this is a closed year and that if the Assessing Officer cannot make any additions in the absence of incriminating material, then the same principle

RAJDEEP BUILDCON PRIVAT LIMITED, AHMEDNAGAR,AHMEDNAGAR vs. DY. COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE 1(2), PUNE, PUNE

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

Bench: SHRI R. K. PANDA (Vice President), SHRI VINAY BHAMORE (Judicial Member)

10. The appellant has also submitted that all its investments are in SPV entities formed for the purpose of executing the infrastructure projects. The Ld Assessing Officer made the addition only on the ground that this is a closed year and that if the Assessing Officer cannot make any additions in the absence of incriminating material, then the same principle