ASHOK BHARTI GOSWAMI,PUNE vs. ACIT, CENTRAL CIRCLE 2(1), PUNE , PUNE

In the result, all the appeals filed by the respective assessees are allowed

Bench: Shri R. K. Panda & Shri Vinay Bhamore

reassessment under Section 153C of the Act has been specified as twelve months from the end of financial year during which the last authorisation to search under section 132 of the Act or requisition under section 132A of the Act, was executed.” 37. The Ld. Counsel for the assessee submitted that typically, the jurisdiction u/s 127

CHITRA NARENDRA PARMAR,PUNE vs. ASSISTANT COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-2(1), PUNE, PUNE

In the result, all the appeals filed by the respective assessees are allowed

Bench: Shri R. K. Panda & Shri Vinay Bhamore

reassessment under Section 153C of the Act has been specified as twelve months from the end of financial year during which the last authorisation to search under section 132 of the Act or requisition under section 132A of the Act, was executed.” 37. The Ld. Counsel for the assessee submitted that typically, the jurisdiction u/s 127

RAMLAL BHIKULAL SHAH,PUNE vs. ACIT, CENTRAL CIRCLE 2(1), PUNE , PUNE

In the result, all the appeals filed by the respective assessees are allowed

Bench: Shri R. K. Panda & Shri Vinay Bhamore

reassessment under Section 153C of the Act has been specified as twelve months from the end of financial year during which the last authorisation to search under section 132 of the Act or requisition under section 132A of the Act, was executed.” 37. The Ld. Counsel for the assessee submitted that typically, the jurisdiction u/s 127

RAMANLAL BHIKULAL SHAH,PUNE vs. ACIT, CENTRAL CIRCLE 2(1), PUNE , PUNE

In the result, all the appeals filed by the respective assessees are allowed

Bench: Shri R. K. Panda & Shri Vinay Bhamore

reassessment under Section 153C of the Act has been specified as twelve months from the end of financial year during which the last authorisation to search under section 132 of the Act or requisition under section 132A of the Act, was executed.” 37. The Ld. Counsel for the assessee submitted that typically, the jurisdiction u/s 127

CHITRA NARENDRA PARMAR ,PUNE vs. ACIT, CENTRAL CIRCLE 2(1), PUNE , PUNE

In the result, all the appeals filed by the respective assessees are allowed

Bench: Shri R. K. Panda & Shri Vinay Bhamore

reassessment under Section 153C of the Act has been specified as twelve months from the end of financial year during which the last authorisation to search under section 132 of the Act or requisition under section 132A of the Act, was executed.” 37. The Ld. Counsel for the assessee submitted that typically, the jurisdiction u/s 127

DEEPAK KANTILAL JAIN,PUNE vs. ACIT, CENTRAL CIRCLE 2(1), PUNE , PUNE

The appeal stands dismissed

Bench: Shri R. K. Panda & Shri Vinay Bhamore

reassessment under Section 153C of the Act has been specified as twelve months from the end of financial year during which the last authorisation to search under section 132 of the Act or requisition under section 132A of the Act, was executed.” 37. The Ld. Counsel for the assessee submitted that typically, the jurisdiction u/s 127

DEEPAK KANTILAL JAIN ,PUNE vs. ACIT, CENTRAL CIRCLE 2(1), PUNE , PUNE

The appeal stands dismissed

Bench: Shri R. K. Panda & Shri Vinay Bhamore

reassessment under Section 153C of the Act has been specified as twelve months from the end of financial year during which the last authorisation to search under section 132 of the Act or requisition under section 132A of the Act, was executed.” 37. The Ld. Counsel for the assessee submitted that typically, the jurisdiction u/s 127

GOPAL EXTRUSIONS PVT LTD,,JALGAON vs. INCOME-TAX OFFICER, WARD - 1(2),, JALGAON

Bench: Dr.Manish Borad & Shri Vinay Bhamoreआयकर अपील सं. / Ita. No.1633/Pun/2017 Assessment Year : 2008-09

reassessment proceedings are bad in law. B. No Approval u/s 151 is obtained on the reasons recorded. C. The Approval alongwith proposal clearly shows that it was only proposal and there is no finding about the reason to believe. D. The appellant has discharged the burden u/s 68 by furnishing the supporting documents. E. There is no material to show

RAJENDRAKUMAR SHRISHRIMAL,PUNE vs. INCOME TAX OFFICER WARD 5(1), PUNE

In the result, appeal of the assessee is allowed

Bench: Ms.Astha Chandra & Dr.Dipak P. Ripoteआयकर अपऩल सं. / Ita No.3282/Pun/2025 निर्धारण वषा / Assessment Year: 2017-18 Rajendrakumar Shrishrimal, V The Income Tax Officer, 685/3, Anant Vashat, S Ward-5(1), Pune. Bibwewadi, Pune – 411037. Pan: Bjsps9226G Appellant/ Assessee Respondent /Revenue Assessee By Shri Abhilash Hiran Revenue By Shri Sadananda – Jcit(Dr) Date Of Hearing 11/02/2026 Date Of Pronouncement 12/02/2026 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], Passed Under Section 250 Of The Income Tax Act, 1961 For The A.Y.2017-18 Dated 16.10.2025 Emanating From The Assessment Order Passed Under Section 147 Read With Section 144B Of The I.T.Act, 1961 Dated 03.05.2023. The Assessee Has Raised The Following Grounds Of Appeal :

reassessment order passed may be quashed and set aside. The Appellant craves leave to add, alter, vary, omit, substitute or amend the above grounds of appeal, at any time before or at, the time of hearing of the appeal, so as to enable the Hon'ble Tribunal to decide this appeal according to law.” 2 ITA No.3282/PUN/2025 [A] Submission

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, the same is sufficient for the purpose of section 12A(b) of the Act. For the above proposition, we rely on the decision of the Delhi Bench of the Tribunal in the case of United Educational Society vs. JCIT reported in 107 taxmann.com 127

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, the same is sufficient for the purpose of section 12A(b) of the Act. For the above proposition, we rely on the decision of the Delhi Bench of the Tribunal in the case of United Educational Society vs. JCIT reported in 107 taxmann.com 127

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, the same is sufficient for the purpose of section 12A(b) of the Act. For the above proposition, we rely on the decision of the Delhi Bench of the Tribunal in the case of United Educational Society vs. JCIT reported in 107 taxmann.com 127

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, the same is sufficient for the purpose of section 12A(b) of the Act. For the above proposition, we rely on the decision of the Delhi Bench of the Tribunal in the case of United Educational Society vs. JCIT reported in 107 taxmann.com 127

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, the same is sufficient for the purpose of section 12A(b) of the Act. For the above proposition, we rely on the decision of the Delhi Bench of the Tribunal in the case of United Educational Society vs. JCIT reported in 107 taxmann.com 127

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, the same is sufficient for the purpose of section 12A(b) of the Act. For the above proposition, we rely on the decision of the Delhi Bench of the Tribunal in the case of United Educational Society vs. JCIT reported in 107 taxmann.com 127

ADISH SHANTILAL SOLANKI,PUNE vs. ASSISTANT COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-2(1), PUNE, PUNE

Bench: Shri R. K. Panda & Shri Vinay Bhamore

reassessment under Section 153C of the Act has been specified as twelve months from the end of financial year during which the last authorisation to search under section 132 of the Act or requisition under section 132A of the Act, was executed.” 37. The Ld. Counsel for the assessee submitted that typically, the jurisdiction u/s 127

SOPAN DHONDIBA TUPE,,PUNE vs. ASSISTANT COMMISSIONER OF INCOME-TAX,,

Bench: Shri D. Karunakara Rao, Am & Shri Vikas Awasthy, Jm आयकर अऩीऱ सं. / Ita No.2108/Pun/2013 यनधाारण वषा / Assessment Year : 2006-07 Shri Sandip Bhanudas Tupe, S. No. 202, Sade-Stra-Nali, Near Vitthal Mandir, Hadapsar, Pune – 411028 Pan : Aampt1909M .......अऩीऱाथी / Appellant बनाम / V/S. Assistant Commissioner Of Income Tax, Central Circle – 2(1), Pune ……प्रत्यथी / Respondent आयकर अऩीऱ सं. / Ita No.2109/Pun/2013 यनधाारण वषा / Assessment Year : 2006-07 Shri Sopan Dhondiba Tupe, S. No. 202, Sade-Stra-Nali, Near Vitthal Mandir, Hadapsar, Pune – 411028 Pan : Aajpt0436E .......अऩीऱाथी / Appellant बनाम / V/S. Assistant Commissioner Of Income Tax, Central Circle – 2(1), Pune ……प्रत्यथी / Respondent आयकर अऩीऱ सं. / Ita Nos.2110 & 2111/Pun/2013 यनधाारण वषा / Assessment Years : 2006-07 & 2009-10

Reassessment under s 147 on the basis of incriminating material against assessee found in search of third party and forwarded to assessee by the search Officer was illegal and void ab initio as in such a situation assessment could be made only under s 153C which specifically ousted the application of ss. 147 and 148". 2. The provisions of Section

SANDIP BHANUDAS TUPE,,PUNE vs. ASSISTANT COMMISSIONER OF INCOME-TAX,,

Bench: Shri D. Karunakara Rao, Am & Shri Vikas Awasthy, Jm आयकर अऩीऱ सं. / Ita No.2108/Pun/2013 यनधाारण वषा / Assessment Year : 2006-07 Shri Sandip Bhanudas Tupe, S. No. 202, Sade-Stra-Nali, Near Vitthal Mandir, Hadapsar, Pune – 411028 Pan : Aampt1909M .......अऩीऱाथी / Appellant बनाम / V/S. Assistant Commissioner Of Income Tax, Central Circle – 2(1), Pune ……प्रत्यथी / Respondent आयकर अऩीऱ सं. / Ita No.2109/Pun/2013 यनधाारण वषा / Assessment Year : 2006-07 Shri Sopan Dhondiba Tupe, S. No. 202, Sade-Stra-Nali, Near Vitthal Mandir, Hadapsar, Pune – 411028 Pan : Aajpt0436E .......अऩीऱाथी / Appellant बनाम / V/S. Assistant Commissioner Of Income Tax, Central Circle – 2(1), Pune ……प्रत्यथी / Respondent आयकर अऩीऱ सं. / Ita Nos.2110 & 2111/Pun/2013 यनधाारण वषा / Assessment Years : 2006-07 & 2009-10

Reassessment under s 147 on the basis of incriminating material against assessee found in search of third party and forwarded to assessee by the search Officer was illegal and void ab initio as in such a situation assessment could be made only under s 153C which specifically ousted the application of ss. 147 and 148". 2. The provisions of Section

RAMDAS BHANUDASTUPE,,PUNE vs. ASSISTANT COMMISSIONER OF INCOME-TAX,,

Bench: Shri D. Karunakara Rao, Am & Shri Vikas Awasthy, Jm आयकर अऩीऱ सं. / Ita No.2108/Pun/2013 यनधाारण वषा / Assessment Year : 2006-07 Shri Sandip Bhanudas Tupe, S. No. 202, Sade-Stra-Nali, Near Vitthal Mandir, Hadapsar, Pune – 411028 Pan : Aampt1909M .......अऩीऱाथी / Appellant बनाम / V/S. Assistant Commissioner Of Income Tax, Central Circle – 2(1), Pune ……प्रत्यथी / Respondent आयकर अऩीऱ सं. / Ita No.2109/Pun/2013 यनधाारण वषा / Assessment Year : 2006-07 Shri Sopan Dhondiba Tupe, S. No. 202, Sade-Stra-Nali, Near Vitthal Mandir, Hadapsar, Pune – 411028 Pan : Aajpt0436E .......अऩीऱाथी / Appellant बनाम / V/S. Assistant Commissioner Of Income Tax, Central Circle – 2(1), Pune ……प्रत्यथी / Respondent आयकर अऩीऱ सं. / Ita Nos.2110 & 2111/Pun/2013 यनधाारण वषा / Assessment Years : 2006-07 & 2009-10

Reassessment under s 147 on the basis of incriminating material against assessee found in search of third party and forwarded to assessee by the search Officer was illegal and void ab initio as in such a situation assessment could be made only under s 153C which specifically ousted the application of ss. 147 and 148". 2. The provisions of Section