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

reassessment\nunder Sections 147/148 of the I.T. Act stands saved, failing which, the Revenue\nwould be left without remedy. It is on such observations the conclusions as\nrendered by the Supreme Court and which are relevant to the case in hand, are\nrequired to be noted, which reads thus:\n\"14

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

Section 153C of the Act are enacted for the purpose of simplifying the procedure in search cases. The import of such provisioncannot be to oust the recourse to the normal provisions, which in any event are available for assessment / reassessment of an income of an assessee. [para 62]. 14

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

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

14 Pushpadevi Shivlal Rathi Ashish Agrawal (supra) , all the further course of action needs to be adhered as per the provisions of section 148A of the Act. After the letter was issued to the assessee on 28.05.2022, assessee was required to reply within a period not exceeding 30 days to which necessary compliance was made and reply was filed

SHANKAR NAGAPPA JADAGOUDA,KOLHAPUR vs. NFAC, DELHI

Appeal is allowed in above terms

Bench: Shri Satbeer Singh Godara

reassess income in respect of any other issue though the reasons for such issue had not been included in the reasons recorded under section 148(2). 14

TEJAS SHIVAJI ADSUL,KOLHAPUR vs. INCOME TAX OFFICER WARD 1(1), KOLHAPUR, KOLHAPUR

In the result, appeal of the assessee is allowed

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

reassessed or recomputed in a preceding order:" 7.5 Section 270A(2) provides list of instances upon meeting which it can be considered that there is 'Under reported income' in the hands of assessee. Section 270A(3) gives method to arrive at quantum of 'Under reported income' in the hands of assessee. 270A(2)(b) clearly states that 'under reported income

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)

14. Similar view had been taken by the Jodhpur ITAT in the case Suncity Alloys (P.) Ltd. v. Asstt. CIT [2009] 124 TTJ (Jodh.) 674 "The expression 'assessment or reassessment’ used in section

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)

14. Similar view had been taken by the Jodhpur ITAT in the case Suncity Alloys (P.) Ltd. v. Asstt. CIT [2009] 124 TTJ (Jodh.) 674 "The expression 'assessment or reassessment’ used in section

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)

14. Similar view had been taken by the Jodhpur ITAT in the case Suncity Alloys (P.) Ltd. v. Asstt. CIT [2009] 124 TTJ (Jodh.) 674 "The expression 'assessment or reassessment’ used in section

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

In the result, both the appeals of the Revenue are

Bench: Shri Rama Kanta Panda & Shri Vinay Bhamore

reassessed. 11 ITA.Nos.1939 & 1940/PUN./2024 (4) Subject to the provisions of sub-section (6), where the source of any receipt. deposit or investment in any assessment year is claimed to be an amount added to income or deducted while computing loss, as the case may be, in the assessment of such person in any year prior to the assessment

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

In the result, both the appeals of the Revenue are

Bench: Shri Rama Kanta Panda & Shri Vinay Bhamore

reassessed. 11 ITA.Nos.1939 & 1940/PUN./2024 (4) Subject to the provisions of sub-section (6), where the source of any receipt. deposit or investment in any assessment year is claimed to be an amount added to income or deducted while computing loss, as the case may be, in the assessment of such person in any year prior to the assessment

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:

14. We accordingly set aside the impugned order dated 18.08.2022 passed under Section 148A(d) of the Act and the consequential notice issued under section 148 dated 23.08.2022, and all other proceedings/orders emanating therefrom. 15. Rule is made absolute in the aforesaid terms and the Writ Petition is also disposed of in terms thereof. No order as to costs. ”Unquote

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:

14. We accordingly set aside the impugned order dated 18.08.2022 passed under Section 148A(d) of the Act and the consequential notice issued under section 148 dated 23.08.2022, and all other proceedings/orders emanating therefrom. 15. Rule is made absolute in the aforesaid terms and the Writ Petition is also disposed of in terms thereof. No order as to costs. ”Unquote

SATISH VISHNU THOMBARE, INCOME TAX OFFICER, WARD-1, AHMEDNAGAR, AHMEDNAGAR vs. VARSHA PRAFULLA ZENDE, AHMEDNAGAR

In the result, the appeal of the Revenue is dismissed

Bench: Shri R.K. Panda & Ms. Astha Chandraआयकर अपील सं. / Ita No.1656/Pun/2024 धििाारण वर्ा / Assessment Year : 2010-11 Satish Vishnu Thombare, Varsha Prafulla Zende, Income Tax Officer, Prop Of Bleach Chem Enterprises, Ward-1, Ahmednagar Vs. Industrial Estate, Shrirampur, Maharashtra-413709 Pan : Aabpz2541C अपीलार्थी / Appellant प्रत्यर्थी / Respondent Assessee By : Miss Shivani Shah (Virtual) Department By : Shri Akhilesh Srivastva Date Of Hearing : 06-08-2025 Date Of 29-10-2025 Pronouncement : आदेश / Order

reassess income in respect of any other issue though the reasons for such issue had not been included in the reasons recorded under section 148(2). 14

VINODKUMAR DHANULALJI SAWJI,JALNA vs. ITO WARD 1 , JALNA

In the result, appeals of the Assessee are partly allowed\nfor statistical purposes

reassessment\nproceedings under section 147/148 bad in law liable to be set\naside.\n5. The above grounds of appeal are without prejudice to one\nanother.\n6. The appellant craves leave to furnish Additional Evidence\nwhich may be relevant to the above Grounds of Appeal in\ncourse of the appeal proceedings.\"\nThe assessee also raised additional ground which reads\nas under

DEPUTY COMMISSIONER OF INCOME TAX CIRCLE 7 PUNE, PUNE vs. KOLTE PATIL INTEGRATED TOWNSHIPS LIMITED, PUNE

In the result, both the appeals filed by the Revenue are dismissed

section to apportion the interest\ncost between the WIP and sales. Since interest expenditure is a period cost, the\nsame has to be allowed in the year in which it has been incurred. For the above\nproposition, he relied on the following decisions:\na. Lokhandwala Construction Industries Ltd. [260 ITR 579].\nb. Lodha Developers Ltd. [143 Taxmann.com

ADVIK HI TECH PVT LTD,PUNE vs. DY.COMM..OF INCOMETAX, CIRCLE 8, PUNE

In the result, appeal of the assessee is allowed

Bench: Shri Rama Kanta Panda & Ms. Astha Chandra

section 115JC, as the case may be, is greater than the deemed total income assessed or reassessed immediately before such reassessment; g. the income assessed or reassessed has the effect of reducing the loss or converting such loss into income. 5.1. Referring to the above clauses, he submitted that assessee does not fall under any of the above clauses

RAJENDRA CHANDRAKANT CHINCHNIKAR,PUNE vs. CIT(A)-11, PUNE

In the result, the appeal filed by the assessee is dismissed

Bench: Justice (Retd.) C V Bhadang & Shri R. K. Pandaassessment Year : 2019-20 Rajendra Chandrakant Chinchnikar Acit, Central Circle, 2165, B Ward, Koshti Galli, Vs. Kolhapur Mangalwar Peth, Pune – 416012 Pan: Acppc3559D (Appellant) (Respondent) Assessee By : Shri Tanzil Padvekar Department By : Shri Milind Debaje, Jcit Date Of Hearing : 25-08-2025 Date Of Pronouncement : 29-09-2025 O R D E R Per R.K. Panda, Vp:

reassessed has the effect of reducing the loss or converting such loss into income. (3) …… (4) …... (5) …… 12 (6) ….. (7) …. (8) …. (9) The cases of misreporting of income referred to in sub-section (8) shall be the following, namely:— (a) misrepresentation or suppression of facts; (b) failure to record investments in the books of account; (c) claim of expenditure

A.C.I.T ,WARDHA CIRCLE , WARDHA , WARDHA vs. M/S KAPIL SOLVEX PVT .LTD , YAVATMAL

In the result, the appeal filed by the Revenue is dismissed

Bench: Shri R. K. Panda & Ms Astha Chandraassessment Year : 2009-10

reassessment order could not be upheld. 14. Referring to various other decisions, he submitted that where the Assessing Officer has passed the order without disposing of the objections raised by the assessee to the reopening of assessment, such re-assessment proceedings are held to be null and void. He submitted that in the instant case when the reasons were never