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

142 has been issued to him, or\n(b) a return of income has been furnished by such other person but no\nnotice under sub-section (2) of section 143 has been served and limitation\nof serving the notice under sub-section (2) of section 143 has expired, or\n(c) assessment or reassessment, if any, has been made, before

MANOJ MADANLAL CHHAJED,PUNE vs. THE ASSISTANT COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-1(1), PUNE

reassess such income and also any\nother income chargeable to tax which has escaped assessment and which comes to\nhis notice subsequently in the course of the proceedings under section 147 of the\nAct\n28.1 The first proviso to section 147 is important. As per this proviso, where an\nassessment under subsection (3) of section 143 or section

SHRI MANOJ MADANLAL CHHAJED,PUNE vs. THE ASSISTANT COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-1(1), PUNE

reassess such income and also any\nother income chargeable to tax which has escaped assessment and which comes to\nhis notice subsequently in the course of the proceedings under section 147 of the\nAct\n28.1 The first proviso to section 147 is important. As per this proviso, where an\nassessment under subsection (3) of section 143 or section

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 147 of the Income Tax Act, 1961.” 3. Brief facts of the case as culled out from the records are that the assessee is a Partnership firm engaged in the business of Land Development at Nashik. Nil income declared in the return of income for A.Y. 2014-15 furnished on 17.11.2014. Return was taken up for scrutiny and assessment

ITO, WARD-1(1), SOLAPUR, SOLAPUR vs. MS. KSHIRSAGAR FABRICS, SOLAPUR

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

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

reassessment proceedings were validly initiated. What is however material to note is that in that particular case the Court has given a clear finding that the assessee had created and recorded bogus entries of loan and, therefore, the Court held that the assessee could not say that it had truly and fully disclosed all material facts necessary for the assessment

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

142(1) of the Act requesting Petitioner to attend his office on 16/10/2019 at 11.00 a.m. Petitioner, vide order dated 15/10/2019, informed Respondent No.1 that the objections against the reopening notice have not been disposed of. On 29/11/2019, Respondent No.1 passed the order of disposing of objections holding that notice under Section 147 is based on tangible material. 8. Petitioner

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:

3(1) of TOLA contained an explanation that provisions of section 147 to 151 of the Act prior to April 1, 2021 (herein after referred to as “old regime”) shall be applied to reassessment proceedings initiated under them between April 1,2021 and June 30,2021. Accordingly, Notification No.20 of 2021 dated March

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:

3(1) of TOLA contained an explanation that provisions of section 147 to 151 of the Act prior to April 1, 2021 (herein after referred to as “old regime”) shall be applied to reassessment proceedings initiated under them between April 1,2021 and June 30,2021. Accordingly, Notification No.20 of 2021 dated March

SAGAR BABANRAO AWATADE,NAVI MUMBAI vs. INCOME TAX OFFICER, WARD-1, PANVEL, PANVEL

Appeal is allowed

Bench: Shri Satbeer Singh Godaraआयकर अपील सं. /Ita No.79/Pun/2024 "नधा"रण वष" / Assessment Year : 2014-15

reassess such income and also any other income chargeable to tax which has escaped assessment and which comes to his notice subsequently in the course of the proceedings under this section, or recompute the loss or the depreciation allowance or any other allowance, as the case may be, for the assessment year concerned (hereafter in this section and in sections

SATYAPREM RAJABHAU DHOLE,BEED vs. ITO, WARD-1(5), AURANGABAD, AURANGABAD

In the result, the appeal of the assessee is allowed

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

142(1). It was proposed to assess income under section 144 on the basis of material available on record. The assessee was given an opportunity to show cause Under Section 144B(1)(ix) of the Income Tax, 1961 as to why the assessment should not be completed ex parte under Section 144 read with section 147 read with 144B

INCOME TAX OFFICER, WARD-1, JALNA, JALNA vs. ATUL OMPRAKASH MANTRI, JALNA

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

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

section 148 for same transaction could not be issued as there was no fresh tangible material. The relevant observations of the Hon’ble High Court read as under: “3. The Petitioner had filed her return of income for AY 2014-15 on 28th July 2014. The Assessing Officer ("AO") had passed an order u/s 143 (3

INCOME TAX OFFICER, WARD-1, JALNA, JALNA vs. PRAMILA OMPRAKASH MANTRI, JALNA

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

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

section 148 for same transaction could not be issued as there was no fresh tangible material. The relevant observations of the Hon’ble High Court read as under: “3. The Petitioner had filed her return of income for AY 2014-15 on 28th July 2014. The Assessing Officer ("AO") had passed an order u/s 143 (3

INCOME TAX OFFICER, WARD-1, JALNA, JALNA vs. OMPRAKASH ASARAM MANTRI, JALNA

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

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

section 148 for same transaction could not be issued as there was no fresh tangible material. The relevant observations of the Hon’ble High Court read as under: “3. The Petitioner had filed her return of income for AY 2014-15 on 28th July 2014. The Assessing Officer ("AO") had passed an order u/s 143 (3

INCOME TAX OFFICER, WARD-1, JALNA, JALNA vs. ATUL OMPRAKASH MANTRI, JALNA

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

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

section 148 for same transaction could not be issued as there was no fresh tangible material. The relevant observations of the Hon’ble High Court read as under: “3. The Petitioner had filed her return of income for AY 2014-15 on 28th July 2014. The Assessing Officer ("AO") had passed an order u/s 143 (3

INCOME TAX OFFICER, WARD -1, JALNA, JALNA vs. PRAMILA OMPRAKASH MANTRI, JALNA

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

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

section 148 for same transaction could not be issued as there was no fresh tangible material. The relevant observations of the Hon’ble High Court read as under: “3. The Petitioner had filed her return of income for AY 2014-15 on 28th July 2014. The Assessing Officer ("AO") had passed an order u/s 143 (3

INCOME TAX OFFICER, WARD-1, JALNA, JALNA vs. OMPRAKASH ASARAM MANTRI, JALNA

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

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

section 148 for same transaction could not be issued as there was no fresh tangible material. The relevant observations of the Hon’ble High Court read as under: “3. The Petitioner had filed her return of income for AY 2014-15 on 28th July 2014. The Assessing Officer ("AO") had passed an order u/s 143 (3

INCOME TAX OFFICER, WARD-1, JALNA, JALNA vs. ASHISH OMPRAKASH MANTRI, JALNA

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

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

section 148 for same transaction could not be issued as there was no fresh tangible material. The relevant observations of the Hon’ble High Court read as under: “3. The Petitioner had filed her return of income for AY 2014-15 on 28th July 2014. The Assessing Officer ("AO") had passed an order u/s 143 (3

INCOME TAX OFFICER, WARD 1, JALNA, JALNA vs. ASHISH OMPRAKASH MANTRI, JALNA

section 148 for same\ntransaction could not be issued as there was no fresh tangible material. The\nrelevant observations of the Hon'ble High Court read as under:\n“3. The Petitioner had filed her return of income for AY 2014-15 on 28th July\n2014. The Assessing Officer (\"AO\") had passed an order u/s 143 (3

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 or recomputed in a preceding order. (11) No addition or disallowance of an amount shall form the basis for imposition of penalty, if such addition or disallowance has formed the basis of Imposition of penalty in the case of the person for the same or any other assessment year. (12) The penalty referred to in sub-section (1) shall