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

reassessment dated 3rd March 2025 passed under Section 147 read with Section 144B of the Act, the Notice of Demand

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

reassessment order, the A.O has initiated penalty u/s 270A on a vague charge of furnishing inaccurate particulars of income' also in the notice u/s 274 r.w.s 270A, the exact limb of section 270A(9) which has been allegedly violated by the assessee has not been specified and hence, the 7 ITA No.59/PUN/2025, AY 2018-19 penalty order passed u/s 270A

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

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

sections": [ "147", "148", "144B", "250", "68", "153C" ], "issues": "Whether reassessment proceedings initiated under Section 147/148 were valid when the transactions

MRS NEHA VITTHAL DIMBLE,PUNE vs. ITO, WARD-3(3), PUNE, PUNE

In the result, the appeal of the assessee is allowed for statistical\npurposes

reassessment proceedings\nwhich constrained the Ld. AO to complete the assessment u/s 147 r.w.s.144B\nof the Act on 19.02.2024 at an assessed income of Rs.83,31,620/- by making\naddition of - (i) Rs.66,65,000/- in respect of cash deposits in bank treating the\nsame as unexplained money under section 69A; (ii) Rs.14,08,073/- in respect\nof purchase

ASSISTANT COMMISSIONER OF INCOME TAX CIRCLE 12, PUNE vs. VARUN JAIN, PUNE

In the result, Cross Objection appeal filed by the assessee is allowed

Bench: Dr.Dipak P. Ripote & Shri Vinay Bhamorecross Objection No.14/Pun/2025 (Arising Out Of Ita No.2720/Pun/2024) िनधा"रण वष" / Assessment Year: 2018-19 Varun Jain, The Acit, P-024, Forest County, Kharadi, V Circle-12, Pune. Pune – 411014. S. Maharashtra. Pan:Aexpj0171J Appellant/ Assessee Respondent / Revenue आयकर अपील सं. / Ita No.2720/Pun/2024 िनधा"रण वष" / Assessment Year: 2018-19 The Acit, Varun Jain, Circle-12, Pune. Vs. P-024, Forest County, Kharadi, Pune – 411014. Maharashtra. Pan:Aexpj0171J Appellant / Revenue Respondent / Assessee Assessee By Shri Fenil Bhatt – Ar(Virtual) Revenue By Shri Abhinay Kumbhar - Dr Date Of Hearing 05/05/2025 Date Of Pronouncement 07/05/2025 आदेश/ Order Per Dr. Dipak P. Ripote, Am: In This Case, Revenue Has Filed An Appeal Against The Order Of Ld.Commissioner Of Income Tax(Appeal)[Nfac] Passed Under C.O.No.14/Pun/2025 [A] & Ita No.2720/Pun/2024 [R]

reassessment order dated March 19, 2024 under section 147 read with section 144B of the Act ("reassessment order") are bad-in-law on account

BVG INDIA LIMITED,PUNE vs. DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-1(2), PUNE, PUNE

In the result, the appeal of the assessee is allowed

Bench: Shri S.S. Viswanethra Ravi & Shri G.D. Padmahshali

reassessment is passed pursuant to a search operation is a mandatory requirement of Section 153D of the Act and that such approval is not meant to be given mechanically. The Court also concurs with the finding of the ITAT that in the present cases such approval was granted mechanically without application of mind by the Additional CIT resulting in vitiating

ANANDA GORAKHANATH PAWAR,SATARA vs. ASSESSING OFFICER, WARD 3, SATARA, SATARA

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

Bench: Shri R. K. Panda & Shri Vinay Bhamoreआयकर अपील सं. / Ita No.1796/Pun/2025 िनधा"रण वष" / Assessment Year : 2018-19 Ananda Gorakhanath Pawar, Vs. Ito, Ward-3, Satara. At Post Ambawade, Khatav, Satara- 415506. Pan : Blhpp6081R Appellant Respondent Assessee By Shri R. C. Doshi : Revenue By : Shri Milind Debaje Date Of Hearing : 28.08.2025 Date Of Pronouncement : 28.08.2025 आदेश / Order Per Vinay Bhamore, Jm: This Appeal Filed By The Assessee Is Directed Against The Order Dated 30.06.2025 Passed By Ld. Cit(A)/Nfac For The Assessment Year 2018-19. 2. The Appellant Has Filed The Following Grounds Of Appeal :- “1. The Learned Cit Has Erred Both On Facts & In Law In Dismissing The Appeal Of The Appellant By Refusing To Condone The Delay Of 26 Days On Grounds Of Period Of Limitation, Notwithstanding The Fact That Appellant Has Submitted The Application & Explained The Reasons For Delay.

reassessment dated 29/03/2022. b) The Copy of the approval given by the prescribed authority was not enclosed with notice u/s 148A(b), u/s 148 as well as order u/s 184A(d) of the Act as required by CBDT guidelines and various judicial pronouncement. c) The information of cash withdrawal from bank does not suggest escapement of income liable

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

INCOME TAX OFFICER WARD 3, SATARA, INCOME TAX OFFICE SATARA vs. NANDKUMAR DATTATRAY KHOT, DAHIWADI MAN

In the result, Cross Objection appeal filed by the assessee is allowed

Bench: Dr.Dipak P. Ripote & Shri Vinay Bhamoreआयकर अपील सं. /Ita No.1562/Pun/2024 िनधा"रण वष" / Assessment Year: 2015-16 The Income Tax Officer, V Nandkumar Dattatray Khot, Ward-3, Satara S Shri Agencies Dahiwadi, Dahiwadi, Man Satara. Maharashtra – 415508. Pan: Aatpk8947P Appellant/ Revenue Respondent/ Assessee Cross Objection No.11/Pun/2025 िनधा"रण वष" / Assessment Year: 2015-16 Nandkumar Dattatray Khot, V The Income Tax Officer, Shri Agencies Dahiwadi, S Ward-3, Satara. Dahiwadi, Man Satara. Maharashtra – 415508. Pan:Aatpk8947P Appellant/ Assessee Respondent /Revenue Assessee By Shri Suhas Kulkarni - Ar Shri Vidya Ratna Kishor – (Dr)(Virtual) Revenue By Date Of Hearing 25/03/2025 Date Of Pronouncement 24/04/2025 आदेश/ Order Per Dr. Dipak P. Ripote, Am: This Is An Appeal Filed By The Revenue Against The Order Of The Commissioner Of Income Tax (Appeal) (Nfac) Under Section 250 Of

Section 144B of the Income Tax envisages administrative freedom to the CBD'T to transfer any assessment proceedings, including proceedings relating to issuance of notice u/s.148 of the Act to the Assessing Officer havingjurisdiction over such case in proper utilization of its resources and therefore, reassessment

BABABHAI SADARBHAI SHAIKH,AHMEDNAGAR vs. ITO WARD 1, AHMEDNAGAR, AHMEDNAGAR

In the result, the appeal filed by the assessee is allowed for statistical purposes

Bench: Shri R. K. Panda & Ms. Astha Chandraassessment Year : 2015-16 Bababhai Sadarbhai Shaikh Ito, Ward 1, Nr Goraba Takies Jamkhed, Vs. Ahmednagar Ahmednagar – 413201 Pan: Hozps1445M (Appellant) (Respondent) Assessee By : Shri Suhas P Bora Department By : Shri Ratnakar Bhimrao Shelake Date Of Hearing : 10-09-2025 Date Of Pronouncement : 23-10-2025 O R D E R Per R.K. Panda, Vp:

Section 144B of the Act and subsequently confirmed by the Commissioner of Income Tax (Appeals) [CIT(A)], is bad in law due to the following reasons: a) The reassessment

ANWAR HUSAIN MEHBOOB SHAIKH,JALGAON vs. INCOME TAX OFFICER, JALGAON

In the result, appeal of the assessee is allowed for statistical purpose

Bench: Dr.Dipak P. Ripote & Shri Vinay Bhamoreआयकर अपऩल सं. / Ita No.2561/Pun/2025 निर्धारण वषा / Assessment Year: 2018-19 Anwar Husain Mehboob V The Income Tax Officer, Shaikh, S Jalgaon. H. No.K 258/I Railway North Area, Bhusawal, Jalgaon – 425201. Pan: Bodps9742F Appellant/ Assessee Respondent / Revenue Assessee By None Revenue By Shri Sandeep Sathe - Dr Date Of Hearing 10/12/2025 Date Of Pronouncement 12/12/2025 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.2018-19 Dated 21.08.2025 Emanating From The Assessment Order Passed Under Section 147 R.W.S 144 Of The Act, Dated 31.01.2024. The Assessee Has Raised The Following Grounds Of Appeal :

reassessment of income for the AY 2018-19 was wrongly issued by by the Jurisdictional Assessing Officer instead of Faceless Assessing Officer. 2. That the Jurisdictional AO has under section 148 of the Act. Excess is authority by issuing notice under section 148 of the Act. 3. That the notice issued under section 148 violates the section 151A and 144B

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

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

Bench: Dr. Manish Borad & Shri Vinay Bhamore

section 250 of the Income Tax Act, 1961 (“Act”) which are arising out of separate orders u/s. 147 r.w.s. 144B of the Act, dated 29/03/2022 & 28/03/2022 for the Assessment Years (AY) 2014-15 & 2015-16 respectively. 2 ITA.Nos.1415 & 1416/PUN./2024 (Vinodkumar Dhanulalji Sawji) 2. There is a delay of 163 and 164 days in filing

SACHIN PRAKASHCHAND AANCHALIYA,AURANGABAD vs. ITO WARD 1 (1), AURANGABAD

In the result, appeal of the assessee is allowed for statistical purpose

Bench: Or At The Time Of Hearing Of The Appeal.”

section 144B of the Income Tax Act, 1961 vide DIN NO.:ITBA/AST/S/147/2021- 22/1042122519(1) dated 30/03/2022 along with notice of demand dated 30/03/2022 is not tenable in law and therefore the same may please be cancelled. 3. The appellant craves to add, delete, modify withdraw any of the grounds before or at the time of hearing of the appeal

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

reassessments under s. 147 because s. 144B stated that it applied only to "an assessment to be made under sub- s. (3) of s. 143". The submission cannot be accepted because the words we have quoted from s. 148 cannot be ignored. A notice having been issued under s. 148, the procedure set out in the sections

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

reassessments under s. 147 because s. 144B stated that it applied only to "an assessment to be made under sub- s. (3) of s. 143". The submission cannot be accepted because the words we have quoted from s. 148 cannot be ignored. A notice having been issued under s. 148, the procedure set out in the sections

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

reassessments under s. 147 because s. 144B stated that it applied only to "an assessment to be made under sub- s. (3) of s. 143". The submission cannot be accepted because the words we have quoted from s. 148 cannot be ignored. A notice having been issued under s. 148, the procedure set out in the sections

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

reassessments under s. 147 because s. 144B stated that it applied only to "an assessment to be made under sub- s. (3) of s. 143". The submission cannot be accepted because the words we have quoted from s. 148 cannot be ignored. A notice having been issued under s. 148, the procedure set out in the sections

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

reassessments under s. 147 because s. 144B stated that it applied only to "an assessment to be made under sub- s. (3) of s. 143". The submission cannot be accepted because the words we have quoted from s. 148 cannot be ignored. A notice having been issued under s. 148, the procedure set out in the sections

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

reassessments under s. 147 because s. 144B stated that it applied only to "an assessment to be made under sub- s. (3) of s. 143". The submission cannot be accepted because the words we have quoted from s. 148 cannot be ignored. A notice having been issued under s. 148, the procedure set out in the sections