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5 results for “reassessment”+ Section 144C(5)clear

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Key Topics

Section 14811Section 148A9Addition to Income5Section 144C(5)4Section 144C(1)4Section 1473Section 56(2)(x)3Reassessment3Section 144C(13)2Section 143(3)

MR. ABRAR FAKIRMOHMMAD SHAIKH,SOLAPUR vs. INCOME TAX OFFICER(INTERNATIONAL TAXATION), NASHIK

In the result, the appeal filed by the assessee stands partly allowed

ITA 208/PUN/2023[2014-15]Status: DisposedITAT Pune18 Oct 2023AY 2014-15

Bench: Shri Inturi Rama Rao & Shri S. S. Viswanethra Raviआयकर अपील सं. / Ita No.208/Pun/2023 िनधा"रण वष" / Assessment Year : 2014-15 Mr. Abrar Fakirmohmmad Vs. Ito (International Shaikh, Taxation), Nashik. At Manakeshwar, North Solapur, Tal. Bhoom, Barshi, Solapur- 413213. Pan : Chfps0191E Appellant Respondent Assessee By : Shri Rajiv Khandelwal Revenue By : Shri Prashant Gadekar Date Of Hearing : 10.10.2023 Date Of Pronouncement : 18.10.2023 आदेश / Order Per Inturi Rama Rao, Am: This Is An Appeal Filed By The Assessee Directed Against The Final Assessment Order Dated 20.12.2022 Passed U/S 147 R.W.S. 144C(13) Of The Income Tax Act, 1961 (‘The Act’) For The Assessment Year 2014-15. 2 2. Briefly, The Facts Of The Case Are That The Appellant Is An Individual & Non-Resident Indian In Terms Of Income-Tax Purpose. The Return Of Income For The Assessment Year 2014-15 Was Filed On 05.07.2014 Disclosing Total Income Of Rs.1,85,740/-. Against The Said Return Of Income, No Scrutiny Assessment Was Made. Subsequently, On Receipt Of The Information That The Appellant Made Cash Deposit Of Rs.1,20,40,000/- With Solapur District Co- Operative Central Bank, The Assessing Officer Formed An Opinion That The Income Had Escaped Assessment To Tax. Accordingly, The Assessing Officer Had Issued A Notice U/S 148 On 31.03.2021. In Response To Said Notice U/S 148, The Appellant Filed The Return Of Income On 03.04.2021 Disclosing Same Income As Declared In The Original Return Of Income. Against The Said Return Of Income, The Assessment Was Completed By The Assessing Officer Vide Order Dated 20.12.2022 Passed U/S 144C(13) R.W.S. 147 Of The Act At A Total Income Of Rs.1,23,98,740/-. While Doing So, The Assessing Officer Brought To Tax A Sum Of Rs.1,21,80,000/- Being The Amount Of Cash Deposits In The Bank I.E. Cash Deposits Of Rs.1,20,40,000/- Made With Solapur District Co-

For Appellant: Shri Rajiv Khandelwal
2
Transfer Pricing2
Disallowance2
For Respondent: Shri Prashant Gadekar
Section 144CSection 144C(13)Section 147Section 148Section 5

section 5 69A of the Act and passed a draft assessment order u/s 144C of the Act vide order dated 30.03.2022. On receipt of the draft assessment order, the appellant filed the objections before the DRP contending that the validity of the initiation of reassessment

LEAR AUTOMOTIVE INDIA P. LTD. ,PUNE vs. ASSISTANT COMMISSIONER OF INCOME TAX, CIRCLE-8, PUNE, PUNE

ITA 554/PUN/2024[2016-17]Status: DisposedITAT Pune10 Oct 2025AY 2016-17
For Appellant: \nShri Dhanesh Bafna &For Respondent: \nShri Prakash L. Pathade
Section 143(3)Section 144C(13)Section 144C(5)

reassessed\nRs.42,04,70,990/- by the Ld. AO vide draft assessment order passed u/s\n143(3)/254 r.w.s. 144B r.w.s. 144C(1) dated 31.03.2023 which was\nchallenged by the assessee by filing objections before the Ld. DRP.\n2.3 Before the Ld. DRP, the assessee raised the following objections\npertaining to allocation of RHQ charges :\n1.\n“6.1. Issue

LIQUIDHUB ANALYTICS PVT. LTD. (NOW MERGED WITH CAPGEMINI TECHNOLOGY SERVICES INDIA LTD),PUNE vs. NFAC, PUNE

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

ITA 1952/PUN/2024[2020-21]Status: DisposedITAT Pune25 Mar 2025AY 2020-21

Bench: Shri R. K. Panda & Shri Vinay Bhamoreassessment Year : 2020-21

For Appellant: Shri Nikhil PathakFor Respondent: Smt Nilu Jaggi, CIT
Section 143Section 143(3)Section 144C(1)

144C(13) dated July 26, 2024 on the name of the Appellant company which has ceased to exist pursuant to the merger with Capgemini Technology Services India Limited wef 1st April, 2020, duly approved by National Company Law Tribunal (NCLT) order dated 24 June 2021, thereby making the entire assessment proceedings as void-ab-initio and is liable

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

ITA 1796/PUN/2025[2018-19]Status: DisposedITAT Pune28 Aug 2025AY 2018-19

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.

For Respondent: Shri Milind Debaje
Section 143(2)Section 144BSection 147Section 148Section 148ASection 151ASection 184ASection 4

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

SHRI GURUDEV CHANDRASHEKHAR KARANTH,PUNE vs. INCOME TAX DEPARTMENT CIT(DRP-3), MUMBAI

In the result, Grounds Number 1 and 2 raised by the Assessee are allowed

ITA 147/PUN/2025[2018-19]Status: DisposedITAT Pune02 Jun 2025AY 2018-19

Bench: Dr.Manish Borad & Shri Vinay Bhamoreआयकर अपील सं. / Ita No.147/Pun/2025 िनधा"रण वष" / Assessment Year: 2018-19 Shri Gurudev Chandrashekhar V Income Tax Department Karanth, S. Cit(Drp-3), Mumbai-1. 21 Cozy Retreat, Sindh Colony, Aundh, Pune – 411007. Maharashtra. Pan: Cgnpk6203J Appellant/ Assessee Respondent / Revenue Assessee By Shri B.C.Malakar – Advocate Revenue By Shri Prakash L Pathade – Cit-Dr Date Of Hearing 04/03/2025 Date Of Pronouncement 02/06/2025 आदेश/ Order Per Vinay Bhamore, Jm: This Is An Appeal Filed By The Assessee Against The Assessment Order Under Section 147 R.W.S 144C(13) Of The Income Tax Act, 1961 Dated 23.12.2024 For The A.Y.2018-19, Emanating From The Order Of The Dispute Resolution Panel U/S.144C(5) Of The Act, Dated 20.12.2024. The Assessee Has Raised The Following Grounds Of Appeal :

Section 139Section 143(2)Section 144C(1)Section 144C(5)Section 147Section 148Section 148ASection 56(2)(x)Section 6

144C(13) of the Income Tax Act, 1961 dated 23.12.2024 for the A.Y.2018-19, emanating from the order of the Dispute Resolution Panel u/s.144C(5) of the Act, dated 20.12.2024. The Assessee has raised the following grounds of appeal : ITA No.147/PUN/2025 [A] “1. On the facts and in the circumstances of the case and in law the Hon'ble Dispute Resolution