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:

2. The Grounds of Appeal raised by the assessee are as under: ITA Nos.3280 & 3281/PUN/2025 [A] ITA Nos.3280 & 3281/PUN/2025 [A] 3. Both these appeals were heard together and are disposed by this common order. In this case for AY 2016-17 the assessee had filed Return of Income on 17/10/2016 declaring Total Income at Rs.11,41,070/-. Assessee had filed

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:

2. The Grounds of Appeal raised by the assessee are as under: ITA Nos.3280 & 3281/PUN/2025 [A] ITA Nos.3280 & 3281/PUN/2025 [A] 3. Both these appeals were heard together and are disposed by this common order. In this case for AY 2016-17 the assessee had filed Return of Income on 17/10/2016 declaring Total Income at Rs.11,41,070/-. Assessee had filed

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

reassessment under Sections 139, 147, 148, 149, 151 & 153.\n28. The language of explanation 2 to new Section 148 is akin

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

section 151. The brief fact is that the assessee applied to the AO for a copy of inward and outward register maintained between 24.03.2017 to 05.04.2017 but the request was rejected citing that those were confidential records and cannot be provided. Thereafter, the assessee requested for a copy of online approval from PrCIT u/s 151. The AO however stated that

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

reassessment under Sections 139, 147, 148, 149, 151 & 153. 28. The language of explanation 2 to new Section 148 is akin

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 notice issued and the consequential order passed may quashed and set aside 2. Ground No 2: Approval obtained under section 151

MUKUNDA PANDIT CHAUGULE,PANDHURLI vs. INCOME TAX OFFICER, NASHIK

In the result, appeal of the assessee is allowed

Bench: Dr.Dipak P. Ripote & Shri Vinay Bhamoreआयकर अपऩल सं. / Ita No.3194/Pun/2025 निर्धारण वषा / Assessment Year: 2017-18 Mukunda Pandit Chaugule, V The Income Tax Officer, 471A, Shimpi Lane, Pandurli S Nashik. B.O., Pandhurli, Nashik – 422502 Pan: Atepc5427G Appellant/ Assessee Respondent /Revenue Assessee By Shri Sanket Joshi (Virtual) Revenue By Shri Sadananda – Jcit(Dr) Date Of Hearing 10/02/2026 Date Of Pronouncement 11/02/2026 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 26.09.2025 Emanating From The Assessment Order Passed Under Section 147R.W.S 144 Read With Section 144B Of The I.T.Act, 1961 Dated 20.04.2023. The Assessee Has Raised The Following Grounds Of Appeal :

reassessment comes to be issued after the expiry of four years by virtue of the extended period of time made available by TOLA, all the impugned notices would fall within the ken of sub-section (2) of the pre-amendment Section 151

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

Section 151(2) has extended time till 31 March 2021 to grant approval; 11 Pushpadevi Shivlal Rathi f. The directions in Ashish Agarwal (supra) will extend to all the ninety thousand reassessment

MAHESH GOKULDAS FULWANI,AURANGABAD vs. ITO WARD 1(1) AURANGABAD, AURANGABAD

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

Bench: Shri R. K. Panda & Ms. Astha Chandraassessment Year : 2017-18 Mahesh Gokuldas Fulwani Ito, Ward 1(1), Mahesh Traders C O Girls Fashion, Aurangabad Vs. 2/7/63, Tilak Path, Paithan Gate, Aurangabad- 431001 Pan: Aajpf4456C (Appellant) (Respondent) Assessee By : Shri Girish Ladda Department By : Shri Ramnath P Murkunde Date Of Hearing : 28-07-2025 Date Of Pronouncement : 30-07-2025 O R D E R

151 (ii) from chief commissioner of Income tax. Accordingly, the reassessment Proceedings so initiated without valid approval/sanction may kindly be annulled. a) Reliance placed on Bombay HC Holiday Developers (P.) Ltd, 159 taxmann.com 178 b) Bombay HC in case of Gigantic Mercantile (P.) Ltd. vs. ACIT, 165 taxmann.com 646 c) PUNE ITAT in Rajaram Jaju ITA 1882/PUN/2024 dated 07/03/2025 2

SOMNATH RAMDAS JADHAV,AHMEDNAGAR vs. ITO WARD2, AHMEDNAGAR

Accordingly, the appeal in ITA No.1092/PUN/2025 for A.Y. 2013-14 involving the issue of penalty u/s 271(1)(c) of the Act is allowed

Bench: Shri Manish Borad & Shri Vinay Bhamore

151 and section 153, where the Assessing Officer is satisfied that,— (a) any money, bullion, jewellery or other valuable article or thing, seized or requisitioned, belongs to; or (b) any books of account or documents, seized or requisitioned, pertains or pertain to, or any information contained therein, relates to, a person other than the person referred to in section 153A

SOMNATH RAMDAS JADHAV,AHMEDNAGAR vs. ITO, WARD 2, AHMEDNAGAR, AHMEDNAGAR

Accordingly, the appeal in ITA No.1092/PUN/2025 for A.Y. 2013-14 involving the issue of penalty u/s 271(1)(c) of the Act is allowed

Bench: Shri Manish Borad & Shri Vinay Bhamore

151 and section 153, where the Assessing Officer is satisfied that,— (a) any money, bullion, jewellery or other valuable article or thing, seized or requisitioned, belongs to; or (b) any books of account or documents, seized or requisitioned, pertains or pertain to, or any information contained therein, relates to, a person other than the person referred to in section 153A

SOMNATH RAMDAS JADHAV,AHMEDNAGAR vs. ITO WARD 2, AHMEDNAGAR

Accordingly, the appeal in ITA No.1092/PUN/2025 for A.Y. 2013-14 involving the issue of penalty u/s 271(1)(c) of the Act is allowed

Bench: Shri Manish Borad & Shri Vinay Bhamore

151 and section 153, where the Assessing Officer is satisfied that,— (a) any money, bullion, jewellery or other valuable article or thing, seized or requisitioned, belongs to; or (b) any books of account or documents, seized or requisitioned, pertains or pertain to, or any information contained therein, relates to, a person other than the person referred to in section 153A

SOMNATH RAMDAS JADHAV,AHMEDNAGAR vs. ITO, WARD 2, AHMEDNAGAR, AHMEDNAGAR

Accordingly, the appeal in ITA No.1092/PUN/2025 for A.Y. 2013-14 involving the issue of penalty u/s 271(1)(c) of the Act is allowed

Bench: Shri Manish Borad & Shri Vinay Bhamore

151 and section 153, where the Assessing Officer is satisfied that,— (a) any money, bullion, jewellery or other valuable article or thing, seized or requisitioned, belongs to; or (b) any books of account or documents, seized or requisitioned, pertains or pertain to, or any information contained therein, relates to, a person other than the person referred to in section 153A

AMIT SURESH AGRAWAL,SATARA vs. ITO WARD-2, SATARA

In the result, appeal of the assessee is partly allowed

Bench: Dr.Dipak P. Ripote & Shri Vinay Bhamoreआयकर अपऩल सं. / Ita No.2225/Pun/2025 निर्धारण वषा / Assessment Year: 2016-17 Amit Suresh Agrawal, V The Income Tax Officer, Amit Trading Co, Plot No.35, S Ward-2, Satara. Satara – 415002. Maharashtra. Pan: Abgpa2925D Appellant/ Assessee Respondent / Revenue Assessee By Shri Suhas Kulkarni – Advocate Revenue By Shri Eknath Abhang – Add.Cit(Dr) Date Of Hearing 30/10/2025 Date Of Pronouncement 30/10/2025 आदेश/ Order Per Dr. Dipak P. Ripote, Am: This 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.2016-17 Dated 02.04.2025 Emanating From The Assessment Order Passed Under Section 147 R.W.S 144B Of The Income Tax Act, 1961 Dated 10.05.2023. The Assessee Has Raised The Following Grounds Of Appeal :

2. The sanction under Section 151 of the Income Tax Act required for issuing the notice under Section 148 has been obtained from an Authority lacking jurisdiction to grant such approval, thereby rendering the entire reassessment

DY.COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-1, AURANGABAD, AURANGABAD vs. PARTH MULTITRADE PVT LTD, JALNA

In the result, the appeal filed by the Revenue and the CO filed by the assessee are allowed for statistical purposes

Bench: Shri R. K. Panda & Shri Vinay Bhamoreassessment Year : 2008-09

2), Mumbai to issue notice u/s 148 for the AY under consideration. Thus, the AO has not taken 3 CO No.28/PUN/2024 approval of the specified authority as prescribed in law. Since the approval itself is incorrect, the mandatory condition as provided under section 151 of the Act has not been fulfilled and therefore the notice issued under section

M/S KARIA BUILDERS ,PUNE vs. ITO WARD 14(3), PUNE

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

Bench: Shri R. K. Panda & Ms. Astha Chandraassessment Year : 2017-18 M/S. Karia Builders Ito, Ward 14(3), Pune 402, Konark Indrayu, Kondhwa, Vs. Pune – 411048 Pan: Aadfk5220B (Appellant) (Respondent) Assessee By : Shri Sanket M Joshi Department By : Shri Ramnath P Murkunde Date Of Hearing : 17-07-2025 Date Of Pronouncement : 23-07-2025 O R D E R

2. I, therefore, propose to assess or reassess such income or recompute the loss or the depreciation allowance or any other allowance or deduction for the Assessment Year 2017-18 and I, hereby, require you to furnish, within 30 days from the service of this notice, a return in the prescribed form for Assessment Year. 3. This notice is being

M/S ACCORD MEDIPLUS PVT LTD,PUNE vs. INCOME TAX OFFICER, WARD-1(1), PUNE, PUNE

151, reopening of assessment\nwas justified -Held, yes [Paras 2 and 3]\nIn the case Export Credit Guarantee Corporation of India Ltd. v\nAdditional Commissioner of Income-tax* DR. D.Y. CHANDRACHUD\nAND A.A. SAYED, JJ. WRIT PETITION NO. 502 OF 2012\nJANUARY 10/11, 2013, HIGH COURT OF BOMBAY, [2013] 30\ntaxmann.com 211 (Bombay), it is observed and decision delivered

M/S ACCORD MEDIPLUS PVT LTD,PUNE vs. INCOME TAX OFFICER, WARD-1(1), PUNE, PUNE

Bench: Dr.Manish Borad & Shri Vinay Bhamore

reassessment order as well as additions made therein may please be quashed. M/s. Accord Mediplus Pvt. Ltd. 7. On the facts and in the circumstances of the case, Ld. CIT- Appeal as well as Ld. AO have erred in law and on facts, in sustaining/making the addition of Rs. 8,96,41,183/- without appreciating the real intent behind introduction

M/S ACCORD MEDIPLUS PVT LTD,PUNE vs. INCOME TAX OFFICER, WARD-1(1), PUNE, PUNE

Bench: Dr.Manish Borad & Shri Vinay Bhamore

reassessment order as well as additions made therein may please be quashed. M/s. Accord Mediplus Pvt. Ltd. 7. On the facts and in the circumstances of the case, Ld. CIT- Appeal as well as Ld. AO have erred in law and on facts, in sustaining/making the addition of Rs. 8,96,41,183/- without appreciating the real intent behind introduction