M/S MANILAL P. SAVLA & COMPANY,PUNE vs. ACIT, CIRCLE 5, PUNE

In the result, the appeal of the assessee is allowed

reassessment order u/s 147 is without jurisdiction and bad in law\nbecause the assessing officer has wrongly invoked the provisions of section 189

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

189 W.P. (T) No. 675 of 2022 (Ranchi), has held at paragraphs 11 and 12 has held as under (page 543 of 455 ITR): "It is well settled principles with regard to reassessment. A reassessment proceeding is to be adjudged on the basis of ’reason to believe" disclosed to the assesses and the said reasons cannot be supplemented

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

189 Taxman 1 (Bombay), the Hon'ble High Court held as under: "9. Section 147 provides that if the Assessing Officer has reason to believe that any income chargeable to tax has escaped assessment for any assessment year, he may subject to the provisions of sections 148 to 163, assess or reassess

SHAMKANT KESHAV KOTKAR (PROP. NANDAN BUILDERS),PUNE vs. PR. COMMISSIONER OF INCOME TAX (CENTRAL), PUNE

In the result, appeal of the assessee is allowed

Bench: SHRI VINAY BHAMORE (Judicial Member)

189/- with reference to interest on TDS has been made under section 40(a)(i) of the Act. 8. The Principal Commissioner of Income Tax(Central)[Pr.CIT], Pune on perusal of the records, invoked jurisdiction u/s.263 of the 9 ITA No.1358/PUN/2025 [A] Act. The Pr.CIT issued Show cause notice to the Assessee dated 30.05.2024 u/s.263 of the Act, which

CLARION TECHNOLOGIES PVT. LTD.,,PUNE vs. DEPUTY COMMISSIONER OF INCOME-TAX,,

In the result, the appeal of assessee is allowed

Bench: Shri R.S. Syal & Shri S.S. Viswanethra Ravi

sections 148 to 153, assess or reassess such income and also any other income chargeable to tax which has escaped assessment and which comes to his notice subsequently. He submits that if an assessment was made u/s. 143(3) of the Act and no action can be taken u/s. 147 of the Act after the expiry of four years from

DEPUTY COMMISSIONER OF INCOME-TAX vs. CLARION TECHNOLOGIES PVT. LTD.,, PUNE

In the result, the appeal of assessee is allowed

Bench: Shri R.S. Syal & Shri S.S. Viswanethra Ravi

sections 148 to 153, assess or reassess such income and also any other income chargeable to tax which has escaped assessment and which comes to his notice subsequently. He submits that if an assessment was made u/s. 143(3) of the Act and no action can be taken u/s. 147 of the Act after the expiry of four years from

NARENDRA KACHRULAL ABAD,JALNA vs. INCOME-TAX OFFICER, WARD - 1,, JALNA

In the result, appeal of the assessee partly allowed

Bench: Dr.Dipak P. Ripote & Shri Vinay Bhamoreआयकर अपऩल सं. / Ita No.866/Pun/2019 निर्धारण वषा / Assessment Year: 2009-10 Shri Narendra Kachrulal Abad, V The Income Tax Officer, Abad House, Nal Galli, S Ward-1, Jalna. Kadrabad, Jalna – 431203. Maharashtra. Pan: Acspa9531C Appellant/ Assessee Respondent / Revenue Assessee By Shri Hari Krishan – Ar Revenue By Shri Arvind Renge –Addl.Cit(Dr) Date Of Hearing 28/07/2025 Date Of Pronouncement 06/10/2025 आदेश/ Order Per Dr. Dipak P. Ripote, Am: This Is An Appeal Filed By Assessee Against The Order Of Ld.Commissioner Of Income Tax(Appeal)-1, Aurangabadpassed Under Section 250 Of The Income Tax Act, 1961 For The A.Y.2009-10 Dated 30.03.2019, Emanating From Order U/S.143(3) R.W.S 147Of The Income Tax Act, 1961, Dated 03.11.2017. The Assessee Has Raised The Following Concise Grounds Of Appeal :

section 147 the item of income on which the Commissioner of Income Tax (Appeals) has made the enhancement, does not fall within the scope of reassessment u/s 147 of the Act. There was no information/record etc. before the Assessing Officer in there-assessment proceedings from which he could have noted that the item of income of Rs.29

ACIT, CENTRAL CIRCLE-1, NASHIK, NASHIK vs. RAJENDRA RASIKLAL SHAH, NASHIK

In the result, the appeal of the Revenue is dismissed

Bench: Dr.Manish Borad & Ms. Astha Chandraआयकर अपील सं. / Ita No.1015/Pun/2024 Assessment Year : 2013-14

reassessment proceedings which culminated into the impugned addition. Now the facts narrated by the ld. Counsel for the appeal indicate that the assessee purchased land during F.Y. 1992-93 and sold it in F.Y. 1996-97 for a consideration of Rs.45.00 lakhs and the assessee after claiming the cost of acquisition at Rs.21,98,230/- offered the remaining profit

DEPUTY COMMISSIONER OF INCOME TAX, CIRCLE-1, AURANGABAD, AURANGABAD vs. PRABHA FARMS PRIVATE LIMITED, AURANGABAD

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

Bench: Shri R. K. Panda & Shri Vinay Bhamoreआयकर अपील सं. / Ita No.1748/Pun/2024 िनधा"रण वष" / Assessment Year : 2013-14 Dcit, Circle-1, Vs. Prabha Farms Private Aurangabad. Limited, Akash, Paithan Road, Aurangabad- 431005. Pan : Aaccp3782D Appellant Respondent C. O. No.07/Pun/2025 (Arising Out Of Ita No.1748/Pun/2024) िनधा"रण वष" / Assessment Year : 2013-14 Prabha Farms Private Vs. Dcit, Circle-1, Limited, Aurangabad. Akash, Paithan Road, Aurangabad- 431005. Pan : Aaccp3782D Appellant Respondent Revenue By : Shri Arvind Desai Assessee By : Shri N. R. Agrawal Date Of Hearing : 24.02.2025 Date Of Pronouncement : 16.05.2025 आदेश / Order Per Vinay Bhamore, Jm: This Appeal Filed By The Revenue Is Directed Against The Order Dated 26.06.2024 Passed By Ld. Cit(A)/Nfac For The Assessment

reassessment order however an appeal was preferred before Ld. CIT(A)/NFAC against the penalty order dated 27.09.2022. Ld. CIT(A)/NFAC allowed the appeal by deleting the penalty levied at Rs.72,93,114/- and this is the order against which the Revenue is in appeal before the Tribunal. 3. The Revenue has raised the following grounds of appeal

SANDVIK AB,,PUNE vs. ASSISTANT COMMISSIONER OF INCOME-TAX, (IT),CIRCLE -2, , PUNE

The appeal of the assessee is partly allowed for statistical purposes

Bench: Shri R.S. Syal & Shri Partha Sarathi Chaudhury, Jm आयकर अपील सं. / Ita No.1311/Pun/2019 "नधा"रण वष" / Assessment Year : 2016-17 Sandvik Ab, ………. अपीलाथ" / C/O. Sandvik Asia Private Limited, Appellant Mumbai – Pune Road, Dapodi, Pune, Maharashtra. Pan : Aahcs7486E. बनाम V/S ………. ""यथ" / The Asst. Commissioner Of Income Respondent Tax (International Taxation), Circle – 2, Pune.

reassessment proceedings was invalid. 2007-08 59,297,919 Taxable Taxable Not taxable. (The Hon’ble ITAT held that the Management Service Fees are not taxable in India, since managerial in nature and also the ‘make available’ clause is not satisfied.) Taxable Taxable 2008-09 86,002,251 Not taxable. (The Hon’ble ITAT held that the Management Service Fees