VATSALABAI KARBHARI DEORE,KALWAN vs. INCOME TAX OFFICER, WARD 1(5), NASHIK

In the result, the appeal filed by the assessee is allowed as per terms indicated above

Bench: Dr.Manish Borad & Shri Vinay Bhamoreआयकर अपील सं. / Ita No.2274/Pun/2025 Assessment Year : 2011-12

197 9. PCIT v. Raja Transports (Madras HC) [2023] 154 Taxmann 589 8. On the other hand, ld. Departmental Representative vehemently argued supporting the order of ld.CIT(A) and submitted that the Assessing Officer has reason to believe that income has escaped assessment and that the reassessment proceedings have been initiated within four years from the end of the assessment

RAJARSHI SHAHU SHIKSHAN SANSTHA INAM DHAMANI,SANGLI vs. ITO EXEMPTION, KOLHAPUR, KOLHAPUR

In the result, all the appeals filed by the assessee are partly allowed as per terms indicated hereinabove

Bench: Dr.Manish Borad & Shri Vinay Bhamoreआयकर अपील सं. / Ita Nos.1121 To 1126/Pun/2024 Assessment Years : 2012-13 To 2017-18

reassessment is bad in law being not validly initiated. 8. Learned CIT [A] has erred in fact and in law in following decision of Pune ITAT in the case of Ninaidevi Shikshan Prasarak Mandal, as well as in the case of Everest Education society because in both these cases trust did not file proper details and filed

RAJARSHI SHAHU SHIKSHAN SANSTHA INAM DHAMANI,SANGLI vs. ITO EXEMPTION, KOLHAPUR, KOLHAPUR

In the result, all the appeals filed by the assessee are partly allowed as per terms indicated hereinabove

Bench: Dr.Manish Borad & Shri Vinay Bhamoreआयकर अपील सं. / Ita Nos.1121 To 1126/Pun/2024 Assessment Years : 2012-13 To 2017-18

reassessment is bad in law being not validly initiated. 8. Learned CIT [A] has erred in fact and in law in following decision of Pune ITAT in the case of Ninaidevi Shikshan Prasarak Mandal, as well as in the case of Everest Education society because in both these cases trust did not file proper details and filed

RAJARSHI SHAHU SHIKSHAN SANSTHA INAM DHAMANI,SANGLI vs. ITO EXEMPTION, KOLHAPUR

In the result, all the appeals filed by the assessee are partly allowed as per terms indicated hereinabove

Bench: Dr.Manish Borad & Shri Vinay Bhamoreआयकर अपील सं. / Ita Nos.1121 To 1126/Pun/2024 Assessment Years : 2012-13 To 2017-18

reassessment is bad in law being not validly initiated. 8. Learned CIT [A] has erred in fact and in law in following decision of Pune ITAT in the case of Ninaidevi Shikshan Prasarak Mandal, as well as in the case of Everest Education society because in both these cases trust did not file proper details and filed

RAJARSHI SHAHU SHIKSHAN SANSTHA INAM DHAMANI,SANGLI vs. ITO EXEMPTION , KOLHAPUR, KOLHAPUR

In the result, all the appeals filed by the assessee are\npartly allowed as per terms indicated hereinabove

reassessment is\nmade merely on the basis of change of opinion having similar set of\nfacts and such an attempt is not sustainable and ergo the\nreassessment is bad in law being not validly initiated.\n8. Learned_CIT [A] has erred in fact and in law in following\ndecision of Pune ITAT in the case of Ninaidevi Shikshan Prasarak\nMandal

RAJARSHI SHAHU SHIKSHAN SANSTHA INAM DHAMANI,SANGLI vs. ITO EXEMPTION, KOLHAPUR, KOLHAPUR

In the result, all the appeals filed by the assessee are\npartly allowed as per terms indicated hereinabove

reassessment is\nmade merely on the basis of change of opinion having similar set of\nfacts and such an attempt is not sustainable and ergo the\nreassessment is bad in law being not validly initiated.\n8. Learned_CIT [A] has erred in fact and in law in following\ndecision of Pune ITAT in the case of Ninaidevi Shikshan Prasarak\nMandal

RAJARSHI SHAHU SHIKSHAN SANSTHA INAM DHAMANI,SANGLI vs. ITO EXEMPTION, KOLHAPUR

In the result, all the appeals filed by the assessee are\npartly allowed as per terms indicated hereinabove

reassessment is\nmade merely on the basis of change of opinion having similar set of\nfacts and such an attempt is not sustainable and ergo the\nreassessment is bad in law being not validly initiated.\n8. Learned_CIT [A] has erred in fact and in law in following\ndecision of Pune ITAT in the case of Ninaidevi Shikshan Prasarak\nMandal

KISHOR KESARIMAL OSWAL,PUNE vs. INCOME-TAX OFFICER, WARD 6(3), PUNE

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

Bench: Shri R.S. Syal & Shri Partha Sarathi Chaudhury

reassessment the amount was added as per the provision of IDS 2016 by noting as under: 2 ITA 415/PUN/2021 Kishor Kesarimal Oswal A.Y. 2011-12 “The assessee was declarant under IDS 2016 who have committed default in making payments as per schedule. As the assessee did not pay tax amount within specified time, the declaration became invalid. Action against

KAY POWER AND PAPER LIMITED,SATARA vs. INCOME TAX OFFICER, WARD-2, SATARA

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

Bench: Shri R. K. Panda & Shri Vinay Bhamore

197 (Madhya remedy of appeal was available Pradesh) Kailash Kedia vs ITO [(2023) 147 taxmann.com 126(Orissa) [(2022) taxmann.com 64(SC)] after 01.04.2021 under unamended section 148 of the Act. 3 Salil Gulati vs ACIT Applicability of first proviso to [(2023) 150 taxmann.com 50(SC)] section 149 and whether initiation of reassessment

KAY POWER AND PAPER LIMITED,SATARA vs. INCOME TAX OFFICER, WARD-2, SATARA

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

Bench: Shri R. K. Panda & Shri Vinay Bhamore

197 (Madhya remedy of appeal was available Pradesh) Kailash Kedia vs ITO [(2023) 147 taxmann.com 126(Orissa) [(2022) taxmann.com 64(SC)] after 01.04.2021 under unamended section 148 of the Act. 3 Salil Gulati vs ACIT Applicability of first proviso to [(2023) 150 taxmann.com 50(SC)] section 149 and whether initiation of reassessment

JOHN DEERE EQUIPMENT PVT.LTD,,PUNE vs. DEPUTY COMMISSIONER OF INCOME TAX,, PUNE

In the result, both the appeals of assessee are allowed as indicated above

Bench: Ms. Sushma Chowla, Jm & Shri Anil Chaturvedi, Am आयकर अपीऱ सं. / Ita No.1163/Pun/2017 यििाारण वषा / Assessment Year : 2008-09 John Deere Equipment Pvt. Ltd., (Now Merged With John Deere India Pvt. Ltd.) Tower Xiv, Cybercity, Magarpatta City, Hadapsar, अऩीऱाथी/Appellant Pune – 411028 …. Pan: Aaacl7331A Vs. The Dy. Commissioner Of Income Tax, …. प्रत्यथी / Respondent Circle 14, Pune

reassessment u/s. 147 be declared null and void. 2] The learned CIT(A) erred in confirming the disallowance of Rs.12,837,828/- u/s. 40(a)(i) of the Act in respect of information system charges and telecommunication expenses debited by the assessee without appreciating that no disallowance was warranted on facts of the case. ITA Nos.1163 & 1164/PUN/2017 3 John Deere

JOHN DEERE INDIA PVT.LTD,,PUNE vs. DEPUTY COMMISSIONER OF INCOME TAX,, PUNE

In the result, both the appeals of assessee are allowed as indicated above

Bench: Ms. Sushma Chowla, Jm & Shri Anil Chaturvedi, Am आयकर अपीऱ सं. / Ita No.1163/Pun/2017 यििाारण वषा / Assessment Year : 2008-09 John Deere Equipment Pvt. Ltd., (Now Merged With John Deere India Pvt. Ltd.) Tower Xiv, Cybercity, Magarpatta City, Hadapsar, अऩीऱाथी/Appellant Pune – 411028 …. Pan: Aaacl7331A Vs. The Dy. Commissioner Of Income Tax, …. प्रत्यथी / Respondent Circle 14, Pune

reassessment u/s. 147 be declared null and void. 2] The learned CIT(A) erred in confirming the disallowance of Rs.12,837,828/- u/s. 40(a)(i) of the Act in respect of information system charges and telecommunication expenses debited by the assessee without appreciating that no disallowance was warranted on facts of the case. ITA Nos.1163 & 1164/PUN/2017 3 John Deere

SHAKIL SHAKUR BIJAPURE,SATARA vs. DCIT , SATARA

In the result, both the appeals filed by the assessee are allowed for statistical purposes

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

section 197(b) of the Finance Act, 2016 where the declarant fails to make the prescribed payment, the declaration stands void ab initio, and the disclosed income becomes chargeable to tax under the regular provisions of the Income Tax Act, 1961. Consequently, the declaration made by the assessee lost its legal sanctity and the amount of Rs.95

SHAKIL SHAKUR BIJAPURE ,SATARA vs. DCIT, SATARA

In the result, both the appeals filed by the assessee are allowed for statistical purposes

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

section 197(b) of the Finance Act, 2016 where the declarant fails to make the prescribed payment, the declaration stands void ab initio, and the disclosed income becomes chargeable to tax under the regular provisions of the Income Tax Act, 1961. Consequently, the declaration made by the assessee lost its legal sanctity and the amount of Rs.95

SANJAY PATIL,MAHARASHTRA vs. INCOME TAX OFFICER, WARD 2(1), KOLHAPUR, KOLHAPUR

In the result Appeal of the Assessee Allowed

Bench: Dr.Dipak P. Ripote & Shir Vinay Bhamoreआयकर अपील सं. / Ita No.1239/Pun/2024 िनधा"रण वष" / Assessment Year: 2017-18 Sanjay Shamrao Patil, Vs The Income Tax Officer, 2013/3, Anu Krishna Niwas E Ward-2(1), Kolhapur. Ward, Rukmini Nagar, Maharashtra – 416001. Pan: Abqpp6417K Appellant/ Assessee Respondent / Revenue Assessee By None Revenue By Shri Sandeep P Sathe – Jcit(Dr) Date Of Hearing 22/08/2024 Date Of Pronouncement 23/08/2024 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)[Nfac], Passed Under Section 250 Of The Income Tax Act, Dated 30.03.2024For The A.Y.2017-18. The Assessee Has Raised The Following Grounds Of Appeal : 1) The Order Dated 30-03-2024 Hearing No. Itba/Nfac/S/250/2023- 24/1063699666(1) Passed Under Section 250 Of Income-Tax Act, 1961 By The Hon'Ble Cit[Appeals], National Faceless Appeal Centre [Nfac], Sanjay Patil[A]

Section 187(3) & 197 of IDS 2016, Income of Rs.17,64,513/- was treated as Income of AY 2017-18, hence notice u/s 148 was issued in the case of the assessee. During the reassessment

DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-2, NASHIK, NASHIK vs. ABHAYRAJ FATTEHRAJ CHORDIYA, C/O LAXMI OIL MIL

In the result, the appeal filed by the Revenue is dismissed and the CO filed by the assessee is allowed

Bench: Shri R. K. Panda & Ms. Astha Chandraassessment Year : 2014-15

197 (Karnataka), he submitted that the Hon’ble High Court in the said decision has held that the satisfaction note is required to be recorded under section 153C for each assessment year, therefore, where a consolidated satisfaction note has been recorded for different assessment years the same vitiates the entire assessment proceedings. He submitted that the SLP filed

DY. COMMISSIONER OF INCOME TAX (EXEMPTIONS), CIRCLE, PUNE, SWARGATE, PUNE vs. DR D Y PATIL UNITECH SOCIETY, PUNE

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

Bench: Shri R. K. Panda & Ms. Astha Chandraassessment Year : 2013-14 Dcit (Exemption) Dr D Y Patil Unitech Society Circle, Pune Flat No.101, Shree Motisagar Vs. Apartment, G G Thakkar Road, S No.173A, Pune – 411001 Pan: Aabtd1482A (Appellant) (Respondent) Assessee By : Shri Nikhil S Pathak Department By : Shri Amol Khairnar, Cit-Dr Date Of Hearing : 27-10-2025 Date Of Pronouncement : 04-11-2025 O R D E R Per R.K. Panda, Vp:

section 11(2) of the Act does not extend to nullify the absolute exemption. Similar view has been taken by the Hon’ble Supreme Court in the case of CIT vs. Programme for Community Organization reported in 248 ITR 1 (SC). The decision of the Pune Bench of the Tribunal in the case of Maharshi Karve Stree Shikshan Samstha

CHANDUKAKA SARAF AND SONS PVT.LTD,,PUNE vs. PR. COMMISSIONER OF INCOME-TAX , (CENTRAL),, PUNE

In the result, all the seven appeals of the assessee are partly allowed

197/- 37,92,68,944/- 2015-16 27,54,93,430/- 28,04,03,784/- 5. From the above table, it is evident that the Assessing Officer made certain additions (i.e. Rs.42,24,481/- for A.Y. 2009-10) on account of bogus purchases calculating at the rate of 2% of URD purchases made in cash on ad-hoc basis. This

CHANDUKAKA SARAF AND SONS PVT.LTD,,PUNE vs. PR. COMMISSIONER OF INCOME-TAX , (CENTRAL),, PUNE

In the result, all the seven appeals of the assessee are partly allowed

197/- 37,92,68,944/- 2015-16 27,54,93,430/- 28,04,03,784/- 5. From the above table, it is evident that the Assessing Officer made certain additions (i.e. Rs.42,24,481/- for A.Y. 2009-10) on account of bogus purchases calculating at the rate of 2% of URD purchases made in cash on ad-hoc basis. This