MAHATMA GANDHI NAGRI SAHAKARI PAT SANSTHA MYDT UDGIR,LATUR vs. INCOME TAX OFFICER- WARD 1 -LATUR, LATUR

In the result, the appeal of the assessee is allowed

reassessment\nproceedings under Section 147 and has strenuously submitted\nthat the Assessing Officer has rightly observed that the interest\nderived from the credit provided to its member is deductible\nunder Section 80P(2)(a)(i) of the Act, however, on verification of\nthe case record at the stage of scrutiny assessment, it was\nnoticed that the assessee had received interest

INCOME TAX OFFICER, PUNE vs. SAGAR CONSTRUCTION COMPANY, PUNE

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 : 2017-18

E R PER R.K. PANDA, VP: This appeal filed by the Revenue is directed against the order dated 12.06.2025 of the Ld. CIT(A) / NFAC, Delhi relating to assessment year 2017-18. The assessee has filed the CO against the appeal filed by the Revenue. For the sake of convenience, the appeal filed by the Revenue and the CO filed

CAPGEMINI TECHNOLOGY SERVICES INDIA LIMITED ( SUCCESSOR OF ARICENT TECHNOLOGIES HOLDINGS LIMITED),PUNE vs. ASSISTANT COMMISSIONER OF INCOME TAX, CIRCLE 1(1), PUNE, PUNE

In the result, the appeal of the assessee is allowed

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

reassessment, referred to in clause (a) of sub-section (1), in a case where an order under sub-section (4) has been made accepting the application.‖. 5.3 Before leaping to section 270A of the Act, we first consider section 270AA of the Act in order to find out whether the Form 68 filed by the Assessee Company on 06/10/2022

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

e portal on or before 28/03/2024.\nSANTOSH KUMAR\n6.\nRejecting the various explanations given by the assessee, he set aside the\norder dated 13.12.2021 passed by the Assessing Officer disposing of the objections\nof the assessee to the notice dated 31.03.2021 issued u/s 148 of the Act for proper\nverification of fact and to re-examine the issues. The relevant

SHRI SHANTINATH BHAGWAN JAIN SHWETAMBAR MURTIPUJAK SANGH,PUNE vs. CIT, EXEMPTION,, PUNE

Appeal is allowed

Bench: Shri S.S. Godara & Shri G.D. Padmahshali

E)’s impugned order exercising section 263 revision jurisdiction terms the corresponding assessment /reassessment herein dated 29-09-2017 as an erroneous one causing prejudice to interest of the Revenue. Mr. Jain’s first and foremost arguments challenges the foregoing reassessment itself as not sustainable in law since the assessing officer had initiated the same regarding income of trust chargeable

SHANKAR NAGAPPA JADAGOUDA,KOLHAPUR vs. NFAC, DELHI

Appeal is allowed in above terms

Bench: Shri Satbeer Singh Godara

E-APPEAL] Assessment Year 2010-2011 Mr. Shankar Nagappa Jadagouda, Door No.127, The National Faceless Appeal Kalamba Road, HUDCO Centre [“NFAC”]. Colony, Kolhapur-416 012. vs. Delhi Maharashtra. PAN AELPJ7163G (Appellant) (Respondent) For Assessee : Shri Nikhil Pathak For Revenue : Shri Manish Mehta Date of Hearing : 22.03.2024 Date of Pronouncement : 17.04.2024 ORDER This assessee’s appeal for assessment year

VIJAYSHREE ALLOYS PUNE PRIVATE LTD.,,PUNE vs. DEPUTY COMMISSIONER OF INCOME-TAX,,

In the result, the impugned order is set aside and the appeal of assessee is partly allowed in the terms aforesaid

Bench: Shri D. Karunakara Rao, Am & Shri Vikas Awasthy, Jm

section 2(22)(e) of the Act. “(22) Dividend includes xxxxxxxxxxxx (e) any payment by a company, not being a company in which the public are substantially interested, of any sum (whether as representing a part of the assets of the company or otherwise) made after the 31st day of May, 1987, by way of advance or loan

RAJENDRA CHANDRAKANT CHINCHNIKAR,PUNE vs. CIT(A)-11, PUNE

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

Bench: Justice (Retd.) C V Bhadang & Shri R. K. Pandaassessment Year : 2019-20 Rajendra Chandrakant Chinchnikar Acit, Central Circle, 2165, B Ward, Koshti Galli, Vs. Kolhapur Mangalwar Peth, Pune – 416012 Pan: Acppc3559D (Appellant) (Respondent) Assessee By : Shri Tanzil Padvekar Department By : Shri Milind Debaje, Jcit Date Of Hearing : 25-08-2025 Date Of Pronouncement : 29-09-2025 O R D E R Per R.K. Panda, Vp:

reassessed has the effect of reducing the loss or converting such loss into income. (3) …… (4) …... (5) …… 12 (6) ….. (7) …. (8) …. (9) The cases of misreporting of income referred to in sub-section (8) shall be the following, namely:— (a) misrepresentation or suppression of facts; (b) failure to record investments in the books of account; (c) claim of expenditure

JAYANT KANERIA,,PUNE vs. DEPUTY COMMISSIONER OF INCOME-TAX, CIRCLE - 2,, PUNE

Appeal is allowed in above terms

Bench: Shri S.S.Godara, Jm & Shri Dr. Dipak P. Ripote, Am आयकर अपीऱ सं. / Ita No.1719/Pun/2019 ननधधारण वषा / Assessment Year : 2007-08

reassessment herein dated 23.12.2011 invoking section 2(22)(e) deemed dividend addition of Rs.1,02,00,000/- as assessee was the registered

PUNE MATHADI HAMAL AND OTHER MANUAL WORKERS BOARD,PUNE vs. INCOME TAX OFFICER, WARD-5(1), PUNE, PUNE

In the result, appeal of the assessee is partly allowed

Bench: Shri S.S.Godara & Dr. Dipak P. Ripoteआयकर अपील सं. / Ita No.1012/Pun/2023 िनधा"रण वष" / Assessment Year : 2018-19 Pune Mathadihamal & Other The Income Tax Manual Workers Board, V Officer, Shramashakti Bhavan, S Ward-5(1), Pune. Coomercial Plot No.1, Market Yard, Pune – 411037. Pan: Aaalp0097L Appellant/ Assessee Respondent /Revenue Assessee By Shri Vipul Joshi – Ar Revenue By Shri Ajay Kumar Keshari & Shri Rajesh Gawali– Dr’S Date Of Hearing 17/04/2024 Date Of Pronouncement 27/06/2024 आदेश/ Order Per Dr. Dipak P. Ripote, Am: This Appeal Filed By The Assessee Is Against The Orders Of Ld.Commissionerof Income Tax(Appeals)[Nfac], Under Section 250 Of The Act Dated 14.07.2023 :

reassessment proceedings that were pending would also come under the ambit of the first proviso to section 12A(2) of the Act. 6.5 The second proviso to section 12A(2) also provides that no action u/s 147 of the Act shall be taken merely for non-registration of trust or institution. Reading this proviso with the first proviso to section

KAILASH KANHAIYALAL GIDWANI,,SANGLI vs. ASSISTANT COMMISSIONER OF INCOME TAX,, SANGLI

In the result, both the appeals of assessee are allowed

Bench: Shri Anil Chaturvedi & Shri Partha Sarathi Chaudhury

section 2(22)(e) of the Act was in respect of Jay Maharashtra Consumers Pvt. Ltd., whereas the addition made by the Assessing Officer under the said provision is with regard to Apeksha Impex Pvt. Ltd. as evident from para 7 of the Assessing Officer‟s order. 4. The ld. AR of the assessee further stated that in the related

SUNIL KANHAIYALAL GIDWANI,,SANGLI vs. ASSISTANT COMMISSIONER OF INCOME TAX,, SANGLI

In the result, both the appeals of assessee are allowed

Bench: Shri Anil Chaturvedi & Shri Partha Sarathi Chaudhury

section 2(22)(e) of the Act was in respect of Jay Maharashtra Consumers Pvt. Ltd., whereas the addition made by the Assessing Officer under the said provision is with regard to Apeksha Impex Pvt. Ltd. as evident from para 7 of the Assessing Officer‟s order. 4. The ld. AR of the assessee further stated that in the related

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, proceedings must be initiated under Section 153C, not Section 147. The Hon. Court held that the AO lacked jurisdiction under Section 147, rendering the notice invalid. Consequently, the court quashed and set aside the notice under Section 148 and allowed the petition of the assessee. (Relevant paragraphs 16 to 24). • In the case of Shyam Sunder Khandelwal vs. ACIT

PRAKASH R.OSWAL,,PUNE vs. INCOME-TAX OFFICER, WARD - 5(3),, PUNE

In the result, the appeal of the assessee is allowed

Bench: Ms. Sushma Chowla, Jm आयकर अपील सं. / Ita No.2658/Pun/2017 िनधा"रण वष" / Assessment Year : 2010-11 Prakash R. Oswal, C/O. Shah Khandelwal Jain & Associates, Chartered Accountants, Level 3, Riverside Business Bay, Plot No.84, Wellesley Road, Near Rto, Pune-411001. अपीलाथ"/Appellant Pan: Aaapo6465D …. Vs. The Income Tax Officer, …. ""यथ" / Respondent Ward- 5(3), Pune. अपीलाथ" क" ओर से / Appellant By : Shri Rajiv Thakkar & Shri Rishab Gujrathi : Shri Rajesh Gawali ""यथ" क" ओर से / Respondent By घोषणा क" तारीख / सुनवाई क" तारीख / Date Of Pronouncement: 28.12.2018 Date Of Hearing : 17.12.2018 आदेश / Order Per Sushma Chowla, Jm: The Appeal Filed By The Assessee Is Against The Order Of Cit(A)-4, Pune Dated 12.06.2017 Relating To Assessment Year 2010-11 Against Order Passed Under Section 143(3) Read With Section 147 Of The Income-Tax Act, 1961 (In Short ‘The Act’).

section 2(22)(e) of the Act and the Assessing Officer made the addition on this account and also made further addition on account of perquisites value of rent free accommodation provided to the assessee. The first issue, on which reassessment

MAHATMA GANDHI NAGRI SAHAKARI PAT SANSTHA MYDT UDGIR,LATUR vs. INCOME TAX OFFICER- WARD 1 -LATUR, LATUR

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

E-assessment Scheme, 2019 on the following issues : (i) Bonus or Commission to Employee; (ii) Investment/Advances/Loans and (iii) AYs 2018-19 & 2020-21 Deduction from total income under Chapter VI-A. Accordingly, statutory notice(s) u/s 142(1) of the Act were issued and served upon the assessee seeking information regarding the deduction claimed by the assessee, in response

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

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

E account as 'income' only'. Categorising Appellant's 'donations' claim, as Section 68 specified 'income' would not have made any change in assessment. The Special Scheme of Taxation of Section 68 income u/s 115BBE at a Special Rate was introduced only from AY 2017-18 and onwards. Even the negative condition of denial of set- off of any other LOSS

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

E account as 'income' only'. Categorising Appellant's 'donations' claim, as Section 68 specified 'income' would not have made any change in assessment. The Special Scheme of Taxation of Section 68 income u/s 115BBE at a Special Rate was introduced only from AY 2017-18 and onwards. Even the negative condition of denial of set- off of any other LOSS

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

E account as 'income' only'. Categorising Appellant's 'donations' claim, as Section 68 specified 'income' would not have made any change in assessment. The Special Scheme of Taxation of Section 68 income u/s 115BBE at a Special Rate was introduced only from AY 2017-18 and onwards. Even the negative condition of denial of set- off of any other LOSS