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

249, grant immunity from imposition of penalty under section 270A and initiation of proceedings under section 276C or section 276CC, where the proceedings for penalty under section 270A has not been initiated under the circumstances referred to in sub-section (9) of the said section 270A. (4) The Assessing Officer shall, within a period of one month from

SHRIKANT CHANDRAKANT LOKHANDE,LATUR vs. ITO, WARD-1, LATUR, LATUR

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

Bench: Dr.Manish Borad & Shri Vinay Bhamoreआयकर अपील सं. / Ita No.2696/Pun/2024 Assessment Year : 2015-16

249(4) of the Act. Hence, wis prayed that the Order passed by the Ld.CIT(A) may please be annulled and may please be set aside for adjudication on merits. GROUND NO.IV On the facts and in the circumstances of the case as well as in law, the Ld.CIT(A) has grossly erred in dismissing the appeal in limine without

ARUNA SINGH ,THANE vs. ITO WARD 3(1), KALYAN

In the result, the appeal of the assessee is allowed for statistical\npurposes

reassessment which is done for the benefit of Revenue.\nHence, in our view, clause (b) of Section 249(4) of the Act will

SWAMINATH BABURAO PATIL,SOLAPUR vs. ITO WARD 2(3) SOLAPUR, SOLAPUR

In the result, appeal of the Assessee is allowed for statistical purpose

Bench: Ms.Astha Chandra & Dr.Dipak P. Ripoteआयकर अपऩल सं. / Ita No.832/Pun/2025 निर्धारण वषा / Assessment Year: 2014-15 Swaminath Baburao Patil, V The Income Tax Officer, C37, Siddheshwar Market S Ward-2(3), Solapur. Yard, Hyderabad Road, Solapur – 431005. Maharashtra. Pan: Akwpp4321P Appellant/ Assessee Respondent / Revenue Assessee By Shri Girish Ladda Revenue By Shri Ambarnath Khule (Through Virtual Hearing) – Jcit(Dr) Date Of Hearing 24/11/2025 Date Of Pronouncement 25/11/2025 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.2014-15 Dated 27.01.2025 Emanating From The Assessment Order Passed Under Section 147 R.W.S 144B Of The Act, Dated 19.05.2023. The Assessee Has Raised The Following Grounds Of Appeal :

reassessment order passed u/s 147 may please be quashed being passed without issue of statutory Notice u/s 143(2) of Income Tax Act even when the appellant filed a Return of Income on 03/02/2023 vide Acknowledgment Number 947198020030223. Non-issuance of the Statutory Notice u/s 143(2) is a jurisdictional defect not curable u/s 292BB. 3) Proceedings u/s 148 invalid

MRINALINI JAYANT PURANIK,PUNE vs. ITO, WARD-2(2), PUNE, PUNE

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

Bench: Shri R. K. Panda & Ms. Astha Chandraassessment Year : 2019-20 Mrinalini Jayant Puranik Ito, Ward 2(2), Pune Flat 14, Khagol Coop Society, Vs. S.No.38/1, Panchavati, Pashan, Pune – 411008 Pan: Almpp5163E (Appellant) (Respondent) Assessee By : Shri Suhas Kulkarni Department By : Shri A D Kulkarni Date Of Hearing : 26-11-2025 Date Of Pronouncement : 28-11-2025 O R D E R Per R.K. Panda, Vp:

249, grant immunity from imposition of penalty under section 270A and initiation of proceedings under section 276C or section 276CC, where the proceedings for penalty under section 270A has not been initiated under the circumstances referred to in sub-section (9) of the said section 270A. (4) The Assessing Officer shall, within a period of one month from

DEPUTY COMMISSIONER OF INCOME TAX, NASHIK vs. CHAKRADHAR CONTRACTORS AND ENGINEERS PRIVATE LIMITED, JALGAON

In the result, both the appeals of the Revenue are

Bench: Shri Rama Kanta Panda & Shri Vinay Bhamore

reassessed or recomputed in a preceding order. (11) No addition or disallowance of an amount shall form the basis for imposition of penalty, if such addition or disallowance has formed the basis of Imposition of penalty in the case of the person for the same or any other assessment year. (12) The penalty referred to in sub-section (1) shall

DEPUTY COMMISSIONER OF INCOME TAX, NASHIK vs. CHAKRAHAR CONTRACTORS AND ENGINEERS PRIVATE LIMITED, JALGAON

In the result, both the appeals of the Revenue are

Bench: Shri Rama Kanta Panda & Shri Vinay Bhamore

reassessed or recomputed in a preceding order. (11) No addition or disallowance of an amount shall form the basis for imposition of penalty, if such addition or disallowance has formed the basis of Imposition of penalty in the case of the person for the same or any other assessment year. (12) The penalty referred to in sub-section (1) shall

KETAN ARVIND DESHPANDE,NANDED vs. INCOME TAX OFFICER WARD(1) NANDED, NANDED

In the result, the appeal filed by the assessee is allowed for statistical purposes

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

section 249(4) of IT Act without considering the fact that assessee has already filed his return of income and was not liable for payment of Advance tax. In view of this prayer is made that current appeal may kindly be restored back to the file of Learned CIT Appeal for adjudication on merit 2. On the facts

SARFARAZ SALIM KACCHI,SANGLI vs. INCOME TAX OFFICER, SANGLI

In the result, the appeal filed by the assessee is allowed for statistical purposes

Bench: Dr.Manish Borad

4. When the case called for, none appeared on behalf of the assessee despite due service of notice of hearing. Even on the previous date of hearing, i.e. on 04.09.2025 assessee failed to appear nor has placed any application for adjournment. I therefore proceed to adjudicate the appeal with the assistance of ld. Departmental Representative. 5. I have heard

SHAHBAZ MOHAMMED SHAFEEQUE,MALEGAON vs. INCOME TAX OFFICER, WARD - 1, MALEGAON

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

Bench: Ms.Astha Chandra & Dr.Dipak P. Ripoteआयकर अपऩल सं. / Ita No.2291/Pun/2025 निर्धारण वषा / Assessment Year: 2015-16 Shahbaz Mohammed V The Income Tax Officer, Shafeeque, S. Ward-1, Malegaon. House No.904, Lane No.2, Malegaon City S.O., Malegaon, Nashik, Malegaon – 423203. Maharashtra. Pan: Cfppm6844A Appellant/ Assessee Respondent / Revenue Assessee By Shri Sanket Joshi (Virtual) Revenue By Smt Saumya Pandey Jain-Addl.Cit Date Of Hearing 20/11/2025 Date Of Pronouncement 20/11/2025 आदेश/ Order Per Dr. Dipak P. Ripote, Am: In This Case, Appeal Has Been Filed By The Assessee Against The Order Of Ld.Commisioner Of Income Tax(Appeal)[Nfac] Passed Under Section 250 Of The Income Tax Act, 1961 For The A.Y.2015-16 Dated 28.02.2025. The Assessee Has Raised The Following Grounds Of Appeal :

249(3) of the Act. Therefore, I am satisfied that the appellant 3 ITA No.2291/PUN/2025 [A] did not have sufficient cause for not presenting the appeal within the doe date. Therefore, this appeal is able to be rejected on this ground also: 7. Hence, the appeal of the assessee is dismissed.”Unquote. 2.1 Thus, it can be observed that ld.CIT

DEPUTY COMMISSIONER OF INCOME TAX, CIRCLE-1, AURANGABAD, AURANGABAD vs. ENDURANCE TECHNOLOGIES LIMITED, AURANGABAD

In the result, all the appeals filed by the Revenue are dismissed

reassessment,\nshould the law otherwise permit it, and if the circumstances justify it. We have\nquashed the impugned notices only because they were issued to a non- existing\ncompany or entity despite the respondents' knowledge of its non-existence. All\ncontentions in this regard are left open because we have not addressed them in\nthis order.\"\n30.\nThe various other

GULAMAHEMAD HAMIDULLA KHAN,PUNE vs. ITO WARD 14(3), PUNE

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

Bench: Dr.Dipak P. Ripote & Shri Vinay Bhamore

reassessment proceeding under the new provisions of section 147 as inserted by finance act 2021, on the basis of information gathered during the search conducted on M/s Renukamata Multistate Urban Co-operative Credit Society, therefore the action is illegal as the proceedings ought to have been initiated u/s 153C, therefore consequential order passed is bad in law and deserves

INCOME TAX OFFICER, WARD-1, JALNA, JALNA vs. ASHISH OMPRAKASH MANTRI, JALNA

In the result, all the appeals filed by the Revenue are dismissed

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

4 years. 18. Referring to the decision of the Hon’ble Bombay High Court in the case of South Yarra Holdings vs. ITO (2019) 263 Taxman 594 (Bom), he submitted that where after expiry of four years from end of relevant year, Assessing Officer initiated reassessment proceedings on basis of information received from Investigation wing that

INCOME TAX OFFICER, WARD-1, JALNA, JALNA vs. OMPRAKASH ASARAM MANTRI, JALNA

In the result, all the appeals filed by the Revenue are dismissed

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

4 years. 18. Referring to the decision of the Hon’ble Bombay High Court in the case of South Yarra Holdings vs. ITO (2019) 263 Taxman 594 (Bom), he submitted that where after expiry of four years from end of relevant year, Assessing Officer initiated reassessment proceedings on basis of information received from Investigation wing that

INCOME TAX OFFICER, WARD-1, JALNA, JALNA vs. OMPRAKASH ASARAM MANTRI, JALNA

In the result, all the appeals filed by the Revenue are dismissed

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

4 years. 18. Referring to the decision of the Hon’ble Bombay High Court in the case of South Yarra Holdings vs. ITO (2019) 263 Taxman 594 (Bom), he submitted that where after expiry of four years from end of relevant year, Assessing Officer initiated reassessment proceedings on basis of information received from Investigation wing that

INCOME TAX OFFICER, WARD-1, JALNA, JALNA vs. ATUL OMPRAKASH MANTRI, JALNA

In the result, all the appeals filed by the Revenue are dismissed

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

4 years. 18. Referring to the decision of the Hon’ble Bombay High Court in the case of South Yarra Holdings vs. ITO (2019) 263 Taxman 594 (Bom), he submitted that where after expiry of four years from end of relevant year, Assessing Officer initiated reassessment proceedings on basis of information received from Investigation wing that

INCOME TAX OFFICER, WARD-1, JALNA, JALNA vs. ATUL OMPRAKASH MANTRI, JALNA

In the result, all the appeals filed by the Revenue are dismissed

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

4 years. 18. Referring to the decision of the Hon’ble Bombay High Court in the case of South Yarra Holdings vs. ITO (2019) 263 Taxman 594 (Bom), he submitted that where after expiry of four years from end of relevant year, Assessing Officer initiated reassessment proceedings on basis of information received from Investigation wing that

INCOME TAX OFFICER, WARD-1, JALNA, JALNA vs. PRAMILA OMPRAKASH MANTRI, JALNA

In the result, all the appeals filed by the Revenue are dismissed

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

4 years. 18. Referring to the decision of the Hon’ble Bombay High Court in the case of South Yarra Holdings vs. ITO (2019) 263 Taxman 594 (Bom), he submitted that where after expiry of four years from end of relevant year, Assessing Officer initiated reassessment proceedings on basis of information received from Investigation wing that

INCOME TAX OFFICER, WARD -1, JALNA, JALNA vs. PRAMILA OMPRAKASH MANTRI, JALNA

In the result, all the appeals filed by the Revenue are dismissed

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

4 years. 18. Referring to the decision of the Hon’ble Bombay High Court in the case of South Yarra Holdings vs. ITO (2019) 263 Taxman 594 (Bom), he submitted that where after expiry of four years from end of relevant year, Assessing Officer initiated reassessment proceedings on basis of information received from Investigation wing that