Search: reassessment

ASSISTANT COMMISSIONER OF INCOME TAX CIRCLE 12, PUNE vs. VARUN JAIN, PUNE

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

ITA 2720/PUN/2024[2018]Status: DisposedITAT Pune07 May 2025

Bench: Dr.Dipak P. Ripote & Shri Vinay Bhamorecross Objection No.14/Pun/2025 (Arising Out Of Ita No.2720/Pun/2024) िनधा"रण वष" / Assessment Year: 2018-19 Varun Jain, The Acit, P-024, Forest County, Kharadi, V Circle-12, Pune. Pune – 411014. S. Maharashtra. Pan:Aexpj0171J Appellant/ Assessee Respondent / Revenue आयकर अपील सं. / Ita No.2720/Pun/2024 िनधा"रण वष" / Assessment Year: 2018-19 The Acit, Varun Jain, Circle-12, Pune. Vs. P-024, Forest County, Kharadi, Pune – 411014. Maharashtra. Pan:Aexpj0171J Appellant / Revenue Respondent / Assessee Assessee By Shri Fenil Bhatt – Ar(Virtual) Revenue By Shri Abhinay Kumbhar - Dr Date Of Hearing 05/05/2025 Date Of Pronouncement 07/05/2025 आदेश/ Order Per Dr. Dipak P. Ripote, Am: In This Case, Revenue Has Filed An Appeal Against The Order Of Ld.Commissioner Of Income Tax(Appeal)[Nfac] Passed Under C.O.No.14/Pun/2025 [A] & Ita No.2720/Pun/2024 [R]

Section 10(35)Section 133ASection 143(3)Section 144BSection 147Section 148ASection 250Section 253(4)

253(4) of the Act. 1.1 Revenue has raised the following Grounds of appeal “a. Whether on facts and circumstances of the case, the CITIA) was justified in allowing the dividend income of ₹5,59,37,863 as exempt under Section 10(35). overlooking the evidence obtained during the survey on JM Financial Asset Management Ltd., which confirmed violations

ASSISTANT COMMISSIONER OF INCOME-TAX,, PUNE vs. NORD DRIVE SYSTEMS PVT. LTD.,, PUNE

In the result, the appeal as well as cross objection are

ITA 825/PUN/2016[2011-12]Status: DisposedITAT Pune28 Nov 2019AY 2011-12

Bench: Shri R.S. Syal & Shri Partha Sarathi Chaudhuryआयकर अपील सं. / Ita No.825/Pun/2016 िनधा"रण वष" / Assessment Year : 2011-12 Acit, Circle-2, Vs. Nord Drive Systems Pvt. Ltd., Pune 282/2, 283/2, Plot No.15, Village Mann, Mulshi, Pune – 411 057 Pan : Aaccn0708R Appellant Respondent C.O. No.12/Pun/2018 (Arising Out Of Ita No.825/Pun/2016) िनधा"रण वष" / Assessment Year : 2011-12 Nord Drive Systems Pvt. Ltd., Vs. Acit, Circle-2, 282/2, 283/2, Plot No.15, Pune Village Mann, Taluka Mulshi, Adj. Hinjewadi Midc, Phase-Ii, Pune – 411 057 Pan : Aaccn0708R Cross Objector Appellant In The Appeal Assessee By Shri Sharad Shah & Shri Rohit Tapadia Revenue By Shri T. Vijaya Bhaskar Reddy Date Of Hearing 27-11-2019 Date Of Pronouncement 28-11-2019 आदेश / Order

Section 143(3)

253 of the Act, which, prior to its omission w.e.f. 1.6.2016, was inserted by the Finance Act, 2012 w.e.f. 1.7.2012 and later on amended by the Finance (No.2) Act, 2014 w.r.e.f. 1.6.2013 providing that: `The Principal Commissioner or Commissioner may, if he objects to any direction issued by the Dispute Resolution Panel under sub-section (5) of section 144C

BAJAJ HOUSING FINANCE LIMITED,PUNE vs. ITO, WARD-8(1), PUNE, PUNE

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

ITA 1608/PUN/2025[2017-18]Status: DisposedITAT Pune09 Oct 2025AY 2017-18

Bench: Dr.Manish Borad

For Respondent: Appellant by Shri Nikhil Mutha

Section 143(1)Section 250Section 250(6)Section 270ASection 270A(9)

reassessed has the effect of reducing the loss or converting such loss into income. 11. The assessees case would fall only in clause (g) of Section 270A(2) of the Act as the ultimate assessment had the effect of reducing the loss retuned by the assessee. It was further pointed out that under reporting of income has got certain exceptions

DEPUTY COMMISSIONER OF INCOME-TAX vs. THE JAWAHARLAL NEHRU PORT TRUST,, RAIGAD

In the result, all the three appeals filed by the Revenue are dismissed and all the three appeals filed by the assessee are partly allowed

ITA 543/PUN/2016[2003-04]Status: DisposedITAT Pune30 Sept 2025AY 2003-04

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

For Appellant: S/Shri Madhur Agrawal, AdvocateFor Respondent: S/Shri Sham Walve, Special Counsel along with Tanzil Padvekar and Bhavik Chheda

Section 10(20)Section 11Section 12ASection 142Section 143(1)Section 143(3)Section 263

253 wherein, dealing with identical facts, the claim of the assessee was allowed. He submitted that similar view has been taken by the Indore Bench ITA Nos.1153, 1155 & 1154/MUM/2016 of the Tribunal in the case of Akshay Academy vs. ITO reported in 167 taxmann.com 382. 33. The Ld. Counsel for the assessee submitted that as per the provision of section

DEPUTY COMMISSIONER OF INCOME-TAX vs. THE JAWAHARLAL NEHRU PORT TRUST,, RAIGAD

In the result, all the three appeals filed by the Revenue are dismissed and all the three appeals filed by the assessee are partly allowed

ITA 545/PUN/2016[2005-06]Status: DisposedITAT Pune30 Sept 2025AY 2005-06

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

For Appellant: S/Shri Madhur Agrawal, AdvocateFor Respondent: S/Shri Sham Walve, Special Counsel along with Tanzil Padvekar and Bhavik Chheda

Section 10(20)Section 11Section 12ASection 142Section 143(1)Section 143(3)Section 263

253 wherein, dealing with identical facts, the claim of the assessee was allowed. He submitted that similar view has been taken by the Indore Bench ITA Nos.1153, 1155 & 1154/MUM/2016 of the Tribunal in the case of Akshay Academy vs. ITO reported in 167 taxmann.com 382. 33. The Ld. Counsel for the assessee submitted that as per the provision of section

JAWAHAR LAL NEHRU PORT TRUST,NAVI MUMBAI vs. ACIT PANVEL, PANVEL

In the result, all the three appeals filed by the Revenue are dismissed and all the three appeals filed by the assessee are partly allowed

ITA 1153/MUM/2016[2003-04]Status: DisposedITAT Pune30 Sept 2025AY 2003-04

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

For Appellant: S/Shri Madhur Agrawal, AdvocateFor Respondent: S/Shri Sham Walve, Special Counsel along with Tanzil Padvekar and Bhavik Chheda

Section 10(20)Section 11Section 12ASection 142Section 143(1)Section 143(3)Section 263

253 wherein, dealing with identical facts, the claim of the assessee was allowed. He submitted that similar view has been taken by the Indore Bench ITA Nos.1153, 1155 & 1154/MUM/2016 of the Tribunal in the case of Akshay Academy vs. ITO reported in 167 taxmann.com 382. 33. The Ld. Counsel for the assessee submitted that as per the provision of section

JAWAHAR LAL NEHRU PORT TRUST,NAVI MUMBAI vs. ACIT PANVEL, PANVEL

In the result, all the three appeals filed by the Revenue are dismissed and all the three appeals filed by the assessee are partly allowed

ITA 1154/MUM/2016[2005-06]Status: DisposedITAT Pune30 Sept 2025AY 2005-06

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

For Appellant: S/Shri Madhur Agrawal, AdvocateFor Respondent: S/Shri Sham Walve, Special Counsel along with Tanzil Padvekar and Bhavik Chheda

Section 10(20)Section 11Section 12ASection 142Section 143(1)Section 143(3)Section 263

253 wherein, dealing with identical facts, the claim of the assessee was allowed. He submitted that similar view has been taken by the Indore Bench ITA Nos.1153, 1155 & 1154/MUM/2016 of the Tribunal in the case of Akshay Academy vs. ITO reported in 167 taxmann.com 382. 33. The Ld. Counsel for the assessee submitted that as per the provision of section

JAWAHAR LAL NEHRU PORT TRUST,NAVI MUMBAI vs. ACIT PANVEL, PANVEL

In the result, all the three appeals filed by the Revenue are dismissed and all the three appeals filed by the assessee are partly allowed

ITA 1155/MUM/2016[2004-05]Status: DisposedITAT Pune30 Sept 2025AY 2004-05

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

For Appellant: S/Shri Madhur Agrawal, AdvocateFor Respondent: S/Shri Sham Walve, Special Counsel along with Tanzil Padvekar and Bhavik Chheda

Section 10(20)Section 11Section 12ASection 142Section 143(1)Section 143(3)Section 263

253 wherein, dealing with identical facts, the claim of the assessee was allowed. He submitted that similar view has been taken by the Indore Bench ITA Nos.1153, 1155 & 1154/MUM/2016 of the Tribunal in the case of Akshay Academy vs. ITO reported in 167 taxmann.com 382. 33. The Ld. Counsel for the assessee submitted that as per the provision of section

DEPUTY COMMISSIONER OF INCOME-TAX vs. THE JAWAHARLAL NEHRU PORT TRUST,, RAIGAD

In the result, all the three appeals filed by the Revenue are dismissed and all the three appeals filed by the assessee are partly allowed

ITA 544/PUN/2016[2004-05]Status: DisposedITAT Pune30 Sept 2025AY 2004-05

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

For Appellant: S/Shri Madhur Agrawal, AdvocateFor Respondent: S/Shri Sham Walve, Special Counsel along with Tanzil Padvekar and Bhavik Chheda

Section 10(20)Section 11Section 12ASection 142Section 143(1)Section 143(3)Section 263

253 wherein, dealing with identical facts, the claim of the assessee was allowed. He submitted that similar view has been taken by the Indore Bench ITA Nos.1153, 1155 & 1154/MUM/2016 of the Tribunal in the case of Akshay Academy vs. ITO reported in 167 taxmann.com 382. 33. The Ld. Counsel for the assessee submitted that as per the provision of section

JANAKEE PETROLIUM,SATARA vs. ITO WD-4, SATARA

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

ITA 2322/PUN/2025[2015-16]Status: DisposedITAT Pune29 Jan 2026AY 2015-16

Bench: Dr.Dipak P. Ripote & Shri Vinay Bhamoreआयकर अपऩल सं. / Ita Nos.2322 & 2327/Pun/2025 निर्धारण वषा / Assessment Year: 2015-16 Janakee Petrolium, V Income Tax Officer, Gat No.1041/B, Wai Surru S Ward-4, Satara. Roadk Kavathe Wai, Satara – 415516 Pan: Aajfj9486C Appellant/ Assessee Respondent /Revenue Assessee By Shri Tanzil Padvekar Revenue By Smt Neha Thakur (Virtual) Date Of Hearing 21/01/2026 Date Of Pronouncement 29/01/2026 आदेश/ Order Per Bench : These Two Appeals Filed By The Assessee Against The Separate Orders Of Ld.Commissioner Of Income Tax(Appeal)[Nfac], Passed Under Section 250 Of The Income Tax Act, 1961 For The A.Y.2015-16 Both Dated 20.08.2025 Emanating From The Assessment Order Passed Under Section 147 R.W.S 144 Of The Act, Dated 22.02.2023 & Penalty Order Under Section 271(1)(C) Of The Act, 10.08.2023

Section 144Section 147Section 148Section 148ASection 151ASection 250Section 271(1)(c)Section 69A

253/- is bad in law and is liable to be deleted. ITA Nos.2322 & 2327/PUN/2025 [A] 5. On the facts and in law, the impugned notice issued under Section 148 of the Act is bad in law since, the mandatory condition that income chargeable to tax has escaped assessment is not met in this case since, the alleged income has already

JANAKEE PETROLIUM,SATARA vs. ITO WD-4, SATARA

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

ITA 2327/PUN/2025[2015-16]Status: DisposedITAT Pune29 Jan 2026AY 2015-16

Bench: Dr.Dipak P. Ripote & Shri Vinay Bhamoreआयकर अपऩल सं. / Ita Nos.2322 & 2327/Pun/2025 निर्धारण वषा / Assessment Year: 2015-16 Janakee Petrolium, V Income Tax Officer, Gat No.1041/B, Wai Surru S Ward-4, Satara. Roadk Kavathe Wai, Satara – 415516 Pan: Aajfj9486C Appellant/ Assessee Respondent /Revenue Assessee By Shri Tanzil Padvekar Revenue By Smt Neha Thakur (Virtual) Date Of Hearing 21/01/2026 Date Of Pronouncement 29/01/2026 आदेश/ Order Per Bench : These Two Appeals Filed By The Assessee Against The Separate Orders Of Ld.Commissioner Of Income Tax(Appeal)[Nfac], Passed Under Section 250 Of The Income Tax Act, 1961 For The A.Y.2015-16 Both Dated 20.08.2025 Emanating From The Assessment Order Passed Under Section 147 R.W.S 144 Of The Act, Dated 22.02.2023 & Penalty Order Under Section 271(1)(C) Of The Act, 10.08.2023

Section 144Section 147Section 148Section 148ASection 151ASection 250Section 271(1)(c)Section 69A

253/- is bad in law and is liable to be deleted. ITA Nos.2322 & 2327/PUN/2025 [A] 5. On the facts and in law, the impugned notice issued under Section 148 of the Act is bad in law since, the mandatory condition that income chargeable to tax has escaped assessment is not met in this case since, the alleged income has already

DEPUTY COMMISSIONER OF INCOME-TAX vs. FINOLEX INDUSTRIES LTD.,, PUNE

In the result, the appeal of Revenue is dismissed

ITA 357/PUN/2016[2006-07]Status: DisposedITAT Pune09 Feb 2018AY 2006-07

Bench: Shri Anil Chaturvedi, Am & Shri Vikas Awasthy, Jm

For Appellant: Shri C.H. NaniwadekarFor Respondent: Shri Rajeev Kumar, CIT

Section 111ASection 143(2)Section 143(3)Section 153ASection 2(13)Section 253

253 of the Income Tax 1. Act is emanating out of the order of Commissioner of Income Tax (A) - Pune – 11 dt.21.12.2015 for the assessment year 2006-07. 2. The relevant facts as culled out from the material on record are as under :- 2.1 Assessee is a company engaged in the business of manufacturing and sale of PVC Resin

AGARWAL GROUP CORPORATE HOLDING P. LTD.,,PUNE vs. ASSISTANT COMMISSIONER OF INCOME-TAX,,

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

ITA 1667/PUN/2015[2007-08]Status: DisposedITAT Pune29 Nov 2018AY 2007-08

Bench: Ms. Sushma Chowla, Jm & Shri Anil Chaturvedi, Am आयकर अपीऱ सं. / Ita No.1666/Pun/2015 यििाारण वषा / Assessment Year : 2007-08 Shri Brijendra Nath Agarwal, Mzsk & Associates, Chartered Accountants Level 3, Business Bay, Plot No.84, Wellesley Road, अऩीऱाथी/Appellant Near Rto, Pune – 411001 …. Pan: Aawpa9005D Vs. The Dy. Commissioner Of Income Tax, …. प्रत्यथी / Respondent Central Circle 2(1), Pune

For Appellant: Shri Neelesh KhandelwalFor Respondent: Shri S.B. Prasad

Section 143(3)Section 147Section 148Section 153A

reassessment proceedings got abated on issue of notice under section 153A(i) of the Act. It further be held that the Hon'ble CIT(A) erred in concluding that issue of notice u/s 153A(i) for the year under consideration is void-ab-initio. The assessment framed by the AO and that confirmed

BRIJENDRA NATH AGARWAL,,PUNE vs. ASSISTANT COMMISSIONER OF INCOME-TAX,,

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

ITA 1666/PUN/2015[2007-08]Status: DisposedITAT Pune29 Nov 2018AY 2007-08

Bench: Ms. Sushma Chowla, Jm & Shri Anil Chaturvedi, Am आयकर अपीऱ सं. / Ita No.1666/Pun/2015 यििाारण वषा / Assessment Year : 2007-08 Shri Brijendra Nath Agarwal, Mzsk & Associates, Chartered Accountants Level 3, Business Bay, Plot No.84, Wellesley Road, अऩीऱाथी/Appellant Near Rto, Pune – 411001 …. Pan: Aawpa9005D Vs. The Dy. Commissioner Of Income Tax, …. प्रत्यथी / Respondent Central Circle 2(1), Pune

For Appellant: Shri Neelesh KhandelwalFor Respondent: Shri S.B. Prasad

Section 143(3)Section 147Section 148Section 153A

reassessment proceedings got abated on issue of notice under section 153A(i) of the Act. It further be held that the Hon'ble CIT(A) erred in concluding that issue of notice u/s 153A(i) for the year under consideration is void-ab-initio. The assessment framed by the AO and that confirmed

MR VIKAS JAYRAM BHUKAN,PUNE vs. ITO WARD 12(3), PUNE

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

ITA 2483/PUN/2024[2012-13]Status: DisposedITAT Pune30 May 2025AY 2012-13

Bench: Shri Manish Borad & Shri Vinay Bhamoreआयकर अपील सं. / Ita No.2483/Pun/2024 िनधा"रण वष" / Assessment Year : 2012-13 Mr. Vikas Jayram Bhukan, Vs. Ito, Ward-12(3), Pune. Survey No.34, House No.80, Azad Chowk, Opposite Ramma, Lohegaon, Near Gram Panchayat, Pune- 411047. Pan : Alqpb0811K Appellant Respondent Assessee By : Shri Bhuvanesh Kankani Revenue By : Shri Kumar Manish Singha Date Of Hearing : 08.04.2025 Date Of Pronouncement : 30.05.2025 आदेश / Order Per Vinay Bhamore, Jm: This Appeal Filed By The Assessee Is Directed Against The Order Dated 03.09.2024 Passed By Ld. Cit(A)/Nfac For The Assessment Year 2012-13. 2. The Appellant Has Raised The Following Grounds Of Appeal :- “1. On The Facts & Circumstance Prevailing In The Case & As Per Provisions & Scheme Of The Act It Be Held That The Notice For Levy Of Penalty Was Defective Since No Specific Charge Of Violation, Was Made Out In The Notice & Thus The Consequent Penalty So Levied Be Kindly Deleted.

For Appellant: Shri Bhuvanesh KankaniFor Respondent: Shri Kumar Manish Singha

Section 271(1)(c)Section 274

reassessment shall be deemed to constitute satisfaction of the Assessing Officer for initiation of the penalty proceeding under the said clause (c). In the present set of facts the Assessing Officer has noted in the assessment order the concealment of particulars of income by the respondent/assessee. Notices were also directed to be issued as has been observed in the assessment

AADHUNIK INFRASTRUCTURE DEVELOPMENT PRIVATE LIMITED,JALGAON vs. THE DEPUTY COMMISSIONER OF INCOME TAX, CIRCLE-1, JALGAON

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

ITA 439/PUN/2023[2012-13]Status: DisposedITAT Pune18 Sept 2024AY 2012-13

Bench: Shri R. K. Panda & Shri Vinay Bhamoreassessment Year : 2012-13

For Appellant: Shri Kishor B PhadkeFor Respondent: Shri Ramnath P Murkunde

Section 143(3)Section 14ASection 271(1)(c)Section 68

reassessment proceedings. Thus there was no borrowed satisfaction on the part of the AO. There was independent application of mind on the part of the AO. Further reliance is placed upon clause (b) of explanation 2 to provisions of section 147 of the Act as on the basis of the facts of the case the AO had the basis

VILSON ROOFING PRODUCTS PRIVATE LIMITED,KOLHAPUR vs. THE ASSISTANT COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE, KOLHAPUR

The appeal of the assessee is DISMISSED

ITA 956/PUN/2023[2009-10]Status: DisposedITAT Pune12 Dec 2023AY 2009-10

Bench: Shri Partha Sarathi Chaudhury & Shri G. D. Padmahshaliआयकर अपऩल सं. / Ita No. 956/Pun/2023 निर्धारण वर्ा / Assessment Year : 2009-10 Vilson Roofing Products Pvt. Ltd., 1St Lane, Opp. Prataprao Jagdale Hall, Rajarampuri, Kolhapur, Pin – 416 008 . . . . . . . अपऩलधथी / Appellant Pan: Aaccv0661M

For Appellant: Mr Sharad Vaze [‘Ld. AR’]For Respondent: Mr M G Jasnani [‘Ld. DR’]

Section 143(3)Section 147Section 148Section 250Section 253(1)(a)Section 68

253(1)(a) of the Act on following grounds; “1. On the basis of facts and in the circumstances of the case and as per law, the notice issued u/s 148 is bad in law. ITAT-Pune Page 2 of 14 Vilson Roofing Products Pvt. Ltd., ITA No.956/PUN/2023 A.Y. 2009-10 2. On the basis of facts

DEPUTY COMMISSIONER OF INCOME-TAX vs. DAIMLER CHRYSLER INDIA PVT. LTD.,, PUNE

In the result, the cross objection of the assessee is dismissed

ITA 1325/PUN/2003[1998-99]Status: DisposedITAT Pune08 Aug 2018AY 1998-99

Bench: Shri D.Karunakara Rao, Am & Shri Vikas Awasthy, Jm आयकर आयकर अपील आयकर आयकर अपील अपील संसंसंसं. / Ita No.1381/Pun/2003 अपील िनधा"रण िनधा"रण वष" िनधा"रण िनधा"रण वष" वष" / Assessment Year : 1998-09 वष"

For Appellant: Shri Pramod AchuthanFor Respondent: Shri Rajeev Kumar, CIT

Section 143(3)Section 15ASection 35A

reassessment proceedings were not held to be valid. The contention of the Revenue therefore, is that adjudication on admissibility on deduction u/s.35AB could not be examined on merits and, therefore, deduction u/s. 35AB cannot be said to have been allowed in the AY 1995-96 i.e. the first year on merit. During the course of the hearing before

DAIMLER CHRYSLER INDIA PVT. LTD.,,PUNE vs. DEPUTY COMMISSIONER OF INCOME-TAX,, PUNE

In the result, the cross objection of the assessee is dismissed

ITA 1381/PUN/2003[1998-99]Status: DisposedITAT Pune08 Aug 2018AY 1998-99

Bench: Shri D.Karunakara Rao, Am & Shri Vikas Awasthy, Jm आयकर आयकर अपील आयकर आयकर अपील अपील संसंसंसं. / Ita No.1381/Pun/2003 अपील िनधा"रण िनधा"रण वष" िनधा"रण िनधा"रण वष" वष" / Assessment Year : 1998-09 वष"

For Appellant: Shri Pramod AchuthanFor Respondent: Shri Rajeev Kumar, CIT

Section 143(3)Section 15ASection 35A

reassessment proceedings were not held to be valid. The contention of the Revenue therefore, is that adjudication on admissibility on deduction u/s.35AB could not be examined on merits and, therefore, deduction u/s. 35AB cannot be said to have been allowed in the AY 1995-96 i.e. the first year on merit. During the course of the hearing before

KIRLOSKAR BROTHERS LIMITED,,PUNE vs. DCIT, CIRCLE 11(1),, PUNE

In the result, the appeal of the assessee for A

ITA 2611/PUN/2012[2002-03]Status: DisposedITAT Pune19 Sept 2018AY 2002-03

Bench: Shri D. Karunakara Rao, Am & Shri Vikas Awasthy, Jm आयकर अपील सं आयकर अपील सं. / Ita Nos. 2611 & 2612/Pun/2012 आयकर अपील सं आयकर अपील सं िनधा"रण वष" िनधा"रण वष" / Assessment Years : 2002-03 & 2003-04 िनधा"रण वष" िनधा"रण वष"

For Appellant: Shri Sharad ShahFor Respondent: Shri Mukesh Jha

Section 271(1)(c)Section 37(1)

reassessment proceedings is the additional legal issue raised in particular for adjudication vide the appeal ITA No.2612/PUN/2012. 2. Assessee raised various grounds originally. However, during the proceedings before us, assessee filed concise grounds and the said grounds for A.Y. 2002-03 are as under : “Ground of appeal No.1: The Ld. AO erred in CIT(A) erred in confirming the levy