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 under Section 143 & 147/148. 27. Section 153A and 153C starts with non-obstante clause. The procedure for assessment/reassessment in Section

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." 20. Sub-section (18) of Section 155 of the Income Tax Act is inserted vide Finance Act, 2022 w.e.f. 01.04.2022. The above referred provisions provide that deduction of any surcharge, cess, which

RAJDEEP BUILDCON PRIVAT LIMITED, AHMEDNAGAR,AHMEDNAGAR vs. DY. COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE 1(2), PUNE, PUNE

In the result, the appeal filed by the assessee in ITA

Bench: SHRI R. K. PANDA (Vice President), SHRI VINAY BHAMORE (Judicial Member)

section and a harmonious construction of the entire provision would lead to an irresistible conclusion that the word 'assess has been used in the context of abated proceedings and reassess has been used for completed assessment proceedings, which would not abate as they are not pending on the date of initiation of the search or making of requisition and which

RAJDEEP BUILDCON PVT LTD, AHMEDNAGAR,AHMEDNAGAR vs. DY. COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE 1(2), PUNE, PUNE

In the result, the appeal filed by the assessee in ITA

Bench: SHRI R. K. PANDA (Vice President), SHRI VINAY BHAMORE (Judicial Member)

section and a harmonious construction of the entire provision would lead to an irresistible conclusion that the word 'assess has been used in the context of abated proceedings and reassess has been used for completed assessment proceedings, which would not abate as they are not pending on the date of initiation of the search or making of requisition and which

RAJDEEP BUILDCOM PRIVATE LIMITED,AHMEDNAGAR vs. DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE - 1(2), PUNE, PUNE

In the result, the appeal filed by the assessee in ITA

Bench: SHRI R. K. PANDA (Vice President), SHRI VINAY BHAMORE (Judicial Member)

section and a harmonious construction of the entire provision would lead to an irresistible conclusion that the word 'assess has been used in the context of abated proceedings and reassess has been used for completed assessment proceedings, which would not abate as they are not pending on the date of initiation of the search or making of requisition and which

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

SHANKAR NAGAPPA JADAGOUDA,KOLHAPUR vs. NFAC, DELHI

Appeal is allowed in above terms

Bench: Shri Satbeer Singh Godara

27,878/- in his bank account with M/s. Vijay Share Cooperative Bank. Meaning thereby that they have not made any addition qua the foregoing sole reason recorded in the reopening reasons (supra). Faced with this situation, I quote hon’ble jurisdictional high court’s landmark decision in CIT vs. Jet Airways (I) Ltd., [2011] 331 ITR 236 (Bom.) having settling

SACHIN MOHANLAL CHORDIA,PUNE vs. INCOME TAX OFFICER WARD 5(1), PUNE

Appeal of the assessee is partly allowed as we do not intend to adjudicate other grounds raised by the assessee

Bench: Ms. Astha Chandra & Dr. Dipak P. Ripoteआयकर अपील सं. / Ita Nos.3280 & 3281/Pun/2025 िनधा"रण वष" / Assessment Years: 2016-17 & 2017-18 Sachin Mohanlal Chordia, V The Income Tax Officer, B-101, Isha Emerald, S. Ward-5(1), Pune. Bibwewdi, Kondhwa Road, Marketyard, Pune- 411037. Pan: Aanpc8554C Appellant Respondent Assessee By Shri Abhilash Hiran Revenue By Shri Amit Bobade & Shri Sanjay Dhivare (Virtual) Date Of Hearing 05/03/2026 Date Of Pronouncement 30/03/2026 आदेश/ Order Per Bench : These Are Two Appeals Filed By Assessee Against The Separate Orders Of Commissioner Of Income Tax (Appeal) (Nfac) U/S 250 Of The Income Tax Act 1961 For Ay 2016-17, 2017-18 Passed On 22/10/2025 Emanating From Separate Assessment Orders U/S 147 Rws 144 Dated 11/05/2023 & 23/05/2023. 2. The Grounds Of Appeal Raised By The Assessee Are As Under:

section 147 to 151 of the Act prior to April 1, 2021 (herein after referred to as “old regime”) shall be applied to reassessment proceedings initiated under them between April 1,2021 and June 30,2021. Accordingly, Notification No.20 of 2021 dated March 31, 2021 [(2021) 432 ITR (St.) 141] and Notification No.38 of 2021 dated April 27

SACHIN MOHANLAL CHORDIA,PUNE vs. INCOME TAX OFFICER WARD 5(1), PUNE

Appeal of the assessee is partly allowed as we do not intend to adjudicate other grounds raised by the assessee

Bench: Ms. Astha Chandra & Dr. Dipak P. Ripoteआयकर अपील सं. / Ita Nos.3280 & 3281/Pun/2025 िनधा"रण वष" / Assessment Years: 2016-17 & 2017-18 Sachin Mohanlal Chordia, V The Income Tax Officer, B-101, Isha Emerald, S. Ward-5(1), Pune. Bibwewdi, Kondhwa Road, Marketyard, Pune- 411037. Pan: Aanpc8554C Appellant Respondent Assessee By Shri Abhilash Hiran Revenue By Shri Amit Bobade & Shri Sanjay Dhivare (Virtual) Date Of Hearing 05/03/2026 Date Of Pronouncement 30/03/2026 आदेश/ Order Per Bench : These Are Two Appeals Filed By Assessee Against The Separate Orders Of Commissioner Of Income Tax (Appeal) (Nfac) U/S 250 Of The Income Tax Act 1961 For Ay 2016-17, 2017-18 Passed On 22/10/2025 Emanating From Separate Assessment Orders U/S 147 Rws 144 Dated 11/05/2023 & 23/05/2023. 2. The Grounds Of Appeal Raised By The Assessee Are As Under:

section 147 to 151 of the Act prior to April 1, 2021 (herein after referred to as “old regime”) shall be applied to reassessment proceedings initiated under them between April 1,2021 and June 30,2021. Accordingly, Notification No.20 of 2021 dated March 31, 2021 [(2021) 432 ITR (St.) 141] and Notification No.38 of 2021 dated April 27

DEPUTY COMMISSIONER OF INCOME TAX CIRCLE 7 PUNE, PUNE vs. KOLTE PATIL INTEGRATED TOWNSHIPS LIMITED, PUNE

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

reassessment notice under section 148 of the new regime. Thus, in this\nillustration, the time limit for issuance of a notice under section 148 of the new\nregime will end on 18 August 2022.\n22. He submitted that it is abundantly clear from the above decision that the time\nbetween the issue of original notice u/s 148 under

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

section 151 have not been complied with in this case and respectfully following the judgments of the Honorable courts, I am of the considered view that notice issued u/s 148 is bad in law and the reopening u/s 147 is not sustainable and liable to be quashed. Hence, the notice u/s. 148 issued by the AO and the consequent assessment

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

27,993/- u/s 270A of the Act being 50% of tax determined for underreporting of income. 4.3. On perusal of sec 270A, it is observed that the sub- section 2 of sec 270A prescribes the persons falling under the category of under reported his income and one of the clause (c) of sub-section (2) prescribed that "the income reassessed

ASSTT. COMMISSIONER OF INCOME TAX (EXEMPTIONS), CIRCLE, PUNE, PUNE vs. ZEAL EDUCATION SOCIETY, PUNE

In the result, appeal of the Revenue is dismissed

Bench: Shri Manish Borad & Ms. Astha Chandra

27,447/- payable on under-reporting income of Rs.6,04,24,824/- as per the provisions of 270A of the Act. 3. Aggrieved, the assessee filed appeal before the Ld. CIT(A) challenging the penalty of Rs. 90,63,723/- imposed by the Ld.AO u/s 270A of the Act. Before the Ld. CIT(A), the assessee furnished its written submissions

RAJENDRAKUMAR SHRISHRIMAL,PUNE vs. INCOME TAX OFFICER WARD 5(1), PUNE

In the result, appeal of the assessee is allowed

Bench: Ms.Astha Chandra & Dr.Dipak P. Ripoteआयकर अपऩल सं. / Ita No.3282/Pun/2025 निर्धारण वषा / Assessment Year: 2017-18 Rajendrakumar Shrishrimal, V The Income Tax Officer, 685/3, Anant Vashat, S Ward-5(1), Pune. Bibwewadi, Pune – 411037. Pan: Bjsps9226G Appellant/ Assessee Respondent /Revenue Assessee By Shri Abhilash Hiran Revenue By Shri Sadananda – Jcit(Dr) Date Of Hearing 11/02/2026 Date Of Pronouncement 12/02/2026 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.2017-18 Dated 16.10.2025 Emanating From The Assessment Order Passed Under Section 147 Read With Section 144B Of The I.T.Act, 1961 Dated 03.05.2023. The Assessee Has Raised The Following Grounds Of Appeal :

27 July 2022 for AY 2017-18 is time barred after taking into consideration the surviving period for the reassessment notices issued between 01 April 2021 to 30 June 2021 hence the impugned reassessment notice issued and the consequential order passed may quashed and set aside 2. Ground No 2: Approval obtained under section

DEPUTY COMMISSIONER OF INCOME TAX, AURANGABAD vs. SANDEEP BIPINCHANDRA JHAVERI, MUMBAI

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

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

reassess the 'total income' taking into consideration the incriminating material collected during the search and other material which would include income declared in the returns, if any, furnished by the assessee as well as the undisclosed income.” In view of the above discussion and the binding nature of the order of the Hon’ble Supreme Court and the jurisdictional High

A.C.I.T ,WARDHA CIRCLE , WARDHA , WARDHA vs. M/S KAPIL SOLVEX PVT .LTD , YAVATMAL

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

Bench: Shri R. K. Panda & Ms Astha Chandraassessment Year : 2009-10

reassess such income and also any other income chargeable to tax which has escaped assessment and which comes to his notice subsequently in the course of the proceedings under this section, or recompute the loss or the depreciation allowance or any other allowance, as the case may be. In the present case, the Respondents do not state that any income

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

section 40A(3) of the Act and unsecured loans taken from Akash Foods and Feeds for which Assessing Officer was satisfied with the reply filed by the assessee and re- assessment proceedings were concluded after making addition u/s.68 of the Act at ₹83,56,232 and disallowed u/s.40(a)(ia) of the Act at ₹1,36,378. Assessed income

JASMINE ZUBIN SHROFF,PUNE vs. ITO, WARD-7(1), PUNE, PUNE

In the result, appeal of the Assessee is allowed

Bench: Dr.Dipak P. Ripote & Shri Vinay Bhamoreआयकर अपऩल सं. / Ita No.2380/Pun/2025 निर्धारण वषा / Assessment Year: 2012-13 Mrs.Jasmine Zubin Shroff V The Income Tax (Through Legal Heir Zubin K S Officer, Shroff), Ward-7(1), Pune. 826/C No.5, Anklesharia Blocks, Dastur Meher Road, Camp, Pune - 411001. Pan:Basps7144E Appellant/ Assessee Respondent /Revenue Assessee By Shri B C Malakar Revenue By Shri Sandeep Sathe - Jcit Date Of Hearing 08/12/2025 Date Of Pronouncement 28/01/2026 आदेश/ Order Per Dr. Dipak P. Ripote, Am: This Is An Appeal Filed By The Legal Heir Of Late Jasmine Z. Shroff 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.2012-13 Dated 19.12.2023 Emanating From The Assessment Order Passed Under Section 144 Of The

Section 147 & 148 of the Act. 27. Consequently, the writ petition is allowed. The impugned reassessment notice dated 22.03.2018 issuedunder