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

TEJAS SHIVAJI ADSUL,KOLHAPUR vs. INCOME TAX OFFICER WARD 1(1), KOLHAPUR, KOLHAPUR

In the result, appeal of the assessee is allowed

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

reassessment order, the A.O has initiated penalty u/s 270A on a vague charge of furnishing inaccurate particulars of income' also in the notice u/s 274 r.w.s 270A, the exact limb of section

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

274 r.w.s. 270A, whether penalty is proposed for any of the conditions mentioned in section 270A(2)(a) to 270A(2)(g) by virtue of which the income of the appellant is held as under- reported and in section 270A(9)(a) to 270A(9)(g) by virtue of which the income of the appellant is held as mis-reported

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

274 r.w.s. 270A, whether penalty is proposed for any of the conditions mentioned in section 270A(2)(a) to 270A(2)(g) by virtue of which the income of the appellant is held as under- reported and in section 270A(9)(a) to 270A(9)(g) by virtue of which the income of the appellant is held as mis-reported

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

274 r.w.s. 270A of the Act, the assessee vide its reply dated 30/12/2021 submitted as under:- “While the return of income was filed, it was inadvertently taken the amount of Rs. 548212549/- as the assessee's revenue expenditure for the purpose of application of income since the assessee was eligible to exemption u/s 11 of the Act, Such expenditure claimed

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:

274 r.w.s. 270A. 5. The assessee in response to the notice issued u/s 270A by the Ld. CIT(A) submitted that he has declared the additional income voluntarily and in a transparent manner by revising the return of income after the survey and disclosed the additional income so found during the course of survey accurately. The assessee complied with

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

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

Bench: Dr.Manish Borad

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

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:

274 r.w.s. 270A of the Act was issued and served on the assessee in response to which the assessee made her submissions. She also filed an application for grant of immunity in Form No.68. The assessee filed a copy of challan evidencing the payment of such tax. 4. However, the Assessing Officer was not satisfied with the submissions

SAGAR SUBHASH WEDHANE,NASHIK vs. INCOME TAX OFFICER, NASHIK

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

Bench: Shri R. K. Panda & Shri Vinay Bhamoreआयकर अपील सं. / Ita No.191/Pun/2024 िनधा"रण वष" / Assessment Year: 2018-19 Sagar Subhash Wedhane, Vs. Ito, Nashik. 75, Midc, Bosch Limited, Satpur, Nashik- 422007. Pan : Aavpw1338A Appellant Respondent Assessee By : Smt. Abhilasha Sanjay Pawar Revenue By Shri Sourabh Nayak : Date Of Hearing : 12.06.2024 Date Of Pronouncement : 03.07.2024 आदेश / Order Per Vinay Bhamore, Jm: This Appeal Filed By The Assessee Is Directed Against The Order Dated 26.01.2024 Passed By Ld Cit(A)/Nfac For The Assessment Year 2018-19. 2. The Appellant Has Raised The Following Grounds Of Appeal :- “1. The Learned Cit Is Not Justified In Levying Penalty U/S 270A Of Rs.1,61,548/- On The Ground That The Assesses Has Under-Reporting In Consequence Of Mis-Reporting Without Appreciating That The Said Levy Of Penalty Was Not Justified In Law.

reassessment proceedings u/s 147/148 of the IT Act the assesse furnished true & correct return by claiming appropriate deduction under chapter VI of the IT Act. The return of income was accepted by the Assessing Officer except difference of 7 Rs.5,430/- which arises due to disallowance of other charges paid to school but claimed as tuition fee. In the assessment

SACHIN BADRINARAYAN SOMANI,PUNE vs. ITO WARD , HINGOLI

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

Bench: Dr. Manish Borad & Shri Vinay Bhamoreआयकर अपील सं./Ita No. 2112 & 2113/Pun/2025 धििेंारण वर्ा /Assessment Year: 2013-14 Sachin Badrinarayan Somani, Ito Ward, Hingoli Rathi Rathi & Co., 501-504, Akshay Landmarks, Oppo. Pu Vs. La Garden, Sinhagad Road, Pune-411030 Maharashtra Pan-Cncps2724N अपीलेंर्थी / Appellant प्रत्यर्थी / Respondent Assessee By: Shri Nemin Shah Department By: Shri Ganesh B. Budruk-Addl. Cit Date Of Hearing: 18-12-2025 Date Of Pronouncement: 23-12-2025 आदीश /Order

Section 274 of the Act. Ground 4: The Appellant craves leave to add, alter, vary, omit, amend or delete the above grounds of appeal at any time before, or at the time of, hearing of the appeal, so as to enable the learned Appellate Commissioner to decide this appeal according to law. Assessee has raised following grounds of appeal

SACHIN BADRINARAYAN SOMANI,PUNE vs. ITO WARD , HINGOLI

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

Bench: Dr. Manish Borad & Shri Vinay Bhamoreआयकर अपील सं./Ita No. 2112 & 2113/Pun/2025 धििेंारण वर्ा /Assessment Year: 2013-14 Sachin Badrinarayan Somani, Ito Ward, Hingoli Rathi Rathi & Co., 501-504, Akshay Landmarks, Oppo. Pu Vs. La Garden, Sinhagad Road, Pune-411030 Maharashtra Pan-Cncps2724N अपीलेंर्थी / Appellant प्रत्यर्थी / Respondent Assessee By: Shri Nemin Shah Department By: Shri Ganesh B. Budruk-Addl. Cit Date Of Hearing: 18-12-2025 Date Of Pronouncement: 23-12-2025 आदीश /Order

Section 274 of the Act. Ground 4: The Appellant craves leave to add, alter, vary, omit, amend or delete the above grounds of appeal at any time before, or at the time of, hearing of the appeal, so as to enable the learned Appellate Commissioner to decide this appeal according to law. Assessee has raised following grounds of appeal

SHRI POPAT KARBHARI BHALERAO,NASHIK vs. INCOME TAX OFFICER, WARD-2(1), NASHIK, NASHIK

In the result, appeal of the assessee is allowed

Bench: Shri S.S.Godara & Dr. Dipak P. Ripoteआयकर अपील सं. / Ita Nos.1323 & 1324/Pun/2023 िनधा"रण वष" / Assessment Year : 2017-18 & 2018-19 Shri Popat Karbhari Bhalerao, The Income Tax Officer, Yeshdei Niwas, Maratha V Ward-2(1), Nashik. Nagar, Near Rajrajeshwari S Mangal Karyalay, Jailroad, Nashik Road, Nashik-422101. Pan: Aaqpb3523N Appellant / Assessee Respondent / Revenue Assessee By Shri Sanket Joshi – Ar Revenue By Shri Sourabh Nayak – Addl.Cit(Dr) Date Of Hearing 19/03/2024 Date Of Pronouncement 26/03/2024 आदेश/ Order Per Dr. Dipak P. Ripote, Am: This Is An Appeal Filed By The Assessee Against The Order Of Ld.Cit(A)[Nfac] For A.Y.2017-18 Dated 02.09.2022 Under Section 250 Of The Income Tax Act, 1961, Emanating From Penalty Order Under Section 270A Of The Act, Dated 30.12.2021. The Assessee Raised The Following Grounds Of Appeal :

reassessment order, the A.O has initiated penalty u/s 270A on a vague charge of ‘furnishing inaccurate particulars of income’ also in the notice u/s 274 r.w.s 270A, the exact limb of section

SHRI POPAT KARBHARI BHALERAO,NASHIK vs. INCOME TAX OFFICER, WARD.2(1), PUNE, PUNE

In the result, appeal of the assessee is allowed

Bench: Shri S.S.Godara & Dr. Dipak P. Ripoteआयकर अपील सं. / Ita Nos.1323 & 1324/Pun/2023 िनधा"रण वष" / Assessment Year : 2017-18 & 2018-19 Shri Popat Karbhari Bhalerao, The Income Tax Officer, Yeshdei Niwas, Maratha V Ward-2(1), Nashik. Nagar, Near Rajrajeshwari S Mangal Karyalay, Jailroad, Nashik Road, Nashik-422101. Pan: Aaqpb3523N Appellant / Assessee Respondent / Revenue Assessee By Shri Sanket Joshi – Ar Revenue By Shri Sourabh Nayak – Addl.Cit(Dr) Date Of Hearing 19/03/2024 Date Of Pronouncement 26/03/2024 आदेश/ Order Per Dr. Dipak P. Ripote, Am: This Is An Appeal Filed By The Assessee Against The Order Of Ld.Cit(A)[Nfac] For A.Y.2017-18 Dated 02.09.2022 Under Section 250 Of The Income Tax Act, 1961, Emanating From Penalty Order Under Section 270A Of The Act, Dated 30.12.2021. The Assessee Raised The Following Grounds Of Appeal :

reassessment order, the A.O has initiated penalty u/s 270A on a vague charge of ‘furnishing inaccurate particulars of income’ also in the notice u/s 274 r.w.s 270A, the exact limb of section

LEAR AUTOMOTIVE INDIA P. LTD. ,PUNE vs. ASSISTANT COMMISSIONER OF INCOME TAX, CIRCLE-8, PUNE, PUNE

reassessed\nRs.42,04,70,990/- by the Ld. AO vide draft assessment order passed u/s\n143(3)/254 r.w.s. 144B r.w.s. 144C(1) dated 31.03.2023 which was\nchallenged by the assessee by filing objections before the Ld. DRP.\n2.3 Before the Ld. DRP, the assessee raised the following objections\npertaining to allocation of RHQ charges :\n1.\n“6.1. Issue

M/S KARIA BUILDERS ,PUNE vs. ITO WARD 14(3), PUNE

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

Bench: Shri R. K. Panda & Ms. Astha Chandraassessment Year : 2017-18 M/S. Karia Builders Ito, Ward 14(3), Pune 402, Konark Indrayu, Kondhwa, Vs. Pune – 411048 Pan: Aadfk5220B (Appellant) (Respondent) Assessee By : Shri Sanket M Joshi Department By : Shri Ramnath P Murkunde Date Of Hearing : 17-07-2025 Date Of Pronouncement : 23-07-2025 O R D E R

274 r.w.s. 271D of the Act was issued to the assessee on 17.08.2022 which reads as under: 9 19. Thus, the penalty proceedings were initiated on 17.08.2022. We find the JCIT in the show cause notice for penalty u/s 271D of the Act issued on 13.02.2023 has also mentioned the time barring date i.e. 28.02.2023 for levy of penalty

SHRI PRAPHULL KALURAM SHIVALE,PUNE vs. CENTRAL CIRCLE 2(3), PUNE

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

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

section 147 of the Act. Accordingly, a notice u/s 148 of the Act was issued to the assessee on 08.03.2021 after recording the reasons and obtaining the approval from the competent authority. The assessee in response to the same vide letter dated 06.04.2021 stated that the return of income filed on 14.02.2018 may be treated as return in response

SMT ANJALI PRAPHULL SHIVALE,PUNE vs. ACIT CIRCLE2(3), PUNE

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

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

section 147 of the Act. Accordingly, a notice u/s 148 of the Act was issued to the assessee on 08.03.2021 after recording the reasons and obtaining the approval from the competent authority. The assessee in response to the same vide letter dated 06.04.2021 stated that the return of income filed on 14.02.2018 may be treated as return in response

SHRI PRAPHULL KALURAM SHIVALE,PUNE vs. CENTRAL CIRCLE 2(4), PUNE

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

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

section 147 of the Act. Accordingly, a notice u/s 148 of the Act was issued to the assessee on 08.03.2021 after recording the reasons and obtaining the approval from the competent authority. The assessee in response to the same vide letter dated 06.04.2021 stated that the return of income filed on 14.02.2018 may be treated as return in response

SHRI PRAPHULL KALURAM SHIVALE,PUNE vs. CENTRAL CIRCLE 2(3), PUNE

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

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

section 147 of the Act. Accordingly, a notice u/s 148 of the Act was issued to the assessee on 08.03.2021 after recording the reasons and obtaining the approval from the competent authority. The assessee in response to the same vide letter dated 06.04.2021 stated that the return of income filed on 14.02.2018 may be treated as return in response