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

reassess such income or recompute the loss or the depreciation allowance or any other allowance or deduction for such assessment year and for which a prior notice under Section 148 would be required to be issued. Section 147 does not contemplate an eventuality which Section 153A or Section 153C contemplates, the basis of which is inter alia a search action

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

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

32,668 closing WIP of Rs.396,30,86,527 CENVAT credit of\nRs.10,54,94,659) on cost of sales (construction) during the year and it is exclusive\nof finance cost. Further, It is noticed that the assessee had debited entire interest\nexpenses of Rs.32,30,50,317 in profit and loss account ie the same was netted\nagainst revenue

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

Sections 148 to 153, assess or reassess such income and also any other income chargeable to tax which has escaped assessment" In the case at hand, the AO does not say that any income chargeable to tax has escaped assessment. All that the AO desires is 'examination of certain details pertaining to the amount paid by Petitioner to Crown'. That

ITO, WARD-1(1), SOLAPUR, SOLAPUR vs. MS. KSHIRSAGAR FABRICS, SOLAPUR

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

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

reassessment will be invalid because the Assessing Officer had formed an opinion in the original assessment, though he had not recorded his reasons. 5.7 The Hon'ble Bombay High Court in IL&FS Investment Managers Ltd. vs ITO [2008] 298 ITR 32 has held as under:- "11. We have considered the submissions of both the counsel. In the facts

MAHATMA PHULE GRAMIN BIGARSHETI SAHAKAR PAT SANSTHA LTD,KOLHAPUR vs. PCIT-1, PUNE, PUNE

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

Bench: Shri R. K. Panda & Ms. Astha Chandraassessment Year : 2018-19 Mahatma Phule Gramin Bigarsheti Pcit-1, Pune Sahakar Pat Sanstha Vs. A/P Hattiwade, Ajara, Kolhapur – 416505 Pan: Aaaam2608K (Appellant) (Respondent) Assessee By : None (Written Submission Filed) Department By : Shri Amol Khairnar, Cit-Dr Date Of Hearing : 09-12-2025 Date Of Pronouncement : 09-01-2026 O R D E R

reassessment, Assessing Officer ultimately comes to conclude that no additions or modifications are warranted under those heads, it would not be entitled to make any additions in respect of other items forming part of original return. 7 10. Relying on various other decisions, it has been mentioned that the Assessing Officer has no power to make additions beyond reason

ASHOK BHARTI GOSWAMI,PUNE vs. ACIT, CENTRAL CIRCLE 2(1), PUNE , PUNE

In the result, all the appeals filed by the respective assessees are allowed

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

reassess the income of the other person in accordance with the provisions of section 153A, if, that AO is satisfied that such books of account or documents have a bearing on the determination of the total income of such other person. Therefore, the provisions of section 153C of the Act squarely apply to the case of the appellant and thus

RAMANLAL BHIKULAL SHAH,PUNE vs. ACIT, CENTRAL CIRCLE 2(1), PUNE , PUNE

In the result, all the appeals filed by the respective assessees are allowed

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

reassess the income of the other person in accordance with the provisions of section 153A, if, that AO is satisfied that such books of account or documents have a bearing on the determination of the total income of such other person. Therefore, the provisions of section 153C of the Act squarely apply to the case of the appellant and thus

RAMLAL BHIKULAL SHAH,PUNE vs. ACIT, CENTRAL CIRCLE 2(1), PUNE , PUNE

In the result, all the appeals filed by the respective assessees are allowed

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

reassess the income of the other person in accordance with the provisions of section 153A, if, that AO is satisfied that such books of account or documents have a bearing on the determination of the total income of such other person. Therefore, the provisions of section 153C of the Act squarely apply to the case of the appellant and thus

CHITRA NARENDRA PARMAR,PUNE vs. ASSISTANT COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-2(1), PUNE, PUNE

In the result, all the appeals filed by the respective assessees are allowed

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

reassess the income of the other person in accordance with the provisions of section 153A, if, that AO is satisfied that such books of account or documents have a bearing on the determination of the total income of such other person. Therefore, the provisions of section 153C of the Act squarely apply to the case of the appellant and thus

CHITRA NARENDRA PARMAR ,PUNE vs. ACIT, CENTRAL CIRCLE 2(1), PUNE , PUNE

In the result, all the appeals filed by the respective assessees are allowed

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

reassess the income of the other person in accordance with the provisions of section 153A, if, that AO is satisfied that such books of account or documents have a bearing on the determination of the total income of such other person. Therefore, the provisions of section 153C of the Act squarely apply to the case of the appellant and thus

ASHISH RAMESH OSWAL,PUNE vs. ACIT, CENTRAL CIRCLE 2(1), PUNE, PUNE

In the result, all the appeals filed by the respective assessees are allowed

reassessment under Section 153C of the Act has\nbeen specified as twelve months from the end of financial year during which the\nlast authorisation to search under section 132 of the Act or requisition under\nsection 132A of the Act, was executed.”\n37. The Ld. Counsel for the assessee submitted that typically, the jurisdiction u/s\n127 is assigned in favour

DEEPAK KANTILAL JAIN,PUNE vs. ACIT, CENTRAL CIRCLE 2(1), PUNE , PUNE

reassessment under Section 153C of the Act has\nbeen specified as twelve months from the end of financial year during which the\nlast authorisation to search under section 132 of the Act or requisition under\nsection 132A of the Act, was executed.”\n37. The Ld. Counsel for the assessee submitted that typically, the jurisdiction u/s\n127 is assigned in favour

ADISH SHANTILAL SOLANKI,PUNE vs. ASSISTANT COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-2(1), PUNE, PUNE

reassessment under Section 153C of the Act has\nbeen specified as twelve months from the end of financial year during which the\nlast authorisation to search under section 132 of the Act or requisition under\nsection 132A of the Act, was executed.”\n37. The Ld. Counsel for the assessee submitted that typically, the jurisdiction u/s\n127 is assigned in favour

DEEPAK KANTILAL JAIN ,PUNE vs. ACIT, CENTRAL CIRCLE 2(1), PUNE , PUNE

In the result, all the appeals filed by the respective assessees are allowed

reassessment under Section 153C of the Act has\nbeen specified as twelve months from the end of financial year during which the\nlast authorisation to search under section 132 of the Act or requisition under\nsection 132A of the Act, was executed.”\n37. The Ld. Counsel for the assessee submitted that typically, the jurisdiction u/s\n127 is assigned in favour

ASHOK BHARTI GOSWAMI ,PUNE vs. ACIT, CENTRAL CIRCLE 2(1), PUNE, PUNE

In the result, all the appeals filed by the respective assessees are allowed

reassessment under Section 153C of the Act has\nbeen specified as twelve months from the end of financial year during which the\nlast authorisation to search under section 132 of the Act or requisition under\nsection 132A of the Act, was executed.”\n37. The Ld. Counsel for the assessee submitted that typically, the jurisdiction u/s\n127 is assigned in favour

ASHISH RAMESH OSWAL,PUNE vs. ACIT, CENTRAL CIRCLE 2(1), PUNE , PUNE

In the result, all the appeals filed by the respective assessees are allowed

reassessment under Section 153C of the Act has\nbeen specified as twelve months from the end of financial year during which the\nlast authorisation to search under section 132 of the Act or requisition under\nsection 132A of the Act, was executed.”\n\n37.\nThe Ld. Counsel for the assessee submitted that typically, the jurisdiction u/s\n127 is assigned

SHRI MANOJ MADANLAL CHHAJED,PUNE vs. THE ASSISTANT COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-1(1), PUNE

Section 80IA/IB of the Act.\nIt must follow that there is due application of mind by the Assessing\nOfficer to the issue raised.\nThe above observations apply on all fours to this Petition, so far as the\nRevenue's submission of no change of opinion is concerned.\n11. The further submission of Mr. Walve that in the absence