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

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

35(2AB) of the Act amounting to Rs.2,63,91,741/-. We find\nbefore the Ld. CIT(A) / NFAC the assessee, apart from challenging the addition on\nmerit, challenged the validity of the assessment on the ground that the same has\nbeen passed on a non existing entity. We find the Ld. CIT(A) / NFAC not only\ndirected the Assessing

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

35(2AB) of the Act amounting to Rs.2,63,91,741/-. We find\nbefore the Ld. CIT(A) / NFAC the assessee, apart from challenging the addition on\nmerit, challenged the validity of the assessment on the ground that the same has\nbeen passed on a non existing entity. We find the Ld. CIT(A) / NFAC not only\ndirected the Assessing

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

35(2AB) of the Act amounting to Rs.2,63,91,741/-. We find\nbefore the Ld. CIT(A) / NFAC the assessee, apart from challenging the addition on\nmerit, challenged the validity of the assessment on the ground that the same has\nbeen passed on a non existing entity. We find the Ld. CIT(A) / NFAC not only\ndirected the Assessing

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

35(2AB) of the Act amounting to Rs.2,63,91,741/-. We find\nbefore the Ld. CIT(A) / NFAC the assessee, apart from challenging the addition on\nmerit, challenged the validity of the assessment on the ground that the same has\nbeen passed on a non existing entity. We find the Ld. CIT(A) / NFAC not only\ndirected the Assessing

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

35,789 cost incurred during\nthe year of Rs.327,42,32,668 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

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 Sections 139, 147, 148, 149, 151 & 153. 28. The language of explanation 2 to new Section 148 is akin to Section 153A and Section 153C Corollary being that after seizing of operational period of Section 153A to 153D. the cases being dealt thereunder were circumscribed in the scope of newly substituted Section 148." We are in complete agreement

SOMNATH RAMDAS JADHAV,AHMEDNAGAR vs. ITO, WARD 2, AHMEDNAGAR, AHMEDNAGAR

Accordingly, the appeal in ITA No.1092/PUN/2025 for A.Y. 2013-14 involving the issue of penalty u/s 271(1)(c) of the Act is allowed

Bench: Shri Manish Borad & Shri Vinay Bhamore

35 [sub-section (2) of section 115WD or sub-section (1) of section 142 or under sub-section (1) of section 115WH or under section 148 for the making of the return or by the notice under the first proviso to section 115WF or under the first proviso to section 144] to show cause why the assessment should

SOMNATH RAMDAS JADHAV,AHMEDNAGAR vs. ITO WARD 2, AHMEDNAGAR

Accordingly, the appeal in ITA No.1092/PUN/2025 for A.Y. 2013-14 involving the issue of penalty u/s 271(1)(c) of the Act is allowed

Bench: Shri Manish Borad & Shri Vinay Bhamore

35 [sub-section (2) of section 115WD or sub-section (1) of section 142 or under sub-section (1) of section 115WH or under section 148 for the making of the return or by the notice under the first proviso to section 115WF or under the first proviso to section 144] to show cause why the assessment should

SOMNATH RAMDAS JADHAV,AHMEDNAGAR vs. ITO WARD2, AHMEDNAGAR

Accordingly, the appeal in ITA No.1092/PUN/2025 for A.Y. 2013-14 involving the issue of penalty u/s 271(1)(c) of the Act is allowed

Bench: Shri Manish Borad & Shri Vinay Bhamore

35 [sub-section (2) of section 115WD or sub-section (1) of section 142 or under sub-section (1) of section 115WH or under section 148 for the making of the return or by the notice under the first proviso to section 115WF or under the first proviso to section 144] to show cause why the assessment should

SOMNATH RAMDAS JADHAV,AHMEDNAGAR vs. ITO, WARD 2, AHMEDNAGAR, AHMEDNAGAR

Accordingly, the appeal in ITA No.1092/PUN/2025 for A.Y. 2013-14 involving the issue of penalty u/s 271(1)(c) of the Act is allowed

Bench: Shri Manish Borad & Shri Vinay Bhamore

35 [sub-section (2) of section 115WD or sub-section (1) of section 142 or under sub-section (1) of section 115WH or under section 148 for the making of the return or by the notice under the first proviso to section 115WF or under the first proviso to section 144] to show cause why the assessment should

SOMNATH RAMDAS JADHAV,AHMEDNAGAR vs. ITO WARD 2, AHMEDNAGAR

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

35 [sub-section (2) of\nsection 115WD or sub-section (1) of section 142 or under\nsub-section (1) of section 115WH or under section 148 for\nthe making of the return or by the notice under the first\nproviso to section 115WF or under the first proviso to\nsection 144] to show cause why the assessment should

SOMNATH RAMDAS JADHAV,AHMEDNAGAR vs. ITO WARD 2, AHMEDNAGAR, AHMEDNAGAR

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

35 [sub-section (2) of\nsection 115WD or sub-section (1) of section 142 or under\nsub-section (1) of section 115WH or under section 148 for\nthe making of the return or by the notice under the first\nproviso to section 115WF or under the first proviso to\nsection 144] to show cause why the assessment should

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)

1). Therefore, in view of the decision of the Supreme Court in the case of CIT v: Sun Engg. Works (P.) Ltd. (1992) 198 ITR 297/64 Taxman 442, the assessee could not be permitted to claim the benefit of closing favourable to the assessee. (Para 11] Therefore, in assessment proceedings under section 1534, which are for the benefit

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)

1). Therefore, in view of the decision of the Supreme Court in the case of CIT v: Sun Engg. Works (P.) Ltd. (1992) 198 ITR 297/64 Taxman 442, the assessee could not be permitted to claim the benefit of closing favourable to the assessee. (Para 11] Therefore, in assessment proceedings under section 1534, which are for the benefit

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)

1). Therefore, in view of the decision of the Supreme Court in the case of CIT v: Sun Engg. Works (P.) Ltd. (1992) 198 ITR 297/64 Taxman 442, the assessee could not be permitted to claim the benefit of closing favourable to the assessee. (Para 11] Therefore, in assessment proceedings under section 1534, which are for the benefit

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

1) of the Act read with third proviso to said Section, in case of the search\nexecuted during the financial year commencing on or after 01.04.2019, the period\nof limitation for assessment or 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

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

1) of the Act read with third proviso to said Section, in case of the search\nexecuted during the financial year commencing on or after 01.04.2019, the period\nof limitation for assessment or 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

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

reassessment order, as the case may be, is required to be passed by the Assessing Officer with the prior approval of the [Principal Commissioner or Commissioner] under sub-section (12) of Section 144- BA." 11. A plain reading of the aforesaid provision evinces an uncontrived position of law that the approval under Section 153D

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

reassessment order, as the case may be, is required to be passed by the Assessing Officer with the prior approval of the [Principal Commissioner or Commissioner] under sub-section (12) of Section 144- BA." 11. A plain reading of the aforesaid provision evinces an uncontrived position of law that the approval under Section 153D