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

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)

37, 40, 41, 44, 47, 50/2012 and D.B Income tax Appeal No 7/2016) wherein the Hon'ble Court upheld the proposition that returns of income filed in response to notice u/s 153A are a consequence of search action taken under section 132 on the assessee These proceedings are analogous to proceedings under section 147 i.e. reassessment

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)

37, 40, 41, 44, 47, 50/2012 and D.B Income tax Appeal No 7/2016) wherein the Hon'ble Court upheld the proposition that returns of income filed in response to notice u/s 153A are a consequence of search action taken under section 132 on the assessee These proceedings are analogous to proceedings under section 147 i.e. reassessment

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)

37, 40, 41, 44, 47, 50/2012 and D.B Income tax Appeal No 7/2016) wherein the Hon'ble Court upheld the proposition that returns of income filed in response to notice u/s 153A are a consequence of search action taken under section 132 on the assessee These proceedings are analogous to proceedings under section 147 i.e. reassessment

DCIT-CIRCLE 7 PUNE, BODHI TOWER SALISBURY PARK PUNE vs. TRIO CHEMSUCROTECH ENG. PROJECTS PVT. LTD, PUNE

reassessment proceedings. Mr. Ajit Satam confessed that he had earned income of Rs 26.55 crores earned from the assessee with respect to the Tilaknagar project. A copy of said letter dated 28.03.2016 is enclosed at Pg 96-100 of the Paper Book. The said disclosure was made on 29th March 2016. He has voluntarily offered the above sum of Rs.26.55

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

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

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]

37,863 as exempt under Section 10(35). overlooking the evidence obtained during the survey on JM Financial Asset Management Ltd., which confirmed violations of SEBI regulations and established that the mutual fund used Unit Premium Reserves to declare dividends, in violation of regulatory norms. b. Whether on facts and circumstances of the case, the CIT(A) was justified

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

reassessed has no effect on reducing loss or conversion of loss into income. In Trust's case, there is no concept of loss and deficit is not/adjustable to subsequent years" As can be seen from the above, for levy of penalty u/s. 270A of the Act the assessed income should be greater than the processed income

DINDAYAL MAGASVARGIYA SAHAKARI SOOT GIRNI LTD,SANGLI vs. ASSISTANT COMMISSIONER OF INCOME TAX CIRCLE SANGLI, CIRCLE SANGLI

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

Bench: Shri Manish Borad & Shri Vinay Bhamoreआयकर अपील सं. / Ita No.205/Pun/2025 िनधा"रण वष" / Assessment Year : 2014-15 Dindayal Magasvargiya Vs. Acit, Circle Sangli, Sahakari Soot Girni Ltd., Sangli. At Waghwadi, Post Kameri, Tal. Walwa, Sangli- 415403. Pan : Aaaad0254E Appellant Respondent Assessee By : Shri Pramod S. Shingte Revenue By : Shri Ramnath P. Murkunde Date Of Hearing : 22.09.2025 Date Of Pronouncement : 09.12.2025 आदेश / Order Per Vinay Bhamore, Jm: This Appeal Filed By The Assessee Is Directed Against The Order Dated 05.12.2024 Passed By Ld. Cit(A)/Nfac For The Assessment Year 2014-15. 2. The Appellant Has Raised The Following Grounds Of Appeal :- “1. On The Facts & In The Circumstances Of The Case & In Law, Ld. Ao Erred In Initiating Reassessment Proceedings U/S 147 For Ay 2014-15, Being The Year Beyond 4 Years & For Which Assessment Order U/S 143(3) Has Already Been Passed, Thereby

reassessment proceedings u/s 147 for AY 2014-15 by recording the reason to believe which is based on audit objection. We submit that the reason based on such borrowed satisfaction cannot be the basis of reopening the concluded assessment. Therefore, entire proceedings are void ab initio. 4. Without prejudice to the above grounds on the facts and in the circumstances

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 under Section 153C of the Act has been specified as twelve months from the end of financial year during which the last authorisation to search under section 132 of the Act or requisition under section 132A of the Act, was executed.” 37

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

reassessment under Section 153C of the Act has been specified as twelve months from the end of financial year during which the last authorisation to search under section 132 of the Act or requisition under section 132A of the Act, was executed.” 37

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 under Section 153C of the Act has been specified as twelve months from the end of financial year during which the last authorisation to search under section 132 of the Act or requisition under section 132A of the Act, was executed.” 37

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

reassessment under Section 153C of the Act has been specified as twelve months from the end of financial year during which the last authorisation to search under section 132 of the Act or requisition under section 132A of the Act, was executed.” 37

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

reassessment under Section 153C of the Act has been specified as twelve months from the end of financial year during which the last authorisation to search under section 132 of the Act or requisition under section 132A of the Act, was executed.” 37

DINDAYAL MAGASVARGIYA SAHAKARI SOOT GIRNI LTD ,WAGHWADI vs. ASSISTANT COMMISSIONER OF INCOME TAX, CIRCLE, SANGLI., NISHANT COLONY

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

Bench: Shri Manish Borad & Shri Vinay Bhamoreआयकर अपील सं. / Ita No.2325/Pun/2025 िनधा"रण वष" / Assessment Year : 2013-14 Dindayal Magasvargiya Vs. Acit, Circle Sangli, Sahakari Soot Girni Ltd., Sangli. At Waghwadi, Post Kameri, Tal. Walwa, Sangli- 415403. Pan : Aaaad0254E Appellant Respondent Assessee By : Shri Pramod S. Shingte Revenue By : Shri R. Y. Balawade Date Of Hearing : 27.01.2026 Date Of Pronouncement : 29.01.2026 आदेश / Order Per Vinay Bhamore, Jm: This Appeal Filed By The Assessee Is Directed Against The Order Dated 01.08.2025 Passed By Ld. Cit(A)/Nfac For The Assessment Year 2013-14. 2. The Appellant Has Raised The Following Grounds Of Appeal :- “1. On The Facts & In The Circumstances Of The Case & In Law, Ld. Ao Erred In Initiating Reassessment Proceedings U/S 147 For Ay 2013-14, Being The Year Beyond 4 Years & For Which Assessment Order U/S 143(3) Has Already Been Passed, Thereby

reassessment proceedings u/s 147 for AY 2013-14 by recording the reason to believe which is based on audit objection. We submit that the reason based on such borrowed satisfaction cannot be the basis of reopening the concluded assessment. Therefore, entire proceedings are void ab initio. 4. Without prejudice to the above grounds on the facts and in the circumstances

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

RAJARSHI SHAHU SHIKSHAN SANSTHA INAM DHAMANI,SANGLI vs. ITO EXEMPTION, KOLHAPUR, KOLHAPUR

In the result, all the appeals filed by the assessee are partly allowed as per terms indicated hereinabove

Bench: Dr.Manish Borad & Shri Vinay Bhamoreआयकर अपील सं. / Ita Nos.1121 To 1126/Pun/2024 Assessment Years : 2012-13 To 2017-18

reassessment is invalid merely because no addition was made on the original reason is devoid of merit. Therefore, this ground of appeal may be rejected.” 11. We have heard the rival contentions and perused the record placed before us and carefully gone through the decisions relied on by both the sides. Through Ground No.1, assessee has raised legal issue challenging

RAJARSHI SHAHU SHIKSHAN SANSTHA INAM DHAMANI,SANGLI vs. ITO EXEMPTION, KOLHAPUR

In the result, all the appeals filed by the assessee are partly allowed as per terms indicated hereinabove

Bench: Dr.Manish Borad & Shri Vinay Bhamoreआयकर अपील सं. / Ita Nos.1121 To 1126/Pun/2024 Assessment Years : 2012-13 To 2017-18

reassessment is invalid merely because no addition was made on the original reason is devoid of merit. Therefore, this ground of appeal may be rejected.” 11. We have heard the rival contentions and perused the record placed before us and carefully gone through the decisions relied on by both the sides. Through Ground No.1, assessee has raised legal issue challenging

RAJARSHI SHAHU SHIKSHAN SANSTHA INAM DHAMANI,SANGLI vs. ITO EXEMPTION, KOLHAPUR, KOLHAPUR

In the result, all the appeals filed by the assessee are partly allowed as per terms indicated hereinabove

Bench: Dr.Manish Borad & Shri Vinay Bhamoreआयकर अपील सं. / Ita Nos.1121 To 1126/Pun/2024 Assessment Years : 2012-13 To 2017-18

reassessment is invalid merely because no addition was made on the original reason is devoid of merit. Therefore, this ground of appeal may be rejected.” 11. We have heard the rival contentions and perused the record placed before us and carefully gone through the decisions relied on by both the sides. Through Ground No.1, assessee has raised legal issue challenging