INCOME TAX OFFICER, PUNE vs. SAGAR CONSTRUCTION COMPANY, PUNE

In the result, the appeal filed by the Revenue is dismissed and the CO filed by the assessee is allowed

Bench: Shri R. K. Panda & Ms. Astha Chandraassessment Year : 2017-18

reassess the income in respect of any issue, which has escaped assessment, and such issue comes to his notice subsequently in the course of the proceedings under this section, notwithstanding that the reasons for such issue have not been included in the reasons recorded under sub- section (2) of section 148. Explanation 4

ASHOK DHANRAJ CHORDIA ,PUNE vs. PCIT, PUNE-1, PUNE

reassess the income\nin respect of any issue, which has escaped assessment, and such issue\ncomes to his notice subsequently in the course of the proceedings under this\nsection, notwithstanding that the reasons for such issue have not been\nincluded in the reasons recorded under sub- section (2) of section 148.\nExplanation 4

GAURI SAGAR SHIVALE,PUNE vs. ITO WARD 8(3), PUNE

In the result, the appeal of the assessee is treated as allowed for statistical purposes

Bench: Shri Manish Borad & Ms. Astha Chandraआयकर अपील सं. / Ita No.101/Pun/2025 धििाारण वर्ा / Assessment Year : 2014-15 Gauri Sagar Shivale, Income Tax Officer, S. No. 32/4, Nimbalkar Nagar, Ward – 8(3), Pune Brt Road, Near Rajiv Gandhi Vs. College, Tathawade, Mulshi, Pune-411033 Pan : Bjipp4685G अपीलार्थी / Appellant प्रत्यर्थी / Respondent Assessee By : Shri Nikhil S. Pathak Department By : Shri Ramnath P. Murkunde Date Of Hearing : 15-05-2025 Date Of 21-07-2025 Pronouncement :

reassessment proceedings, the Ld. AO made enquiry about the development agreement entered into by the assessee vide issue of notice(s) u/s 142(1) of the Act and also issued a show cause notice asking the assessee to show cause as to why the addition should not be made taxing the capital gain arising on account of the said development

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

SHRIKANT CHANDRAKANT LOKHANDE,LATUR vs. ITO, WARD-1, LATUR, LATUR

In the result, the appeal of the assessee is allowed for statistical purposes

Bench: Dr.Manish Borad & Shri Vinay Bhamoreआयकर अपील सं. / Ita No.2696/Pun/2024 Assessment Year : 2015-16

reassessment barred by time: That the CIT(A) erred in law in not appreciating the fact that notice under section 148 of the Act was issued based on some information flagged as per Risk Management Strategy formulated by the CBDT in NMS module of insight portal regarding time deposit of amount which was not properly uploaded and there was mistake

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:

4) shall be final. (6) No appeal under section 246A or an application for revision under section 264 shall be admissible against the order of assessment or reassessment

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)

4. Having regard to the provisions of section 139(5) and since the assessments under section 153A are in relation to undisclosed income, it is precisely for this reason that new claim of deduction or allowance cannot be made in the completed assessments. section 153A is not de novo assessment; therefore, there is no merit in the ground to make

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)

4. Having regard to the provisions of section 139(5) and since the assessments under section 153A are in relation to undisclosed income, it is precisely for this reason that new claim of deduction or allowance cannot be made in the completed assessments. section 153A is not de novo assessment; therefore, there is no merit in the ground to make

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)

4. Having regard to the provisions of section 139(5) and since the assessments under section 153A are in relation to undisclosed income, it is precisely for this reason that new claim of deduction or allowance cannot be made in the completed assessments. section 153A is not de novo assessment; therefore, there is no merit in the ground to make

ARUNA SINGH ,THANE vs. ITO WARD 3(1), KALYAN

In the result, the appeal of the assessee is allowed for statistical\npurposes

reassessment which is done for the benefit of Revenue.\nHence, in our view, clause (b) of Section 249(4) of the Act will

PUSHPADEVI SHIVLAL RATHI ,JALNA vs. ITO WARD-1, JALNA

In the result, the appeal of the assessee is partly allowed for statistical purposes

Bench: Dr.Manish Boradआयकर अपील सं. / Ita No.1995/Pun/2024 "नधा"रण वष" / Assessment Years : 2017-18

reassessment notice under section 148 of the new regime. Thus, in this illustration, the time limit for issuance of a 6 Pushpadevi Shivlal Rathi notice under section 148 of the new regime will end on 18 August 2022. 13. In the present case, deemed show cause notice (notice u/s.148 as per old regime) was issued to the Appellant

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. 11 ITA.Nos.1939 & 1940/PUN./2024 (4) Subject to the provisions of sub-section (6), where the source of any receipt

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. 11 ITA.Nos.1939 & 1940/PUN./2024 (4) Subject to the provisions of sub-section (6), where the source of any receipt

SHANKAR NAGAPPA JADAGOUDA,KOLHAPUR vs. NFAC, DELHI

Appeal is allowed in above terms

Bench: Shri Satbeer Singh Godara

reassess income in respect of any issue which comes to his notice subsequently in the course of proceedings under this section, notwithstanding that the reason for such issue has not been included in the reasons recorded under sub-section (2) of section 148." 4

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

reassessed or recomputed in a preceding order:" 7.5 Section 270A(2) provides list of instances upon meeting which it can be considered that there is 'Under reported income' in the hands of assessee. Section 270A(3) gives method to arrive at quantum of 'Under reported income' in the hands of assessee. 270A(2)(b) clearly states that 'under reported income

SWAMINATH BABURAO PATIL,SOLAPUR vs. ITO WARD 2(3) SOLAPUR, SOLAPUR

In the result, appeal of the Assessee is allowed for statistical purpose

Bench: Ms.Astha Chandra & Dr.Dipak P. Ripoteआयकर अपऩल सं. / Ita No.832/Pun/2025 निर्धारण वषा / Assessment Year: 2014-15 Swaminath Baburao Patil, V The Income Tax Officer, C37, Siddheshwar Market S Ward-2(3), Solapur. Yard, Hyderabad Road, Solapur – 431005. Maharashtra. Pan: Akwpp4321P Appellant/ Assessee Respondent / Revenue Assessee By Shri Girish Ladda Revenue By Shri Ambarnath Khule (Through Virtual Hearing) – Jcit(Dr) Date Of Hearing 24/11/2025 Date Of Pronouncement 25/11/2025 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.2014-15 Dated 27.01.2025 Emanating From The Assessment Order Passed Under Section 147 R.W.S 144B Of The Act, Dated 19.05.2023. The Assessee Has Raised The Following Grounds Of Appeal :

reassessment order passed u/s 147 may please be quashed being passed without issue of statutory Notice u/s 143(2) of Income Tax Act even when the appellant filed a Return of Income on 03/02/2023 vide Acknowledgment Number 947198020030223. Non-issuance of the Statutory Notice u/s 143(2) is a jurisdictional defect not curable u/s 292BB. 3) Proceedings u/s 148 invalid

SAGAR BABANRAO AWATADE,NAVI MUMBAI vs. INCOME TAX OFFICER, WARD-1, PANVEL, PANVEL

Appeal is allowed

Bench: Shri Satbeer Singh Godaraआयकर अपील सं. /Ita No.79/Pun/2024 "नधा"रण वष" / Assessment Year : 2014-15

reassess the income in respect of any issue, which has escaped assessment, and such issue comes to his notice subsequently in the course of the proceedings under this section, notwithstanding that the reasons for such issue have not been included in the reasons recorded under subsection (2) of section 148. Explanation 4

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

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 the section. The first proviso to section 147 has no application in the facts of this case. The basic postulate which underlines section 147 is the formation of the belief

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:

4. For understanding the decision of Rajeev Bansal case, it is imperative to understand the interplay of TOLA, changes brought 5 ITA Nos.3280 & 3281/PUN/2025 [A] in the reassessment provisions by Finance Act, 2021 and the decision of Hon.Supreme Court in Union of India v. Ashish Agarwal [2022]444ITR1(SC)(Annexure-5). Back ground of the Rajeev Bansal case COVID