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

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

JITENDRA PRATAPRAO SONAR,,PUNE vs. DEPUTY COMMISSIONER OF INCOME-TAX,,

In the result, all the three appeals of the assessee are

Bench: Ms. Sushma Chowla, Jm & Shri Anil Chaturvedi, Am

42,104/- 3,00,35,988/- 3,00,35,988/- On the additional income offered by the assessee in the revised return of income for the three assessment years, AO vide order dt.26.09.2014 levied penalty of Rs.12,16,305/- (for A.Y. 2009-10), Rs.48,78,801/- (for A.Y. 2010-11) and Rs.50

JITENDRA PRATAPRAO SONAR,,PUNE vs. DEPUTY COMMISSIONER OF INCOME-TAX,,

In the result, all the three appeals of the assessee are

Bench: Ms. Sushma Chowla, Jm & Shri Anil Chaturvedi, Am

42,104/- 3,00,35,988/- 3,00,35,988/- On the additional income offered by the assessee in the revised return of income for the three assessment years, AO vide order dt.26.09.2014 levied penalty of Rs.12,16,305/- (for A.Y. 2009-10), Rs.48,78,801/- (for A.Y. 2010-11) and Rs.50

JITENDRA PRATAPRAO SONAR,,PUNE vs. DEPUTY COMMISSIONER OF INCOME-TAX,,

In the result, all the three appeals of the assessee are

Bench: Ms. Sushma Chowla, Jm & Shri Anil Chaturvedi, Am

42,104/- 3,00,35,988/- 3,00,35,988/- On the additional income offered by the assessee in the revised return of income for the three assessment years, AO vide order dt.26.09.2014 levied penalty of Rs.12,16,305/- (for A.Y. 2009-10), Rs.48,78,801/- (for A.Y. 2010-11) and Rs.50

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:

42,650/-. A survey u/s 133A of the Act was conducted at the business premises of the assessee from 5th to 7th February, 2020 during which certain registers were impounded containing the undisclosed professional receipts according to which such undisclosed receipts for the year under consideration were Rs.49,64,120/-. When confronted the assessee admitted that the receipts contained

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

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

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

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

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

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

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

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

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

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

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

The appeal stands dismissed

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. The Ld. Counsel for the assessee submitted that typically, the jurisdiction u/s 127 is assigned in favour

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

1. Accommodation loan entries\n9\nITA No.1178/PUN/2023\nITA No.2017/PUN/2024\n6.2.1 The AO passed the assessment order under section 143(3) rws 148 of the act\non 28/12/2018 by making a total addition of Rs 2,79,78,912/-. The addition of this\namount has been made by the assessing officer by arriving at the figure of net\ncredit

VISHNU SUBHASH AGARWAL,PUNE vs. ITO WARD 6(1), PUNE

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

Bench: Shri R. K. Panda & Shri Vinay Bhamoreassessment Year : 2015-16

42 of the paper book. He submitted that in the instant case notice u/s 148 of the Act is dated 08.04.2021. Referring to the decision of Hon'ble Supreme Court in the case of Union of India vs. Rajeev Bansal (supra), he submitted that as per the said decision the due date of issuing notice

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

The appeal stands dismissed

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. The Ld. Counsel for the assessee submitted that typically, the jurisdiction u/s 127 is assigned in favour

MERCEDES - BENZ INDIA PVT. LTD.,,PUNE vs. DEPUTY COMMISSIONER OF INCOME-TAX,

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

Bench: Shri D. Karunakara Rao, Am & Shri Vikas Awasthy, Jm आयकर अऩीऱ सं./ Ita No. 1865/Pun/2013 यनधाारण वषा / Assessment Year : 1999-2000 Mercedes Benz India Private Limited. ( Formerly Known As Daimler Chrysler India Private Limited) E-3, Midc Chakan, Phase-Iii, Chakan Industrial Area, Kuruli & Nighoje, Tal : Khed, Pune-410 501. Pan : Aabcm 1789L .......अऩीऱाथी / Appellant बनाम / V/S. The Deputy Commissioner Of Income Tax, Circle-9, Pune. ……प्रत्यथी / Respondent

1) whereas in MB India's case, the deduction is claimed under section 35AB which was introduced later in the point of time due to change in intention of the Government (to attract flow of technology into India) to allow deduction for such payments. In MB India's case, the transfer of technical know-how for consideration (between MB India

DEPUTY COMMISSIONER OF INCOME-TAX vs. DAIMLER CHRYSLER INDIA PVT. LTD.,, PUNE

In the result, the cross objection of the assessee is dismissed

Bench: Shri D.Karunakara Rao, Am & Shri Vikas Awasthy, Jm आयकर आयकर अपील आयकर आयकर अपील अपील संसंसंसं. / Ita No.1381/Pun/2003 अपील िनधा"रण िनधा"रण वष" िनधा"रण िनधा"रण वष" वष" / Assessment Year : 1998-09 वष"

1) whereas in MB India's case, the deduction is claimed under section 35AB which was introduced later in the point of time due to change in intention of the Government (to attract flow of technology into India) to allow deduction for such payments. In MB India's case, the transfer of technical know-how for consideration (between MB India

DAIMLER CHRYSLER INDIA PVT. LTD.,,PUNE vs. DEPUTY COMMISSIONER OF INCOME-TAX,, PUNE

In the result, the cross objection of the assessee is dismissed

Bench: Shri D.Karunakara Rao, Am & Shri Vikas Awasthy, Jm आयकर आयकर अपील आयकर आयकर अपील अपील संसंसंसं. / Ita No.1381/Pun/2003 अपील िनधा"रण िनधा"रण वष" िनधा"रण िनधा"रण वष" वष" / Assessment Year : 1998-09 वष"

1) whereas in MB India's case, the deduction is claimed under section 35AB which was introduced later in the point of time due to change in intention of the Government (to attract flow of technology into India) to allow deduction for such payments. In MB India's case, the transfer of technical know-how for consideration (between MB India