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

45,000\n60,000\n9\n1500\n1500000\nASHOK C\nASHOK D CHORDIYA\n1,75,500\n45,000\n14.\nReferring to the papers enclosed with the chart submitted by the ACIT,\nCentral Circle 1(1), Pune, the details of which are placed at pages 8 to 13 of the\npaper book, the Ld. Counsel for the assessee drew the attention

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 in cases where assets belonging to the assessee or books of account or documents, which contain information pertaining to the assessee are found pursuant to a search conducted under Section 132 of the Act or requisition made under Section 132A of the Act, in respect of a person other than the assessee.” Accordingly, it is to submit that

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

45,890) after adjusting the incremental liability that may arise on disallowing health and education Cess. He, therefore, submitted that there is no basis for holding that the assessee has under-reported its income or done any act without good faith and due diligence and hence the provisions of section 270A of the Act do not apply 5 ITA No.1260/PUN/2025

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)

reassessment’ used in this section has to be understood in the context of section 153A alone. The word 'assessment’ is used in a number of provisions in a comprehensive sense and if can comprehend the whole procedure for ascertaining and imposing liability upon the taxpayer and the machinery for enforcement thereof. The concept of expression ‘assessment’ is used

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)

reassessment’ used in this section has to be understood in the context of section 153A alone. The word 'assessment’ is used in a number of provisions in a comprehensive sense and if can comprehend the whole procedure for ascertaining and imposing liability upon the taxpayer and the machinery for enforcement thereof. The concept of expression ‘assessment’ is used

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)

reassessment’ used in this section has to be understood in the context of section 153A alone. The word 'assessment’ is used in a number of provisions in a comprehensive sense and if can comprehend the whole procedure for ascertaining and imposing liability upon the taxpayer and the machinery for enforcement thereof. The concept of expression ‘assessment’ is used

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, 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

PADMAKAR VISHWAS DATE,BHOSARI vs. INCOME TAX E ASSESSMENT, PUNE

In the result, appeal of the assessee is dismissed

Bench: Shri S.S.Godara & Dr. Dipak P. Ripoteआयकर अपील सं. / Ita Nos.929, 930 & 931/Pun/2023 िनधा"रण वष" / Assessment Years : 2013-14, 2014-15 & 2015-16 Padmakar Vishwas Date, The Income Tax Officer S.No.218, Near Shri Krishn V –Tds(2), Pune. Mandir, Alandi Road, S Bhosari, Pune – 411038. Pan: Anhpd3804B Appellant/ Assessee Respondent /Revenue Assessee By None Revenue By Shri Sourabh Nayak – Addl.Cit(Dr) Date Of Hearing 15/02/2024 Date Of Pronouncement 16/02/2024 आदेश/ Order Per Dr. Dipak P. Ripote, Am: These Three Appeals Filed By The Assessee Are Against The Separate Orders Of Ld.Commissioner Of Income Tax(Appeals)[Nfac], Passed Under Section 250 Of The Income Tax Act, 1961 All Dated 26.06.2023. Since Issue Involved Is Same, All These Appeals Were Heard Together & Decided By This Consolidated Order. We Treat Appeal In Ita No.929/Pun/2023 For A.Y.2013-14

45 of the Income Tax Rules. 5. It is observed from Form No.35 of the assessee in which, in Column No.12.1 assessee has referred to the letter dated 02.09.2022 of ITO(TDS), Ward-2, Pune. Nowhere in Form No.35 assessee has referred to order under section 201 of the Act. Thus, it is clear that assessee had filed appeal before

PADMAKAR VISHWAS DATE,BHOSARI vs. INCOME TAX E ASSESSMENT , PUNE

In the result, appeal of the assessee is dismissed

Bench: Shri S.S.Godara & Dr. Dipak P. Ripoteआयकर अपील सं. / Ita Nos.929, 930 & 931/Pun/2023 िनधा"रण वष" / Assessment Years : 2013-14, 2014-15 & 2015-16 Padmakar Vishwas Date, The Income Tax Officer S.No.218, Near Shri Krishn V –Tds(2), Pune. Mandir, Alandi Road, S Bhosari, Pune – 411038. Pan: Anhpd3804B Appellant/ Assessee Respondent /Revenue Assessee By None Revenue By Shri Sourabh Nayak – Addl.Cit(Dr) Date Of Hearing 15/02/2024 Date Of Pronouncement 16/02/2024 आदेश/ Order Per Dr. Dipak P. Ripote, Am: These Three Appeals Filed By The Assessee Are Against The Separate Orders Of Ld.Commissioner Of Income Tax(Appeals)[Nfac], Passed Under Section 250 Of The Income Tax Act, 1961 All Dated 26.06.2023. Since Issue Involved Is Same, All These Appeals Were Heard Together & Decided By This Consolidated Order. We Treat Appeal In Ita No.929/Pun/2023 For A.Y.2013-14

45 of the Income Tax Rules. 5. It is observed from Form No.35 of the assessee in which, in Column No.12.1 assessee has referred to the letter dated 02.09.2022 of ITO(TDS), Ward-2, Pune. Nowhere in Form No.35 assessee has referred to order under section 201 of the Act. Thus, it is clear that assessee had filed appeal before

PADMAKAR VISHWAS DATE,,BHOSARI vs. INCOME TAX E ASSESSMENT, PUNE

In the result, appeal of the assessee is dismissed

Bench: Shri S.S.Godara & Dr. Dipak P. Ripoteआयकर अपील सं. / Ita Nos.929, 930 & 931/Pun/2023 िनधा"रण वष" / Assessment Years : 2013-14, 2014-15 & 2015-16 Padmakar Vishwas Date, The Income Tax Officer S.No.218, Near Shri Krishn V –Tds(2), Pune. Mandir, Alandi Road, S Bhosari, Pune – 411038. Pan: Anhpd3804B Appellant/ Assessee Respondent /Revenue Assessee By None Revenue By Shri Sourabh Nayak – Addl.Cit(Dr) Date Of Hearing 15/02/2024 Date Of Pronouncement 16/02/2024 आदेश/ Order Per Dr. Dipak P. Ripote, Am: These Three Appeals Filed By The Assessee Are Against The Separate Orders Of Ld.Commissioner Of Income Tax(Appeals)[Nfac], Passed Under Section 250 Of The Income Tax Act, 1961 All Dated 26.06.2023. Since Issue Involved Is Same, All These Appeals Were Heard Together & Decided By This Consolidated Order. We Treat Appeal In Ita No.929/Pun/2023 For A.Y.2013-14

45 of the Income Tax Rules. 5. It is observed from Form No.35 of the assessee in which, in Column No.12.1 assessee has referred to the letter dated 02.09.2022 of ITO(TDS), Ward-2, Pune. Nowhere in Form No.35 assessee has referred to order under section 201 of the Act. Thus, it is clear that assessee had filed appeal before

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:

45 (Chennai-Trib.), he submitted that unless a person is considered to have under-reported his income as contemplated by sub-section (2) of section 270A, he cannot be found to have attracted penalty under section 270A as envisaged for 'under-reporting of income in consequence of mis-reporting'. He accordingly submitted that the order

GULAMAHEMAD HAMIDULLA KHAN,PUNE vs. ITO WARD 14(3), PUNE

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

Bench: Shri R.K. Panda & Ms. Astha Chandra

45,130/- and as such the nature and sources of the credits cannot be ascertained during the year under consideration. Hence, the nature and sources of the credits of Rs. 2,20,79,550/- made in his bank account remains unexplained in view of the provisions of section 69A of the Act. In the above context

SHRIKANT GAJANAN VYAVAHARE,NASHIK vs. INCOME TAX OFFICER, NASHIK

In the result, appeal of the assessee in ITA No

Bench: Shri S.S.Godara & Dr. Dipak P. Ripoteआयकर अपील सं. / Ita Nos.915 & 916/Pun/2023 िनधा"रण वष" / Assessment Years : 2017-18 & 2018-19 Shrikant Gajanan Vyavahare, The Income Tax Officer, Plot No.06, S.No.16/3/1, V Nashik. Samarth Bungla, Near S Modakeshwar Mandir, Modakeshwar Nagar, Kamatwade, Nashik – 422010. Pan: Aakpv1138N Appellant/ Assessee Respondent /Revenue Assessee By Miss Abhilasha Sanjay Pawar – Ar Revenue By Shri Sourabh Nayak – Addl.Cit-Dr Date Of Hearing 14/02/2024 Date Of Pronouncement 12/04/2024 आदेश/ Order Per Dr. Dipak P. Ripote, Am: These Two Appeals Filed By The Assessee Are Against The Separate Order Of Ld.Commissioner Of Income Tax(Appeals)[Nfac], Passed Under Section 250 Of The Income Tax Act, 1961 Both Dated 15.02.2023, Emanating From Penalty Order Under Section 270A Of The Act Dated 19.01.2022 & 20.01.2022 For A.Y.2017-18 & 2018-19 Respectively. Since Issue Involved Is

45,200/- 80CCC Rs.4800/- 80TTA Rs.2001/- Total Rs.1,52,001/- 6.1 The assessee was eligible to claim deduction under Chapter VIA of only Rs.1,52,001/-. This explains that the assessee was well aware of the facts. This explains that Assessee has consciously claimed excess deduction under Chapter VIA. Be it as it may be, menserea is not required

SHRIKANT GAJANAN VYAVAHARE,KAMATWADE vs. INCOME TAX OFFICER, NASHIK

In the result, appeal of the assessee in ITA No

Bench: Shri S.S.Godara & Dr. Dipak P. Ripoteआयकर अपील सं. / Ita Nos.915 & 916/Pun/2023 िनधा"रण वष" / Assessment Years : 2017-18 & 2018-19 Shrikant Gajanan Vyavahare, The Income Tax Officer, Plot No.06, S.No.16/3/1, V Nashik. Samarth Bungla, Near S Modakeshwar Mandir, Modakeshwar Nagar, Kamatwade, Nashik – 422010. Pan: Aakpv1138N Appellant/ Assessee Respondent /Revenue Assessee By Miss Abhilasha Sanjay Pawar – Ar Revenue By Shri Sourabh Nayak – Addl.Cit-Dr Date Of Hearing 14/02/2024 Date Of Pronouncement 12/04/2024 आदेश/ Order Per Dr. Dipak P. Ripote, Am: These Two Appeals Filed By The Assessee Are Against The Separate Order Of Ld.Commissioner Of Income Tax(Appeals)[Nfac], Passed Under Section 250 Of The Income Tax Act, 1961 Both Dated 15.02.2023, Emanating From Penalty Order Under Section 270A Of The Act Dated 19.01.2022 & 20.01.2022 For A.Y.2017-18 & 2018-19 Respectively. Since Issue Involved Is

45,200/- 80CCC Rs.4800/- 80TTA Rs.2001/- Total Rs.1,52,001/- 6.1 The assessee was eligible to claim deduction under Chapter VIA of only Rs.1,52,001/-. This explains that the assessee was well aware of the facts. This explains that Assessee has consciously claimed excess deduction under Chapter VIA. Be it as it may be, menserea is not required

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

45 taxmann.com 20 (Gujarat). In this case also, the issue was that reasons for reopening was against the claim of assessee u/s.54E of the Act but thereafter Hon’ble Court has observed that section 54E of the Act is neither applicable nor sought to be applied by the assessee and also Hon’ble Court observing as follows : “2. The petitioner

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

45 taxmann.com 20 (Gujarat). In this case also, the issue was that reasons for reopening was against the claim of assessee u/s.54E of the Act but thereafter Hon’ble Court has observed that section 54E of the Act is neither applicable nor sought to be applied by the assessee and also Hon’ble Court observing as follows : “2. The petitioner

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

45 taxmann.com 20 (Gujarat). In this case also, the issue was that reasons for reopening was against the claim of assessee u/s.54E of the Act but thereafter Hon’ble Court has observed that section 54E of the Act is neither applicable nor sought to be applied by the assessee and also Hon’ble Court observing as follows : “2. The petitioner

DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-2, NASHIK, NASHIK vs. ABHAYRAJ FATTEHRAJ CHORDIYA, C/O LAXMI OIL MIL

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 : 2014-15

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 144BA.” 41. We, therefore, find merit in the arguments of the Ld. Counsel for the assessee that the approval u/s 153D of the Act has to be given