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

AHAMAD BIN MUBARAK CHAUOSE,NANDED vs. ITO, WARD (1), NANDED, NANDED

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

Bench: Dr.Dipak P. Ripote & Shri Vinay Bhamoreआयकर अपील सं. / Ita No.1545/Pun/2025 िनधा"रण वष" / Assessment Year: 2012-13 Ahamad Bin Mubarak V The Income Tax Officer, Chauose, S Ward-(1), Nanded. H.No.1-7-1349, Peerburhan Nagar, Nanded – 431506. Maharashtra. Pan: Alzpc8261D Appellant/ Assessee Respondent / Revenue Assessee By None Revenue By Shri Ajay D. Kulkarni – Addl.Cit(Dr) Date Of Hearing 07/08/2025 Date Of Pronouncement 08/08/2025 आदेश/ Order Per Dr. Dipak P. Ripote, Am: This Is An Appeal Filed By The Assessee Directed Against The Order Of Ld.Addl./Joint Commissioner Of Income Tax(A), Kanpur Passed Under Section 250 Of The Income Tax Act, 1961 Dated 18.10.2024 For The A.Y.2012-13 Emanating From The Assessment Order Under Section 144 Of The Income Tax Act, 1961, Dated

4. That the reassessment order passed under section 147/144 is illegal and unsustainable in law as the reasons recorded were never communicated to the Appellant, contrary to settled legal principles and precedents. 5. That the reassessment proceedings were barred by limitation as per the provisions of section 153(2) of the Act, and hence, the assessment framed on 09/03/2016

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

58,67,123/-, on account of unsecured loans and the interest thereon. 5.5. However, the appellant has strongly argued that the reasons recorded were wrong and the reassessment proceedings were initiated on the basis of wrong reasons. The appellant stated that reassessment proceedings were initiated after recording reasons that "bogus companies run by Mr. Anand Sharma and group had provided

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

58,75,26,422/- (declared as per income and expenditure account). The relevant observations and findings of the Ld. CIT(A) are reproduced below:- “6.4. During the appellate proceedings, the appellant has furnished written submissions by stating that it has filed ITR declaring total income at Rs. Nil, return is processed u/s.143(1)(a) by assessing income

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:

4. On the facts and in law, the Ld. CIT(A) erred by failing put to the notice of the Appellant of limb under which the Penalty was sought to be levied under Section 270A of the Act. 5. On the facts and in law, the impugned Notice for levy of Notice under Section 270A of the Act and impugned

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

58,817/- Revised return 28.08.2017 Rs.8,64,630/- Rs.3,52,500/- Revised return 28.11.2017 Rs.4,02,000/- Rs.1,60,818/- Return filed in Response to 13.3.2020 Rs.8,73,080/- notice u/s 148 3. The Assessing Officer(AO) passed re-assessment order assessing the total income at Rs.8,81,897/-. The AO initiated ITA Nos.915 & 916/PUN/2023 for A.Y’s.2017-18

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

58,817/- Revised return 28.08.2017 Rs.8,64,630/- Rs.3,52,500/- Revised return 28.11.2017 Rs.4,02,000/- Rs.1,60,818/- Return filed in Response to 13.3.2020 Rs.8,73,080/- notice u/s 148 3. The Assessing Officer(AO) passed re-assessment order assessing the total income at Rs.8,81,897/-. The AO initiated ITA Nos.915 & 916/PUN/2023 for A.Y’s.2017-18

AUTOCOMP CORPORATION PANSE PRIVATE LIMITED ,PUNE vs. ASST. COMMISSIONER OF INCOME TAX, PUNE

In the result, both the appeals filed by the assessee are allowed for statistical purposes

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

reassessment u/s 147. The learned CITA failed to consider the submissions made against the aforesaid addition and failed to appreciate that- 4.1 The appellant had accumulated and capitalised the expenses incurred on tooling and dies at the behest and on behalf of the Customers of Rs.6,00,43,068/- under Capital Work in Progress (CWIP) in the General Ledger

AUTOCOMP CORPORATION PANSE PRIVATE LIMITED ,PUNE vs. ASST. COMMISSIONER OF INCOME TAX, CIRCLE 1(1), PUNE

In the result, both the appeals filed by the assessee are allowed for statistical purposes

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

reassessment u/s 147. The learned CITA failed to consider the submissions made against the aforesaid addition and failed to appreciate that- 4.1 The appellant had accumulated and capitalised the expenses incurred on tooling and dies at the behest and on behalf of the Customers of Rs.6,00,43,068/- under Capital Work in Progress (CWIP) in the General Ledger

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

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

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

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

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

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

58,47,391/- which was denied by the Assessing Officer on the ground that\nthe relevant R & D unit was not approved by DSIR u/s 35(2AB) and therefore, the\nassessee is not entitled to claim the deduction. He submitted that before the\nAssessing Officer it was clarified that the assessee had made an application before\nDSIR and merely because

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

58,47,391/- which was denied by the Assessing Officer on the ground that\nthe relevant R & D unit was not approved by DSIR u/s 35(2AB) and therefore, the\nassessee is not entitled to claim the deduction. He submitted that before the\nAssessing Officer it was clarified that the assessee had made an application before\nDSIR and merely because

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

58,47,391/- which was denied by the Assessing Officer on the ground that\nthe relevant R & D unit was not approved by DSIR u/s 35(2AB) and therefore, the\nassessee is not entitled to claim the deduction. He submitted that before the\nAssessing Officer it was clarified that the assessee had made an application before\nDSIR and merely because

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

58,47,391/- which was denied by the Assessing Officer on the ground that\nthe relevant R & D unit was not approved by DSIR u/s 35(2AB) and therefore, the\nassessee is not entitled to claim the deduction. He submitted that before the\nAssessing Officer it was clarified that the assessee had made an application before\nDSIR and merely because

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

reassessment\nproceedings are initiated on the basis of report of Investigation wing Kolkata and\nincriminating material found in the search of appellant and then the provisions of\nSec.153C of the Act are applicable which override the applicability of Sec. 147\nand Sec. 148 of the Act.”\n14\nITA No.1178/PUN/2023\nITA No.2017/PUN/2024\n10. The ld. Counsel for the assessee submitted that