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

section 147. 27. Referring to the decision of Hon’ble Delhi High Court in the case of CIT vs. Anil Kumar Bhatia reported in (2013) 352 ITR 493 (Del), he submitted that the Hon’ble High Court in the said decision has held that post search reassessment in respect of all 6

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

6 of the paper book filed by the Revenue, the. Ld. Counsel\nfor the assessee drew the attention of the Bench to the same which reads as under:\nOFFICE OF THE\nAsset Commissioner Of Income Tax, Central Circle 111), Pane\nPune 41103\nThinc 24263617\nEmail id pune delt.ceni. Laincometax.gov.in\nNo.Pu/DCIT.Cen.Cir.1(1)/Sharing of Info./2020-21/\nDate:27/03/2021\nTo\nThe Deputy Commissioner

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

6) of the Act. Accordingly penalty u/s 270A of the Act for under reporting of income in consequence of mis- reporting of income as per section 270A is leviable. For better understanding relevant portion of provisions made in section 270A of the Act is reproduced below:- "(2) A person shall be considered to have under-reported his income

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

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

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

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

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)

6. The facts, in brief, are that the assessee is a company registered under the provisions of the Companies Act, 1956. It is engaged in the business of civil contractors and development of infrastructure projects on BOT basis through various Special Purpose Vehicle (SPV) entities formed for the execution of such projects as per the conditions of the respective authorities

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)

6. The facts, in brief, are that the assessee is a company registered under the provisions of the Companies Act, 1956. It is engaged in the business of civil contractors and development of infrastructure projects on BOT basis through various Special Purpose Vehicle (SPV) entities formed for the execution of such projects as per the conditions of the respective authorities

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)

6. The facts, in brief, are that the assessee is a company registered under the provisions of the Companies Act, 1956. It is engaged in the business of civil contractors and development of infrastructure projects on BOT basis through various Special Purpose Vehicle (SPV) entities formed for the execution of such projects as per the conditions of the respective authorities

SHANKAR NAGAPPA JADAGOUDA,KOLHAPUR vs. NFAC, DELHI

Appeal is allowed in above terms

Bench: Shri Satbeer Singh Godara

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 section 147. 3 ITA.No.381/PUN./2024 6

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

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:

reassessment, aiming to make the process more structured and transparent. The key highlights of the new regime were Opportunity before issue of notice u/s 148 : 6 ITA Nos.3280 & 3281/PUN/2025 [A] a. Introduction of new Section

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:

reassessment, aiming to make the process more structured and transparent. The key highlights of the new regime were Opportunity before issue of notice u/s 148 : 6 ITA Nos.3280 & 3281/PUN/2025 [A] a. Introduction of new Section

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

section 148 of the Income-tax Act, 1961 to assess the income of the assessee for the assessment year 2009-10. Since more than four years have been passed from the end of the relevant assessment year and tax effect on income escaping assessment is more than one lakh. Hence, the approval of Principal Commissioner of Income-tax is necessary

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

reassessment proceedings was initiated without complying with the requirement of section 151 of the Act. The relevant findings and observations of the Ld. CIT(A) is reproduced below : “6

ASSTT. COMMISSIONER OF INCOME TAX (EXEMPTIONS), CIRCLE, PUNE, PUNE vs. THE SHETKARI SHIKSHAN MANDAL, PUNE

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

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

section 11(6) is that in respect of an asset two deductions cannot be claimed. If cost of the assets is claimed, then depreciation cannot be claimed. It follows that if cost of the asset is allowed as application, loan availed to purchase the asset cannot then be allowed. I find no infirmity in the finding

ADVIK HI TECH PVT LTD,PUNE vs. DY.COMM..OF INCOMETAX, CIRCLE 8, PUNE

In the result, appeal of the assessee is allowed

Bench: Shri Rama Kanta Panda & Ms. Astha Chandra

section 115JC, as the case may be, is greater than the deemed total income assessed or reassessed immediately before such reassessment; g. the income assessed or reassessed has the effect of reducing the loss or converting such loss into income. 5.1. Referring to the above clauses, he submitted that assessee does not fall under any of the above clauses

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:

section 115JC, as the case may be, is greater than the deemed total income assessed or reassessed immediately before such reassessment; (g) the income assessed or reassessed has the effect of reducing the loss or converting such loss into income. (3) …… (4) …... (5) …… 12 (6