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

reassessment, referred to in clause (a) of sub-section (1), in a case where an order under sub- section (4) has been made accepting the application." 20. Sub-section (18) of Section 155 of the Income Tax Act is inserted vide Finance Act, 2022 w.e.f. 01.04.2022. The above referred provisions provide that deduction of any surcharge, cess, which

JAYANT KANERIA,,PUNE vs. DEPUTY COMMISSIONER OF INCOME-TAX, CIRCLE - 2,, PUNE

Appeal is allowed in above terms

Bench: Shri S.S.Godara, Jm & Shri Dr. Dipak P. Ripote, Am आयकर अपीऱ सं. / Ita No.1719/Pun/2019 ननधधारण वषा / Assessment Year : 2007-08

reassessed based on the ratio laid down in the above case laws, i.e. deemed dividend, if any, needs to be taxed in the hands of beneficial shareholder and not at the hands of the firm. The ratio laid down in the above judgments can be applied to the case of Shri Jayant Kaneria by observing the following facts: The payment

SHANKAR NAGAPPA JADAGOUDA,KOLHAPUR vs. NFAC, DELHI

Appeal is allowed in above terms

Bench: Shri Satbeer Singh Godara

63 of the paper book record. 3. It is in this factual backdrop that the Revenue could hardly dispute that both the learned lower authorities have assessed the assessee’s cash deposits of Rs.38,27,878/- in his bank account with M/s. Vijay Share Cooperative Bank. Meaning thereby that they have not made any addition qua the foregoing sole reason

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

63,723/- imposed by the Ld.AO u/s 270A of the Act. Before the Ld. CIT(A), the assessee furnished its written submissions which are recorded by the Ld. CIT(A) in para 6.4 of his appellate order. The Ld.CIT(A), after considering the submissions of the assessee, deleted the penalty imposed by the Ld. AO observing that for levy

A.C.I.T ,WARDHA CIRCLE , WARDHA , WARDHA vs. M/S KAPIL SOLVEX PVT .LTD , YAVATMAL

In the result, the appeal filed by the Revenue is dismissed

Bench: Shri R. K. Panda & Ms Astha Chandraassessment Year : 2009-10

section 68 by proving the identity and 5 creditworthiness of the share applicants and the genuineness of the transactions. Relying on various decisions, it was argued that the addition u/s 68 is not in accordance with law. However, the CIT(A) while deleting the addition on merit, dismissed the grounds challenging the validity of re-assessment proceedings by observing

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:

63,15,529/-, the Assessing Officer, after recording reasons, issued notice to reopen the assessment as per provisions of section 147 of the Act and accordingly notice u/s 148 of the Act was issued. The assessee in response to the same filed the return declaring total income at Rs.70,13,970/-. the Assessing Officer issued notices

SHATRUNJAY PARKS AND RESORTS P LTD., ,KOLHAPUR vs. INCOME-TAX OFFICER, CENTRAL, KOLHAPUR

Appeal is allowed

Bench: Shri Satbeer Singh Godara & Dr. Dipak P. Ripote

63 DTR 212 (Del). In that case, the return filed by the assessee for the asst. yr. 1999-2000 declaring income @ Rs. 1,22,460 was processed under s. 143(1) of the IT Act. However, notice was issued under section 148 of the Act subsequently, on the information received from the Director of IT (Inv.), New Delhi

MEENAKSHI DHANAJI PATIL,,KOLHAPUR vs. INCOME-TAX OFFICER, WARD - 2 (2),, KOLHAPUR

Appeal is allowed

Bench: Shri S.S.Godara

63 DTR 212 (Del). In that case, the return filed by the assessee for the asst. yr. 1999-2000 declaring income @ Rs. 1,22,460 was processed under s. 143(1) of the IT Act. However, notice was issued under section 148 of the Act subsequently, on the information received from the Director of IT (Inv.), New Delhi

SMT . SUSHILABAI ISHWARDAS BAMB,,PUNE vs. INCOME-TAX OFFICER, WARD - 5(1),, PUNE

In the result, the appeal is dismissed

Bench: Shri R.S. Syal & Shri Partha Sarathi Chaudhury

reassessment order, because the same was passed without disposal of the objections filed by the appellant against the second notice under section 148 of the Act, dt.28.3.2016, vide her letter, dt.17.12.2016. 9. All the aforesaid Grounds of Appeal are without prejudice to one another. 3 Smt. Sushilabai Ishwardas Bamb 10. The appellant craves-leave to add, alter, amend, modify

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

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

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

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. 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

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

PRITESH RATANSHI VED,PUNE vs. INCOME TAX OFFICER, WARD 1(2), JALGAON

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

Bench: SHRI MANISH BORAD (Accountant Member), SHRI VINAY BHAMORE (Judicial Member)

63,000/- and also purchased immovable property of Rs.90 lakh, and has deposited cash of Rs.42 lakh and has also paid credit card bills of Rs.10,35,665/- and also received rental income of Rs.75,984/-, however the return of income for the period under consideration was not furnished therefore the JAO had reason to believe that the income

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

DEPUTY COMMISSIONER OF INCOME-TAX,, PUNE vs. M/S. SECO TOOLS INDIA PVT. LTD.,, PUNE

In the result, the Cross Objections of assessee are allowed and appeals of Revenue are dismissed

Bench: Ms. Sushma Chowla, Jm & Shri Anil Chaturvedi, Am आयकर अपीऱ सं. / Ita Nos.812 & 813/Pun/2017 यििाारण वषा / Assessment Years : 2002-03 & 2003-04

reassessment proceedings on merits. 5. It is settled position in law that the decision of the Court has to be read in the context of the facts involved therein and not on the basis of what logically flows therefrom as held by the Supreme Court in Ambica Quarry Works Vs. State of Gujarat, 1987(1) SCC 213. The Apex Court

ASSISTANT COMMISSIONER OF INCOME-TAX, CIRCLE-7, PUNE vs. PAN INTERNATIONAL, PUNE

Bench: Hon’Ble Shri S. S. Viswanethra Ravi & Shri G. D. Padmahshaliआयकर अपील सं. / Ita No.175/Pun/2020 & Co No. 23/Pun/2022 धििाारण वर्ा / Assessment Year : 2008-2009 Dy. Commissioner Of Income Tax, Circle-7, Pune . . . . . . . अपीलार्थी / Appellant बिाम / V/S. Pan International, 347, Afl House, Off Dhole Patil Rd, Behind Hotel Meru, Pune – 411 001 . . . . . . . प्रत्यर्थी / Respondent Pan: Aabfp4234F & Cross Objector द्वारा / Appearances Assessee By : Shri Sharad Vaze Revenue By : Shri M. G. Jasnani सुनवाई की तारीख / Date Of Conclusive Hearing : 09/12/2022 घोषणा की तारीख / Date Of Pronouncement : 09/12/2022 आदेश / Order Per G. D. Padmahshali, Am; The Revenue Challenges The Order Of Commissioner Of Income Tax (Appeals)-8, Pune [For Short “Cit(A)”] Dt. 06/11/2019 Passed U/S 250 Of The Income-Tax Act, 1961 [For Short “The Act”] Quashing The Order Of Assessment Dt. 10/03/2014 Passed U/S 143(3) R.W.S. 147 By The Dy. Commissioner Of Income Tax, Circle 1(2), Pune[For Short “Ao”] For The Assessment Year [For Short “Ay”] 2008-09 On Technical-Cum-Legal Ground.

reassessment proceeding is saved by section 292BB of the Act? 3. Before taking up the grounds for adjudication, let us first voice the facts emanating from case records are; 3.1 The assessee is a resident firm engaged in the business of manufacturing of machined components and exports thereof and trading in glass epoxy-sheets and machine tools etc., which filed