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:

65,09,748/-, which is more than 50 lakhs. 148 notice was issued on 25.07.2022, which is beyond the period of three years. So admittedly, the approval has to be obtained from the Principal Chief Commissioner or Principal Director General or Chief Commissioner or Director General as defined under Section 151(ii). But, in the present case, the approval

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

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)

1. Whether on facts and in law, disallowance u/s 14A of the Income Tax Act can be made on expenditure incurred for earning exempt income where the interest free funds were sufficient and available to make investment earning exempt income? 2. Whether on facts and in law, disallowance u/s 14A of the Income Tax Act can be made on expenditure

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)

1. Whether on facts and in law, disallowance u/s 14A of the Income Tax Act can be made on expenditure incurred for earning exempt income where the interest free funds were sufficient and available to make investment earning exempt income? 2. Whether on facts and in law, disallowance u/s 14A of the Income Tax Act can be made on expenditure

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)

1. Whether on facts and in law, disallowance u/s 14A of the Income Tax Act can be made on expenditure incurred for earning exempt income where the interest free funds were sufficient and available to make investment earning exempt income? 2. Whether on facts and in law, disallowance u/s 14A of the Income Tax Act can be made on expenditure

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

1) of the Act read with third proviso to said Section, in case of the search\nexecuted during the financial year commencing on or after 01.04.2019, the period\nof limitation for assessment or reassessment under Section 153C of the Act has\nbeen specified as twelve months from the end of financial year during which the\nlast authorisation to search under

ADISH SHANTILAL SOLANKI,PUNE vs. ASSISTANT COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-2(1), PUNE, PUNE

1) of the Act read with third proviso to said Section, in case of the search\nexecuted during the financial year commencing on or after 01.04.2019, the period\nof limitation for assessment or reassessment under Section 153C of the Act has\nbeen specified as twelve months from the end of financial year during which the\nlast 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

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

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

ASHISH RAMESH OSWAL,PUNE vs. ACIT, CENTRAL CIRCLE 2(1), PUNE , PUNE

In the result, all the appeals filed by the respective assessees are allowed

reassessment order, as the case may be, is required to be\npassed by the Assessing Officer with the prior approval of the [Principal\nCommissioner or Commissioner] under sub-section (12) of Section 144-\nBA.\"\n\n11. A plain reading of the aforesaid provision evinces an uncontrived position of\nlaw that the approval under Section 153D

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

In the result, all the appeals filed by the respective assessees are allowed

reassessment order, as the case may be, is required to be\npassed by the Assessing Officer with the prior approval of the [Principal\nCommissioner or Commissioner] under sub-section (12) of Section 144-\nBA.\"\n11. A plain reading of the aforesaid provision evinces an uncontrived position of\nlaw that the approval under Section 153D

ASHISH RAMESH OSWAL,PUNE vs. ACIT, CENTRAL CIRCLE 2(1), PUNE, PUNE

In the result, all the appeals filed by the respective assessees are allowed

1) of the Act read with third proviso to said Section, in case of the search\nexecuted during the financial year commencing on or after 01.04.2019, the period\nof limitation for assessment or reassessment under Section 153C of the Act has\nbeen specified as twelve months from the end of financial year during which the\nlast authorisation to search under

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

reassessment order, as the case may be, is required to be\npassed by the Assessing Officer with the prior approval of the [Principal\nCommissioner or Commissioner] under sub-section (12) of Section 144-\nBA.\"\n11. A plain reading of the aforesaid provision evinces an uncontrived position of\nlaw that the approval under Section 153D

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

65,822/- and the same has no tax effect as the income of the assessee is fully exempt. The contentions of the assessee were not found to be acceptable by the Ld. AO. However, the Ld.AO vide his order dated 30/12/2019 passed u/s 143(3) of the Act assessed the income of the Assessee at Rs. NIL allowing excess claim

BVG INDIA LIMITED,PUNE vs. DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-1(2), PUNE, PUNE

In the result, the appeal of the assessee is allowed

Bench: Shri S.S. Viswanethra Ravi & Shri G.D. Padmahshali

65,15,083/- and Rs.9,68,69,836/-, respectively. The ld. AR argued that the approving authority Addl. CIT has to verify everything in detail while giving approval u/s. 153D of the Act relating to section 153A of the Act assessments and no such verification has been done as the approval, draft assessment order and final assessment order was passed