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

sections": [ "147", "148", "143(1)", "143(2)", "263", "132", "153C", "153A", "69A", "139", "142", "149", "151", "153", "132A", "153B" ], "issues": "Whether the reassessment

PRASAD RAMCHANDRA PATIL,URAN, PANVEL vs. ITO WARD 3, PANVEL, PANVEL

Accordingly, the grounds raised by the assessee are allowed for statistical purposes

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

69A of the Act being unexplained cash found by the police during interception and seized by the Department u/s 132A of the Act. The Ld. CIT(A) has dismissed the legal grounds raised by the assessee challenging the validity of assessment proceedings under section 153A of the Act following his decision for previous AY 2014-15. On merits, he sustained

PRASAD RAMCHANDRA PATIL,URAN, PANVEL vs. ITO WARD 3, PANVEL, PANVEL

Accordingly, the grounds raised by the assessee are allowed for statistical purposes

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

69A of the Act being unexplained cash found by the police during interception and seized by the Department u/s 132A of the Act. The Ld. CIT(A) has dismissed the legal grounds raised by the assessee challenging the validity of assessment proceedings under section 153A of the Act following his decision for previous AY 2014-15. On merits, he sustained

PRASAD RAMCHANDRA PATIL,URAN, PANVEL vs. ITO - WARD 3, PANVEL, PANVEL

Accordingly, the grounds raised by the assessee are allowed for statistical purposes

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

69A of the Act being unexplained cash found by the police during interception and seized by the Department u/s 132A of the Act. The Ld. CIT(A) has dismissed the legal grounds raised by the assessee challenging the validity of assessment proceedings under section 153A of the Act following his decision for previous AY 2014-15. On merits, he sustained

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

section 69A of the Act is attracted. 3.4 In the above facts and circumstances and in law, the addition u/s 69A of the Act is not warranted and deserves to be deleted. 4. LEAVE : 3 Pushpadevi Shivlal Rathi The Appellant craves leave to add, alter, amend or delete any of the above grounds of appeal.” 3. First I espouse

AMBALAL GORAKH CHOUDHARI,PRAKASHA vs. INCOME TAX OFFICER, WARD-1, DHULE, DHULE

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

Bench: Shri Manish Borad & Shri Vinay Bhamoreआयकर अपील सं. / Ita No.1422/Pun/2025 िनधा"रण वष" / Assessment Year : 2013-14 Ambalal Gorakh Choudhari Vs. Ito, Ward-1, Dhule. Legal Heir Anita Ambalal Chaudhari, Mukteshwar Mandir, At Post Prakasha, Taluka Shahada, Dist. Nandurbar- 425409. Pan : Afrpc1304D Appellant Respondent Assessee By : Shri Sandeep Rathi Revenue By : Shri Harshit Bari Date Of Hearing : 19.08.2025 Date Of Pronouncement : 14.10.2025 आदेश / Order Per Vinay Bhamore, Jm: This Appeal Filed By The Assessee Is Directed Against The Order Dated 31.03.2025 Passed By Ld. Addl./Jcit(A)-2, Gurugram [‘Ld. Cit(A)’] For The Assessment Year 2013-14. 2. The Appellant Has Raised The Following Grounds Of Appeal :- “1. On The Facts & In The Circumstances Of The Case, Learned Assessing Officer & The Cit(A) Is Not Justified In Making/Confirming Additions Of Rs. 1020740/- To Returned Income U/S.69A Of The Act, As Said Section Is Applicable Only When In Any Financial Year The Assessee Is Found To Be Owner Of Any Money, Bullion, Jewellery Or Any Other

69A Issue:- Source of money disclosed and additions unjustified Without prejudice to the above 7. The appellant craves leave to add, alter, amend or withdraw any of the ground of appeal. Relevant Section:-246A 4 Issue:- Addition, alteration or deletion of any ground of appeal.” 3. The appellant has also raised following additional ground of appeal :- (BEFORE ITAT

INCOME TAX OFFICER,WARD-1,AHMEDNAGAR, AHMEDNAGAR vs. NARENDRA SAMPATLAL BAFNA, AHMEDNAGAR

In the result, the appeal filed by the Revenue and the CO filed by the assessee are dismissed

Bench: Shri R. K. Panda & Shri Vinay Bhamoreassessment Year : 2017-18

section 147 of the Act." From Para 10, 11 and 12 of the assessment order, it is clear that the reassessment proceedings have been initiated on the basis of the statement of Sh. Sachin M Nahar and based on material in seized documents. There is no Para 13 in the assessment order which has been referred in the Assessment Order

ASHOK HIRACHAND SHAH,PANVEL vs. ASSESSING OFFICER WARD 2, PANVEL

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

Bench: Shri R.K. Panda & Ms. Astha Chandraआयकर अपील सं. / Ita No.812/Pun/2025 धििाारण वर्ा / Assessment Year : 2011-12 Ashok Hirachand Shah, Assessing Officer, Plot No. 4, Mangal Bunglow, Ward – 2, Panvel Road No. 5, Sector No. 19, Vs. New Panvel, Tal.-Panvel-410206 Pan : Acdps4800M अपीलार्थी / Appellant प्रत्यर्थी / Respondent Assessee By : Shri Ajinkya Shah Department By : Shri Rajesh Gawali Date Of Hearing : 09-12-2025 Date Of 17-12-2025 Pronouncement : आदेश / Order Per Astha Chandra, Jm : The Appeal Filed By The Assessee Is Directed Against The Order Dated 20.01.2025 Of The Ld. Commissioner Of Income Tax (Appeals), Nfac, Delhi [“Cit(A)/Nfac”] Pertaining To Assessment Year (“Ay”) 2011-12. 2. The Assessee Has Raised The Following Grounds Of Appeal :- “1. Denial Of Natural Justice & Proper Opportunity The Learned Commissioner Of Income Tax (Appeals) Erred In Dismissing The Appeal Without Considering That The Appellant Was Denied Proper Opportunity & Natural Justice During The Assessment Proceedings. The Assessing Officer Called For Information At The Far End Of The Assessment Proceedings On 19/11/2018 & Despite The Appellant'S Authorized Representative Submitting The Details On 19/12/2018, The Ao Failed To Discuss Or Consider The Same. The Matter Ought To Have Been Remanded Back For Fresh Adjudication To Allow Proper Analysis Of The Transactions. 2. Addition Without Specifying The Section The Cit(A) Erred In Upholding The Addition Of Rs. 1,49,05,289/- Made By The Ao Without Specifying The Section Under Which The Addition Was Made. The Non-Mention Of The Specific Section Renders The Assessment Order Bad In Law, As It Violates The Principles Of Natural Justice & Transparency In Taxation. 3. Failure To Discharge Onus Under Section 69A

Section 69A, especially when the appellant was not given a proper opportunity to present his case. 7. Non-Consideration of Recent Judicial Pronouncements The CIT(A) erred in not considering recent judicial pronouncements, including the decision of the Hon'ble Supreme Court in Mrs. Rupal Jain Vs C/T(2023) 152 taxmann.com 345 (Allahabad), which emphasizes the need for proper examination

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:

69A r.w.s. 115BBE of the Act since these are professional receipts. He, however, initiated penalty proceedings u/s 270A for under-reporting of income in consequence of misreporting as per the provisions of section 270A(9)(e) of the Act. While doing so, he observed that the revised return filed by the assessee on 30.06.2020 is (a) beyond the due date

GANESH SHANKAR PUJARE,SINDHUDURG vs. INCOME TAX OFFICER, WARD, KUDAL, KUDAL

In the result appeal filed by the assessee stands allowed for the statistical purposes

Bench: Shri R. K. Panda & Shri Vinay Bhamoreआयकर अपील सं. / Ita No.40/Pun/2024 िनधा"रण वष" / Assessment Year: 2014-15 Ganesh Shankar Pujare, Vs. Ito, Ward, Kudal. Bidyewadi, At Post Kalmath, Taluka Kankavli, Sindhudurg- 416602. Pan : Anipp5657R Appellant Respondent Assessee By Shri Tanzil R. Padvekar : Revenue By : Shri Ramnath P. Murkunde Date Of Hearing : 17.04.2024 Date Of Pronouncement : 18.04.2024 आदेश / Order Per Vinay Bhamore, Jm: This Appeal Is Filed By The Assessee Assailing The Order Dated 08.11.2023 Passed By Ld Cit(A) [‘Nfac’] For The Assessment Year 2014-15. 2. The Appellant Raised The Following Grounds Of Appeal :- “I. Legality & Validity Of Reassessment Proceeding; 1. On The Facts & In Law, The Re-Assessment Proceeding Initiated By The Ld. Assessing Officer Under Section 147 Of The Act Is Bad In Law As The Same Is Based On Suspicious & Incorrect Information. Hence, As The Formation Of Belief Is Based On Incorrect, Suspicious & Vague Facts Same Is Unsus Tainable In Eye Of Law. 2. On The Facts & In Law, There Is Serious Jurisdictional Requirement In The Reasons Recorded By The Assessing Officer As He

reassessment proceeding under Section 147 of the Act. That as per reasons recorded by Ld. A. O., information only on alleged suspicious transactions in Bank account, without mentioning name of a Bank, is given as justification which cannot be equated with expression “reason to belief’ as contemplated in Section 147 of the Act. 9. On the facts

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

69A of the Act and added to the total income of the assessee to be taxed as per the provisions of section 115BBE of the Act.” 5 ITA No.165/PUN/2025, AY 2015-16 3. There was non-compliance to the notices issued by the Ld. CIT(A)/NFAC. The Ld. CIT(A)/NFAC therefore dismissed the appeal of the assessee

JANAKEE PETROLIUM,SATARA vs. ITO WD-4, SATARA

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

Bench: Dr.Dipak P. Ripote & Shri Vinay Bhamoreआयकर अपऩल सं. / Ita Nos.2322 & 2327/Pun/2025 निर्धारण वषा / Assessment Year: 2015-16 Janakee Petrolium, V Income Tax Officer, Gat No.1041/B, Wai Surru S Ward-4, Satara. Roadk Kavathe Wai, Satara – 415516 Pan: Aajfj9486C Appellant/ Assessee Respondent /Revenue Assessee By Shri Tanzil Padvekar Revenue By Smt Neha Thakur (Virtual) Date Of Hearing 21/01/2026 Date Of Pronouncement 29/01/2026 आदेश/ Order Per Bench : These Two Appeals Filed By The Assessee Against The Separate Orders Of Ld.Commissioner Of Income Tax(Appeal)[Nfac], Passed Under Section 250 Of The Income Tax Act, 1961 For The A.Y.2015-16 Both Dated 20.08.2025 Emanating From The Assessment Order Passed Under Section 147 R.W.S 144 Of The Act, Dated 22.02.2023 & Penalty Order Under Section 271(1)(C) Of The Act, 10.08.2023

69A of the Act of Rs. 1,27,02,253/- is bad in law and is liable to be deleted. ITA Nos.2322 & 2327/PUN/2025 [A] 5. On the facts and in law, the impugned notice issued under Section 148 of the Act is bad in law since, the mandatory condition that income chargeable to tax has escaped assessment

JANAKEE PETROLIUM,SATARA vs. ITO WD-4, SATARA

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

Bench: Dr.Dipak P. Ripote & Shri Vinay Bhamoreआयकर अपऩल सं. / Ita Nos.2322 & 2327/Pun/2025 निर्धारण वषा / Assessment Year: 2015-16 Janakee Petrolium, V Income Tax Officer, Gat No.1041/B, Wai Surru S Ward-4, Satara. Roadk Kavathe Wai, Satara – 415516 Pan: Aajfj9486C Appellant/ Assessee Respondent /Revenue Assessee By Shri Tanzil Padvekar Revenue By Smt Neha Thakur (Virtual) Date Of Hearing 21/01/2026 Date Of Pronouncement 29/01/2026 आदेश/ Order Per Bench : These Two Appeals Filed By The Assessee Against The Separate Orders Of Ld.Commissioner Of Income Tax(Appeal)[Nfac], Passed Under Section 250 Of The Income Tax Act, 1961 For The A.Y.2015-16 Both Dated 20.08.2025 Emanating From The Assessment Order Passed Under Section 147 R.W.S 144 Of The Act, Dated 22.02.2023 & Penalty Order Under Section 271(1)(C) Of The Act, 10.08.2023

69A of the Act of Rs. 1,27,02,253/- is bad in law and is liable to be deleted. ITA Nos.2322 & 2327/PUN/2025 [A] 5. On the facts and in law, the impugned notice issued under Section 148 of the Act is bad in law since, the mandatory condition that income chargeable to tax has escaped assessment

M/S MANILAL P. SAVLA & COMPANY,PUNE vs. ACIT, CIRCLE 5 , PUNE

In the result, the appeal of the assessee is allowed

69A of the Act by\nthe Ld. AO and also raised an additional ground before the Ld. CIT(A)/NFAC\nthat “the reassessment order u/s 147 is without jurisdiction and bad in law\nbecause the assessing officer has wrongly invoked the provisions of section

M/S MANILAL P. SAVLA & COMPANY,PUNE vs. ACIT, CIRCLE 5, PUNE

In the result, the appeal of the assessee is allowed

69A of the Act by\nthe Ld. AO and also raised an additional ground before the Ld. CIT(A)/NFAC\nthat “the reassessment order u/s 147 is without jurisdiction and bad in law\nbecause the assessing officer has wrongly invoked the provisions of section

ITO, NASHIK vs. ANKIT NARESH TULSIAN, NASHIK

In the result, appeal of the Revenue is dismissed

reassessment proceedings were initiated on a \"mere change of opinion\" without any fresh material. The assessee had fulfilled all conditions for exemption under Section 10(38), and the SEBI's final report absolved the scrip (MFTL) from all charges, contradicting the AO's findings based on an interim report.", "result": "Allowed", "sections": [ "10(38)", "147", "148", "143(3)", "69A

VIKAS MARUTI NALAWADE,SANGLI vs. INCOME TAX OFFICER, SANGLI

In the result, appeal of the assessee is partly allowed

Bench: Dr. Manish Borad & Shri Vinay Bhamoreआयकर अपील सं./Ita No. 737/Pun/2025 धििेंारण वर्ा /Assessment Year: 2017-18 Vikas Maruti Nalawade, Ito, Ward-1, Sangli Vikas Hitech Nursary, Sangli Islampur Road, Near Sootgirni Vs. Tung, Sangli-416301 Maharashtra Pan-Alppn6432M अपीलेंर्थी / Appellant प्रत्यर्थी / Respondent Assessee By: Shri Pramod S Shingte Department By: Shri Amit Bobde-Cit Date Of Hearing: 09-12-2025 Date Of Pronouncement: 16-12-2025 आदीश /Order Per Dr. Manish Borad:- This Appeal At The Instance Of Assessee Is Directed Against The Order Of Ld. Cit(A) Nfac, Delhi Passed U/S 250 Of The Income-Tax Act, 1961 Dated 05.03.2025 Which Is Arising Out Of Assessment Order Passed U/S 147 R.W.S. 144B Of The Act Dated 29.03.2022. 2. Assessee Has Raised Following Grounds Of Appeal:- 1. On The Facts & Circumstances Of The Case & In Law, The 2 Assessment Order, Having Being Passed Without Following The Principles Of Natural Justice, As Narrated In The Statement Of Facts, The Same Is Bad In Law & Hence Needs To Be Quashed.

reassessment proceedings various details called for by the Ld. AO were furnished based on which Ld. AO was satisfied with regard to the submissions made except was not convinced that even when the assessee is having the Current Bank Account why the assessee has deposited cash of Rs. 1,55,73,900/- in the saving Bank Account. Ld. AO concluded

SHRIKANT CHANDRAKANT LOKHANDE,LATUR vs. ITO, WARD-1, LATUR, LATUR

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

Bench: Dr.Manish Borad & Shri Vinay Bhamoreआयकर अपील सं. / Ita No.2696/Pun/2024 Assessment Year : 2015-16

69A and taxed with respect to section 115BBE of the Income Tax Act. As the assessee concealed the particulars of income the penalty u/s271(1)(c) has been initiated separately. Penalty proceedings U/s. 271(1)(b) has been initiated separately for non-compliance of notice U/s. 142(1). Penalty proceedings U/s. 271F has been initiated separately for non-filing

BORA AGRO FOODS,PUNE vs. DCIT, CIR-5, PUNE, PUNE

In the result, all the appeals filed by the Assessee are partly\nallowed

reassessment under Section 147 of the Act\nwould become impermissible\nThe assumption that provisions of Section 153C of the Act precludes\nany proceeding under Section 147 of the Act by virtue of the non\nobstante clause. is unpersuasive. The scheme of Sections 153C of the\nAct indicates that the said provision was enacted to simplify the\nprocedure, while maintaining