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

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:

96,347/- being the penalty @ 50% of tax payable for under- reporting of income as per provisions of section 270A of the Act. We find the Ld. CIT(A) / NFAC confirmed the penalty levied by the Assessing Officer, the reasons of which have already been reproduced in the preceding paragraphs. It is the submission of the Ld. Counsel

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

section 147, under such circumstances no further addition can be been made in view of Bombay High Court judgment in case of CIT V/s. Jet airways (I) Ltd 331 ITR 236 (BOM), we pray for deletion of ail such additions made. 2) On the facts and in the circumstances of the case and in law the lower authorities have erred

M/S ACCORD MEDIPLUS PVT LTD,PUNE vs. INCOME TAX OFFICER, WARD-1(1), PUNE, PUNE

reassessment order deserves to be quashed and set\naside.\n3. On the facts and in the circumstances of the case, Ld. CIT-\nAppeal has erred in law and on facts, in sustaining the addition of Rs\n8,96,41,183/- as excess \"Share Premium\" under Section

M/S ACCORD MEDIPLUS PVT LTD,PUNE vs. INCOME TAX OFFICER, WARD-1(1), PUNE, PUNE

Bench: Dr.Manish Borad & Shri Vinay Bhamore

reassessment order deserves to be quashed and set aside. 3. On the facts and in the circumstances of the case, Ld. CIT- Appeal has erred in law and on facts, in sustaining the addition of Rs 8,96,41,183/- as excess "Share Premium" under Section

M/S ACCORD MEDIPLUS PVT LTD,PUNE vs. INCOME TAX OFFICER, WARD-1(1), PUNE, PUNE

Bench: Dr.Manish Borad & Shri Vinay Bhamore

reassessment order deserves to be quashed and set aside. 3. On the facts and in the circumstances of the case, Ld. CIT- Appeal has erred in law and on facts, in sustaining the addition of Rs 8,96,41,183/- as excess "Share Premium" under Section

M/S ACCORD MEDIPLUS PVT LTD,PUNE vs. INCOME TAX OFFICER, WARD-1(1), PUNE, PUNE

Bench: Dr.Manish Borad & Shri Vinay Bhamore

reassessment order deserves to be quashed and set aside. 3. On the facts and in the circumstances of the case, Ld. CIT- Appeal has erred in law and on facts, in sustaining the addition of Rs 8,96,41,183/- as excess "Share Premium" under Section

M/S ACCORD MEDIPLUS PVT LTD,PUNE vs. INCOME TAX OFFICER, WARD-1(1), PUNE, PUNE

Bench: Dr.Manish Borad & Shri Vinay Bhamore

reassessment order deserves to be quashed and set aside. 3. On the facts and in the circumstances of the case, Ld. CIT- Appeal has erred in law and on facts, in sustaining the addition of Rs 8,96,41,183/- as excess "Share Premium" under Section

RAJARSHI SHAHU SHIKSHAN SANSTHA INAM DHAMANI,SANGLI vs. ITO EXEMPTION, KOLHAPUR, KOLHAPUR

In the result, all the appeals filed by the assessee are partly allowed as per terms indicated hereinabove

Bench: Dr.Manish Borad & Shri Vinay Bhamoreआयकर अपील सं. / Ita Nos.1121 To 1126/Pun/2024 Assessment Years : 2012-13 To 2017-18

reassessment is bad in law being not validly initiated. 8. Learned CIT [A] has erred in fact and in law in following decision of Pune ITAT in the case of Ninaidevi Shikshan Prasarak Mandal, as well as in the case of Everest Education society because in both these cases trust did not file proper details and filed

RAJARSHI SHAHU SHIKSHAN SANSTHA INAM DHAMANI,SANGLI vs. ITO EXEMPTION, KOLHAPUR, KOLHAPUR

In the result, all the appeals filed by the assessee are partly allowed as per terms indicated hereinabove

Bench: Dr.Manish Borad & Shri Vinay Bhamoreआयकर अपील सं. / Ita Nos.1121 To 1126/Pun/2024 Assessment Years : 2012-13 To 2017-18

reassessment is bad in law being not validly initiated. 8. Learned CIT [A] has erred in fact and in law in following decision of Pune ITAT in the case of Ninaidevi Shikshan Prasarak Mandal, as well as in the case of Everest Education society because in both these cases trust did not file proper details and filed

RAJARSHI SHAHU SHIKSHAN SANSTHA INAM DHAMANI,SANGLI vs. ITO EXEMPTION, KOLHAPUR

In the result, all the appeals filed by the assessee are partly allowed as per terms indicated hereinabove

Bench: Dr.Manish Borad & Shri Vinay Bhamoreआयकर अपील सं. / Ita Nos.1121 To 1126/Pun/2024 Assessment Years : 2012-13 To 2017-18

reassessment is bad in law being not validly initiated. 8. Learned CIT [A] has erred in fact and in law in following decision of Pune ITAT in the case of Ninaidevi Shikshan Prasarak Mandal, as well as in the case of Everest Education society because in both these cases trust did not file proper details and filed

RAJARSHI SHAHU SHIKSHAN SANSTHA INAM DHAMANI,SANGLI vs. ITO EXEMPTION , KOLHAPUR, KOLHAPUR

In the result, all the appeals filed by the assessee are\npartly allowed as per terms indicated hereinabove

reassessment is\nmade merely on the basis of change of opinion having similar set of\nfacts and such an attempt is not sustainable and ergo the\nreassessment is bad in law being not validly initiated.\n8. Learned_CIT [A] has erred in fact and in law in following\ndecision of Pune ITAT in the case of Ninaidevi Shikshan Prasarak\nMandal

RAJARSHI SHAHU SHIKSHAN SANSTHA INAM DHAMANI,SANGLI vs. ITO EXEMPTION, KOLHAPUR, KOLHAPUR

In the result, all the appeals filed by the assessee are\npartly allowed as per terms indicated hereinabove

reassessment is\nmade merely on the basis of change of opinion having similar set of\nfacts and such an attempt is not sustainable and ergo the\nreassessment is bad in law being not validly initiated.\n8. Learned_CIT [A] has erred in fact and in law in following\ndecision of Pune ITAT in the case of Ninaidevi Shikshan Prasarak\nMandal

CLARION TECHNOLOGIES PVT. LTD.,,PUNE vs. DEPUTY COMMISSIONER OF INCOME-TAX,,

In the result, the appeal of assessee is allowed

Bench: Shri R.S. Syal & Shri S.S. Viswanethra Ravi

sections 148 to 153, assess or reassess such income and also any other income chargeable to tax which has escaped assessment and which comes to his notice subsequently. He submits that if an assessment was made u/s. 143(3) of the Act and no action can be taken u/s. 147 of the Act after the expiry of four years from

DEPUTY COMMISSIONER OF INCOME-TAX vs. CLARION TECHNOLOGIES PVT. LTD.,, PUNE

In the result, the appeal of assessee is allowed

Bench: Shri R.S. Syal & Shri S.S. Viswanethra Ravi

sections 148 to 153, assess or reassess such income and also any other income chargeable to tax which has escaped assessment and which comes to his notice subsequently. He submits that if an assessment was made u/s. 143(3) of the Act and no action can be taken u/s. 147 of the Act after the expiry of four years from

RAJARSHI SHAHU SHIKSHAN SANSTHA INAM DHAMANI,SANGLI vs. ITO EXEMPTION, KOLHAPUR

In the result, all the appeals filed by the assessee are\npartly allowed as per terms indicated hereinabove

reassessment is\nmade merely on the basis of change of opinion having similar set of\nfacts and such an attempt is not sustainable and ergo the\nreassessment is bad in law being not validly initiated.\n8. Learned_CIT [A] has erred in fact and in law in following\ndecision of Pune ITAT in the case of Ninaidevi Shikshan Prasarak\nMandal

UDAY UTTAMRAO NEVASE,PUNE vs. THE ASSESSING OFFICER / ASSESSMENT UNIT, PUNE

In the result, appeal of the assessee in ITA No

Bench: Dr.Dipak P. Ripote & Shri Vinay Bhamoreआयकर अपऩल सं. / Ita No.2606/Pun/2025 निर्धारण वषा / Assessment Year: 2022-23 Uday Uttamrao Nevase, V The Assessing Officer / Saugandh Niwas, Hind Colony S Assessment Unit, Pune. Lane No.1 A, Bhekrai Nagar, Phursungi, Pune – 412308. Pan: Akqpn1150Q Appellant/ Assessee Respondent /Revenue Assessee By Ca Rohan Gupta Revenue By Shri Harshit Bari – Addl.Cit(Virtual) Date Of Hearing 16/12/2025 Date Of Pronouncement 10/02/2026 आदेश/ Order Per Dr. Dipak P. Ripote, Am: This Is An Appeal Filed By The Assessee Against The Order Of Ld.Commissioner Of Income Tax(Appeal)[Nfac], Passed Under Section 250 Of The Income Tax Act, 1961 For The A.Y.2022-23 Dated 04.09.2025 Emanating From The Penalty Order Passed Under Section 270A, Dated 17.09.2024. The Assessee Has Raised The Following Grounds Of Appeal : “Ground 1 Section 270Aa Immunity Cit A Erred In Law By Confirming The Penalty Of Rs 629382 Under Section 270A Without Considering And

96,108 for AY 2022-2023 2. During filing of the original return, the tax practitioner of assessee inadvertently claimed certain deductions under sections 80DD, 80CCD(2), 80DDB, 80E, 80EEA, 80EEB, 80GGC and excess HRA claim. ITA No.2606/PUN/2025 [A] 3. These claims arose purely from misunderstanding on the part of tax return practitioner of the eligibility and unintentional clerical errors

SHAMKANT KESHAV KOTKAR (PROP. NANDAN BUILDERS),PUNE vs. PR. COMMISSIONER OF INCOME TAX (CENTRAL), PUNE

In the result, appeal of the assessee is allowed

Bench: SHRI VINAY BHAMORE (Judicial Member)

96 taxmann.com 468 (SC).  High Court of Delhi Bench in PCIT Vs. Meeta [2017] 82 taxmann.com 287 (Delhi)  Hon‟ble Supreme Court in ITO Vs. Saksham Commodities Ltd., [2025] 170 taxmann.com 87 (SC). 6 ITA No.1358/PUN/2025 [A] Submission of ld.DR : 4. Ld.Departmental Representative(ld.DR) for the Revenue Mr.Amit Bobde-IRS, Commissioner of Income Tax(DR) vehemently supported order u/s.263

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

96,142/- wherein he made addition of Rs.2,79,78,912/- by observing as\nunder:\n“07. Therefore, considering the facts and circumstances of the case as discussed\nabove it is held that there was no real transaction in nature of unsecured loan in\nthe case of assessee from above said Kolkata based companies. Therefore, the net\ncredit amounting