ROYAL SWAN CHARITABLE MINORITY TRUST,NANDED vs. ITO (EXEMPTION), NANDED

In the result, appeals of the assessee for all the three AYs 2012-13,

Bench: Ms. Astha Chandra & Shree G.D. Padmahshali

u/s 133A on 06.09.2013 at the premises of the trust, The Ld CIT(A) failed to appreciate the implication of pre and post amended law w.r.t section 133A. 4.2. The Ld. CIT(A) failed to appreciate that the survey in the premises of charitable trust was void ab initio in view of pre amended law. The addition is liable

SMT ANJALI PRAPHULL SHIVALE,PUNE vs. ACIT CIRCLE2(3), PUNE

In the result, all the appeals filed by the assessee are allowed for statistical purposes

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

133A was conducted in the case of the appellant and his wife Smt. Anjali Praphull Shivale who are engaged in the business of land development, plotting and selling on 13/09/2019. There was one more survey conducted in the case of the appellant on 28.09.2017. During the course of survey proceedings, evidences of unaccounted receipts on account of sale of lands

SHRI PRAPHULL KALURAM SHIVALE,PUNE vs. CENTRAL CIRCLE 2(3), PUNE

In the result, all the appeals filed by the assessee are allowed for statistical purposes

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

133A was conducted in the case of the appellant and his wife Smt. Anjali Praphull Shivale who are engaged in the business of land development, plotting and selling on 13/09/2019. There was one more survey conducted in the case of the appellant on 28.09.2017. During the course of survey proceedings, evidences of unaccounted receipts on account of sale of lands

SHRI PRAPHULL KALURAM SHIVALE,PUNE vs. CENTRAL CIRCLE 2(4), PUNE

In the result, all the appeals filed by the assessee are allowed for statistical purposes

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

133A was conducted in the case of the appellant and his wife Smt. Anjali Praphull Shivale who are engaged in the business of land development, plotting and selling on 13/09/2019. There was one more survey conducted in the case of the appellant on 28.09.2017. During the course of survey proceedings, evidences of unaccounted receipts on account of sale of lands

SHRI PRAPHULL KALURAM SHIVALE,PUNE vs. CENTRAL CIRCLE 2(3), PUNE

In the result, all the appeals filed by the assessee are allowed for statistical purposes

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

133A was conducted in the case of the appellant and his wife Smt. Anjali Praphull Shivale who are engaged in the business of land development, plotting and selling on 13/09/2019. There was one more survey conducted in the case of the appellant on 28.09.2017. During the course of survey proceedings, evidences of unaccounted receipts on account of sale of lands

SHRI PRAPHULL KALURAM SHIVALE,PUNE vs. CENTRAL CIRCLE 2(4), PUNE, PUNE

In the result, all the appeals filed by the assessee are allowed for statistical purposes

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

133A was conducted in the case of the appellant and his wife Smt. Anjali Praphull Shivale who are engaged in the business of land development, plotting and selling on 13/09/2019. There was one more survey conducted in the case of the appellant on 28.09.2017. During the course of survey proceedings, evidences of unaccounted receipts on account of sale of lands

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

Survey action under Section 133A was carried out on M/s.P.H. Infrastructure (a group concern of the respondent). 1.3 Originally, assessment u/s 143(3) was completed on 16.12.2016, accepting the returned income. Thereafter, the assessment was reopened by issue of notice u/s 148 and completed by framing order u/s 143(3) r.w.s 147 on 29.12.2017, making addition of Rs.8

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

survey u/s 133A of the Act was conducted on six premises of the assessee on 13/02/2019. Summons was issued to various donors, President and accountant of the assessee. Many statements were recorded. Thereafter, Re-assessment proceedings u/s 147 were initiated against the appellant from AY 2012-13 to AY 2017-18. 4. The learned AO, while concluding the 147 assessments

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

survey u/s 133A of the Act was conducted on six premises of the assessee on 13/02/2019. Summons was issued to various donors, President and accountant of the assessee. Many statements were recorded. Thereafter, Re-assessment proceedings u/s 147 were initiated against the appellant from AY 2012-13 to AY 2017-18. 4. The learned AO, while concluding the 147 assessments

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

survey u/s 133A of the Act was conducted on six premises of the assessee on 13/02/2019. Summons was issued to various donors, President and accountant of the assessee. Many statements were recorded. Thereafter, Re-assessment proceedings u/s 147 were initiated against the appellant from AY 2012-13 to AY 2017-18. 4. The learned AO, while concluding the 147 assessments

ASSISTANT COMMISSIONER OF INCOME TAX CIRCLE 12, PUNE vs. VARUN JAIN, PUNE

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

Bench: Dr.Dipak P. Ripote & Shri Vinay Bhamorecross Objection No.14/Pun/2025 (Arising Out Of Ita No.2720/Pun/2024) िनधा"रण वष" / Assessment Year: 2018-19 Varun Jain, The Acit, P-024, Forest County, Kharadi, V Circle-12, Pune. Pune – 411014. S. Maharashtra. Pan:Aexpj0171J Appellant/ Assessee Respondent / Revenue आयकर अपील सं. / Ita No.2720/Pun/2024 िनधा"रण वष" / Assessment Year: 2018-19 The Acit, Varun Jain, Circle-12, Pune. Vs. P-024, Forest County, Kharadi, Pune – 411014. Maharashtra. Pan:Aexpj0171J Appellant / Revenue Respondent / Assessee Assessee By Shri Fenil Bhatt – Ar(Virtual) Revenue By Shri Abhinay Kumbhar - Dr Date Of Hearing 05/05/2025 Date Of Pronouncement 07/05/2025 आदेश/ Order Per Dr. Dipak P. Ripote, Am: In This Case, Revenue Has Filed An Appeal Against The Order Of Ld.Commissioner Of Income Tax(Appeal)[Nfac] Passed Under C.O.No.14/Pun/2025 [A] & Ita No.2720/Pun/2024 [R]

survey conducted u/s. 133A of the Income tax Act, 1961 ("the Act") on JM Finance Asset Management Ltd by DDIT Unit 3(1), Mumbai. The Appellant humbly prays that reopening u/s. 147 of the Act and the reassessment

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:

133A of the Act was conducted at the business premises of the assessee from 5th to 7th February, 2020 during which certain registers were impounded containing the undisclosed professional receipts according to which such undisclosed receipts for the year under consideration were Rs.49,64,120/-. When confronted the assessee admitted that the receipts contained in the said registers

NARENDRA KACHRULAL ABAD,JALNA vs. INCOME-TAX OFFICER, WARD - 1,, JALNA

In the result, appeal of the assessee partly allowed

Bench: Dr.Dipak P. Ripote & Shri Vinay Bhamoreआयकर अपऩल सं. / Ita No.866/Pun/2019 निर्धारण वषा / Assessment Year: 2009-10 Shri Narendra Kachrulal Abad, V The Income Tax Officer, Abad House, Nal Galli, S Ward-1, Jalna. Kadrabad, Jalna – 431203. Maharashtra. Pan: Acspa9531C Appellant/ Assessee Respondent / Revenue Assessee By Shri Hari Krishan – Ar Revenue By Shri Arvind Renge –Addl.Cit(Dr) Date Of Hearing 28/07/2025 Date Of Pronouncement 06/10/2025 आदेश/ Order Per Dr. Dipak P. Ripote, Am: This Is An Appeal Filed By Assessee Against The Order Of Ld.Commissioner Of Income Tax(Appeal)-1, Aurangabadpassed Under Section 250 Of The Income Tax Act, 1961 For The A.Y.2009-10 Dated 30.03.2019, Emanating From Order U/S.143(3) R.W.S 147Of The Income Tax Act, 1961, Dated 03.11.2017. The Assessee Has Raised The Following Concise Grounds Of Appeal :

u/s 133A of the Income Tax Act, 1961 at the premises of 12 brokers and few of their clients across India on 23.03.2015. 4. The survey report has been prepared by the ADIT(Inv) Unit-1(3), Ahmedabad on the basis of data received from National stock exchange(NSE). After analysis of date received from NSE and after considering

GOURISHANKAR EDUCATION SOCIETY,SATARA vs. CIT EXEMPTION, PUNE

In the result, the appeal filed by the assessee in ITA

Bench: Shri R. K. Panda & Shri Vinay Bhamoreआयकर अपील सं. / Ita Nos.1234 & 1235/Pun/2024 िनधा"रण वष" / Assessment Years : 2013-14 & 2014-15 Gourishankar Education Vs. Cit, Exemption, Pune. Society, Panchganga Apartment, Opp. Axis Bank, Radhika Road, Satara- 415001. Pan : Aaatg6668A Appellant Respondent Assessee By : Shri Kishor B. Phadke Revenue By : Shri Amol Khairnar Date Of Hearing : 21.11.2024 Date Of Pronouncement 10.01.2025 : आदेश / Order Per Vinay Bhamore, Jm: These Appeals Filed By The Assessee Are Directed Against The Separate Orders Dated 30.03.2024 Passed By Ld. Cit, Exemption, Pune U/S 263 Of The It Act For The Assessment Years 2013-14 & 2014-15 Respectively. 2. Since Identical Facts & Common Issues Are Involved In Both The Above Captioned Appeals Of The Assessee, Therefore, We Proceed To Dispose Of The Same By This Common Order. 3. First, We Shall Take Up The Appeal Of The Assessee In Ita No.1234/Pun/2024 For A.Y. 2013-14 For Adjudication.

133A of the IT Act was conducted on 02.05.2019 in the case of Gourishanker Educational & Charitable Trust. During the course of survey proceedings, it was found that the assessee trust has advanced interest-free loan to Gourishanker Educational & Charitable Trust, although, the assessee himself has raised interest bearing loans from various banks/cooperative credit societies etc. Accordingly, the assessee’s case

GOURISHANKAR EDUCATION SOCIETY,SATARA vs. CIT EXEMPTION, PUNE

In the result, the appeal filed by the assessee in ITA

Bench: Shri R. K. Panda & Shri Vinay Bhamoreआयकर अपील सं. / Ita Nos.1234 & 1235/Pun/2024 िनधा"रण वष" / Assessment Years : 2013-14 & 2014-15 Gourishankar Education Vs. Cit, Exemption, Pune. Society, Panchganga Apartment, Opp. Axis Bank, Radhika Road, Satara- 415001. Pan : Aaatg6668A Appellant Respondent Assessee By : Shri Kishor B. Phadke Revenue By : Shri Amol Khairnar Date Of Hearing : 21.11.2024 Date Of Pronouncement 10.01.2025 : आदेश / Order Per Vinay Bhamore, Jm: These Appeals Filed By The Assessee Are Directed Against The Separate Orders Dated 30.03.2024 Passed By Ld. Cit, Exemption, Pune U/S 263 Of The It Act For The Assessment Years 2013-14 & 2014-15 Respectively. 2. Since Identical Facts & Common Issues Are Involved In Both The Above Captioned Appeals Of The Assessee, Therefore, We Proceed To Dispose Of The Same By This Common Order. 3. First, We Shall Take Up The Appeal Of The Assessee In Ita No.1234/Pun/2024 For A.Y. 2013-14 For Adjudication.

133A of the IT Act was conducted on 02.05.2019 in the case of Gourishanker Educational & Charitable Trust. During the course of survey proceedings, it was found that the assessee trust has advanced interest-free loan to Gourishanker Educational & Charitable Trust, although, the assessee himself has raised interest bearing loans from various banks/cooperative credit societies etc. Accordingly, the assessee’s case

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

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

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