SATISH VISHNU THOMBARE, INCOME TAX OFFICER, WARD-1, AHMEDNAGAR, AHMEDNAGAR vs. VARSHA PRAFULLA ZENDE, AHMEDNAGAR

In the result, the appeal of the Revenue is dismissed

Bench: Shri R.K. Panda & Ms. Astha Chandraआयकर अपील सं. / Ita No.1656/Pun/2024 धििाारण वर्ा / Assessment Year : 2010-11 Satish Vishnu Thombare, Varsha Prafulla Zende, Income Tax Officer, Prop Of Bleach Chem Enterprises, Ward-1, Ahmednagar Vs. Industrial Estate, Shrirampur, Maharashtra-413709 Pan : Aabpz2541C अपीलार्थी / Appellant प्रत्यर्थी / Respondent Assessee By : Miss Shivani Shah (Virtual) Department By : Shri Akhilesh Srivastva Date Of Hearing : 06-08-2025 Date Of 29-10-2025 Pronouncement : आदेश / Order

reassessment proceedings u/s 147 of the Income Tax Act, 1961 were initiated in the case of appellant for the A.Y 2010-11. After considering the submissions of the appellant, the AO made addition

TEJAS SHIVAJI ADSUL,KOLHAPUR vs. INCOME TAX OFFICER WARD 1(1), KOLHAPUR, KOLHAPUR

In the result, appeal of the assessee is allowed

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

147 r.w.s 144B of the Act assessing total income at Rs. 24,70,490/- thereby accepting the income returned by the assessee without making any addition thereto. The Ld. AO however initiated penalty proceedings u/s 270A of the Act for under reporting of income in consequence of mis- reporting of income. During the penalty proceedings, the submissions/reply filed by assessee

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

addition was made u/s 115BBC of the Act. It is, therefore, contended that the reassessment is invalid. In this regard, it is submitted that the validity of reassessment proceedings is to be examined with reference to the existence of a reason to believe that income has escaped assessment and not with reference to the ultimate section under which such income

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

addition was made u/s 115BBC of the Act. It is, therefore, contended that the reassessment is invalid. In this regard, it is submitted that the validity of reassessment proceedings is to be examined with reference to the existence of a reason to believe that income has escaped assessment and not with reference to the ultimate section under which such income

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

addition was made u/s 115BBC of the Act. It is, therefore, contended that the reassessment is invalid. In this regard, it is submitted that the validity of reassessment proceedings is to be examined with reference to the existence of a reason to believe that income has escaped assessment and not with reference to the ultimate section under which such income

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

u/s. 147 r.w.s. 143(3) of the Act. 2. In the instant appeal, Revenue has raised following grounds of appeal:- “1. Whether on the facts and circumstances of the case, the Ld. CTT(A) is justified in deleting the addition of Rs.7,93,62,371/- and Rs.86,63,700/- made by the AO on account of on money receipt

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

addition can be made u/s 69A of the Act. Relying on\nvarious other decisions, the details of which are placed in the paper book, he\nsubmitted that the assessment should have been framed u/s 153C and not u/s 147\nof the Act. Therefore, once the proceedings u/s 147 are held to be void-ab-initio,\nthe Ld. PCIT could

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

reassess such income and also any\nother income chargeable to tax which has escaped assessment and which comes to\nhis notice subsequently in the course of the proceedings under section 147 of the\nAct\n28.1 The first proviso to section 147 is important. As per this proviso, where an\nassessment under subsection (3) of section 143 or section 147

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

reassess such income and also any\nother income chargeable to tax which has escaped assessment and which comes to\nhis notice subsequently in the course of the proceedings under section 147 of the\nAct\n28.1 The first proviso to section 147 is important. As per this proviso, where an\nassessment under subsection (3) of section 143 or section 147

ADVIK HI TECH PVT LTD,PUNE vs. DY.COMM..OF INCOMETAX, CIRCLE 8, PUNE

In the result, appeal of the assessee is allowed

Bench: Shri Rama Kanta Panda & Ms. Astha Chandra

income at 2 ITA.No.1344/PUN./2024 Rs.38,31,53,640/- by enhancing it by Rs.1,33,22930/-. The reassessment was completed by the Assessing Officer on 11.02.2023 u/s 147 of the Act and no addition/disallowance was made in the order. However, it was noted by the AO that the assessee has offered an additional

ASHOK VIJAYKUMAR KOTECHA,JALGAON vs. ACIT, CIRCLE 1, JALGAON, JALGAON

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

Bench: Shri R. K. Panda & Shri Vinay Bhamoreassessment Year : 2011-12

147 of the Income Tax Act, 1961. Thus, notice u/s 148 of Income Tax Act, 1961 is issued after taking prior approval of competent authority. Date: 31/03/2018 ACIT, Central Circle-1, Nashik” 3. In response to the same, the assessee filed the return of income on 06.12.2018 declaring total income of Rs.1,79,42,630/-. The objections raised

SUBHASH RUNWAL,BIBWEWADI, PUNE vs. INCOME TAX OFFICER WARD 5(4) PUNE, PUNE

The appeal of the assessee is ALLOWED

Bench: Hon’Ble Shri G. D. Padmahshali & Hon’Ble Shri Vinay Bhamoreassessment Year : 2012-13 Subhash Runwal 204, Solitari-5, Nr. Kalyan Bhel, Bibwewadi Rd., Pune-411037. Pan: Adbpr7670R. . . . . . . . Appellant

addition of income is made on the basis of which reasons for escapement was recorded for issuance of notice u/s 148 of the Act, then Ld. AO ceased to possess any legal jurisdiction u/s 147 of the Act to tax any other income. In the instance case, we observed that, while recording the reasons for invocation of reassessment

MR. CHITTARANJAN TRIMBAK GAIKWAD,PUNE vs. THE ASST. COMMISSIONER OF INCOME TAX, CIRCLE-4, PUNE, PUNE

In the result, the appeal of the assessee is allowed

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

addition of Rs. 8,29,550/- which also in no case could be held as concealment of income for the facts as detailed above, the assessee humbly contends that no penalty u/s. 271(1)(c) of the Act was attracted in the case of the assessee for such income declared in the Revised Return of Income and so also owing

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

income assessed, reassessed or recomputed in a preceding order. (11)No addition or disallowance of an amount shall form the basis for imposition of penalty, if such addition or disallowance has formed the basis of imposition of penalty in the case of the person for the same or any other assessment year. (12)The penalty referred to in sub-section

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)

reassessment proceedings were also initiated and assessment u/s 143(3) r.w.s. 147 of the IT Act was completed on 10.03.2014 accepting the income assessed u/s 143(3) vide order dated 25.03.2013 without making any addition

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)

reassessment proceedings were also initiated and assessment u/s 143(3) r.w.s. 147 of the IT Act was completed on 10.03.2014 accepting the income assessed u/s 143(3) vide order dated 25.03.2013 without making any addition

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)

reassessment proceedings were also initiated and assessment u/s 143(3) r.w.s. 147 of the IT Act was completed on 10.03.2014 accepting the income assessed u/s 143(3) vide order dated 25.03.2013 without making any addition

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

income of the assessee. We find the CIT(A) / NFAC quashed the re-assessment proceedings holding that the proper course of action before the Assessing Officer should have been u/s 153C of the Act. He also deleted the addition on merit by holding that the said addition was made merely on the basis of the statement recorded u/s

AADHUNIK INFRASTRUCTURE DEVELOPMENT PRIVATE LIMITED,JALGAON vs. THE DEPUTY COMMISSIONER OF INCOME TAX, CIRCLE-1, JALGAON

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

Bench: Shri R. K. Panda & Shri Vinay Bhamoreassessment Year : 2012-13

reassessment proceedings. Thus there was no borrowed satisfaction on the part of the AO. There was independent application of mind on the part of the AO. Further reliance is placed upon clause (b) of explanation 2 to provisions of section 147 of the Act as on the basis of the facts of the case the AO had the basis