AUTOCOMP CORPORATION PANSE PRIVATE LIMITED ,PUNE vs. ASST. COMMISSIONER OF INCOME TAX, PUNE

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

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

condone the delay in filing the appeal, an empathetic humane view of the matter ought to have been adopted. 2. The learned CIT(A) erred in not deciding the appeal on merits further erred in not appreciating and considering all the issues emanating from the order of the AO passed under section 147 read with section 144B. It is prayed

AUTOCOMP CORPORATION PANSE PRIVATE LIMITED ,PUNE vs. ASST. COMMISSIONER OF INCOME TAX, CIRCLE 1(1), PUNE

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

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

condone the delay in filing the appeal, an empathetic humane view of the matter ought to have been adopted. 2. The learned CIT(A) erred in not deciding the appeal on merits further erred in not appreciating and considering all the issues emanating from the order of the AO passed under section 147 read with section 144B. It is prayed

SOMNATH RAMDAS JADHAV,AHMEDNAGAR vs. ITO WARD 2, AHMEDNAGAR

Accordingly, the appeal in ITA No.1092/PUN/2025 for A.Y. 2013-14 involving the issue of penalty u/s 271(1)(c) of the Act is allowed

Bench: Shri Manish Borad & Shri Vinay Bhamore

delay in filing is condoned as per the principles of natural justice. 7.2 The appellant, instead of availing the opportunity to explain the sources for cash deposits, wanted to thrash the entire reassessment proceedings by challenging the assumption of jurisdiction in spite of knowing that it is not maintainable in accordance with law. This attitude of the appellant clearly demonstrated

SOMNATH RAMDAS JADHAV,AHMEDNAGAR vs. ITO, WARD 2, AHMEDNAGAR, AHMEDNAGAR

Accordingly, the appeal in ITA No.1092/PUN/2025 for A.Y. 2013-14 involving the issue of penalty u/s 271(1)(c) of the Act is allowed

Bench: Shri Manish Borad & Shri Vinay Bhamore

delay in filing is condoned as per the principles of natural justice. 7.2 The appellant, instead of availing the opportunity to explain the sources for cash deposits, wanted to thrash the entire reassessment proceedings by challenging the assumption of jurisdiction in spite of knowing that it is not maintainable in accordance with law. This attitude of the appellant clearly demonstrated

SOMNATH RAMDAS JADHAV,AHMEDNAGAR vs. ITO WARD2, AHMEDNAGAR

Accordingly, the appeal in ITA No.1092/PUN/2025 for A.Y. 2013-14 involving the issue of penalty u/s 271(1)(c) of the Act is allowed

Bench: Shri Manish Borad & Shri Vinay Bhamore

delay in filing is condoned as per the principles of natural justice. 7.2 The appellant, instead of availing the opportunity to explain the sources for cash deposits, wanted to thrash the entire reassessment proceedings by challenging the assumption of jurisdiction in spite of knowing that it is not maintainable in accordance with law. This attitude of the appellant clearly demonstrated

SOMNATH RAMDAS JADHAV,AHMEDNAGAR vs. ITO, WARD 2, AHMEDNAGAR, AHMEDNAGAR

Accordingly, the appeal in ITA No.1092/PUN/2025 for A.Y. 2013-14 involving the issue of penalty u/s 271(1)(c) of the Act is allowed

Bench: Shri Manish Borad & Shri Vinay Bhamore

delay in filing is condoned as per the principles of natural justice. 7.2 The appellant, instead of availing the opportunity to explain the sources for cash deposits, wanted to thrash the entire reassessment proceedings by challenging the assumption of jurisdiction in spite of knowing that it is not maintainable in accordance with law. This attitude of the appellant clearly demonstrated

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

delaying the process of claiming deduction under\nSection 80IA/IB of the Act. All this would indicate that Assessing\nOfficer had formed an opinion while passing the order dated 9 th\nMarch, 2005. This Court in Aroni Commercials Ltd. v/s. Assistant\nCommissioner of Income Tax 367 ITR 405 had occasion to consider\nsomewhat similar submission made by the Revenue and negatived

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

delaying the process of claiming deduction under\nSection 80IA/IB of the Act. All this would indicate that Assessing\nOfficer had formed an opinion while passing the order dated 9 th\nMarch, 2005. This Court in Aroni Commercials Ltd. v/s. Assistant\nCommissioner of Income Tax 367 ITR 405 had occasion to consider\nsomewhat similar submission made by the Revenue and negatived

UNUS ABDULGAFAR SHAIKH,PUNE vs. ITO WARD 14(3), PUNE, PUNE

In the result, appeal of the assessee in ITA No

Bench: Dr.Dipak P. Ripote & Shri Vinay Bhamoreआयकर अपील सं. / Ita Nos.652 To 655/Pun/2025 िनधा"रण वष" / Assessment Years: 2014-15 To 2017-18 Unusabdulgafar Shaikh, V The Income Tax Officer, Talwadiuruli Kanchan, Pune- S. Ward-14(3), Pune. Solapur Road, Haveli, Pune – 412202. Maharashtra. Pan: Aceps8721Q Appellant/ Assessee Respondent / Revenue Assessee By Shri Suhas Bora – Ar Revenue By Shri Vinod Pawar – Addl.Cit(Dr) Date Of Hearing 08/05/2025 Date Of Pronouncement 14/05/2025 आदेश/ Order Per Dr. Dipak P. Ripote, Am: These Four Appeals Filed By The Assessee Are Against The Separate Orders Of Ld.Commssioner Of Income Tax(Appeal)[Nfac] Passed Under Section 250 Of The Act, 1961, Respectively. For The Sake Of Convenience, These Four Appeals Were Heard Together & Are Being Disposed Of By This Common Order.We Treat Appeal In Ita No.652/Pun/2025 As “Lead Case”. The Assessee Has Raised The Following Grounds Of Appeal :

u/s 147 r.w.s 144 r.w.s 144B is invalid. as reassessment based on a search action in a third-party case falls under Sec. 153C, not Sec. 147. Grounds on merits 6. The AO made the addition solely based on information from the insight portal and bank statements, without corroborative evidence. 7. Without prejudice if at all addition is warranted

UNUS ABDULGAFAR SHAIKH,PUNE vs. ITO WARD 14(3), PUNE, PUNE

In the result, appeal of the assessee in ITA No

Bench: Dr.Dipak P. Ripote & Shri Vinay Bhamoreआयकर अपील सं. / Ita Nos.652 To 655/Pun/2025 िनधा"रण वष" / Assessment Years: 2014-15 To 2017-18 Unusabdulgafar Shaikh, V The Income Tax Officer, Talwadiuruli Kanchan, Pune- S. Ward-14(3), Pune. Solapur Road, Haveli, Pune – 412202. Maharashtra. Pan: Aceps8721Q Appellant/ Assessee Respondent / Revenue Assessee By Shri Suhas Bora – Ar Revenue By Shri Vinod Pawar – Addl.Cit(Dr) Date Of Hearing 08/05/2025 Date Of Pronouncement 14/05/2025 आदेश/ Order Per Dr. Dipak P. Ripote, Am: These Four Appeals Filed By The Assessee Are Against The Separate Orders Of Ld.Commssioner Of Income Tax(Appeal)[Nfac] Passed Under Section 250 Of The Act, 1961, Respectively. For The Sake Of Convenience, These Four Appeals Were Heard Together & Are Being Disposed Of By This Common Order.We Treat Appeal In Ita No.652/Pun/2025 As “Lead Case”. The Assessee Has Raised The Following Grounds Of Appeal :

u/s 147 r.w.s 144 r.w.s 144B is invalid. as reassessment based on a search action in a third-party case falls under Sec. 153C, not Sec. 147. Grounds on merits 6. The AO made the addition solely based on information from the insight portal and bank statements, without corroborative evidence. 7. Without prejudice if at all addition is warranted

UNUS ABDULGAFAR SHAIKH,PUNE vs. ITO WARD 14(3), PUNE, PUNE

In the result, appeal of the assessee in ITA No

Bench: Dr.Dipak P. Ripote & Shri Vinay Bhamoreआयकर अपील सं. / Ita Nos.652 To 655/Pun/2025 िनधा"रण वष" / Assessment Years: 2014-15 To 2017-18 Unusabdulgafar Shaikh, V The Income Tax Officer, Talwadiuruli Kanchan, Pune- S. Ward-14(3), Pune. Solapur Road, Haveli, Pune – 412202. Maharashtra. Pan: Aceps8721Q Appellant/ Assessee Respondent / Revenue Assessee By Shri Suhas Bora – Ar Revenue By Shri Vinod Pawar – Addl.Cit(Dr) Date Of Hearing 08/05/2025 Date Of Pronouncement 14/05/2025 आदेश/ Order Per Dr. Dipak P. Ripote, Am: These Four Appeals Filed By The Assessee Are Against The Separate Orders Of Ld.Commssioner Of Income Tax(Appeal)[Nfac] Passed Under Section 250 Of The Act, 1961, Respectively. For The Sake Of Convenience, These Four Appeals Were Heard Together & Are Being Disposed Of By This Common Order.We Treat Appeal In Ita No.652/Pun/2025 As “Lead Case”. The Assessee Has Raised The Following Grounds Of Appeal :

u/s 147 r.w.s 144 r.w.s 144B is invalid. as reassessment based on a search action in a third-party case falls under Sec. 153C, not Sec. 147. Grounds on merits 6. The AO made the addition solely based on information from the insight portal and bank statements, without corroborative evidence. 7. Without prejudice if at all addition is warranted

UNUS ABDULGAFAR SHAIKH,PUNE vs. ITO WARD 14(3), PUNE, PUNE

In the result, appeal of the assessee in ITA No

Bench: Dr.Dipak P. Ripote & Shri Vinay Bhamoreआयकर अपील सं. / Ita Nos.652 To 655/Pun/2025 िनधा"रण वष" / Assessment Years: 2014-15 To 2017-18 Unusabdulgafar Shaikh, V The Income Tax Officer, Talwadiuruli Kanchan, Pune- S. Ward-14(3), Pune. Solapur Road, Haveli, Pune – 412202. Maharashtra. Pan: Aceps8721Q Appellant/ Assessee Respondent / Revenue Assessee By Shri Suhas Bora – Ar Revenue By Shri Vinod Pawar – Addl.Cit(Dr) Date Of Hearing 08/05/2025 Date Of Pronouncement 14/05/2025 आदेश/ Order Per Dr. Dipak P. Ripote, Am: These Four Appeals Filed By The Assessee Are Against The Separate Orders Of Ld.Commssioner Of Income Tax(Appeal)[Nfac] Passed Under Section 250 Of The Act, 1961, Respectively. For The Sake Of Convenience, These Four Appeals Were Heard Together & Are Being Disposed Of By This Common Order.We Treat Appeal In Ita No.652/Pun/2025 As “Lead Case”. The Assessee Has Raised The Following Grounds Of Appeal :

u/s 147 r.w.s 144 r.w.s 144B is invalid. as reassessment based on a search action in a third-party case falls under Sec. 153C, not Sec. 147. Grounds on merits 6. The AO made the addition solely based on information from the insight portal and bank statements, without corroborative evidence. 7. Without prejudice if at all addition is warranted

SOMNATH RAMDAS JADHAV,AHMEDNAGAR vs. ITO WARD 2, AHMEDNAGAR, AHMEDNAGAR

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

delay, the\ndelay in filing is condoned as per the principles of natural justice.\n7.2 The appellant, instead of availing the opportunity to explain the\nsources for cash deposits, wanted to thrash the entire reassessment\nproceedings by challenging the assumption of jurisdiction in spite of\nknowing that it is not maintainable in accordance with law. This\nattitude of the appellant

SOMNATH RAMDAS JADHAV,AHMEDNAGAR vs. ITO WARD 2, AHMEDNAGAR

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

delay, the\ndelay in filing is condoned as per the principles of natural justice.\n7.2 The appellant, instead of availing the opportunity to explain the\nsources for cash deposits, wanted to thrash the entire reassessment\nproceedings by challenging the assumption of jurisdiction in spite of\nknowing that it is not maintainable in accordance with law. This\nattitude of the appellant

DEPUTY COMMISSIONER OF INCOME-TAX vs. THE JAWAHARLAL NEHRU PORT TRUST,, RAIGAD

In the result, all the three appeals filed by the Revenue are dismissed and all the three appeals filed by the assessee are partly allowed

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

condone the delay for 'accepting the auditor's report at a later date has only been given to the Income-tax Officer and not thereafter, i.e., at the appellate stage. We find no merit in this submission. The Central Board of Direct Taxes by issuing the circular dated February 9, 1978, has treated the provisions regarding furnishing of the auditor

DEPUTY COMMISSIONER OF INCOME-TAX vs. THE JAWAHARLAL NEHRU PORT TRUST,, RAIGAD

In the result, all the three appeals filed by the Revenue are dismissed and all the three appeals filed by the assessee are partly allowed

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

condone the delay for 'accepting the auditor's report at a later date has only been given to the Income-tax Officer and not thereafter, i.e., at the appellate stage. We find no merit in this submission. The Central Board of Direct Taxes by issuing the circular dated February 9, 1978, has treated the provisions regarding furnishing of the auditor

JAWAHAR LAL NEHRU PORT TRUST,NAVI MUMBAI vs. ACIT PANVEL, PANVEL

In the result, all the three appeals filed by the Revenue are dismissed and all the three appeals filed by the assessee are partly allowed

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

condone the delay for 'accepting the auditor's report at a later date has only been given to the Income-tax Officer and not thereafter, i.e., at the appellate stage. We find no merit in this submission. The Central Board of Direct Taxes by issuing the circular dated February 9, 1978, has treated the provisions regarding furnishing of the auditor

JAWAHAR LAL NEHRU PORT TRUST,NAVI MUMBAI vs. ACIT PANVEL, PANVEL

In the result, all the three appeals filed by the Revenue are dismissed and all the three appeals filed by the assessee are partly allowed

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

condone the delay for 'accepting the auditor's report at a later date has only been given to the Income-tax Officer and not thereafter, i.e., at the appellate stage. We find no merit in this submission. The Central Board of Direct Taxes by issuing the circular dated February 9, 1978, has treated the provisions regarding furnishing of the auditor

JAWAHAR LAL NEHRU PORT TRUST,NAVI MUMBAI vs. ACIT PANVEL, PANVEL

In the result, all the three appeals filed by the Revenue are dismissed and all the three appeals filed by the assessee are partly allowed

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

condone the delay for 'accepting the auditor's report at a later date has only been given to the Income-tax Officer and not thereafter, i.e., at the appellate stage. We find no merit in this submission. The Central Board of Direct Taxes by issuing the circular dated February 9, 1978, has treated the provisions regarding furnishing of the auditor