RATHOD JEWELLERS,PUNE vs. ACIT, CENTRAL CIRCLE -2(3), PUNE

In the result, appeal of the assessee is dismissed

Bench: Shri Rama Kanta Panda & Ms. Astha Chandra

u/s 143(3) r.w.s. 147 of the Act, based on the observations and findings recorded by him, the relevant extract of which is reproduced below: “7.2 Rebuttals: As per the information contained in the letter sent by the DCIT Circle-5, Pune, the above said company I.e., M/s. AB Agrotech Pvt. Ltd, had filed its latest retum for A.Y.2011-12

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 u/s 147, the 'reason' has to be specific and the same can't be extended / enhanced /supplemented, etc. This ratio emerges from the celebrated decision in the case of Hindustan Lever v. R B Wadkar- 268 ITR 332 (Bom)... (copy enclosed and marked as Annexure-6.) 14. Conention-3-Erroneous/Improper charge of escapement of income As per facts

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 u/s 147, the 'reason' has to be specific and the same can't be extended / enhanced /supplemented, etc. This ratio emerges from the celebrated decision in the case of Hindustan Lever v. R B Wadkar- 268 ITR 332 (Bom)... (copy enclosed and marked as Annexure-6.) 14. Conention-3-Erroneous/Improper charge of escapement of income As per facts

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 u/s 147, the 'reason' has to be specific and the same can't be extended / enhanced /supplemented, etc. This ratio emerges from the celebrated decision in the case of Hindustan Lever v. R B Wadkar- 268 ITR 332 (Bom)... (copy enclosed and marked as Annexure-6.) 14. Conention-3-Erroneous/Improper charge of escapement of income As per facts

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

nature of withdrawal or\nretraction. His duty ends where the statement is recorded. If the statements are\nretracted, the fate thereof must be decided by law meaning thereby, a superior\nforum and not by the very authority, who is alleged to have exerted force.\"\n8. The appellant has discharged the primary onus as the appellant has filed the\nrequired details

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

nature of withdrawal or\nretraction. His duty ends where the statement is recorded. If the statements are\nretracted, the fate thereof must be decided by law meaning thereby, a superior\nforum and not by the very authority, who is alleged to have exerted force.\"\n8. The appellant has discharged the primary onus as the appellant has filed the\nrequired details

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

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

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 clearly demonstrated that he had evaded tax by\nnot filing the return

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

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

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 clearly demonstrated that he had evaded tax by\nnot filing the return

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

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 that he had evaded tax by not filing the return

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

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 that he had evaded tax by not filing the return

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

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 that he had evaded tax by not filing the return

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

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 that he had evaded tax by not filing the return

DEPUTY COMMISSIONER OF INCOME TAX, JALGAON vs. TARADEVI RATANLAL BAFNA, JALGAON

147 are applicable to\nfacts of this case and the assessment year under consideration is deemed to be case where income chargeable\nto tax has escaped assessment.\n\nPlease acknowledge receipt of this letter\n\nBHARAT DEVRAJ SHEGAONKAR\nACIT CEN CIR 2, NASHIK\n\n5. He, therefore, issued notice u/s 148 of the Act on 19.03.2020. The assessee\nin response

ASSISTANT COMMISSIONER OF INCOME TAX, JALGAON vs. SIDHARTH RATANLAL BAFNA, JALGAON

147 are applicable to\nfacts of this case and the assessment year under consideration is deemed to be case where income chargeable\nto tax has escaped assessment.\n\nPlease acknowledge receipt of this letter\n\nBHARAT DEVRAJ SHEGAONKAR\nACIT CEN CIR 2, NASHIK\n\n5. He, therefore, issued notice u/s 148 of the Act on 19.03.2020. The assessee\nin response

ASSISTANT COMMISSIONER OF INCOME TAX, JALGAON vs. SIDHARTH RATANLAL BAFNA, JALGAON

147 are applicable to\nfacts of this case and the assessment year under consideration is deemed to be case where income chargeable\nto tax has escaped assessment.\nPlease acknowledge receipt of this letter\n\nBHARAT DEVRAJ SHEGAONKAR\nACIT CEN CIR 2, NASHIK\n\n5. He, therefore, issued notice u/s 148 of the Act on 19.03.2020. The assessee\nin response

SANTOSH SHANKAR GUJAR,NEAR VITTHAL RUKMINI MANDIR vs. INCOME TAX OFFICER, WARD 8(3), PUNE, AKURDI, PUNE

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

Bench: Shri Manish Borad & Shri Vinay Bhamoreआयकर अपील सं. / Ita Nos.1654 & 2038/Pun/2024 िनधा"रण वष" / Assessment Years : 2014-15 & 2013-14 Santosh Shankar Gujar, Vs. Ito, Ward-8(3), Pune. H/No.246, Shiv Parvati Bunglow, Laxmi Nagar, Thergaon- 411033. Pan : Alnpg9944K Appellant Respondent Assessee By : Mrs. Vibha D. Gulabani Revenue By : Shri Umesh Phade Date Of Hearing : 02.09.2025 Date Of Pronouncement : 19.11.2025 आदेश / Order Per Vinay Bhamore, Jm: Both The Above Captioned Appeals Filed By The Assessee Are Directed Against The Separate Orders Dated 05.06.2024 & 29.07.2024 Passed By Ld. Cit(A)/Nfac For The Assessment Years 2014-15 & 2013-14 Respectively. 2. Since The Identical Facts & Common Issues Are Involved In Both The Above Captioned Appeals, 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.1654/Pun/2024 For A.Y. 2014-15 For Adjudication.

natural justice. 6) Appellant made complete submissions in the instant case on three occasions i.e. 10/12/2021, 24/03/2022 & 24/03/2022 and SCN u/s 144 was issued on 29/03/2022 proposing to pass order u/s 144 as best judgment order which is invalid & illegal. 7) The impugned order u/s 147 rws 144 passed as best judgment order was required to passes u/s 147

SANTOSH SHANKAR GUJAR,LAXMI NAGAR, THERGAON vs. INCOME TAX OFFICER, WARD 8(3), PUNE, AKURDI, PUNE

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

Bench: Shri Manish Borad & Shri Vinay Bhamoreआयकर अपील सं. / Ita Nos.1654 & 2038/Pun/2024 िनधा"रण वष" / Assessment Years : 2014-15 & 2013-14 Santosh Shankar Gujar, Vs. Ito, Ward-8(3), Pune. H/No.246, Shiv Parvati Bunglow, Laxmi Nagar, Thergaon- 411033. Pan : Alnpg9944K Appellant Respondent Assessee By : Mrs. Vibha D. Gulabani Revenue By : Shri Umesh Phade Date Of Hearing : 02.09.2025 Date Of Pronouncement : 19.11.2025 आदेश / Order Per Vinay Bhamore, Jm: Both The Above Captioned Appeals Filed By The Assessee Are Directed Against The Separate Orders Dated 05.06.2024 & 29.07.2024 Passed By Ld. Cit(A)/Nfac For The Assessment Years 2014-15 & 2013-14 Respectively. 2. Since The Identical Facts & Common Issues Are Involved In Both The Above Captioned Appeals, 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.1654/Pun/2024 For A.Y. 2014-15 For Adjudication.

natural justice. 6) Appellant made complete submissions in the instant case on three occasions i.e. 10/12/2021, 24/03/2022 & 24/03/2022 and SCN u/s 144 was issued on 29/03/2022 proposing to pass order u/s 144 as best judgment order which is invalid & illegal. 7) The impugned order u/s 147 rws 144 passed as best judgment order was required to passes u/s 147

DINDAYAL MAGASVARGIYA SAHAKARI SOOT GIRNI LTD,SANGLI vs. ASSISTANT COMMISSIONER OF INCOME TAX CIRCLE SANGLI, CIRCLE SANGLI

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

Bench: Shri Manish Borad & Shri Vinay Bhamoreआयकर अपील सं. / Ita No.205/Pun/2025 िनधा"रण वष" / Assessment Year : 2014-15 Dindayal Magasvargiya Vs. Acit, Circle Sangli, Sahakari Soot Girni Ltd., Sangli. At Waghwadi, Post Kameri, Tal. Walwa, Sangli- 415403. Pan : Aaaad0254E Appellant Respondent Assessee By : Shri Pramod S. Shingte Revenue By : Shri Ramnath P. Murkunde Date Of Hearing : 22.09.2025 Date Of Pronouncement : 09.12.2025 आदेश / Order Per Vinay Bhamore, Jm: This Appeal Filed By The Assessee Is Directed Against The Order Dated 05.12.2024 Passed By Ld. Cit(A)/Nfac For The Assessment Year 2014-15. 2. The Appellant Has Raised The Following Grounds Of Appeal :- “1. On The Facts & In The Circumstances Of The Case & In Law, Ld. Ao Erred In Initiating Reassessment Proceedings U/S 147 For Ay 2014-15, Being The Year Beyond 4 Years & For Which Assessment Order U/S 143(3) Has Already Been Passed, Thereby

reassessment proceedings u/s 147 for AY 2014-15 by recording the reason to believe which is based on audit objection. We submit that the reason based on such borrowed satisfaction cannot be the basis of reopening the concluded assessment. Therefore, entire proceedings are void ab initio. 4. Without prejudice to the above grounds on the facts and in the circumstances

DINDAYAL MAGASVARGIYA SAHAKARI SOOT GIRNI LTD ,WAGHWADI vs. ASSISTANT COMMISSIONER OF INCOME TAX, CIRCLE, SANGLI., NISHANT COLONY

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

Bench: Shri Manish Borad & Shri Vinay Bhamoreआयकर अपील सं. / Ita No.2325/Pun/2025 िनधा"रण वष" / Assessment Year : 2013-14 Dindayal Magasvargiya Vs. Acit, Circle Sangli, Sahakari Soot Girni Ltd., Sangli. At Waghwadi, Post Kameri, Tal. Walwa, Sangli- 415403. Pan : Aaaad0254E Appellant Respondent Assessee By : Shri Pramod S. Shingte Revenue By : Shri R. Y. Balawade Date Of Hearing : 27.01.2026 Date Of Pronouncement : 29.01.2026 आदेश / Order Per Vinay Bhamore, Jm: This Appeal Filed By The Assessee Is Directed Against The Order Dated 01.08.2025 Passed By Ld. Cit(A)/Nfac 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 & In Law, Ld. Ao Erred In Initiating Reassessment Proceedings U/S 147 For Ay 2013-14, Being The Year Beyond 4 Years & For Which Assessment Order U/S 143(3) Has Already Been Passed, Thereby

reassessment proceedings u/s 147 for AY 2013-14 by recording the reason to believe which is based on audit objection. We submit that the reason based on such borrowed satisfaction cannot be the basis of reopening the concluded assessment. Therefore, entire proceedings are void ab initio. 4. Without prejudice to the above grounds on the facts and in the circumstances