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133 results for “reassessment u/s 147”+ Section 10(38)clear

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Key Topics

Section 148133Section 143(3)83Section 14783Addition to Income59Section 13241Reassessment37Section 143(1)35Section 153A35Section 263

DCIT CIRCLE 1 NASHIK, NASHIK vs. SHREE SAI PROPERTIES, NASHIK

In the result, appeal of the Revenue is dismissed

ITA 987/PUN/2025[2014-15]Status: DisposedITAT Pune27 Jan 2026AY 2014-15

Bench: Dr. Manish Borad & Shri Vinay Bhamore

For Appellant: Shri Subodh Ratnaparkhi, CAFor Respondent: Shri Amit Bobde, CIT
Section 132Section 143(2)Section 143(3)Section 147Section 148Section 250

10. Ld. Counsel for the assessee referred to the documents placed in the paper book and the case various case laws. Index of the documents as well as the case laws relied on by the ld. Counsel for the assessee are scanned below : 23 ITA.No.987/PUN./2025 (M/s. Shree Sai Properties) 24 ITA.No.987/PUN./2025 (M/s. Shree Sai Properties

Showing 1–20 of 133 · Page 1 of 7

34
Reopening of Assessment33
Section 14A31
Disallowance21

INCOME TAX OFFICER, PUNE vs. SAGAR CONSTRUCTION COMPANY, PUNE

In the result, the appeal filed by the Revenue is dismissed and the CO filed by the assessee is allowed

ITA 1812/PUN/2025[2017-18]Status: DisposedITAT Pune08 Jan 2026AY 2017-18

Bench: Shri R. K. Panda & Ms. Astha Chandraassessment Year : 2017-18

For Appellant: Shri Suhas Bora and Riya OswalFor Respondent: Shri S. Sadananda Singh, JCIT
Section 142(1)Section 143(1)Section 147Section 148Section 269SSection 37Section 68

10. Aggrieved with such order of the Ld. CIT(A) / NFAC the Revenue is in appeal before the Tribunal by raising the following grounds: 1. Whether on the facts and circumstances of the case and in law, the Hon'ble CIT(A) was justified in deleting the addition of Rs.1,61,00,000/- made on account of unsecured loan u/s

INCOME TAX OFFICER, WARD-1, JALNA, JALNA vs. OMPRAKASH ASARAM MANTRI, JALNA

In the result, all the appeals filed by the Revenue are dismissed

ITA 141/PUN/2024[2012]Status: DisposedITAT Pune17 Jul 2025

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

For Appellant: Shri Kishor B PhadkeFor Respondent: Shri Amol Khairnar, CIT-DR
Section 10(38)Section 132Section 143(2)Section 143(3)Section 147Section 148Section 151

section 10(38) and made additions, alleging involvement in penny stock which were being misused for providing bogus accommodation of LTCG, however, there was lack of adverse comments from stock exchange and officials of company involved in these transactions and no material relating to assessee was found in investigation wing report, additions made by AO had rightly been deleted

INCOME TAX OFFICER, WARD-1, JALNA, JALNA vs. ATUL OMPRAKASH MANTRI, JALNA

In the result, all the appeals filed by the Revenue are dismissed

ITA 142/PUN/2024[2011]Status: DisposedITAT Pune17 Jul 2025

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

For Appellant: Shri Kishor B PhadkeFor Respondent: Shri Amol Khairnar, CIT-DR
Section 10(38)Section 132Section 143(2)Section 143(3)Section 147Section 148Section 151

section 10(38) and made additions, alleging involvement in penny stock which were being misused for providing bogus accommodation of LTCG, however, there was lack of adverse comments from stock exchange and officials of company involved in these transactions and no material relating to assessee was found in investigation wing report, additions made by AO had rightly been deleted

INCOME TAX OFFICER, WARD-1, JALNA, JALNA vs. ASHISH OMPRAKASH MANTRI, JALNA

In the result, all the appeals filed by the Revenue are dismissed

ITA 148/PUN/2024[2012]Status: DisposedITAT Pune17 Jul 2025

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

For Appellant: Shri Kishor B PhadkeFor Respondent: Shri Amol Khairnar, CIT-DR
Section 10(38)Section 132Section 143(2)Section 143(3)Section 147Section 148Section 151

section 10(38) and made additions, alleging involvement in penny stock which were being misused for providing bogus accommodation of LTCG, however, there was lack of adverse comments from stock exchange and officials of company involved in these transactions and no material relating to assessee was found in investigation wing report, additions made by AO had rightly been deleted

INCOME TAX OFFICER, WARD-1, JALNA, JALNA vs. ATUL OMPRAKASH MANTRI, JALNA

In the result, all the appeals filed by the Revenue are dismissed

ITA 143/PUN/2024[2012]Status: DisposedITAT Pune17 Jul 2025

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

For Appellant: Shri Kishor B PhadkeFor Respondent: Shri Amol Khairnar, CIT-DR
Section 10(38)Section 132Section 143(2)Section 143(3)Section 147Section 148Section 151

section 10(38) and made additions, alleging involvement in penny stock which were being misused for providing bogus accommodation of LTCG, however, there was lack of adverse comments from stock exchange and officials of company involved in these transactions and no material relating to assessee was found in investigation wing report, additions made by AO had rightly been deleted

INCOME TAX OFFICER, WARD-1, JALNA, JALNA vs. OMPRAKASH ASARAM MANTRI, JALNA

In the result, all the appeals filed by the Revenue are dismissed

ITA 140/PUN/2024[2011]Status: DisposedITAT Pune17 Jul 2025

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

For Appellant: Shri Kishor B PhadkeFor Respondent: Shri Amol Khairnar, CIT-DR
Section 10(38)Section 132Section 143(2)Section 143(3)Section 147Section 148Section 151

section 10(38) and made additions, alleging involvement in penny stock which were being misused for providing bogus accommodation of LTCG, however, there was lack of adverse comments from stock exchange and officials of company involved in these transactions and no material relating to assessee was found in investigation wing report, additions made by AO had rightly been deleted

INCOME TAX OFFICER, WARD -1, JALNA, JALNA vs. PRAMILA OMPRAKASH MANTRI, JALNA

In the result, all the appeals filed by the Revenue are dismissed

ITA 146/PUN/2024[2012]Status: DisposedITAT Pune17 Jul 2025

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

For Appellant: Shri Kishor B PhadkeFor Respondent: Shri Amol Khairnar, CIT-DR
Section 10(38)Section 132Section 143(2)Section 143(3)Section 147Section 148Section 151

section 10(38) and made additions, alleging involvement in penny stock which were being misused for providing bogus accommodation of LTCG, however, there was lack of adverse comments from stock exchange and officials of company involved in these transactions and no material relating to assessee was found in investigation wing report, additions made by AO had rightly been deleted

INCOME TAX OFFICER, WARD-1, JALNA, JALNA vs. PRAMILA OMPRAKASH MANTRI, JALNA

In the result, all the appeals filed by the Revenue are dismissed

ITA 145/PUN/2024[2011]Status: DisposedITAT Pune17 Jul 2025

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

For Appellant: Shri Kishor B PhadkeFor Respondent: Shri Amol Khairnar, CIT-DR
Section 10(38)Section 132Section 143(2)Section 143(3)Section 147Section 148Section 151

section 10(38) and made additions, alleging involvement in penny stock which were being misused for providing bogus accommodation of LTCG, however, there was lack of adverse comments from stock exchange and officials of company involved in these transactions and no material relating to assessee was found in investigation wing report, additions made by AO had rightly been deleted

JAIBHAGWAN BANARASIDAS JINDAL,JALNA vs. THE INCOME TAX OFFICER, WARD-1, JALNA

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

ITA 2016/PUN/2024[2016-17]Status: DisposedITAT Pune27 Feb 2025AY 2016-17

Bench: Shri R. K. Panda & Ms. Astha Chandraassessment Year : 2016-17

For Appellant: Shri Jaiprakash BairagraFor Respondent: Shri Ramnath P Murkunde
Section 10(38)Section 142(1)Section 143(1)Section 143(2)Section 143(3)Section 147Section 148Section 151

38,145/- during the A.Y. 2016-17. Section 147 of the Act lays down that the reopening the assessment can be done by the Assessing Officer (AO) if he has 'reason to believe' that the income has escaped assessment. Escapement of income chargeable to tax can be due to not filing of return of income by the appellant despite having

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

In the result, all the above 6 appeals filed by the Revenue are dismissed and

ITA 1565/PUN/2024[2018-19]Status: DisposedITAT Pune27 Oct 2025AY 2018-19

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

For Appellant: S/Shri Suchek Anchaliya andFor Respondent: Shri Amit Bobde, CIT
Section 10(38)Section 132Section 143(3)Section 147Section 148Section 153A

10(38) of the Act, he also deleted the addition made by the Assessing Officer u/s 69C of the Act being the commission @ 3% paid for accommodation entries taken. 11. Aggrieved with such order of the Ld. CIT(A) / NFAC the Revenue is in appeal before the Tribunal by raising the following grounds: 1. On the facts

POONAWALLA SHARES & SECURITIES PVT.LTD,PUNE vs. ASSISTANT COMMISSIONER OF WEALTH-TAX, CIRCLE-4, PUNE

Appeal is partly allowed in above terms

ITA 380/PUN/2020[2016/17]Status: DisposedITAT Pune29 Jul 2022

Bench: Shri S.S.Godara & Dr. Dipak P. Ripoteआयकर अपीलसं. / Ita No.380/Pun/2020 िनधा"रण वष" / Assessment Year : 2016-17 Poonawalla Shares & Securities The Assistant Pvt. Ltd., Vs Commissioner Of Income 16-B,/1, Sarosh Bhavan, Tax, Dr.Ambedkar Road, Circle-4, Pune. Pune – 411001 Pan: Aaacp 6087 H Appellant/ Assessee Respondent /Revenue Assessee By Shri Percy Pardiwala – Ar Revenue By Shri M.G.Jasnani – Dr Date Of Hearing 08/07/2022 Date Of Pronouncement 29/07/2022 आदेश/ Order Per S.S.Godara, Jm: This Assessee’S Appeal For Assessment Year 2016-17 Is Directed Against The Commissioner Of Income Tax(Appeals)-3, Pune’S Order Dated 11.12.2019 Passed In Case No.Pn/Cit(A)-3/Cir 4/193/2018-19/428, In Proceedings U/S.143(3) Of The Income Tax Act, 1961 [In Short “The Act”].

Section 143(3)Section 14A

reassess under section 147 or pass an order enhancing the assessment or reducing a refund already made or otherwise increasing the liability of the assessee under section 154, for any assessment year beginning on or before the 1st day of April, 2001.]” 5.5 If the provisions of law contained under section 14A and diction of section 14A is perused

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

In the result, all the above 6 appeals filed by the Revenue are dismissed and

ITA 497/PUN/2025[2013-14]Status: DisposedITAT Pune27 Oct 2025AY 2013-14

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

For Appellant: S/Shri Suchek Anchaliya andFor Respondent: Shri Amit Bobde, CIT
Section 10(38)Section 132Section 143(3)Section 147Section 148Section 153A

10(38) of the Act, he also deleted the addition made by the Assessing Officer u/s 69C of the Act being the commission @ 3% paid for accommodation entries taken. 11. Aggrieved with such order of the Ld. CIT(A) / NFAC the Revenue is in appeal before the Tribunal by raising the following grounds: 1. On the facts

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

In the result, all the above 6 appeals filed by the Revenue are dismissed and

ITA 1555/PUN/2024[2013-14]Status: DisposedITAT Pune27 Oct 2025AY 2013-14

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

For Respondent: S/Shri Suchek Anchaliya and
Section 10(38)Section 132Section 143(3)Section 147Section 148Section 153A

10(38) of the Act, he also deleted the addition made by the Assessing Officer u/s 69C of the Act being the commission @ 3% paid for accommodation entries taken. 11. Aggrieved with such order of the Ld. CIT(A) / NFAC the Revenue is in appeal before the Tribunal by raising the following grounds: 14 ITA Nos.1555/PUN/2024 & Ors CO Nos.2

DEPUTY DIRECTOR OF INCOME-TAX,, PUNE vs. SANDVIK A B.,, PUNE

ITA 623/PUN/2014[2005-06]Status: DisposedITAT Pune05 Jun 2018AY 2005-06

Bench: Ms. Sushma Chowla, Jm & Shri D. Karunakara Rao, Am आयकर अपीऱ सं. / Ita No.608/Pun/2014 यििाारण वषा / Assessment Year :2006-07

For Appellant: S/Shri Nikhil Pathak & S. SrinivasFor Respondent: S/Shri Rajeev Kumar, CIT & Ajay Modi, JCIT
Section 143(3)Section 144C(13)Section 148Section 151(2)

u/s. 148 are explicit and good enough to make out a fit case for re-opening of the assessment. 5. On the facts and circumstances of the present case, the learned DRP erred in not following the decision of the Hon'ble jurisdictional ITAT, Pune in the case of Cummins Inc. in ITA Nos.73&74/PN/2011 dtd. 8/08/2013 wherein the assessee

DEPUTY DIRECTOR OF INCOME-TAX vs. SANDVIK A B.,, PUNE

ITA 608/PUN/2014[2006-07]Status: DisposedITAT Pune05 Jun 2018AY 2006-07

Bench: Ms. Sushma Chowla, Jm & Shri D. Karunakara Rao, Am आयकर अपीऱ सं. / Ita No.608/Pun/2014 यििाारण वषा / Assessment Year :2006-07

For Appellant: S/Shri Nikhil Pathak & S. SrinivasFor Respondent: S/Shri Rajeev Kumar, CIT & Ajay Modi, JCIT
Section 143(3)Section 144C(13)Section 148Section 151(2)

u/s. 148 are explicit and good enough to make out a fit case for re-opening of the assessment. 5. On the facts and circumstances of the present case, the learned DRP erred in not following the decision of the Hon'ble jurisdictional ITAT, Pune in the case of Cummins Inc. in ITA Nos.73&74/PN/2011 dtd. 8/08/2013 wherein the assessee

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

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

ITA 1453/PUN/2023[2011-12]Status: DisposedITAT Pune24 Feb 2025AY 2011-12

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

For Appellant: Shri Kishor B PhadkeFor Respondent: Shri Uma Shankar Prasad
Section 143(3)Section 147Section 148Section 153A

Section 69C of ITA, 1961 amounting to Rs.1,52,62,200 and Rs.9,15,732 respectively thereby confirming the assessed income to the tune of Rs.3,41,20,562/- as against the returned income of Rs.1,79,42,630/- 2. The learned CIT(A) erred in upholding the reassessment proceedings when admittedly conditions specified u/s 147

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

ITA 1124/PUN/2024[2015-16]Status: DisposedITAT Pune18 Dec 2025AY 2015-16

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

For Appellant: Shri Kishor B PhadkeFor Respondent: Shri Amit Bobde &
Section 115BSection 143(3)Section 147Section 148Section 155BSection 68

10. Appellant craves to leave, add / alter or amend any other grounds of appeal.” 4. Assessee has also raised following additional grounds of appeal : “11. Without prejudice to other Grounds of appeal, Appellant contends that income from alleged "Anonymous Donations", taxable u/s 115BBC, can't exceed "Total Income" of the Appellant, considering the mechanism emerging from section 115BBC read

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

ITA 1126/PUN/2024[2017-18]Status: DisposedITAT Pune18 Dec 2025AY 2017-18

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

For Appellant: Shri Kishor B PhadkeFor Respondent: Shri Amit Bobde &
Section 115BSection 143(3)Section 147Section 148Section 155BSection 68

10. Appellant craves to leave, add / alter or amend any other grounds of appeal.” 4. Assessee has also raised following additional grounds of appeal : “11. Without prejudice to other Grounds of appeal, Appellant contends that income from alleged "Anonymous Donations", taxable u/s 115BBC, can't exceed "Total Income" of the Appellant, considering the mechanism emerging from section 115BBC read

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

ITA 1121/PUN/2024[2012-13]Status: DisposedITAT Pune18 Dec 2025AY 2012-13

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

For Appellant: Shri Kishor B PhadkeFor Respondent: Shri Amit Bobde &
Section 115BSection 143(3)Section 147Section 148Section 155BSection 68

10. Appellant craves to leave, add / alter or amend any other grounds of appeal.” 4. Assessee has also raised following additional grounds of appeal : “11. Without prejudice to other Grounds of appeal, Appellant contends that income from alleged "Anonymous Donations", taxable u/s 115BBC, can't exceed "Total Income" of the Appellant, considering the mechanism emerging from section 115BBC read