DEPUTY COMMISSIONER OF INCOME-TAX,, PUNE vs. M/S. SECO TOOLS INDIA PVT. LTD.,, PUNE

In the result, the Cross Objections of assessee are allowed and appeals of Revenue are dismissed

Bench: Ms. Sushma Chowla, Jm & Shri Anil Chaturvedi, Am आयकर अपीऱ सं. / Ita Nos.812 & 813/Pun/2017 यििाारण वषा / Assessment Years : 2002-03 & 2003-04

d) 1 Sandvik Receipt for 19,414,64 19,414,64 Refer Note Asia IT support 2 2 7 to Limited, services Appendix Mumbai- C Pune Road, Dapodi, Pune- 411012 2 Walter Receipt for 310,396 310,396 Refer Note Tools India IT support 7 to Private services Appendix Limited, C Mumbai- Pune Road, Dapodi, Pune- 411012 16. In view

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

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

d) 1 Sandvik Asia Receipt for IT 19,414,642 19,414,642 Refer Note 7 Limited, support to Appendix Mumbai-Pune services C Road, Dapodi, Pune-411012 CO Nos.20 & 28/PUN/2015 2 Walter Tools Receipt for IT 310,396 310,396 Refer Note 7 India Private support to Appendix Limited, services C Mumbai-Pune Road, Dapodi, Pune

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

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

d) 1 Sandvik Asia Receipt for IT 19,414,642 19,414,642 Refer Note 7 Limited, support to Appendix Mumbai-Pune services C Road, Dapodi, Pune-411012 CO Nos.20 & 28/PUN/2015 2 Walter Tools Receipt for IT 310,396 310,396 Refer Note 7 India Private support to Appendix Limited, services C Mumbai-Pune Road, Dapodi, Pune

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

reassessment, proceedings must be initiated under Section 153C, not Section 147. The Hon. Court held that the AO lacked jurisdiction under Section 147, rendering the notice invalid. Consequently, the court quashed and set aside the notice under Section 148 and allowed the petition of the assessee. (Relevant paragraphs 16 to 24). • In the case of Shyam Sunder Khandelwal vs. ACIT

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

D E R PER R.K. PANDA, V.P: The above appeals filed by the Revenue and the assessee are cross appeals and are directed against the separate orders dated 21.12.2015 of the Ld. CIT(A)-2, Aurangabad relating to assessment years 2003-04 to 2005-06 respectively. Since ITA Nos.1153, 1155 & 1154/MUM/2016 common issues are involved in all these appeals, therefore

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

D E R PER R.K. PANDA, V.P: The above appeals filed by the Revenue and the assessee are cross appeals and are directed against the separate orders dated 21.12.2015 of the Ld. CIT(A)-2, Aurangabad relating to assessment years 2003-04 to 2005-06 respectively. Since ITA Nos.1153, 1155 & 1154/MUM/2016 common issues are involved in all these appeals, therefore

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

D E R PER R.K. PANDA, V.P: The above appeals filed by the Revenue and the assessee are cross appeals and are directed against the separate orders dated 21.12.2015 of the Ld. CIT(A)-2, Aurangabad relating to assessment years 2003-04 to 2005-06 respectively. Since ITA Nos.1153, 1155 & 1154/MUM/2016 common issues are involved in all these appeals, therefore

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

D E R PER R.K. PANDA, V.P: The above appeals filed by the Revenue and the assessee are cross appeals and are directed against the separate orders dated 21.12.2015 of the Ld. CIT(A)-2, Aurangabad relating to assessment years 2003-04 to 2005-06 respectively. Since ITA Nos.1153, 1155 & 1154/MUM/2016 common issues are involved in all these appeals, therefore

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

D E R PER R.K. PANDA, V.P: The above appeals filed by the Revenue and the assessee are cross appeals and are directed against the separate orders dated 21.12.2015 of the Ld. CIT(A)-2, Aurangabad relating to assessment years 2003-04 to 2005-06 respectively. Since ITA Nos.1153, 1155 & 1154/MUM/2016 common issues are involved in all these appeals, therefore

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

D E R PER R.K. PANDA, V.P: The above appeals filed by the Revenue and the assessee are cross appeals and are directed against the separate orders dated 21.12.2015 of the Ld. CIT(A)-2, Aurangabad relating to assessment years 2003-04 to 2005-06 respectively. Since ITA Nos.1153, 1155 & 1154/MUM/2016 common issues are involved in all these appeals, therefore

MRS. VASUNDHARA SHAILESH JOSHI,,PUNE vs. DEPUTY COMMISSIONER OF INCOME-TAX,,

In the result, appeals in the case of Mrs

Bench: Ms. Sushma Chowla, Jm & Shri D. Karunakara Rao, Am आयकर अपीऱ सं. / Ita Nos.95 & 96/Pun/2016 यििाारण वषा / Assessment Years : 2009-10 & 2010-11

D. Ashtekar Vs. ITO (2013) 39 taxmann.com 103 (Pune – Trib.), it may be pointed out that the said order of Pune Bench of Tribunal has been recalled in MA No.112/PN/2013, order dated 21.06.2013 and has no binding effect for deciding the present issue. Further reference was made to the decision of CIT Vs. Continental Warehousing Corporation (NHAVA Sheva

JOSHI WADEWALE SHEWALWADI,,PUNE vs. DEPUTY COMMISSIONER OF INCOME-TAX,,

In the result, appeals in the case of Mrs

Bench: Ms. Sushma Chowla, Jm & Shri D. Karunakara Rao, Am आयकर अपीऱ सं. / Ita Nos.95 & 96/Pun/2016 यििाारण वषा / Assessment Years : 2009-10 & 2010-11

D. Ashtekar Vs. ITO (2013) 39 taxmann.com 103 (Pune – Trib.), it may be pointed out that the said order of Pune Bench of Tribunal has been recalled in MA No.112/PN/2013, order dated 21.06.2013 and has no binding effect for deciding the present issue. Further reference was made to the decision of CIT Vs. Continental Warehousing Corporation (NHAVA Sheva

JOSHI WADEWALE HADAPSAR,,PUNE vs. DEPUTY COMMISSIONER OF INCOME-TAX,,

In the result, appeals in the case of Mrs

Bench: Ms. Sushma Chowla, Jm & Shri D. Karunakara Rao, Am आयकर अपीऱ सं. / Ita Nos.95 & 96/Pun/2016 यििाारण वषा / Assessment Years : 2009-10 & 2010-11

D. Ashtekar Vs. ITO (2013) 39 taxmann.com 103 (Pune – Trib.), it may be pointed out that the said order of Pune Bench of Tribunal has been recalled in MA No.112/PN/2013, order dated 21.06.2013 and has no binding effect for deciding the present issue. Further reference was made to the decision of CIT Vs. Continental Warehousing Corporation (NHAVA Sheva

JOSHI WADEWALE SHEWALWADI,,PUNE vs. DEPUTY COMMISSIONER OF INCOME-TAX,,

In the result, appeals in the case of Mrs

Bench: Ms. Sushma Chowla, Jm & Shri D. Karunakara Rao, Am आयकर अपीऱ सं. / Ita Nos.95 & 96/Pun/2016 यििाारण वषा / Assessment Years : 2009-10 & 2010-11

D. Ashtekar Vs. ITO (2013) 39 taxmann.com 103 (Pune – Trib.), it may be pointed out that the said order of Pune Bench of Tribunal has been recalled in MA No.112/PN/2013, order dated 21.06.2013 and has no binding effect for deciding the present issue. Further reference was made to the decision of CIT Vs. Continental Warehousing Corporation (NHAVA Sheva

JOSHI WADEWALE PRABHAT CINEMA,,PUNE vs. DEPUTY COMMISSIONER OF INCOME-TAX,,

In the result, appeals in the case of Mrs

Bench: Ms. Sushma Chowla, Jm & Shri D. Karunakara Rao, Am आयकर अपीऱ सं. / Ita Nos.95 & 96/Pun/2016 यििाारण वषा / Assessment Years : 2009-10 & 2010-11

D. Ashtekar Vs. ITO (2013) 39 taxmann.com 103 (Pune – Trib.), it may be pointed out that the said order of Pune Bench of Tribunal has been recalled in MA No.112/PN/2013, order dated 21.06.2013 and has no binding effect for deciding the present issue. Further reference was made to the decision of CIT Vs. Continental Warehousing Corporation (NHAVA Sheva

MRS. VASUNDHARA SHAILESH JOSHI,,PUNE vs. DEPUTY COMMISSIONER OF INCOME-TAX,,

In the result, appeals in the case of Mrs

Bench: Ms. Sushma Chowla, Jm & Shri D. Karunakara Rao, Am आयकर अपीऱ सं. / Ita Nos.95 & 96/Pun/2016 यििाारण वषा / Assessment Years : 2009-10 & 2010-11

D. Ashtekar Vs. ITO (2013) 39 taxmann.com 103 (Pune – Trib.), it may be pointed out that the said order of Pune Bench of Tribunal has been recalled in MA No.112/PN/2013, order dated 21.06.2013 and has no binding effect for deciding the present issue. Further reference was made to the decision of CIT Vs. Continental Warehousing Corporation (NHAVA Sheva

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

11. In view of the above discussion, we annul the reopening of assessment u/s.147 of the Act.” In this case, it was held that the reasons for which reopening was made have been proved to be wrong, then in that event, any decision/addition made on the basis of said reassessment is unsustainable and becomes void. 5.9 The appellant has also

SACHIN MOHANLAL CHORDIA,PUNE vs. INCOME TAX OFFICER WARD 5(1), PUNE

Appeal of the assessee is partly allowed as we do not intend to adjudicate other grounds raised by the assessee

Bench: Ms. Astha Chandra & Dr. Dipak P. Ripoteआयकर अपील सं. / Ita Nos.3280 & 3281/Pun/2025 िनधा"रण वष" / Assessment Years: 2016-17 & 2017-18 Sachin Mohanlal Chordia, V The Income Tax Officer, B-101, Isha Emerald, S. Ward-5(1), Pune. Bibwewdi, Kondhwa Road, Marketyard, Pune- 411037. Pan: Aanpc8554C Appellant Respondent Assessee By Shri Abhilash Hiran Revenue By Shri Amit Bobade & Shri Sanjay Dhivare (Virtual) Date Of Hearing 05/03/2026 Date Of Pronouncement 30/03/2026 आदेश/ Order Per Bench : These Are Two Appeals Filed By Assessee Against The Separate Orders Of Commissioner Of Income Tax (Appeal) (Nfac) U/S 250 Of The Income Tax Act 1961 For Ay 2016-17, 2017-18 Passed On 22/10/2025 Emanating From Separate Assessment Orders U/S 147 Rws 144 Dated 11/05/2023 & 23/05/2023. 2. The Grounds Of Appeal Raised By The Assessee Are As Under:

d) 20/07/2022 21/07/2022 3 ITA Nos.3280 & 3281/PUN/2025 [A] Notice u/s 148 20/07/2022 21/07/2022 Notice Approved by Pr.CIT-3 Pune Pr.CIT -3 Pune 5. Ld.AR pleaded that for AY 2016-17 and AY 2017-18 the Notices have been approved by Pr.CIT, whereas as per Section 151, after the lapse of three years form the end of the Assessment Year

SACHIN MOHANLAL CHORDIA,PUNE vs. INCOME TAX OFFICER WARD 5(1), PUNE

Appeal of the assessee is partly allowed as we do not intend to adjudicate other grounds raised by the assessee

Bench: Ms. Astha Chandra & Dr. Dipak P. Ripoteआयकर अपील सं. / Ita Nos.3280 & 3281/Pun/2025 िनधा"रण वष" / Assessment Years: 2016-17 & 2017-18 Sachin Mohanlal Chordia, V The Income Tax Officer, B-101, Isha Emerald, S. Ward-5(1), Pune. Bibwewdi, Kondhwa Road, Marketyard, Pune- 411037. Pan: Aanpc8554C Appellant Respondent Assessee By Shri Abhilash Hiran Revenue By Shri Amit Bobade & Shri Sanjay Dhivare (Virtual) Date Of Hearing 05/03/2026 Date Of Pronouncement 30/03/2026 आदेश/ Order Per Bench : These Are Two Appeals Filed By Assessee Against The Separate Orders Of Commissioner Of Income Tax (Appeal) (Nfac) U/S 250 Of The Income Tax Act 1961 For Ay 2016-17, 2017-18 Passed On 22/10/2025 Emanating From Separate Assessment Orders U/S 147 Rws 144 Dated 11/05/2023 & 23/05/2023. 2. The Grounds Of Appeal Raised By The Assessee Are As Under:

d) 20/07/2022 21/07/2022 3 ITA Nos.3280 & 3281/PUN/2025 [A] Notice u/s 148 20/07/2022 21/07/2022 Notice Approved by Pr.CIT-3 Pune Pr.CIT -3 Pune 5. Ld.AR pleaded that for AY 2016-17 and AY 2017-18 the Notices have been approved by Pr.CIT, whereas as per Section 151, after the lapse of three years form the end of the Assessment Year