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

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

d) where a person is found to have any asset (including financial interest\nin any entity) located outside India.\nExplanation 3.--For the purpose of assessment or reassessment\nunder this section, the Assessing Officer may assess or reassess the income\nin respect of any issue, which has escaped assessment, and such issue\ncomes to his notice subsequently in the course

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

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

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

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

DEPUTY COMMISSIONER OF INCOME TAX CIRCLE 7 PUNE, PUNE vs. KOLTE PATIL INTEGRATED TOWNSHIPS LIMITED, PUNE

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

147.\nAs per the decision of Hon'ble Supreme Court in the case of Rajeev Bansal [167\ntaxmann.com 70], the notice under the new provision of section 148 have to be\nseen considering the proviso to section 149. We find in the instant case for both\nthe assessment years the Assessing Officer had initially issued notice u/s 148 in\nJune

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

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

11. Learned counsel has further argued that the benefit of allowable deduction of education cess was claimed by the petitioner-company when it was permitted as per law, however, as soon as the amendment under Section 155 of the Act was introduced by way of inserting sub-section (18), the petitionercompany immediately suo moto withdrew its claim for cess amounting

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

Section 80IA/IB of the Act.\nIt must follow that there is due application of mind by the Assessing\nOfficer to the issue raised.\nThe above observations apply on all fours to this Petition, so far as the\nRevenue's submission of no change of opinion is concerned.\n11. The further submission of Mr. Walve that in the absence

ASHIRWAD CHARITABLE TRUST,MUMBAI vs. DEPUTY COMMISSIONER OF INCOME TAX (EXEMPTIONS) CIRCLE, PUNE

In the result, the appeal of the assessee is allowed for statistical purposes

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

d) the legal presumption that all material facts had been duly considered at the time of assessment is applicable in this case; and (e) re-assessment would involve change of opinion, which is not permitted. The said objections raised by the assessee were rejected by the Ld. AO vide his order dated 18.02.2022. The assessee thereafter filed submission (letter) before

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

147 was not valid and the proper course of action that should have been taken by the Assessing Officer was u/s 153C as the provisions of section 153C of the Act are clearly applicable to the facts of the case. We, therefore, uphold the order of the CIT(A) / NFAC on the issue of validity of re-assessment proceedings

PUNE MATHADI HAMAL AND OTHER MANUAL WORKERS BOARD,PUNE vs. INCOME TAX OFFICER, WARD-5(1), PUNE, PUNE

In the result, appeal of the assessee is partly allowed

Bench: Shri S.S.Godara & Dr. Dipak P. Ripoteआयकर अपील सं. / Ita No.1012/Pun/2023 िनधा"रण वष" / Assessment Year : 2018-19 Pune Mathadihamal & Other The Income Tax Manual Workers Board, V Officer, Shramashakti Bhavan, S Ward-5(1), Pune. Coomercial Plot No.1, Market Yard, Pune – 411037. Pan: Aaalp0097L Appellant/ Assessee Respondent /Revenue Assessee By Shri Vipul Joshi – Ar Revenue By Shri Ajay Kumar Keshari & Shri Rajesh Gawali– Dr’S Date Of Hearing 17/04/2024 Date Of Pronouncement 27/06/2024 आदेश/ Order Per Dr. Dipak P. Ripote, Am: This Appeal Filed By The Assessee Is Against The Orders Of Ld.Commissionerof Income Tax(Appeals)[Nfac], Under Section 250 Of The Act Dated 14.07.2023 :

reassessment proceedings that were pending would also come under the ambit of the first proviso to section 12A(2) of the Act. 6.5 The second proviso to section 12A(2) also provides that no action u/s 147 of the Act shall be taken merely for non-registration of trust or institution. Reading this proviso with the first proviso to section

DY. COMMISSIONER OF INCOME TAX (EXEMPTIONS), CIRCLE, PUNE, SWARGATE, PUNE vs. DR D Y PATIL UNITECH SOCIETY, PUNE

In the result, the appeal filed by the Revenue is dismissed

Bench: Shri R. K. Panda & Ms. Astha Chandraassessment Year : 2013-14 Dcit (Exemption) Dr D Y Patil Unitech Society Circle, Pune Flat No.101, Shree Motisagar Vs. Apartment, G G Thakkar Road, S No.173A, Pune – 411001 Pan: Aabtd1482A (Appellant) (Respondent) Assessee By : Shri Nikhil S Pathak Department By : Shri Amol Khairnar, Cit-Dr Date Of Hearing : 27-10-2025 Date Of Pronouncement : 04-11-2025 O R D E R Per R.K. Panda, Vp:

D E R PER R.K. PANDA, VP: This appeal filed by the Revenue is directed against the order dated 06.03.2025 of the Ld. Addl / JCIT(A)-3, Delhi relating to assessment year 2013- 14. 2. Facts of the case, in brief, are that the assessee is a trust primarily engaged in educational activities. It is also engaged in providing medical

DEPUTY COMMISSIONER OF INCOME TAX CIRCLE-7 PUNE, PUNE vs. KOLTE PATIL INTEGRATED TOWNSHIPS LIMITED, PUNE

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

147 by issuing notice u/s 148A(d) of the Act on 25.07.2022 by recording\nas under:\n“GOVERNMENT OF INDIA\nMINISTRY OF FINANCE\nINCOME TAX DEPARTMENT\nOFFICE OF THE ASSISTANT\nCOMMISSIONER OF INCOME TAX\nCIRCLE 7, PUNE\nTo\nKOLTE-PATIL\nINTEGRATED\nTOWNSHIPS\nLIMITED\nSURVEY NO. 74, MARUNJI HINJEWADI\nMARUNJI, KASARSAI ROAD, TAL MULSHI\nPUNE PUNE 411057, Maharashtra India\nPAN