INCOME-TAX OFFICER vs. SHRI VASANTRAO LAXMAN KHANDGE,, PUNE

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

Bench: Ms. Sushma Chowla, Jm & Shri Anil Chaturvedi, Am आयकर अपीऱ सं. / Ita No.1971/Pun/2014 यििाारण वषा / Assessment Year : 2006-07

u/s 147 r.w.s. 148 of the Income-tax Act, 1961 as void ab-initio. 4. The learned Authorized Representative for the assessee pointed out that the additional ground of appeal raised by the assessee is against invoking of provisions of section 147 of the Act when provisions of section 153C of the Act were applicable, was purely a question

INCOME-TAX OFFICER vs. SHRI DATTATRAYA LAXMAN KHANDGE,, PUNE

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

Bench: Ms. Sushma Chowla, Jm & Shri Anil Chaturvedi, Am आयकर अपीऱ सं. / Ita No.1971/Pun/2014 यििाारण वषा / Assessment Year : 2006-07

u/s 147 r.w.s. 148 of the Income-tax Act, 1961 as void ab-initio. 4. The learned Authorized Representative for the assessee pointed out that the additional ground of appeal raised by the assessee is against invoking of provisions of section 147 of the Act when provisions of section 153C of the Act were applicable, was purely a question

D.L. KHANDGE,,PUNE vs. INCOME-TAX OFFICER,,

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

Bench: Ms. Sushma Chowla, Jm & Shri Anil Chaturvedi, Am आयकर अपीऱ सं. / Ita No.1971/Pun/2014 यििाारण वषा / Assessment Year : 2006-07

u/s 147 r.w.s. 148 of the Income-tax Act, 1961 as void ab-initio. 4. The learned Authorized Representative for the assessee pointed out that the additional ground of appeal raised by the assessee is against invoking of provisions of section 147 of the Act when provisions of section 153C of the Act were applicable, was purely a question

V.L. KHANDGE,,PUNE vs. INCOME-TAX OFFICER,,

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

Bench: Ms. Sushma Chowla, Jm & Shri Anil Chaturvedi, Am आयकर अपीऱ सं. / Ita No.1971/Pun/2014 यििाारण वषा / Assessment Year : 2006-07

u/s 147 r.w.s. 148 of the Income-tax Act, 1961 as void ab-initio. 4. The learned Authorized Representative for the assessee pointed out that the additional ground of appeal raised by the assessee is against invoking of provisions of section 147 of the Act when provisions of section 153C of the Act were applicable, was purely a question

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

133A of the Act was conducted on six premises of the assessee on 13/02/2019. Summons was issued to various donors, President and accountant of the assessee. Many statements were recorded. Thereafter, Re-assessment proceedings u/s 147 were initiated against the appellant from AY 2012-13 to AY 2017-18. 4. The learned AO, while concluding the 147 assessments, held that

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

133A of the Act was conducted on six premises of the assessee on 13/02/2019. Summons was issued to various donors, President and accountant of the assessee. Many statements were recorded. Thereafter, Re-assessment proceedings u/s 147 were initiated against the appellant from AY 2012-13 to AY 2017-18. 4. The learned AO, while concluding the 147 assessments, held that

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

133A of the Act was conducted on six premises of the assessee on 13/02/2019. Summons was issued to various donors, President and accountant of the assessee. Many statements were recorded. Thereafter, Re-assessment proceedings u/s 147 were initiated against the appellant from AY 2012-13 to AY 2017-18. 4. The learned AO, while concluding the 147 assessments, held that

ANIL BABANLAL AGRAWAL,,JALGAON vs. INCOME-TAX OFFICER,,

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

u/s 147 r.w.s. 143(3) of the Act is unsustainable in law. For this proposition, ld. Counsel relied on the various decisions including the decision of the Pune Bench of the Tribunal in the case of Shri V. L. Khandge vs. ITO in ITA No.1971/PUN/2014 for the assessment year 2006-07 dated 24.04.2018 and submitted that this appeal also pertains

LATE SHRI BABANLAL B AGARWAL,,JALGAON vs. INCOME-TAX OFFICER,, JALGAON

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

u/s 147 r.w.s. 143(3) of the Act is unsustainable in law. For this proposition, ld. Counsel relied on the various decisions including the decision of the Pune Bench of the Tribunal in the case of Shri V. L. Khandge vs. ITO in ITA No.1971/PUN/2014 for the assessment year 2006-07 dated 24.04.2018 and submitted that this appeal also pertains

LATE SHRI BABANLAL BHIKULAL AGRAWAL,,JALGAON vs. INCOME-TAX OFFICER,,

In the result, the appeal of the assessee is allowed

Bench: Shri D. Karunakara Rao, Am & Shri Laliet Kumar, Jm आयकर अपील सं. / Ita No.19/Pun/2015 िनधा"रण वष" / Assessment Year : 2003-04 Late Shri Babanlal Bhikulal Agrawal, Through L/H Shri Anil Babanlal Agrawal, 84-85, Main Road, Raver, Dist. Jalgaon-425508 .......अपीलाथ" / Appellant Pan : Aabha7676P बनाम / V/S. Ito, Ward-2(2), ……""यथ" / Respondent Jalgaon. Assessee By : Shri Sunil Ganoo Revenue By : Shri Vijay Netke सुनवाई क" तारीख / Date Of Hearing : 10.02.2020 घोषणा क" तारीख / Date Of Pronouncement : 12.02.2020 आदेश / Order Per D. Karunakara Rao, Am: This Appeal Filed By The Assessee Is Against The Order Of The Cit(A)-2, Nashik Dated 28.10.2014 For The Assessment Year 2003-04. 2. The Grounds Raised By The Assessee Are As Under :- “1] The Ld.Cit(A) Has Grossly Erred In Law & On Facts In Confirming Penalty Imposed Of Rs. 10,12,126/- U/S.271(1)(C) On Account Of Alleged Addition Made At Rs.32,13,100/(Inclusive Of Enhanced Income), Without Establishing Any Alleged Facts/Thing & Bringing Any Corroborative Evidence On Record, Even In Penalty Proceedings & Hence, Penalty Be Deleted 2] On The Facts & In The Prevailing Circumstances Of The Case, The Learned Cit(A) Has Grossly Erred In Confirming The Penalty U/S.271(1)(C) Of The I T Act, Without Rebutting Any Contention Of The Appellant Filed Before Him. Therefore

u/s 147 r.w.s. 143(3) of the Act is unsustainable in law. For this proposition, ld. Counsel relied on the various decisions including the decision of the Pune Bench of the Tribunal in the case of Shri V. L. Khandge vs. ITO in ITA No.1971/PUN/2014 for the assessment year 2006-07 dated 24.04.2018 and submitted that this appeal also pertains

RAJARSHI SHAHU SHIKSHAN SANSTHA INAM DHAMANI,SANGLI vs. ITO EXEMPTION, KOLHAPUR, KOLHAPUR

In the result, all the appeals filed by the assessee are\npartly allowed as per terms indicated hereinabove

133A of the Act was conducted on six premises of the\nassessee on 13/02/2019. Summons was issued to various donors,\nPresident and accountant of the assessee. Many statements were\nrecorded. Thereafter, Re-assessment proceedings u/s 147 were\ninitiated against the appellant from AY 2012-13 to AY 2017-18.\n4. The learned AO, while concluding the 147 assessments, held that

RAJARSHI SHAHU SHIKSHAN SANSTHA INAM DHAMANI,SANGLI vs. ITO EXEMPTION , KOLHAPUR, KOLHAPUR

In the result, all the appeals filed by the assessee are\npartly allowed as per terms indicated hereinabove

133A of the Act was conducted on six premises of the\nassessee on 13/02/2019. Summons was issued to various donors,\nPresident and accountant of the assessee. Many statements were\nrecorded. Thereafter, Re-assessment proceedings u/s 147 were\ninitiated against the appellant from AY 2012-13 to AY 2017-18.\n4. The learned AO, while concluding the 147 assessments, held that

RAJARSHI SHAHU SHIKSHAN SANSTHA INAM DHAMANI,SANGLI vs. ITO EXEMPTION, KOLHAPUR

In the result, all the appeals filed by the assessee are\npartly allowed as per terms indicated hereinabove

133A of the Act was conducted on six premises of the\nassessee on 13/02/2019. Summons was issued to various donors,\nPresident and accountant of the assessee. Many statements were\nrecorded. Thereafter, Re-assessment proceedings u/s 147 were\ninitiated against the appellant from AY 2012-13 to AY 2017-18.\n4. The learned AO, while concluding the 147 assessments, held that

BORA AGRO FOODS,PUNE vs. DCIT, CIR-5, PUNE, PUNE

In the result, all the appeals filed by the Assessee are partly\nallowed

reassessment under Section 147 of the Act\nwould become impermissible\nThe assumption that provisions of Section 153C of the Act precludes\nany proceeding under Section 147 of the Act by virtue of the non\nobstante clause. is unpersuasive. The scheme of Sections 153C of the\nAct indicates that the said provision was enacted to simplify the\nprocedure, while maintaining

BORA AGRO FOODS,PUNE vs. DCIT, CIR-5, PUNE, PUNE

In the result, all the appeals filed by the Assessee are partly\nallowed

reassessment under Section 147 of the Act\nwould become impermissible\nThe assumption that provisions of Section 153C of the Act precludes\nany proceeding under Section 147 of the Act by virtue of the non\nobstante clause. is unpersuasive. The scheme of Sections 153C of the\nAct indicates that the said provision was enacted to simplify the\nprocedure, while maintaining

BORA AGRO FOODS,PUNE vs. DCIT, CIR-5, PUNE, PUNE

In the result, all the appeals filed by the Assessee are partly\nallowed

reassessment under Section 147 of the Act\nwould become impermissible\nThe assumption that provisions of Section 153C of the Act precludes\nany proceeding under Section 147 of the Act by virtue of the non\nobstante clause. is unpersuasive. The scheme of Sections 153C of the\nAct indicates that the said provision was enacted to simplify the\nprocedure, while maintaining

ASSISTANT COMMISSIONER OF INCOME TAX CIRCLE 12, PUNE vs. VARUN JAIN, PUNE

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

Bench: Dr.Dipak P. Ripote & Shri Vinay Bhamorecross Objection No.14/Pun/2025 (Arising Out Of Ita No.2720/Pun/2024) िनधा"रण वष" / Assessment Year: 2018-19 Varun Jain, The Acit, P-024, Forest County, Kharadi, V Circle-12, Pune. Pune – 411014. S. Maharashtra. Pan:Aexpj0171J Appellant/ Assessee Respondent / Revenue आयकर अपील सं. / Ita No.2720/Pun/2024 िनधा"रण वष" / Assessment Year: 2018-19 The Acit, Varun Jain, Circle-12, Pune. Vs. P-024, Forest County, Kharadi, Pune – 411014. Maharashtra. Pan:Aexpj0171J Appellant / Revenue Respondent / Assessee Assessee By Shri Fenil Bhatt – Ar(Virtual) Revenue By Shri Abhinay Kumbhar - Dr Date Of Hearing 05/05/2025 Date Of Pronouncement 07/05/2025 आदेश/ Order Per Dr. Dipak P. Ripote, Am: In This Case, Revenue Has Filed An Appeal Against The Order Of Ld.Commissioner Of Income Tax(Appeal)[Nfac] Passed Under C.O.No.14/Pun/2025 [A] & Ita No.2720/Pun/2024 [R]

133A of the Income tax Act, 1961 ("the Act") on JM Finance Asset Management Ltd by DDIT Unit 3(1), Mumbai. The Appellant humbly prays that reopening u/s. 147 of the Act and the reassessment order dated March 19, 2024 under section

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

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

Reassess. It is therefore requested that notice may please be quashed. 2. On the facts and in the circumstance of case and in law, Ld. CIT(A) has erred in dismissing the appellant ground that, the assessment proceedings initiated under section 147 r.w.s 148 is bad in law and void ab initio on several counts. Thus, it is requested that

GOURISHANKAR EDUCATION SOCIETY,SATARA vs. CIT EXEMPTION, PUNE

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

Bench: Shri R. K. Panda & Shri Vinay Bhamoreआयकर अपील सं. / Ita Nos.1234 & 1235/Pun/2024 िनधा"रण वष" / Assessment Years : 2013-14 & 2014-15 Gourishankar Education Vs. Cit, Exemption, Pune. Society, Panchganga Apartment, Opp. Axis Bank, Radhika Road, Satara- 415001. Pan : Aaatg6668A Appellant Respondent Assessee By : Shri Kishor B. Phadke Revenue By : Shri Amol Khairnar Date Of Hearing : 21.11.2024 Date Of Pronouncement 10.01.2025 : आदेश / Order Per Vinay Bhamore, Jm: These Appeals Filed By The Assessee Are Directed Against The Separate Orders Dated 30.03.2024 Passed By Ld. Cit, Exemption, Pune U/S 263 Of The It Act For The Assessment Years 2013-14 & 2014-15 Respectively. 2. Since Identical Facts & Common Issues Are Involved In Both The Above Captioned Appeals Of The Assessee, Therefore, 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.1234/Pun/2024 For A.Y. 2013-14 For Adjudication.

133A of the IT Act was conducted on 02.05.2019 in the case of Gourishanker Educational & Charitable Trust. During the course of survey proceedings, it was found that the assessee trust has advanced interest-free loan to Gourishanker Educational & Charitable Trust, although, the assessee himself has raised interest bearing loans from various banks/cooperative credit societies etc. Accordingly, the assessee’s case