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

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, 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

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

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

ROYAL SWAN CHARITABLE MINORITY TRUST,NANDED vs. ITO (EXEMPTION), NANDED

In the result, appeals of the assessee for all the three AYs 2012-13,

Bench: Ms. Astha Chandra & Shree G.D. Padmahshali

reassessment merely based on DVO’s report is liable to be quashed. 6.2. That for such and other reasons the assessment is liable to be set aside. 7. Initiation of proceedings u/s 271(1)(C) The Ld. ITO erred in initiating penalty u/s 271(1)(c). 8. The appellant craves, leave to add, alter all, or any of the grounds

ROYAL SWAN CHARITABLE MINORITY TRUST,NANDED vs. ITO (EXEMPTION), NANDED

In the result, appeals of the assessee for all the three AYs 2012-13,

Bench: Ms. Astha Chandra & Shree G.D. Padmahshali

reassessment merely based on DVO’s report is liable to be quashed. 6.2. That for such and other reasons the assessment is liable to be set aside. 7. Initiation of proceedings u/s 271(1)(C) The Ld. ITO erred in initiating penalty u/s 271(1)(c). 8. The appellant craves, leave to add, alter all, or any of the grounds

ROYAL SWAN CHARITABLE MINORITY TRUST,NANDED vs. ITO (EXEMPTION), NANDED

In the result, appeals of the assessee for all the three AYs 2012-13,

Bench: Ms. Astha Chandra & Shree G.D. Padmahshali

reassessment merely based on DVO’s report is liable to be quashed. 6.2. That for such and other reasons the assessment is liable to be set aside. 7. Initiation of proceedings u/s 271(1)(C) The Ld. ITO erred in initiating penalty u/s 271(1)(c). 8. The appellant craves, leave to add, alter all, or any of the grounds

NARENDRA KACHRULAL ABAD,JALNA vs. INCOME-TAX OFFICER, WARD - 1,, JALNA

In the result, appeal of the assessee partly allowed

Bench: Dr.Dipak P. Ripote & Shri Vinay Bhamoreआयकर अपऩल सं. / Ita No.866/Pun/2019 निर्धारण वषा / Assessment Year: 2009-10 Shri Narendra Kachrulal Abad, V The Income Tax Officer, Abad House, Nal Galli, S Ward-1, Jalna. Kadrabad, Jalna – 431203. Maharashtra. Pan: Acspa9531C Appellant/ Assessee Respondent / Revenue Assessee By Shri Hari Krishan – Ar Revenue By Shri Arvind Renge –Addl.Cit(Dr) Date Of Hearing 28/07/2025 Date Of Pronouncement 06/10/2025 आदेश/ Order Per Dr. Dipak P. Ripote, Am: This Is An Appeal Filed By Assessee Against The Order Of Ld.Commissioner Of Income Tax(Appeal)-1, Aurangabadpassed Under Section 250 Of The Income Tax Act, 1961 For The A.Y.2009-10 Dated 30.03.2019, Emanating From Order U/S.143(3) R.W.S 147Of The Income Tax Act, 1961, Dated 03.11.2017. The Assessee Has Raised The Following Concise Grounds Of Appeal :

section 147 the item of income on which the Commissioner of Income Tax (Appeals) has made the enhancement, does not fall within the scope of reassessment u/s 147 of the Act. There was no information/record etc. before the Assessing Officer in there-assessment proceedings from which he could have noted that the item of income of Rs.29

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

Reassess. It is therefore requested that\nnotice may please be quashed.\n\n2. On the facts and in the circumstance of case and in law, Ld. CIT(A) has\nerred in dismissing the appellant ground that, the assessment proceedings\ninitiated under section 147 r.w.s 148 is bad in law and void ab initio on\nseveral counts. Thus, it is requested

SMT ANJALI PRAPHULL SHIVALE,PUNE vs. ACIT CIRCLE2(3), PUNE

In the result, all the appeals filed by the assessee are allowed for statistical purposes

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

section 147 of the Act. Accordingly, a notice u/s 148 of the Act was issued to the assessee on 08.03.2021 after recording the reasons and obtaining the approval from the competent authority. The assessee in response to the same vide letter dated 06.04.2021 stated that the return of income filed on 14.02.2018 may be treated as return in response

SHRI PRAPHULL KALURAM SHIVALE,PUNE vs. CENTRAL CIRCLE 2(4), PUNE

In the result, all the appeals filed by the assessee are allowed for statistical purposes

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

section 147 of the Act. Accordingly, a notice u/s 148 of the Act was issued to the assessee on 08.03.2021 after recording the reasons and obtaining the approval from the competent authority. The assessee in response to the same vide letter dated 06.04.2021 stated that the return of income filed on 14.02.2018 may be treated as return in response