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

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

reassessment under Sections 139, 147, 148, 149, 151 & 153. 28. The language of explanation 2 to new Section 148 is akin to Section 153A and Section 153C. Corollary being that after seizing of operational 18 February, 2025 WP3057_2019.DOC period of Section 153A to 153D, the cases being dealt thereunder were circumscribed in the scope of newly substituted Section

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

reassessment under Sections 139, 147, 148, 149, 151 & 153.\n28. The language of explanation 2 to new Section 148 is akin to Section\n153A and Section 153C. Corollary being that after seizing of\noperational 18 February, 2025 WP3057_2019.DOC period of Section\n153A to 153D, the cases being dealt thereunder were circumscribed in the\nscope of newly substituted Section

MR. CHITTARANJAN TRIMBAK GAIKWAD,PUNE vs. THE ASST. COMMISSIONER OF INCOME TAX, CIRCLE-4, PUNE, PUNE

In the result, the appeal of the assessee is allowed

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

reassessment, if any, relating to any assessment year falling within the period of six assessment years referred to in this sub-section pending on the date of initiation of the search under Section 132 or making of requisition under Section 1324, as the case may be, shall abate." What is clear from this is that Section 153A

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

reassess such income and also any\nother income chargeable to tax which has escaped assessment and which comes to\nhis notice subsequently in the course of the proceedings under section 147 of the\nAct\n28.1 The first proviso to section 147 is important. As per this proviso, where an\nassessment under subsection (3) of section 143 or section 147

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

reassess such income and also any\nother income chargeable to tax which has escaped assessment and which comes to\nhis notice subsequently in the course of the proceedings under section 147 of the\nAct\n28.1 The first proviso to section 147 is important. As per this proviso, where an\nassessment under subsection (3) of section 143 or section 147

SOMNATH RAMDAS JADHAV,AHMEDNAGAR vs. ITO, WARD 2, AHMEDNAGAR, AHMEDNAGAR

Accordingly, the appeal in ITA No.1092/PUN/2025 for A.Y. 2013-14 involving the issue of penalty u/s 271(1)(c) of the Act is allowed

Bench: Shri Manish Borad & Shri Vinay Bhamore

139, after the expiry of one month from the date on which (a) he was served with a notice under sub-section (1) of section 142 or [sub-section (2) of section 115WE or] sub-section (2) of section 143 or after the completion of the assessment, whichever is earlier; (b) where he has made no such retum, after

SOMNATH RAMDAS JADHAV,AHMEDNAGAR vs. ITO WARD 2, AHMEDNAGAR

Accordingly, the appeal in ITA No.1092/PUN/2025 for A.Y. 2013-14 involving the issue of penalty u/s 271(1)(c) of the Act is allowed

Bench: Shri Manish Borad & Shri Vinay Bhamore

139, after the expiry of one month from the date on which (a) he was served with a notice under sub-section (1) of section 142 or [sub-section (2) of section 115WE or] sub-section (2) of section 143 or after the completion of the assessment, whichever is earlier; (b) where he has made no such retum, after

SOMNATH RAMDAS JADHAV,AHMEDNAGAR vs. ITO WARD2, AHMEDNAGAR

Accordingly, the appeal in ITA No.1092/PUN/2025 for A.Y. 2013-14 involving the issue of penalty u/s 271(1)(c) of the Act is allowed

Bench: Shri Manish Borad & Shri Vinay Bhamore

139, after the expiry of one month from the date on which (a) he was served with a notice under sub-section (1) of section 142 or [sub-section (2) of section 115WE or] sub-section (2) of section 143 or after the completion of the assessment, whichever is earlier; (b) where he has made no such retum, after

SOMNATH RAMDAS JADHAV,AHMEDNAGAR vs. ITO, WARD 2, AHMEDNAGAR, AHMEDNAGAR

Accordingly, the appeal in ITA No.1092/PUN/2025 for A.Y. 2013-14 involving the issue of penalty u/s 271(1)(c) of the Act is allowed

Bench: Shri Manish Borad & Shri Vinay Bhamore

139, after the expiry of one month from the date on which (a) he was served with a notice under sub-section (1) of section 142 or [sub-section (2) of section 115WE or] sub-section (2) of section 143 or after the completion of the assessment, whichever is earlier; (b) where he has made no such retum, after

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

reassessment notice under section 148 of the new regime. Thus, in this\nillustration, the time limit for issuance of a notice under section 148 of the new\nregime will end on 18 August 2022.\n22. He submitted that it is abundantly clear from the above decision that the time\nbetween the issue of original notice u/s 148 under

SUBHASH RUNWAL,BIBWEWADI, PUNE vs. INCOME TAX OFFICER WARD 5(4) PUNE, PUNE

The appeal of the assessee is ALLOWED

Bench: Hon’Ble Shri G. D. Padmahshali & Hon’Ble Shri Vinay Bhamoreassessment Year : 2012-13 Subhash Runwal 204, Solitari-5, Nr. Kalyan Bhel, Bibwewadi Rd., Pune-411037. Pan: Adbpr7670R. . . . . . . . Appellant

1) of section 139 of the Act the addition of interest made while framing the re-assessment u/ 144 r.w.s. 147 of the Act in first place cannot to be said to escaped income, therefore such interest do not solitary could have formed basis for invoking reassessment jurisdiction. On the other hand, records also reveals us that, the addition

SOMNATH RAMDAS JADHAV,AHMEDNAGAR vs. ITO WARD 2, AHMEDNAGAR

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

139,\nafter the expiry of one month from the date on which (a) he\nwas served with a notice under sub-section (1) of section\n142 or [sub-section (2) of section 115WE or] sub-section\n(2) of section 143 or after the completion of the\nassessment, whichever is earlier;\n(b)\nwhere he has made no such return

SOMNATH RAMDAS JADHAV,AHMEDNAGAR vs. ITO WARD 2, AHMEDNAGAR, AHMEDNAGAR

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

139,\nafter the expiry of one month from the date on which (a) he\nwas served with a notice under sub-section (1) of section\n142 or [sub-section (2) of section 115WE or] sub-section\n(2) of section 143 or after the completion of the\nassessment, whichever is earlier;\n(b) where he has made no such retum

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

147 wherein the Hon’ble High Court has held that the provisions contained in section 12A(b) were only directory in nature and not mandatory. The relevant observations of the Hon’ble High Court read as under: “8. Coming to the first argument that Section 12A(b) is mandatory, learned Counsel appearing for the assessee relies on a judgment

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

147 wherein the Hon’ble High Court has held that the provisions contained in section 12A(b) were only directory in nature and not mandatory. The relevant observations of the Hon’ble High Court read as under: “8. Coming to the first argument that Section 12A(b) is mandatory, learned Counsel appearing for the assessee relies on a judgment

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

147 wherein the Hon’ble High Court has held that the provisions contained in section 12A(b) were only directory in nature and not mandatory. The relevant observations of the Hon’ble High Court read as under: “8. Coming to the first argument that Section 12A(b) is mandatory, learned Counsel appearing for the assessee relies on a judgment

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

147 wherein the Hon’ble High Court has held that the provisions contained in section 12A(b) were only directory in nature and not mandatory. The relevant observations of the Hon’ble High Court read as under: “8. Coming to the first argument that Section 12A(b) is mandatory, learned Counsel appearing for the assessee relies on a judgment

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

147 wherein the Hon’ble High Court has held that the provisions contained in section 12A(b) were only directory in nature and not mandatory. The relevant observations of the Hon’ble High Court read as under: “8. Coming to the first argument that Section 12A(b) is mandatory, learned Counsel appearing for the assessee relies on a judgment

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

147 wherein the Hon’ble High Court has held that the provisions contained in section 12A(b) were only directory in nature and not mandatory. The relevant observations of the Hon’ble High Court read as under: “8. Coming to the first argument that Section 12A(b) is mandatory, learned Counsel appearing for the assessee relies on a judgment