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

143 & 147/148. 27. Section 153A and 153C starts with non- obstante clause. The procedure for assessment/reassessment in Section 153A, 153C in cases of search or requisition has an overriding effect to the regular provisions for assessment or reassessment under Sections 139, 147, 148, 149, 151 & 153. 28. The language of explanation 2 to new Section 148 is akin to Section

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

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

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

3) Nothing contained in this section shall apply\nin relation to a search initiated under section 132 or books of account,\nother documents or any assets requisitioned under section 132A on or after\nthe 1st day of April, 2021.\n16.\nOn a plain reading of Section 153A, it is clear that it begins with a 'non-\nobstante' clause, when

INCOME TAX OFFICER, WARD-1, JALNA, JALNA vs. PRAMILA OMPRAKASH MANTRI, JALNA

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

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

143(3), notice for reopening under material. 21. Referring to the decision of the Hon’ble Allahabad High Court in the case of PCIT vs. Smt. Renu Agarwal (2023) 153 taxmann.com 578 (Allahabad), he submitted that the Hon’ble High Court in the said decision has held that where AO disallowed exemption claimed by assessee under section

INCOME TAX OFFICER, WARD-1, JALNA, JALNA vs. OMPRAKASH ASARAM MANTRI, JALNA

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

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

143(3), notice for reopening under material. 21. Referring to the decision of the Hon’ble Allahabad High Court in the case of PCIT vs. Smt. Renu Agarwal (2023) 153 taxmann.com 578 (Allahabad), he submitted that the Hon’ble High Court in the said decision has held that where AO disallowed exemption claimed by assessee under section

INCOME TAX OFFICER, WARD-1, JALNA, JALNA vs. OMPRAKASH ASARAM MANTRI, JALNA

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

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

143(3), notice for reopening under material. 21. Referring to the decision of the Hon’ble Allahabad High Court in the case of PCIT vs. Smt. Renu Agarwal (2023) 153 taxmann.com 578 (Allahabad), he submitted that the Hon’ble High Court in the said decision has held that where AO disallowed exemption claimed by assessee under section

INCOME TAX OFFICER, WARD-1, JALNA, JALNA vs. ASHISH OMPRAKASH MANTRI, JALNA

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

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

143(3), notice for reopening under material. 21. Referring to the decision of the Hon’ble Allahabad High Court in the case of PCIT vs. Smt. Renu Agarwal (2023) 153 taxmann.com 578 (Allahabad), he submitted that the Hon’ble High Court in the said decision has held that where AO disallowed exemption claimed by assessee under section

INCOME TAX OFFICER, WARD -1, JALNA, JALNA vs. PRAMILA OMPRAKASH MANTRI, JALNA

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

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

143(3), notice for reopening under material. 21. Referring to the decision of the Hon’ble Allahabad High Court in the case of PCIT vs. Smt. Renu Agarwal (2023) 153 taxmann.com 578 (Allahabad), he submitted that the Hon’ble High Court in the said decision has held that where AO disallowed exemption claimed by assessee under section

INCOME TAX OFFICER, WARD-1, JALNA, JALNA vs. ATUL OMPRAKASH MANTRI, JALNA

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

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

143(3), notice for reopening under material. 21. Referring to the decision of the Hon’ble Allahabad High Court in the case of PCIT vs. Smt. Renu Agarwal (2023) 153 taxmann.com 578 (Allahabad), he submitted that the Hon’ble High Court in the said decision has held that where AO disallowed exemption claimed by assessee under section

INCOME TAX OFFICER, WARD-1, JALNA, JALNA vs. ATUL OMPRAKASH MANTRI, JALNA

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

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

143(3), notice for reopening under material. 21. Referring to the decision of the Hon’ble Allahabad High Court in the case of PCIT vs. Smt. Renu Agarwal (2023) 153 taxmann.com 578 (Allahabad), he submitted that the Hon’ble High Court in the said decision has held that where AO disallowed exemption claimed by assessee under section

INCOME TAX OFFICER, WARD 1, JALNA, JALNA vs. ASHISH OMPRAKASH MANTRI, JALNA

section 147 of\nthe Act. However, the Assessing Officer has not applied his mind to the\ninformation received in the context of the facts on record The impugned\nnotice is bad-in-law, as it has not been issued by the Assessing Officer on\nhis satisfaction that there is reason to believe, that income chargeable to\ntax has escaped assessment

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

reassess such income and also any other income chargeable to tax, which has escaped assessment and which comes to his notice subsequently in the course of the proceedings under the section. The first proviso to section 147 has no application in the facts of this case. The basic postulate which underlines section 147 is the formation of the belief

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

reassessment, referred to in clause (a) of sub-section (1), in a case where an order under sub-section (4) has been made accepting the application.‖. 5.3 Before leaping to section 270A of the Act, we first consider section 270AA of the Act in order to find out whether the Form 68 filed by the Assessee Company on 06/10/2022

ITO, WARD-1(1), SOLAPUR, SOLAPUR vs. MS. KSHIRSAGAR FABRICS, SOLAPUR

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

Bench: Shri R. K. Panda & Ms Astha Chandraassessment Year : 2009-10

u/s 143(3) / 147 of the Act, the Assessing Officer made disallowance of Rs.66,20,000/- on account of violation of provisions of section 40A(3) of the Act. We find the CIT(A) / NFAC quashed the re-assessment proceedings, the reasons of which have already been reproduced in the preceding paragraphs. We do not find any infirmity

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

AMOL PRAMOD MAHAJAN,JALGAON vs. DCIT, CENTRAL CIRCLE-1, NASHIK, NASHIK

In the result, all the appeals filed by the respective assessees are allowed

Bench: Shri R. K. Panda & Shri Vinay Bhamore

u/s. 143(3) r.w.s. 147 of the Act. The CIT(A) quashed the said reassessment by holding the action of JCIT in according sanction was without application of mind which was done in a mechanical manner. The ITAT upheld the order of CIT(A). The Hon‟ble High Court of Madhya Pradesh dismissed the appeal of Revenue by observing

AMOL PRAMOD MAHAJAN,JALGAON vs. DCIT, CENTRAL CIRCLE-1, NASHIK, NASHIK

In the result, all the appeals filed by the respective assessees are allowed

Bench: Shri R. K. Panda & Shri Vinay Bhamore

u/s. 143(3) r.w.s. 147 of the Act. The CIT(A) quashed the said reassessment by holding the action of JCIT in according sanction was without application of mind which was done in a mechanical manner. The ITAT upheld the order of CIT(A). The Hon‟ble High Court of Madhya Pradesh dismissed the appeal of Revenue by observing

PRIYANVADA AMOL MAHAJAN,JALGAON vs. DCIT, CENTRAL CIRCLE-1, NASHIK, NASHIK

In the result, all the appeals filed by the respective assessees are allowed

Bench: Shri R. K. Panda & Shri Vinay Bhamore

u/s. 143(3) r.w.s. 147 of the Act. The CIT(A) quashed the said reassessment by holding the action of JCIT in according sanction was without application of mind which was done in a mechanical manner. The ITAT upheld the order of CIT(A). The Hon‟ble High Court of Madhya Pradesh dismissed the appeal of Revenue by observing