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

144] to show cause why the assessment should not be completed to the best of the judgment of the Assessing Officer, whichever is earlier, (c) where an action has been taken under section 132 or section 132A, after the expiry of one month from the date on which he was served with a notice under sub-section (1) of section

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

144] to show cause why the assessment should not be completed to the best of the judgment of the Assessing Officer, whichever is earlier, (c) where an action has been taken under section 132 or section 132A, after the expiry of one month from the date on which he was served with a notice under sub-section (1) of section

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

144] to show cause why the assessment should not be completed to the best of the judgment of the Assessing Officer, whichever is earlier, (c) where an action has been taken under section 132 or section 132A, after the expiry of one month from the date on which he was served with a notice under sub-section (1) of section

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

reassessment u/s 144 r.w.s. 147 of ITAT-Pune Page 12 of 16 Subhash Runwal Vs ITO ITA No. 1279/PUN/2024 AY: 2012-13 the Act was ill-believed as such addition was not only without any substance but purely was to outdo the settled law and to buy the extended scope subscribed in explanation 3 to section

SATYAPREM RAJABHAU DHOLE,BEED vs. ITO, WARD-1(5), AURANGABAD, AURANGABAD

In the result, the appeal of the assessee is allowed

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

reassessment proceedings. Since, the assessment was complete ex-parte u/s 144 of the Act by the Ld. AO, the Ld. CIT(A)/NFAC set aside the assessment order passed by the Ld. AO for making fresh assessment under the newly inserted proviso to section 251(1)(a) of the Act by observing as under : “5. Decision & findings: I have gone

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

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

144] to show cause why the assessment should not\nbe completed to the best of the judgment of the Assessing\nOfficer, whichever is earlier,\n(c)\nwhere an action has been taken under section 132 or\nsection 132A, after the expiry of one month from the date\non which he was served with a notice under sub-section

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

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

144] to show cause why the assessment should not\nbe completed to the best of the judgment of the Assessing\nOfficer, whichever is earlier,\n(c) where an action has been taken under section 132 or\nsection 132A, after the expiry of one month from the date\non which he was served with a notice under sub-section

DATTAPRASAD RADHAKISAN REVGADE,HIVARGAON vs. ITO WARD 2, AHMEDNAGAR

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

Bench: Ms.Astha Chandra, Judicialmember & Dr.Dipak P. Ripoteआयकर अपऩल सं. / Ita No.1897/Pun/2025 निर्धारण वषा / Assessment Year: 2018-19 Dattaprasad Radhakisan V The Income Tax Officer, Revgade, S Ward-2, Ahmednagar. At Hivargaon Post Dongargaon, Tal Aklole, Ahmednagar – 422609. Pan: Cddpr8213C Appellant/ Assessee Respondent / Revenue Assessee By Shri Piyush Bafna – Ar Revenue By Shri Ambarnath Khule – Jcit(Dr) Date Of Hearing 03/09/2025 Date Of Pronouncement 26/09/2025 आदेश/ Order Per Dr. Dipak P. Ripote, Am: This Appeal Filed By The Assessee Against The Order Of Ld.Commissioner Of Income Tax Appeal(Nfac) Passed Under Section 250 Of The Income Tax Act, 1961 For A.Y.2018-19 Dated 23.06.2025 Emanating From The Assessment Order Under Section 147 R.W.S 144 Read With Section 144B Of The Income Tax Act, 1961

reassessment order passed u/s 147 r.ws 144 read with section 1448 of the Act by the National Faceless Assessment Centre

SACHIN NAGRAJ CHHAJED,PUNE vs. ITO, PUNE

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

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

u/s 147 r.w.s. 144 read with section 144B of the Act. 4. The assessee challenged the ex-parte order before the Ld. CIT(A). Although the appeal was filed late by 14 days, the Ld. CIT(A) condoned the delay and decided the appeal ex-parte for non-compliance of notices of hearing dismissing the appeal of the assessee

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:

147 rws 144 dated 11/05/2023 and 23/05/2023. 2. The Grounds of Appeal raised by the assessee are as under: ITA Nos.3280 & 3281/PUN/2025 [A] ITA Nos.3280 & 3281/PUN/2025 [A] 3. Both these appeals were heard together and are disposed by this common order. In this case for AY 2016-17 the assessee had filed Return of Income on 17/10/2016 declaring Total Income

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:

147 rws 144 dated 11/05/2023 and 23/05/2023. 2. The Grounds of Appeal raised by the assessee are as under: ITA Nos.3280 & 3281/PUN/2025 [A] ITA Nos.3280 & 3281/PUN/2025 [A] 3. Both these appeals were heard together and are disposed by this common order. In this case for AY 2016-17 the assessee had filed Return of Income on 17/10/2016 declaring Total Income

RAJDEEP BUILDCOM PRIVATE LIMITED,AHMEDNAGAR vs. DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE - 1(2), PUNE, PUNE

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

Bench: SHRI R. K. PANDA (Vice President), SHRI VINAY BHAMORE (Judicial Member)

147 i.e. reassessment, to the extent that these proceedings are for the benefit of revenue and not that of the assessee. Therefore, assessee could not be permitted to convert such reassessment proceedings as his appeal or revision in disguise and seek relief in respect of depreciation earlier not claimed in original return of income. 17. Thus, the law is clear

RAJDEEP BUILDCON PRIVAT LIMITED, AHMEDNAGAR,AHMEDNAGAR vs. DY. COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE 1(2), PUNE, PUNE

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

Bench: SHRI R. K. PANDA (Vice President), SHRI VINAY BHAMORE (Judicial Member)

147 i.e. reassessment, to the extent that these proceedings are for the benefit of revenue and not that of the assessee. Therefore, assessee could not be permitted to convert such reassessment proceedings as his appeal or revision in disguise and seek relief in respect of depreciation earlier not claimed in original return of income. 17. Thus, the law is clear

RAJDEEP BUILDCON PVT LTD, AHMEDNAGAR,AHMEDNAGAR vs. DY. COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE 1(2), PUNE, PUNE

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

Bench: SHRI R. K. PANDA (Vice President), SHRI VINAY BHAMORE (Judicial Member)

147 i.e. reassessment, to the extent that these proceedings are for the benefit of revenue and not that of the assessee. Therefore, assessee could not be permitted to convert such reassessment proceedings as his appeal or revision in disguise and seek relief in respect of depreciation earlier not claimed in original return of income. 17. Thus, the law is clear

GULAMAHEMAD HAMIDULLA KHAN,PUNE vs. ITO WARD 14(3), PUNE

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

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

reassessment proceeding under the new provisions of section 147 as inserted by finance act 2021, on the basis of information gathered during the search conducted on M/s Renukamata Multistate Urban Co-operative Credit Society, therefore the action is illegal as the proceedings ought to have been initiated u/s 153C, therefore consequential order passed is bad in law and deserves

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.

section 13(2)(a) of the IT Act are violated. Since the assessee did not reply to any of the notices, the Assessing Officer passed ex-parte assessment order u/s 147 r.w.s. 144 of the IT Act on 16.03.2022 by making the addition of Rs.3.30 crores thereby assessing total income at Rs.3.30 crores. The assessee preferred first appeal before

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.

section 13(2)(a) of the IT Act are violated. Since the assessee did not reply to any of the notices, the Assessing Officer passed ex-parte assessment order u/s 147 r.w.s. 144 of the IT Act on 16.03.2022 by making the addition of Rs.3.30 crores thereby assessing total income at Rs.3.30 crores. The assessee preferred first appeal before

PRITESH RATANSHI VED,PUNE vs. INCOME TAX OFFICER, WARD 1(2), JALGAON

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

Bench: SHRI MANISH BORAD (Accountant Member), SHRI VINAY BHAMORE (Judicial Member)

Section 148 of the new regime within the time limit surviving under the Income Tax Act read with TOLA. All notices issued beyond the surviving period are time barred and liable to be set aside;” 13. We find since the notice u/s 148 of the Act has been issued after the statutory due date as per the decision

MOTIWALA AUTO PVT. LTD.,AURANGABAD vs. ITO, WARD1(1), AURANABAD, AURANGABAD

In the result, the appeal of the assessee is allowed

reassessment proceedings on the ground that\nthe notice issued under Section 148 is barred by limitation. After considering\nthe submissions and documentation furnished by the assessee and in the\nunique facts and circumstances of the case, the Ld. CIT(A)/NFAC opined that\nthe order passed by the Ld. AO under Section 147 read with Section 144 of the\nAct