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

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

144,CIT Vs Dr. R.C. Gupta & Co. (Raj) 122 ITR 567, Union Engineering Co. Vs CIT (Ker) 122 ITR 719,ITO Vs Leela Mammen (ITAT, Cochin) 63 TTJ 252, CIT Vs P.B. Shah & Co. (Pvt.) Ltd. (Cal) 113 ITR 587,ACIT Vs S.M. Kannappa Automobiles (P) Ltd. (ITAT, Bang) 72 ITD 474. In all cases the gist is like this

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\n(1

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\n(1

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

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

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 order u/s 144 r.w.s. 147 was passed, the Ld. ITAT-Pune Page 8 of 16 Subhash Runwal Vs ITO ITA No. 1279/PUN/2024 AY: 2012-13 AO besides making a token addition of interest income of out of the reasons recorded was also made two bullet additions which newly came to his notice during such reopened proceedings; (1) ₹10Lakhs

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

144 r.w.s. 148 of the Act, the Assessing Officer assessed the total income at Rs.21,86,950/- against the returned income. During the assessment proceedings, the Assessing Officer noticed that there was an escapement of income to the tune of Rs.18,52,000/-. The Assessing Officer recorded the reason to belief of the said escapement of income and issued notice

SHRIKANT CHANDRAKANT LOKHANDE,LATUR vs. ITO, WARD-1, LATUR, LATUR

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

Bench: Dr.Manish Borad & Shri Vinay Bhamoreआयकर अपील सं. / Ita No.2696/Pun/2024 Assessment Year : 2015-16

1) of section 143" shall not include the additional income-tax, if any, payable under section 143.]" 3.4. Section 208 "208. Conditions of liability to pay advance tax Advance tax shall be payable during a financial year in every case where the amount of such tax payable by the assessee during that year, as computed in accordance with the provisions

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

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 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

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

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 (NaFAC) is invalid and without jurisdiction since the income of the appellant is admittedly below the monetary limit as specified u/s 149(1

ASHOK BHARTI GOSWAMI,PUNE vs. ACIT, CENTRAL CIRCLE 2(1), PUNE , PUNE

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

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

147, section 140, section 149, section 151 and section 153, where the Assessing Officer is satisfied that- (a) any money, bullion, jewellery or other valuable article or thing, seized or requisitioned, belongs to or (b) any books of account or documents, seized or requisitioned, pertains or pertain to, or any information contained therein, relates to, a person other than

RAMLAL BHIKULAL SHAH,PUNE vs. ACIT, CENTRAL CIRCLE 2(1), PUNE , PUNE

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

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

147, section 140, section 149, section 151 and section 153, where the Assessing Officer is satisfied that- (a) any money, bullion, jewellery or other valuable article or thing, seized or requisitioned, belongs to or (b) any books of account or documents, seized or requisitioned, pertains or pertain to, or any information contained therein, relates to, a person other than