JOSHI WADEWALE HADAPSAR,,PUNE vs. DEPUTY COMMISSIONER OF INCOME-TAX,,

In the result, appeals in the case of Mrs

Bench: Ms. Sushma Chowla, Jm & Shri D. Karunakara Rao, Am आयकर अपीऱ सं. / Ita Nos.95 & 96/Pun/2016 यििाारण वषा / Assessment Years : 2009-10 & 2010-11

144 (Kar), wherein it has been held that Chpter XIV-B does not preclude the Assessing Officer to proceed against the assessee by issuing notice under section 148 of the Act. He thus, stressed that after search proceedings carried out in the case of another person, it was open to the Assessing Officer either to proceed under Chapter

MRS. VASUNDHARA SHAILESH JOSHI,,PUNE vs. DEPUTY COMMISSIONER OF INCOME-TAX,,

In the result, appeals in the case of Mrs

Bench: Ms. Sushma Chowla, Jm & Shri D. Karunakara Rao, Am आयकर अपीऱ सं. / Ita Nos.95 & 96/Pun/2016 यििाारण वषा / Assessment Years : 2009-10 & 2010-11

144 (Kar), wherein it has been held that Chpter XIV-B does not preclude the Assessing Officer to proceed against the assessee by issuing notice under section 148 of the Act. He thus, stressed that after search proceedings carried out in the case of another person, it was open to the Assessing Officer either to proceed under Chapter

JOSHI WADEWALE SHEWALWADI,,PUNE vs. DEPUTY COMMISSIONER OF INCOME-TAX,,

In the result, appeals in the case of Mrs

Bench: Ms. Sushma Chowla, Jm & Shri D. Karunakara Rao, Am आयकर अपीऱ सं. / Ita Nos.95 & 96/Pun/2016 यििाारण वषा / Assessment Years : 2009-10 & 2010-11

144 (Kar), wherein it has been held that Chpter XIV-B does not preclude the Assessing Officer to proceed against the assessee by issuing notice under section 148 of the Act. He thus, stressed that after search proceedings carried out in the case of another person, it was open to the Assessing Officer either to proceed under Chapter

JOSHI WADEWALE SHEWALWADI,,PUNE vs. DEPUTY COMMISSIONER OF INCOME-TAX,,

In the result, appeals in the case of Mrs

Bench: Ms. Sushma Chowla, Jm & Shri D. Karunakara Rao, Am आयकर अपीऱ सं. / Ita Nos.95 & 96/Pun/2016 यििाारण वषा / Assessment Years : 2009-10 & 2010-11

144 (Kar), wherein it has been held that Chpter XIV-B does not preclude the Assessing Officer to proceed against the assessee by issuing notice under section 148 of the Act. He thus, stressed that after search proceedings carried out in the case of another person, it was open to the Assessing Officer either to proceed under Chapter

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

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

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

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

ANIL BABANLAL AGRAWAL,,JALGAON vs. INCOME-TAX OFFICER,,

In the result, appeals of assessee are allowed and appeals of Revenue are dismissed

144 r.w.s. 148 of the Act and not u/s 153C of the Act. In this regard, ld. Counsel raised the legal ground by way of additional grounds/concise grounds in these two appeals. The both the appeals are extracted hereunder :- “ITA No.1427/PUN/2011 – Additional grounds : 1. Since the opportunity to cross examine the author of the seized diaries and related persons from

LATE SHRI BABANLAL B AGARWAL,,JALGAON vs. INCOME-TAX OFFICER,, JALGAON

In the result, appeals of assessee are allowed and appeals of Revenue are dismissed

144 r.w.s. 148 of the Act and not u/s 153C of the Act. In this regard, ld. Counsel raised the legal ground by way of additional grounds/concise grounds in these two appeals. The both the appeals are extracted hereunder :- “ITA No.1427/PUN/2011 – Additional grounds : 1. Since the opportunity to cross examine the author of the seized diaries and related persons from