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

144B of the IT Act by determining the total income at Rs.50,51,750/-. The above assessed income includes addition of Rs.50,51,750/- u/s 69A of the IT Act as unexplained money. 5. Aggrieved with the above assessment order, an appeal was filed before Ld. CIT(A)/NFCA. In appeal, the CIT(A)/NFAC upheld the action

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

144B of the IT Act by determining the total income at Rs.50,51,750/-. The above assessed income includes addition of Rs.50,51,750/- u/s 69A of the IT Act as unexplained money. 5. Aggrieved with the above assessment order, an appeal was filed before Ld. CIT(A)/NFCA. In appeal, the CIT(A)/NFAC upheld the action

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

144B of the IT Act by determining the total income at Rs.50,51,750/-. The above assessed income includes addition of Rs.50,51,750/- u/s 69A of the IT Act as unexplained money. 5. Aggrieved with the above assessment order, an appeal was filed before Ld. CIT(A)/NFCA. In appeal, the CIT(A)/NFAC upheld the action

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

147 read with 144B of the Income Tax Act 1961. Assessee was requested to submit response through registered e-filing account at www.incometax.gov.in by 11:00 hours of 11/10/2023. The assessee did not comply with the notice on stipulated date and time even as on date. Show cause under clause (xii) (b) of section 144B of the Income

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

TEJAS SHIVAJI ADSUL,KOLHAPUR vs. INCOME TAX OFFICER WARD 1(1), KOLHAPUR, KOLHAPUR

In the result, appeal of the assessee is allowed

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

reassessment order, the A.O has initiated penalty u/s 270A on a vague charge of furnishing inaccurate particulars of income' also in the notice u/s 274 r.w.s 270A, the exact limb of section 270A(9) which has been allegedly violated by the assessee has not been specified and hence, the 7 ITA No.59/PUN/2025, AY 2018-19 penalty order passed u/s 270A

MRS NEHA VITTHAL DIMBLE,PUNE vs. ITO, WARD-3(3), PUNE, PUNE

In the result, the appeal of the assessee is allowed for statistical\npurposes

reassessment proceedings\nwhich constrained the Ld. AO to complete the assessment u/s 147 r.w.s.144B\nof the Act on 19.02.2024 at an assessed income of Rs.83,31,620/- by making\naddition of - (i) Rs.66,65,000/- in respect of cash deposits in bank treating the\nsame as unexplained money under section 69A; (ii) Rs.14,08,073/- in respect\nof purchase

ASSISTANT COMMISSIONER OF INCOME TAX CIRCLE 12, PUNE vs. VARUN JAIN, PUNE

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

Bench: Dr.Dipak P. Ripote & Shri Vinay Bhamorecross Objection No.14/Pun/2025 (Arising Out Of Ita No.2720/Pun/2024) िनधा"रण वष" / Assessment Year: 2018-19 Varun Jain, The Acit, P-024, Forest County, Kharadi, V Circle-12, Pune. Pune – 411014. S. Maharashtra. Pan:Aexpj0171J Appellant/ Assessee Respondent / Revenue आयकर अपील सं. / Ita No.2720/Pun/2024 िनधा"रण वष" / Assessment Year: 2018-19 The Acit, Varun Jain, Circle-12, Pune. Vs. P-024, Forest County, Kharadi, Pune – 411014. Maharashtra. Pan:Aexpj0171J Appellant / Revenue Respondent / Assessee Assessee By Shri Fenil Bhatt – Ar(Virtual) Revenue By Shri Abhinay Kumbhar - Dr Date Of Hearing 05/05/2025 Date Of Pronouncement 07/05/2025 आदेश/ Order Per Dr. Dipak P. Ripote, Am: In This Case, Revenue Has Filed An Appeal Against The Order Of Ld.Commissioner Of Income Tax(Appeal)[Nfac] Passed Under C.O.No.14/Pun/2025 [A] & Ita No.2720/Pun/2024 [R]

u/s. 147 of the Act and the reassessment order dated March 19, 2024 under section 147 read with section 144B

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

144B of the Act and made an addition of Rs.2,20,79,550/- u/s 69A r.w.s. 115BBE of the Act as unexplained money on the ground that the assessee failed to explain the nature and source of the cash deposits, to the returned income of Rs.4,45,130/- as computed u/s143(1)(a) of the Act. The relevant finding

MAHATMA PHULE GRAMIN BIGARSHETI SAHAKAR PAT SANSTHA LTD,KOLHAPUR vs. PCIT-1, PUNE, PUNE

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

Bench: Shri R. K. Panda & Ms. Astha Chandraassessment Year : 2018-19 Mahatma Phule Gramin Bigarsheti Pcit-1, Pune Sahakar Pat Sanstha Vs. A/P Hattiwade, Ajara, Kolhapur – 416505 Pan: Aaaam2608K (Appellant) (Respondent) Assessee By : None (Written Submission Filed) Department By : Shri Amol Khairnar, Cit-Dr Date Of Hearing : 09-12-2025 Date Of Pronouncement : 09-01-2026 O R D E R

144B of the Act allowed the claim of deduction u/s 80P of the Act amounting to Rs.18,19,066/- i.e. Rs.8,40,004/- u/s 80P(2)(a)(i), Rs.50,000/- u/s 80P(2)(c)(ii) and Rs.9,29,063/- u/s 80P(2)(d) of the Act. He noticed that the Assessing Officer had not made any query in this regard

ASHIRWAD CHARITABLE TRUST,MUMBAI vs. DEPUTY COMMISSIONER OF INCOME TAX (EXEMPTIONS) CIRCLE, PUNE

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

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

u/s 144B(1)(xvi) of the Act. The Ld. AO has clearly mentioned all the facts in his assessment order and details regarding the submission made by the appellant in his order. Hence, the contention of the appellant are found to be not correct. In view of the above, the ground of appeal nos. 1 to 6 are dismissed

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

INCOME TAX OFFICER WARD 3, SATARA, INCOME TAX OFFICE SATARA vs. NANDKUMAR DATTATRAY KHOT, DAHIWADI MAN

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

Bench: Dr.Dipak P. Ripote & Shri Vinay Bhamoreआयकर अपील सं. /Ita No.1562/Pun/2024 िनधा"रण वष" / Assessment Year: 2015-16 The Income Tax Officer, V Nandkumar Dattatray Khot, Ward-3, Satara S Shri Agencies Dahiwadi, Dahiwadi, Man Satara. Maharashtra – 415508. Pan: Aatpk8947P Appellant/ Revenue Respondent/ Assessee Cross Objection No.11/Pun/2025 िनधा"रण वष" / Assessment Year: 2015-16 Nandkumar Dattatray Khot, V The Income Tax Officer, Shri Agencies Dahiwadi, S Ward-3, Satara. Dahiwadi, Man Satara. Maharashtra – 415508. Pan:Aatpk8947P Appellant/ Assessee Respondent /Revenue Assessee By Shri Suhas Kulkarni - Ar Shri Vidya Ratna Kishor – (Dr)(Virtual) Revenue By Date Of Hearing 25/03/2025 Date Of Pronouncement 24/04/2025 आदेश/ Order Per Dr. Dipak P. Ripote, Am: This Is An Appeal Filed By The Revenue Against The Order Of The Commissioner Of Income Tax (Appeal) (Nfac) Under Section 250 Of

section 144B of the Income Tax Act Against the order u/s 147 rws 1448, dated 22/05/2023, the assessee preferred an appeal before CIT(A) The assessee took around 12 grounds before CIT(A) as mentioned in the page 3 of the Ld CIT(A)'s order. The assessee also took additional ground based on the decision of Telangana

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

BABABHAI SADARBHAI SHAIKH,AHMEDNAGAR vs. ITO WARD 1, AHMEDNAGAR, AHMEDNAGAR

In the result, the appeal filed by the assessee is allowed for statistical purposes

Bench: Shri R. K. Panda & Ms. Astha Chandraassessment Year : 2015-16 Bababhai Sadarbhai Shaikh Ito, Ward 1, Nr Goraba Takies Jamkhed, Vs. Ahmednagar Ahmednagar – 413201 Pan: Hozps1445M (Appellant) (Respondent) Assessee By : Shri Suhas P Bora Department By : Shri Ratnakar Bhimrao Shelake Date Of Hearing : 10-09-2025 Date Of Pronouncement : 23-10-2025 O R D E R Per R.K. Panda, Vp:

reassessment proceedings are initiated on the basis of incriminating material found in the search of 3rd party then the provisions of section 153C of the Act are applicable which override the applicability of sections 147 and 148 of the Act.” 7. The Learned Counsel for the assessee referring to the above additional ground submitted that the additional ground raised

VAISHALI KESHAV KULKARNI,PUNE vs. ITO WARD 13(2), PUNE

In the result the Grounds Numbers 2, 3 and 4 raised by the assessee are allowed

reassessment proceedings under section 147, 148 and 148A of the Act, should be done in a faceless manner.\n4. During the course of assessment, the Ld. A. O. accepted the fact that the sale transaction was not of Rs.3,60,00,000/- as reported by the Insight Portal, but of Rs.1,20,00,000/- as per the document provided

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

144B of the Income Tax Act, 1961, ITA No.1897/PUN/2025 [A] dated 05.01.2024. The Grounds of appeal raised by the Assessee are as under : “1. On the facts and in the circumstances of the case and without prejudice to any other grounds, the leamed NFAC has erred in law and on facts in passing an order under section

BABASAHEB SAHEBARAV JAGDALE,MASANARWADI LINGALI DAUND vs. ASSESSING OFFICER WARD 14(5), AAYAKAR SADAN BODHI TOWER SALISBURY PARK GULTEKDI

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

Bench: CIT(A) as per clause (b) Sec 246A of the IT Act, 1961. The Learned CIT(A) further erred to hold that Appellant should have filed Appeal to ITAT.

147 r.w.s. 144B of the IT Act, 1961 is bad in law, illegal and not tenable on various grounds: a. The proceedings have been initiated, order u/s 148A(d) and notice u/s 148A(b) and 148 have been issued by Jurisdictional Assessing Officer and not by Faceless Assessing Officer as required by section 151A of IT Act, 1961 and CBDT

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 by holding as under : “13. In view of continued non response from the assessee, and also considering the nature of business of the assessee being civil contract, the net profit of the assessee is estimated 8% of the entire gross receipt. The gross receipts from contracts is Rs.7