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:

u/s 148 issued between 01.04.2021 and June 30,2021 under old regime 4.4 The notification issued by the Central Government under section 3(1) of TOLA contained an explanation that provisions of section 147 to 151 of the Act prior to April 1, 2021 (herein after referred to as “old regime”) shall be applied to reassessment proceedings initiated under them

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

148A of the Act, issuing notice under section 148 of the Act by the JAO and passing order by the Ld. AO under section 147 of the Act. The information obtained and relied upon is misleading and incorrect and therefore, the very initiation of the proceeding stands vitiated and the reassessment order passed in case of the appellant

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

147.\nAs per the decision of Hon'ble Supreme Court in the case of Rajeev Bansal [167\ntaxmann.com 70], the notice under the new provision of section 148 have to be\nseen considering the proviso to section 149. We find in the instant case for both\nthe assessment years the Assessing Officer had initially issued notice u/s 148 in\nJune

HEENA IRFAN BEPARI,SANGLI vs. INCOME TAX OFFICER , SANGLI

In the result, appeal of the assessee is partly allowed

Bench: Ms.Astha Chandra & Dr.Dipak P. Ripoteआयकर अपील सं. / Ita Nos.1183 & 1184 /Pun/2025 िनधा"रण वष" / Assessment Years: 2013-14 & 2014-15 Heena Irfan Bepari, V The Income Tax Officer, 661, Raviwar Peth, S Ward-5, Sangli. Madhavnagar, Sangli – 416416. Maharashtra. Pan: Bnepb9635A Appellant/ Assessee Respondent / Revenue Assessee By Shri Pramod S Shingte– Ar Revenue By Shri Sandeep P Sathe –Jcit(Dr) Date Of Hearing 16/07/2025 Date Of Pronouncement 29/07/2025 आदेश/ Order Per Dr. Dipak P. Ripote, Am: These Two Appeals Filed By Assessee Are Against The Separate Orders Of Ld.Commissioner Of Income Tax(Appeal)[[Nfac], Passed Under Section 250 Of The Income Tax Act, 1961 For The A.Y.2013-14 & 2014-15 Both Dated 24.03.2025 Respectively.For The Sake Of Convenience, These Two Appeals Were Heard Together & Are Being Disposed Of By This Common Order. We Treat Appeal In Ita

u/s 148 28.07.2022 21. Therefore, computing the surviving/balance time limit, as per the decision of the Hon’ble Supreme Court in Rajeev Bansal (supra), we find that the Revenue had only 2 days (i.e., between 29/06/2021 to 30/06/2021) to issue notice under section 148 of the Act of the new regime in the present case, i.e. till 26/06/2022, after receipt

HEENA IRFAN BEPATI,SANGLI vs. INCOME TAX OFFICER, SANGLI

In the result, appeal of the assessee is partly allowed

Bench: Ms.Astha Chandra & Dr.Dipak P. Ripoteआयकर अपील सं. / Ita Nos.1183 & 1184 /Pun/2025 िनधा"रण वष" / Assessment Years: 2013-14 & 2014-15 Heena Irfan Bepari, V The Income Tax Officer, 661, Raviwar Peth, S Ward-5, Sangli. Madhavnagar, Sangli – 416416. Maharashtra. Pan: Bnepb9635A Appellant/ Assessee Respondent / Revenue Assessee By Shri Pramod S Shingte– Ar Revenue By Shri Sandeep P Sathe –Jcit(Dr) Date Of Hearing 16/07/2025 Date Of Pronouncement 29/07/2025 आदेश/ Order Per Dr. Dipak P. Ripote, Am: These Two Appeals Filed By Assessee Are Against The Separate Orders Of Ld.Commissioner Of Income Tax(Appeal)[[Nfac], Passed Under Section 250 Of The Income Tax Act, 1961 For The A.Y.2013-14 & 2014-15 Both Dated 24.03.2025 Respectively.For The Sake Of Convenience, These Two Appeals Were Heard Together & Are Being Disposed Of By This Common Order. We Treat Appeal In Ita

u/s 148 28.07.2022 21. Therefore, computing the surviving/balance time limit, as per the decision of the Hon’ble Supreme Court in Rajeev Bansal (supra), we find that the Revenue had only 2 days (i.e., between 29/06/2021 to 30/06/2021) to issue notice under section 148 of the Act of the new regime in the present case, i.e. till 26/06/2022, after receipt

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

148A(d) 26/07/2022 Notice u/s 148 27/07/2022 Order u/s 147 read with 22/05/2023 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

SANCHIT KANTILAL GANORE,BHAGUR vs. ITO WARD 1(1), NASHIK, NASHIK

In the result, appeal of the assessee is partly allowed

Bench: Dr.Dipak P. Ripote & Shri Vinay Bhamoreआयकर अपऩल सं. / Ita No.1767/Pun/2025 निर्धारण वषा / Assessment Year: 2017-18 Sanchit Kantilal Ganore, V The Income Tax Officer, 21, Main Road, Bhagur, S. Ward-1(1), Nashik. Nashik - 422502. Pan: Aprpg4907J Appellant/ Assessee Respondent / Revenue Assessee By Shri Piyush Bafna Revenue By Shri Aviyogi Ambadkar– Add.Cit(Dr) Date Of Hearing 09/09/2025 Date Of Pronouncement 19/09/2025 आदेश/ Order Per Dr. Dipak P. Ripote, Am: This Appeal Is 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.2017-18, Dated 29.05.2025 Emanating From Assessment Order U/S.147 R.W.S 144 Of The I.T.Act, Dated 21.05.2023. The Assessee Has Raised Following Grounds Of Appeal : “1. On The Facts & In The Circumstances Of The Case & In Law & Without Prejudice To Other Grounds, Ld. Nfac Has Erred In Passing A

147 r.w.s. 144 of the Act is bad in law since there was no application of mind, by Ld. AO while issuing the notices u/s 148A(b) and passing order u/s 148A(d) and notice u/s 148 inasmuch as there is no independent verification of the information with facts already available on record to justify the formation of satisfaction that

YEZDI NAUSHIR BHARUCHA,JALGAON vs. ITO WARD 1(3), JALGAON, JALGAON

In the result, appeal of the assessee is partly allowed

Bench: Dr.Dipak P. Ripote & Shri Vinay Bhamoreआयकर अपील सं. / Ita No.315/Pun/2025 िनधा"रण वष" / Assessment Year: 2017-18 Yezdi Naushir Bharucha, V The Income Tax Officer, Bharucha House, New Laxmi S. Ward-1(3), Jalgaon. Talkies Road, Amalner – 425401. Maharashtra. Pan: Abepb6770B Appellant/ Assessee Respondent / Revenue Assessee By Shri Nikhil S Pathak - Ar Revenue By Shri Date Of Hearing 06/05/2025 Date Of Pronouncement 07/05/2025 आदेश/ Order Per Dr. Dipak P. Ripote, Am: This Is An Appeal Filed By The Assessee Against The Order Of Ld.Commssioner Of Income Tax(Appeal)[Nfac] Passed Under Section 250 Of The Act, Dated 11.12.2024 For The A.Y.2017-18. The Assessee Has Raised The Following Grounds Of Appeal : “1] The Learned Cit(A) Erred In Holding That The Reopening U/S 148 Was Valid In Law Without Appreciating That The Notice U/S 148 Was Issued Was Invalid In Law & Accordingly, The Reassessment Order Passed U/S 147 Should Have Been Declared Null & Void.

147 was null and void. 3] The appellant craves leave to add, alter, amend or delete any of the above grounds of appeal.” 1.1 Assessee has raised an Additional Ground of appeal as under : “1] The assessee submits that the notice issued u/s.148 and u/s.148A(d) is invalid in law since the approval as envisaged u/s.151 has not been obtained

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

147 by issuing notice u/s 148A(d) of the Act on 25.07.2022 by recording\nas under:\n“GOVERNMENT OF INDIA\nMINISTRY OF FINANCE\nINCOME TAX DEPARTMENT\nOFFICE OF THE ASSISTANT\nCOMMISSIONER OF INCOME TAX\nCIRCLE 7, PUNE\nTo\nKOLTE-PATIL\nINTEGRATED\nTOWNSHIPS\nLIMITED\nSURVEY NO. 74, MARUNJI HINJEWADI\nMARUNJI, KASARSAI ROAD, TAL MULSHI\nPUNE PUNE 411057, Maharashtra India\nPAN

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

SIDDHARTH RAIKUMAR NAHAR,PUNE vs. DCIT, CIR-5, PUNE, PUNE

In the result, the appeal filed by the assessee is allowed as per terms indicated above

Bench: Dr.Manish Borad & Shri Vinay Bhamoreआयकर अपील सं. / Ita No.2062/Pun/2025 Assessment Year : 2017-18

147 by the learned A.O. is invalid in law and the same may kindly be declared null and void. 6] The learned CIT(A) erred in confirming the addition of Rs.5,00,000/-made u/s 69A of the Act on the ground that the assessee had lent the said amount in cash through Shri Sachin Nahar. 7] The learned

ANANDA GORAKHANATH PAWAR,SATARA vs. ASSESSING OFFICER, WARD 3, SATARA, SATARA

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

Bench: Shri R. K. Panda & Shri Vinay Bhamoreआयकर अपील सं. / Ita No.1796/Pun/2025 िनधा"रण वष" / Assessment Year : 2018-19 Ananda Gorakhanath Pawar, Vs. Ito, Ward-3, Satara. At Post Ambawade, Khatav, Satara- 415506. Pan : Blhpp6081R Appellant Respondent Assessee By Shri R. C. Doshi : Revenue By : Shri Milind Debaje Date Of Hearing : 28.08.2025 Date Of Pronouncement : 28.08.2025 आदेश / Order Per Vinay Bhamore, Jm: This Appeal Filed By The Assessee Is Directed Against The Order Dated 30.06.2025 Passed By Ld. Cit(A)/Nfac For The Assessment Year 2018-19. 2. The Appellant Has Filed The Following Grounds Of Appeal :- “1. The Learned Cit Has Erred Both On Facts & In Law In Dismissing The Appeal Of The Appellant By Refusing To Condone The Delay Of 26 Days On Grounds Of Period Of Limitation, Notwithstanding The Fact That Appellant Has Submitted The Application & Explained The Reasons For Delay.

147 r.w.s. 144 of the IT Act, 1961 is it bad in law, illegal and not tenable – a) Notice u/s 148 and order u/s 148A(d) of the Act dated 30/03/2022 is issued by jurisdictional assessing officer and not by Faceless Assessment office as required by section 151A of IT Act, 1961 and CBDT scheme for faceless reassessment

M/S KARIA BUILDERS ,PUNE vs. ITO WARD 14(3), PUNE

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

Bench: Shri R. K. Panda & Ms. Astha Chandraassessment Year : 2017-18 M/S. Karia Builders Ito, Ward 14(3), Pune 402, Konark Indrayu, Kondhwa, Vs. Pune – 411048 Pan: Aadfk5220B (Appellant) (Respondent) Assessee By : Shri Sanket M Joshi Department By : Shri Ramnath P Murkunde Date Of Hearing : 17-07-2025 Date Of Pronouncement : 23-07-2025 O R D E R

147 r.w.s. 144B of the Act on 16.05.2023. Before completion of the assessment, a notice u/s 274 r.w.s. 271D of the Act was issued to the assessee on 17.08.2022 which reads as under: 9 19. Thus, the penalty proceedings were initiated on 17.08.2022. We find the JCIT in the show cause notice for penalty u/s 271D of the Act issued

MANISH JASHWANTRAI BHUTA,NASHIK vs. ITO WARD 1(1), NASHIK

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

Bench: Shri R. K. Panda & Ms. Astha Chandraassessment Year : 2016-17 Manish Jashwantrai Bhuta Ito, Ward 1(1), Nashik Flat No.8, Pooja Apartment, Vs. Shivam Nagar, Hirawadi, Panchavati, Nashik – 422003 Pan: Aghpb1619F (Appellant) (Respondent) Assessee By : Shri Sanket M Joshi (Through Virtual) Department By : Shri Manish M. Mehta Date Of Hearing : 03-11-2025 Date Of Pronouncement : 20-11-2025 O R D E R Per R.K. Panda, Vp:

reassessment or recomputation under s. 147, and subject to the provisions of s. 148A. the AO shall serve on the assessee a notice, along with a copy of the order passed, if required, under cl. (d) of s. 148A, requiring him to furnish within such period, as may be specified in such notice, a return of his income

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

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 to be struck down. 4. On the facts

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

148A(d) of the Act was passed with the prior approval of the Pr. Chief Commissioner of Income Tax, Pune on 06.04.2022 followed by issuance of notice u/s 148 of the Act on 07.04.2022. Thereafter, statutory notice(s) u/s 143(2) and 142(1) of the Act along with show cause letters were issued to the assessee from time

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)

147 of the Act by issuing notice u/s 148 of the Act on 29.07.2022. The assessee has challenged the order on various grounds including the legal grounds. One of the legal ground raised by the assessee pertains to challenging the validity of notice issued u/s 148 of the Act in the light of judgement passed by Hon’ble Supreme Court

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]

147 to 151A of the Act. Therefore, the reassessment order must be quashed. The Appellant craves leave to amend, alter, modify and add any further grounds of cross objections, if required.” 1.3 Both these appeals were heard together. C.O.No.14/PUN/2025 Submission of ld.AR : 2. Ld.AR for the Assessee submitted that Assessee has filed Return of Income for A.Y.2018-19

MR. HARIVIJAY PRALHAD JOSHI,PUNE vs. ITO WARD 3(3), PUNE, SWARGATE

In the result, appeal of the assessee is partly allowed

Bench: Dr.Dipak P. Ripote & Shri Vinay Bhamoreआयकर अपऩल सं. / Ita No.2297/Pun/2025 निर्धारण वषा / Assessment Year: 2018-19 Mr.Harivijay Prahlad Joshi, V The Income Tax 3 & 4, Megh Terrace 55 S Officer, Rambaug, Colony, Behind Ward-3(3), Pune. Chaitanya Health Club, Kothrud, Pune – 411038. Pan: Aappj9257M Appellant/ Assessee Respondent /Revenue Assessee By Shri Piyush Bafna Revenue By Smt Neha Thakkar – (Virtual) On Rotation Duty Date Of Hearing 22/01/2026 Date Of Pronouncement 27/01/2026 आदेश/ Order Per Dr. Dipak P. Ripote, Am: This Is An 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 The A.Y.2018-19 Dated 14.11.2024 Emanating From The Assessment Order Passed Under

147 r.w.s. 144 of the Act is bad in law inasmuch as the purported sanction granted by the Pr. CIT-2, Pune under section 151 of the Act was never provided to the Appellant neither along with notice u/s 148 or during the course of reassessment proceedings, which is mandatory and ought to have been provided