INCOME TAX OFFICER, PUNE vs. SAGAR CONSTRUCTION COMPANY, PUNE

In the result, the appeal filed by the Revenue is dismissed and the CO filed by the assessee is allowed

Bench: Shri R. K. Panda & Ms. Astha Chandraassessment Year : 2017-18

15. As the controversy revolves around the applicability of Section 153A and more particularly, as to whether Section 153A read with Section 153C vis- a-vis the provisions of Section 147 of the I.T. Act, it will be appropriate to extract the said provisions, which reads thus: "147. Income escaping assessment.--If the Assessing Officer has reason to believe that

ASHOK DHANRAJ CHORDIA ,PUNE vs. PCIT, PUNE-1, PUNE

15-11-2021 and the learned AO has also\ngiven finding to that effect vide order dated 13-12-2021.\n5.\nThe appellant craves leave to add, alter, clarify, explain, modify, delete any\nof the grounds of appeal, and to seek any just and fair relief.\n8.\nThe assessee has also raised the following additional grounds:\n6.\nLearned PCIT

SATISH VISHNU THOMBARE, INCOME TAX OFFICER, WARD-1, AHMEDNAGAR, AHMEDNAGAR vs. VARSHA PRAFULLA ZENDE, AHMEDNAGAR

In the result, the appeal of the Revenue is dismissed

Bench: Shri R.K. Panda & Ms. Astha Chandraआयकर अपील सं. / Ita No.1656/Pun/2024 धििाारण वर्ा / Assessment Year : 2010-11 Satish Vishnu Thombare, Varsha Prafulla Zende, Income Tax Officer, Prop Of Bleach Chem Enterprises, Ward-1, Ahmednagar Vs. Industrial Estate, Shrirampur, Maharashtra-413709 Pan : Aabpz2541C अपीलार्थी / Appellant प्रत्यर्थी / Respondent Assessee By : Miss Shivani Shah (Virtual) Department By : Shri Akhilesh Srivastva Date Of Hearing : 06-08-2025 Date Of 29-10-2025 Pronouncement : आदेश / Order

reassess such income and also any other income chargeable to tax, which has escaped assessment and which comes to his notice subsequently in the course of the proceedings under the section. The first proviso to section 147 has no application in the facts of this case. The basic postulate which underlines section 147 is the formation of the belief

SHRI SHANTINATH BHAGWAN JAIN SHWETAMBAR MURTIPUJAK SANGH,PUNE vs. CIT, EXEMPTION,, PUNE

Appeal is allowed

Bench: Shri S.S. Godara & Shri G.D. Padmahshali

u/s. 263 of the Income Tax Act, 1961; in short “the Act”. Heard both the parties. Case file perused. 2 ITA No.203/PUN/2021, A.Y. 2010-11 2. It emerges at the outset that the CIT(E)’s impugned order exercising section 263 revision jurisdiction terms the corresponding assessment /reassessment herein dated 29-09-2017 as an erroneous one causing prejudice

SHRI MANOJ MADANLAL CHHAJED,PUNE vs. THE ASSISTANT COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-1(1), PUNE

Section 80IA/IB of the Act.\nIt must follow that there is due application of mind by the Assessing\nOfficer to the issue raised.\nThe above observations apply on all fours to this Petition, so far as the\nRevenue's submission of no change of opinion is concerned.\n11. The further submission of Mr. Walve that in the absence

M/S. RAJLAXMI PETROCHEM PVT.LTD,,LATUR vs. INCOME-TAX OFFICER, WARD - 1,, LATUR

Appeals are allowed in above terms

Bench: Shri Satbeer Singh Godara & Dr. Dipak P. Ripote

u/s. 263 of the Income Tax Act, 1961 (in short "the Act"). 2. Heard both the parties. Case files perused. 3. It emerges during the course of hearing that relevant facts in assessee’s former twin appeals hardly require us to delve deeper in the relevant factual matrix so far as its first and foremost substantive grievance challenging correctness

M/S. RAJLAXMI PETROCHEM PVT.LTD,,LATUR vs. PRINCIPAL COMMISSIONER OF INCOME-TAX, , NASHIK

Appeals are allowed in above terms

Bench: Shri Satbeer Singh Godara & Dr. Dipak P. Ripote

u/s. 263 of the Income Tax Act, 1961 (in short "the Act"). 2. Heard both the parties. Case files perused. 3. It emerges during the course of hearing that relevant facts in assessee’s former twin appeals hardly require us to delve deeper in the relevant factual matrix so far as its first and foremost substantive grievance challenging correctness

M/S. RAJLAXMI PETROCHEM PVT.LTD,,LATUR vs. INCOME-TAX OFFICER, WARD - 1,, LATUR

Appeals are allowed in above terms

Bench: Shri Satbeer Singh Godara & Dr. Dipak P. Ripote

u/s. 263 of the Income Tax Act, 1961 (in short "the Act"). 2. Heard both the parties. Case files perused. 3. It emerges during the course of hearing that relevant facts in assessee’s former twin appeals hardly require us to delve deeper in the relevant factual matrix so far as its first and foremost substantive grievance challenging correctness

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

section 147 of the Act. Since admittedly the Assessing Officer in the instant case has reopened the assessment on the basis of information that emerged at the time of search action u/s 132 of the Act at the premises of M/s. Shri Renuka Mata Multistate Credit Society Ltd.. Therefore, we hold that the initiation of proceedings u/s 147

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

section 147 of the Act. Since admittedly the Assessing Officer in the instant case has reopened the assessment on the basis of information that emerged at the time of search action u/s 132 of the Act at the premises of M/s. Shri Renuka Mata Multistate Credit Society Ltd.. Therefore, we hold that the initiation of proceedings u/s 147

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

section 147 of the Act. Since admittedly the Assessing Officer in the instant case has reopened the assessment on the basis of information that emerged at the time of search action u/s 132 of the Act at the premises of M/s. Shri Renuka Mata Multistate Credit Society Ltd.. Therefore, we hold that the initiation of proceedings u/s 147

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

section 147 of the Act. Since admittedly the Assessing Officer in the instant case has reopened the assessment on the basis of information that emerged at the time of search action u/s 132 of the Act at the premises of M/s. Shri Renuka Mata Multistate Credit Society Ltd.. Therefore, we hold that the initiation of proceedings u/s 147

INCOME TAX OFFICER,WARD-1,AHMEDNAGAR, AHMEDNAGAR vs. NARENDRA SAMPATLAL BAFNA, AHMEDNAGAR

In the result, the appeal filed by the Revenue and the CO filed by the assessee are dismissed

Bench: Shri R. K. Panda & Shri Vinay Bhamoreassessment Year : 2017-18

15. The Ld. DR in his rejoinder drew the attention of the Bench to the provisions of section 250(4) of the Act and submitted that as per the said provisions, the CIT(A) may, before disposing of any appeal, make such further enquiry as he thinks fit or may direct the Assessing Officer to make further enquiry and report

CLARION TECHNOLOGIES PVT. LTD.,,PUNE vs. DEPUTY COMMISSIONER OF INCOME-TAX,,

In the result, the appeal of assessee is allowed

Bench: Shri R.S. Syal & Shri S.S. Viswanethra Ravi

u/s. 147 of the Act and the said material itself constitutes a belief that there is an escaped assessment. 14. The Hon‟ble High Court of Andhra Pradesh in the case of Novapan India Ltd. (supra) answered the question “Whether, on the facts and in the circumstances of the case, the ITAT is justified in upholding the CIT(A) orders

DEPUTY COMMISSIONER OF INCOME-TAX vs. CLARION TECHNOLOGIES PVT. LTD.,, PUNE

In the result, the appeal of assessee is allowed

Bench: Shri R.S. Syal & Shri S.S. Viswanethra Ravi

u/s. 147 of the Act and the said material itself constitutes a belief that there is an escaped assessment. 14. The Hon‟ble High Court of Andhra Pradesh in the case of Novapan India Ltd. (supra) answered the question “Whether, on the facts and in the circumstances of the case, the ITAT is justified in upholding the CIT(A) orders

RAJARSHI SHAHU SHIKSHAN SANSTHA INAM DHAMANI,SANGLI vs. ITO EXEMPTION, KOLHAPUR

In the result, all the appeals filed by the assessee are partly allowed as per terms indicated hereinabove

Bench: Dr.Manish Borad & Shri Vinay Bhamoreआयकर अपील सं. / Ita Nos.1121 To 1126/Pun/2024 Assessment Years : 2012-13 To 2017-18

15. Contention-4-Approval: As per facts, the approval availed by learned AO was for proposed taxation of donations u/s 68 of the ITA, 1961. As against, the final taxation is u/s 115BBC. Per se, no approval is sought for taxation u/s 148 for the said Section 115BBC. As an effect, it transpires that, the entire taxation made by learned

RAJARSHI SHAHU SHIKSHAN SANSTHA INAM DHAMANI,SANGLI vs. ITO EXEMPTION, KOLHAPUR, KOLHAPUR

In the result, all the appeals filed by the assessee are partly allowed as per terms indicated hereinabove

Bench: Dr.Manish Borad & Shri Vinay Bhamoreआयकर अपील सं. / Ita Nos.1121 To 1126/Pun/2024 Assessment Years : 2012-13 To 2017-18

15. Contention-4-Approval: As per facts, the approval availed by learned AO was for proposed taxation of donations u/s 68 of the ITA, 1961. As against, the final taxation is u/s 115BBC. Per se, no approval is sought for taxation u/s 148 for the said Section 115BBC. As an effect, it transpires that, the entire taxation made by learned

RAJARSHI SHAHU SHIKSHAN SANSTHA INAM DHAMANI,SANGLI vs. ITO EXEMPTION, KOLHAPUR, KOLHAPUR

In the result, all the appeals filed by the assessee are partly allowed as per terms indicated hereinabove

Bench: Dr.Manish Borad & Shri Vinay Bhamoreआयकर अपील सं. / Ita Nos.1121 To 1126/Pun/2024 Assessment Years : 2012-13 To 2017-18

15. Contention-4-Approval: As per facts, the approval availed by learned AO was for proposed taxation of donations u/s 68 of the ITA, 1961. As against, the final taxation is u/s 115BBC. Per se, no approval is sought for taxation u/s 148 for the said Section 115BBC. As an effect, it transpires that, the entire taxation made by learned

A.C.I.T ,WARDHA CIRCLE , WARDHA , WARDHA vs. M/S KAPIL SOLVEX PVT .LTD , YAVATMAL

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

Bench: Shri R. K. Panda & Ms Astha Chandraassessment Year : 2009-10

section that the reasons which induced the CIT to accord sanction to proceed u/s 34 must also be communicated to the assessee and "the requirement regarding communication of the reasons to the Commissioner is, in our opinion, intended to safeguard the Interests of the assessee against any hasty action on the part of the ITO u/s 34 or an action