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

section 147 to 151A and, therefore the said assessment order may please be quashed. 3. On the facts and in the circumstances of the case and in law, Ld. NFAC has erred in upholding the illegal order passed by the Ld. NaFAC since the Notice u/s 148 dated 04-04-2022 was issued by Jurisdictional Assessing Officer (ITO Ward

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 of the Act ("reassessment order") are bad-in-law on account of failure to satisfy jurisdictional requirements under section 147 to 151A

MOTIWALA AUTO PVT. LTD.,AURANGABAD vs. ITO, WARD1(1), AURANABAD, AURANGABAD

In the result, the appeal of the assessee is allowed

147 rws 144\nby the AO and there are issues which need to be further examined and\ninvestigated by the AO. In view of the above facts and changes in the Act, as\nenumerated above, in my considered opinion the submissions filed by the\nappellant in the appellate proceedings, are germane to the correct appreciation of\nthe issues under deliberation

KAY POWER AND PAPER LIMITED,SATARA vs. INCOME TAX OFFICER, WARD-2, SATARA

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

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

reassessment then the same would equally apply for issuance of notice under Section 148 of the Act. (iii) The conclusion at the bottom of page 2 in paragraph 3 of the Office Memorandum that "Therefore, as provided in the scheme the notice under section 148 of the Act is issued on automated allocation of cases to the Assessing Officer based

KAY POWER AND PAPER LIMITED,SATARA vs. INCOME TAX OFFICER, WARD-2, SATARA

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

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

reassessment then the same would equally apply for issuance of notice under Section 148 of the Act. (iii) The conclusion at the bottom of page 2 in paragraph 3 of the Office Memorandum that "Therefore, as provided in the scheme the notice under section 148 of the Act is issued on automated allocation of cases to the Assessing Officer based

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

151A of the Act read with the Scheme dated 29th March 2022, without properly interpreting the scope provided in Sec. 144B of the Income Tax Act, 1961 and the context in which it was used in the Scheme notified by the CBDT on 28th March 2022. 3) On the facts and circumstances of the case

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

RAJESH BABURAO SHINDE,PARBHANI vs. ITO, WARD- HINGOLI, HINGOLI

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

Bench: Shri R. K. Panda & Shri Vinay Bhamoreआयकर अपील सं. / Ita No.781/Pun/2025 िनधा"रण वष" / Assessment Year : 2015-16 Rajesh Baburao Shinde, Vs. Assessment Unit, Income Sayala Khating, Tq. Dist. Tax Department, Nfac, Parbhani- 431402. Delhi. Pan : Czcps6546Q Appellant Respondent Assessee By : Shri Shubham N. Rathi Revenue By : Shri Akhilesh Srivastva Date Of Hearing : 22.07.2025 Date Of Pronouncement 12.08.2025 : आदेश / Order Per Vinay Bhamore, Jm: This Appeal Filed By The Assessee Is Directed Against The Order Dated 18.07.2024 Passed By Ld. Cit(A)/Nfac For The Assessment Year 2015-16. 2. There Is Delay In Filing Of The Present Appeal. We Are Satisfied With The Reasons Mentioned In The Affidavit For Condonation That The Applicant Was Prevented By Sufficient Cause For Not Filing The Appeal Within The Prescribed Time Limit. After

reassessment proceedings. Therefore, notice issued u/s 148 and the consequential assessment order passed is illegal and deserves to be quashed. WITHOUT PREJUDICE TO ABOVE 2. THE NOTICE U/S 148 IS NOT IN ACCORDANCE WITH THE PROVISIONS OF SECTION 151A 2.1 The Ld. JAO has erred in assuming the jurisdiction to issue the notice u/s 148 which is in non-compliance

MR SHAIKH SHAKIL SHAIKH IBRAHIM BAGWAN,JALGAON vs. ITO, WRD-1(4), JALGAON, JALGAON

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

Bench: Dr. Manish Borad & Shri Vinay Bhamoreआयकर अपील सं. / Ita No.2160/Pun/2025 धििाारण वर्ा / Assessment Year: 2017-18 Mr. Shaikh Shakil Shaikh Vs Ito, Ward-1(4), Ibrahim Bagwan, Jalgaon Prop. Of Javed Vegetable Company (Jvc), Barbhai Galli, Bodwad-425310, Dist-Jalgaon Maharashtra Pan-Attpb3077C Appellant Respondent

reassessment proceedings as per the provisions of section 151A and scheme framed u/s 151A of the Act. 4 8. We however on going through the grounds of appeal observe that in ground No. 4, assessee has mentioned that Ld. CIT(A) has not adjudicated the following 3 grounds raised before Ld. CIT(A) and duly mentioned in Form

SWAMINATH BABURAO PATIL,SOLAPUR vs. ITO WARD 2(3) SOLAPUR, SOLAPUR

In the result, appeal of the Assessee is allowed for statistical purpose

Bench: Ms.Astha Chandra & Dr.Dipak P. Ripoteआयकर अपऩल सं. / Ita No.832/Pun/2025 निर्धारण वषा / Assessment Year: 2014-15 Swaminath Baburao Patil, V The Income Tax Officer, C37, Siddheshwar Market S Ward-2(3), Solapur. Yard, Hyderabad Road, Solapur – 431005. Maharashtra. Pan: Akwpp4321P Appellant/ Assessee Respondent / Revenue Assessee By Shri Girish Ladda Revenue By Shri Ambarnath Khule (Through Virtual Hearing) – Jcit(Dr) Date Of Hearing 24/11/2025 Date Of Pronouncement 25/11/2025 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.2014-15 Dated 27.01.2025 Emanating From The Assessment Order Passed Under Section 147 R.W.S 144B Of The Act, Dated 19.05.2023. The Assessee Has Raised The Following Grounds Of Appeal :

reassessment order passed u/s 147 may please be quashed being passed without issue of statutory Notice u/s 143(2) of Income Tax Act even when the appellant filed a Return of Income on 03/02/2023 vide Acknowledgment Number 947198020030223. Non-issuance of the Statutory Notice u/s 143(2) is a jurisdictional defect not curable u/s 292BB. 3) Proceedings u/s 148 invalid

DR HEDGEWAR SMRUTI RUGNA SEVA MANDIR, HINGOLIE,HINGOLI vs. DCIT, CIR-AURANGABAD, AURANGABAD

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

Bench: Dr. Manish Boradआयकर अपील सं. / Ita No.1531/Pun/2025 धििाारण वर्ा / Assessment Year: 2019-2020 Vs Dcit Dr Hedgewar Smruti Rugna Seva Mandal, 01 Exemption Akola Road, Hingoli S.O Circle, Basamba, Hingoli-431513 Aurangabad Maharashtra Pan-Aabtd5118M Appellant Respondent

section 151A of ITA, 1961, notice u/s 148 of ITA, 1961 ought to have been issued by National Faceless Assessment Center (NFAC) and not by JAO and the same has also been upheld in the pronouncement in case of Hexaware Technologies Limited v/s ACIT (Bombay HC-162 taxmann.com 225). As such, the appellant contends that the present reassessment proceedings

ANWAR HUSAIN MEHBOOB SHAIKH,JALGAON vs. INCOME TAX OFFICER, JALGAON

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

Bench: Dr.Dipak P. Ripote & Shri Vinay Bhamoreआयकर अपऩल सं. / Ita No.2561/Pun/2025 निर्धारण वषा / Assessment Year: 2018-19 Anwar Husain Mehboob V The Income Tax Officer, Shaikh, S Jalgaon. H. No.K 258/I Railway North Area, Bhusawal, Jalgaon – 425201. Pan: Bodps9742F Appellant/ Assessee Respondent / Revenue Assessee By None Revenue By Shri Sandeep Sathe - Dr Date Of Hearing 10/12/2025 Date Of Pronouncement 12/12/2025 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 21.08.2025 Emanating From The Assessment Order Passed Under Section 147 R.W.S 144 Of The Act, Dated 31.01.2024. The Assessee Has Raised The Following Grounds Of Appeal :

reassessment of income for the AY 2018-19 was wrongly issued by the Jurisdictional Assessing Officer instead of Faceless Assessing Officer. 2. That the Jurisdictional AO has excess is authority by issuing notice under section 148 of the Act. 3. That the notice issued under section 148 violates the section 151A

PRADEEP MADHUKAR THOMBARE,AURANGABAD vs. ITO WARD-1(5), AURANGABAD

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

Bench: Dr.Dipak P. Ripote & Shri Vinay Bhamoreआयकर अपऩल सं. / Ita No.3237/Pun/2025 निर्धारण वषा / Assessment Year: 2016-17 Pradeep Madhukar Thombre, V The Income Tax Officer, 101, Padmini Niwas, Prashant S Ward-1(5), Aurangabad. Nagar, Ambajogai – 431517. Pan: Aappt7315L Appellant/ Assessee Respondent /Revenue Assessee By Shri Shubham N Rathi (Virtual) Revenue By Shri Sadananda – Jcit(Dr) Date Of Hearing 10/02/2026 Date Of Pronouncement 11/02/2026

reassessment proceedings in the present case is without jurisdiction WITHOUT PREJUDICE TO THE ABOVE 3. NOTICE U/S 143(2) OF THE ACT IS NOT ISSUED/SERVED ITA No.3237/PUN/2025 [A] 3.1 The Ld. CIT(A) erred in not considering the ground of challenge to an assessment order u/s 147 r.w.s. 144B passed without issuing statutory notice u/s

SHAHBAZ MOHAMMED SHAFEEQUE,MALEGAON vs. INCOME TAX OFFICER, WARD - 1, MALEGAON

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

Bench: Ms.Astha Chandra & Dr.Dipak P. Ripoteआयकर अपऩल सं. / Ita No.2291/Pun/2025 निर्धारण वषा / Assessment Year: 2015-16 Shahbaz Mohammed V The Income Tax Officer, Shafeeque, S. Ward-1, Malegaon. House No.904, Lane No.2, Malegaon City S.O., Malegaon, Nashik, Malegaon – 423203. Maharashtra. Pan: Cfppm6844A Appellant/ Assessee Respondent / Revenue Assessee By Shri Sanket Joshi (Virtual) Revenue By Smt Saumya Pandey Jain-Addl.Cit Date Of Hearing 20/11/2025 Date Of Pronouncement 20/11/2025 आदेश/ Order Per Dr. Dipak P. Ripote, Am: In This Case, Appeal Has Been Filed By The Assessee Against The Order Of Ld.Commisioner Of Income Tax(Appeal)[Nfac] Passed Under Section 250 Of The Income Tax Act, 1961 For The A.Y.2015-16 Dated 28.02.2025. The Assessee Has Raised The Following Grounds Of Appeal :

147 r.w.s 144 of the Act on 23/05/2023 by the AO which was served electronically (on email) on the same day. Accordingly, this appeal is delayed by 126 days for which the assessee has failed to submit sufficient cause for delay as per section 249(3) of the Act. Therefore, I am satisfied that the appellant 3 ITA No.2291/PUN/2025

PRADEEP JANARDHAN SAKHARE,SAMBHAJINAGAR vs. ITO, WARD-1(A), AURANGABAD, AURANGABAD

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

Bench: Shri R.K. Panda & Ms. Astha Chandraआयकर अपील सं. / Ita No.2509/Pun/2025 धििाारण वर्ा / Assessment Year : 2018-19 Pradeep Janardhan Sakhare, Ito, Ward – 1(1), Ashay Regency, Flat No. 9, Aurangabad New Vishal Nagar, Chh. Sambhajinagar, Vs. Maharashtra-431001 Pan : Bobps8283M अपीलार्थी / Appellant प्रत्यर्थी / Respondent Assessee By : Shri Shubham N. Rathi (Virtual) Department By : Smt. Indira R. Adakil Date Of Hearing : 04-12-2025 Date Of 18-12-2025 Pronouncement : आदेश / Order Per Astha Chandra, Jm : The Appeal Filed By The Assessee Is Directed Against The Order Dated 26.09.2025 Of The Ld. Commissioner Of Income Tax (Appeals), Nfac, Delhi [“Cit(A)/Nfac”] Pertaining To Assessment Year (“Ay”) 2018-19. 2. Briefly Stated The Facts Are That The Assessee Is An Individual. For Ay 2018-19, The Assessee Filed His Return Of Income Declaring Income Of Rs.3,17,830/-. Based On The Information Received From The Insight Portal Under „High Risk Criu/Vru Information‟, It Was Found That The Assessee Has Done Transaction In Crypto Currency Of Rs.38,54,500/-, The Source Of Which Requires Verification & Also There Were Unexplained Credit Entries Aggregating To Rs.40,44,044/-. As The Assessee Failed To Disclose The Above Transaction In The Itr Filed For The Ay 2018-19, The Ld. Assessing Officer (“Ao”) Had Reason To Believe That The Above Income In Ay 2018-19 Has Escaped Assessment. Accordingly, The Case Of The Assessee Was Reopened U/S 147 By Issue Of Notice U/S 148 Of The Income Tax Act, 1961 (The “Act”) Dated 07.04.2022. In Response Thereto, The Assessee Filed His Return Of Income On 09.06.2023. Statutory Notice(S) U/S 142(1) & 144 Were Then Issued To The Assessee. As The Assessee Failed To File Any Compliance

147 r.w.s. 144 r.w.s. 144B of the Act thereby making an addition of Rs.38,54,500/- on account of unexplained investments in crypto currency u/s 69B and credit entries of RS.40,44,044/- as unexplained money u/s 69A of the Act, to the returned income of Rs.3,17,830/-. 3. Aggrieved, the assessee filed an appeal before

MANDA SHANTARAM GARADE,TALEGAON DABHADE vs. INCOME TAX OFFICER 9(3), AKURDI

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

Bench: Ms.Astha Chandra & Dr.Dipak P. Ripoteआयकर अपऩल सं. / Ita No.1343/Pun/2025 निर्धारण वषा / Assessment Year: 2019-20 Manda Shantaram Garade, V The Assessing Officer, 66, Dhamane Gavthan, Near S Ward-9(3), Pune. Padmavati Mandir, Talegaon, Maharashtra – 410506. Pan: Bjcpg4762K Appellant/ Assessee Respondent / Revenue Assessee By Shri Nishit Gandhi(Virtual), Aadnya Bhandari(Present In Itat Pune Bench) Revenue By Shri Ramnath P Murkunde – Cit(Dr) Date Of Hearing 18/09/2025 Date Of Pronouncement 19/09/2025 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 Dated 26.03.2025 For The A.Y.2019-20 Emanating From The Assessment Order Passed Under Section 147 R.W.S 144 Read With Section 144B Of The Income Tax Act

REASSESSMENT: 1.1 In the facts and circumstances of the case and in law, the Learned Commissioner of Income Tax (Appeals), National Faceless Appeals Centre ["Ld. CIT(A)" for short) erred in confirming the re-assessment order u/s 144 r.w.s. 147 of the Income Tax Act, 1961 ["the Act" for short] passed by the Learned Income Tax Officer-9 (3), Pune

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

VIJAYMALA VILAS KALOKHE,PUNE vs. ITO WARD-10(1), PUNE

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

Bench: Shri R.K. Panda & Ms. Astha Chandraआयकर अपील सं. / Ita No.1666/Pun/2025 धििाारण वर्ा / Assessment Year : 2013-14 Vijaymala Vilas Kalokhe, Ito, Ward-10(1), Pune Aditya Row House, Lane No. 2, Opp. Patel Garden, Sr. No. 8/2A, Vs. Juni Sangavi, Maharashtra-411027 Pan : Asepk8161G अपीलार्थी / Appellant प्रत्यर्थी / Respondent Assessee By : Shri Kishor B Phadke Department By : Shri Amit Bobde Date Of Hearing : 28-01-2026 Date Of 30-01-2026 Pronouncement : आदेश / Order Per Astha Chandra, Jm : The Appeal Filed By The Assessee Is Directed Against The Order Dated 17.06.2025 Of The Ld. Commissioner Of Income Tax (Appeals)/Nfac, Delhi [“Cit(A)/Nfac”] Pertaining To Assessment Year (“Ay”) 2013-14. 2. Briefly Stated The Facts Are That The Assessee Is An Individual. He Filed His Return Of Income For Ay 2013-14 Declaring Total Income Of Rs.2,21,050/-. The Case Of The Assessee Was Reopened U/S 147 Of The Income Tax Act, 1961 (The “Act”) After Following The Mandate Procedure As Laid Down Under The Relevant Provisions Of The Act. Accordingly, Statutory Notice U/S 142(1) Of The Act & Show Cause Letter(S) Were Issued To The Assessee From Time To Time. However, The Assessee Failed To File Any Response To The Said Notice(S) Which Constrained The Ld. Assessing Officer (“Ao”) To Pass An Ex-Parte Order U/S 144 Of The Act Based On The Material Available On Record. The Ld. Ao Proceeded To Complete The Assessment On Total Income Of Rs.2,66,70,989/-U/S 147 R.W.S. 144 Of The Act Thereby Making An Addition Of Rs.2,63,83,209/- On Account Of Undisclosed Long Term Capital Gain (Ltcg) By Observing As Under : “5.1. On-Going Through The Information Available On Record & In View Of The Order Passed U/S 148A(D) Of The Act Dated 21.07.2022, It Is Noticed That 2

147 r.w.s 144 r.wis 1448 of the ITA, 1961 dated 25/05/2023 without bearing a Document Identification Number" (DIN) on notice u/s 148 dated 21/07/2022 despite the circular no. 19/2019 dated 14th August 2019 which made it mandatory for all Income Tax Authorities to allot "DIN" for communications relating to assessments, appeals, orders etc. from 1st October 2019. As such

BHARAT SHIVAJI CHAVAN,SONARSIDDHNAGAR vs. ITO WARD 5, SANGLI, SANGLI

In the result, appeal of the Assessee is partly allowed

Bench: Dr.Dipak P. Ripote & Shri Vinay Bhamoreआयकर अपील सं. / Ita No.876/Pun/2025 िनधा"रण वष" / Assessment Year: 2013-14 Bharat Shivaji Chavan, V The Income Tax Officer, At Sonarsiddhnagar, Post S Ward-5, Sangli. Kowthali, Tal Atpadi, District Solapur, Kotali – 413101. Maharashtra. Pan: Auwpc0996M Appellant/ Assessee Respondent / Revenue Assessee By Shri Piyush Bafna & Shri Aakash Parakh – Ar’S Revenue By Shri Rajesh Haladkar – Addl.Cit(Dr) Date Of Hearing 25/06/2025 Date Of Pronouncement 26/06/2025 आदेश/ Order Per Dr. Dipak P. Ripote, Am: This Appeal Filed By The Assessee Is Directed Against The Order Of Ld.Commissioner Of Income Tax(Appeals)[Nfac] Passed Under Section 250 Of The Income Tax Act, 1961, Dated 30.01.2025 Emanating From The Assessment Order Passed U/S.144 R.W.S 147 Of The Income Tax Act, 1961, For A.Y.2013-14 Dated 25.03.2022. The Assessee Has Raised Following Grounds Of Appeal :

151A and, therefore the said assessment order may please be quashed. 5. On the Facts and circumstances of the case and in law, the learned Assessing Officer erred in reopening the assessment beyond 4 years especially when allmaterial facts were disclosed in the return of income, therefore the action of reopening is void-ab-initio and deserves to be struck