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

reassessment under Sections 139, 147, 148, 149, 151 & 153. 28. The language of explanation 2 to new Section 148 is akin to Section 153A and Section 153C. Corollary being that after seizing of operational 18 February, 2025 WP3057_2019.DOC period of Section 153A to 153D, the cases being dealt thereunder were circumscribed in the scope of newly substituted Section

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

reassessment under Sections 139, 147, 148, 149, 151 & 153.\n28. The language of explanation 2 to new Section 148 is akin to Section\n153A and Section 153C. Corollary being that after seizing of\noperational 18 February, 2025 WP3057_2019.DOC period of Section\n153A to 153D, the cases being dealt thereunder were circumscribed in the\nscope of newly substituted Section

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

reassess such income and also any\nother income chargeable to tax which has escaped assessment and which comes to\nhis notice subsequently in the course of the proceedings under section 147 of the\nAct\n28.1 The first proviso to section 147 is important. As per this proviso, where an\nassessment under subsection (3) of section 143 or section 147

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

reassess such income and also any\nother income chargeable to tax which has escaped assessment and which comes to\nhis notice subsequently in the course of the proceedings under section 147 of the\nAct\n28.1 The first proviso to section 147 is important. As per this proviso, where an\nassessment under subsection (3) of section 143 or section 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

147, section 148, section 149, section 151 and section 153, where the Assessing Officer is satisfied that,— (a) any money, bullion, jewellery or other valuable article or thing, seized or requisitioned, belongs to; or (b) any books of account or documents, seized or requisitioned, pertains or pertain to, or any information contained therein, relates to, a person other than

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

147, section 148, section 149, section 151 and section 153, where the Assessing Officer is satisfied that,— (a) any money, bullion, jewellery or other valuable article or thing, seized or requisitioned, belongs to; or (b) any books of account or documents, seized or requisitioned, pertains or pertain to, or any information contained therein, relates to, a person other than

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

147, section 148, section 149, section 151 and section 153, where the Assessing Officer is satisfied that,— (a) any money, bullion, jewellery or other valuable article or thing, seized or requisitioned, belongs to; or (b) any books of account or documents, seized or requisitioned, pertains or pertain to, or any information contained therein, relates to, a person other than

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

147, section 148, section 149, section 151 and section 153, where the Assessing Officer is satisfied that,— (a) any money, bullion, jewellery or other valuable article or thing, seized or requisitioned, belongs to; or (b) any books of account or documents, seized or requisitioned, pertains or pertain to, or any information contained therein, relates to, a person other than

SOMNATH RAMDAS JADHAV,AHMEDNAGAR vs. ITO WARD 2, AHMEDNAGAR

In the result, the appeal filed by the assessee in ITA\nNo

2(a) to Section 147 of the Income Tax\nAct, 1961.\n6.5 There is no dispute that appellant had maintained an account\nwith Shri Renuka Matha Multi-State Urban Co-operative Credit\nSociety Ltd. and deposited huge amount of cash into that account.\nHowever, upon verification, it is noticed that he did not file any return\nof income

SOMNATH RAMDAS JADHAV,AHMEDNAGAR vs. ITO WARD 2, AHMEDNAGAR, AHMEDNAGAR

In the result, the appeal filed by the assessee in ITA\nNo

2(a) to Section 147 of the Income Tax\nAct, 1961.\n6.5 There is no dispute that appellant had maintained an account\nwith Shri Renuka Matha Multi-State Urban Co-operative Credit\nSociety Ltd. and deposited huge amount of cash into that account.\nHowever, upon verification, it is noticed that he did not file any return\nof income

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

147 after the expiry of one year from the end of the financial year in which the notice under section 148 was served.” 19. On perusal of sub-section (2) of section 153 of the Act explains that no order of assessment, reassessment or recomputation shall be made u/s

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

147 after the expiry of one year from the end of the financial year in which the notice under section 148 was served.” 19. On perusal of sub-section (2) of section 153 of the Act explains that no order of assessment, reassessment or recomputation shall be made u/s

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

147, section 148, section 149, section 151 and section 153, where the Assessing Officer is satisfied that,— (a) any money, bullion, jewellery or other valuable article or thing, seized or requisitioned, belongs to; or (b) any books of account or documents, seized or requisitioned, pertains or pertain to, or any information contained therein, relates to, a person other than

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

2] The respondent company further submits that the reasons recorded for reopening the case are not correct and the reopening is on reason to suspect and not reason to believe and hence, the reopening u/s 148 is bad in law. 3] The respondent further submits that no approval u/s 151 has been brought on record and therefore, in the absence

VIJAYKUMAR MANGILALJI CHORDIYA,NASHIK vs. NATIONAL FACELESS ASSESSMENT CENTRE, DELHI

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

Bench: Shri R. K. Panda & Shri S.S. Godaraassessment Year : 2013-14

147, section 148, section 149, section 151 and section 153, where the Assessing Officer is satisfied that,— (a) any money, bullion, jewellery or other valuable article or thing, seized or requisitioned, belongs to; or (b) any books of account or documents, seized or requisitioned, pertains or pertain to, or any information contained therein, relates to, a person other than

ATUL VIJAY MADAN ,NASHIK vs. DCIT, CIRCLE -1, NASHIK

In the result, appeal of the assessee is allowed

Bench: Dr.Dipak P. Ripote & Shri Vinay Bhamoreआयकर अपील सं. / Ita No.1529/Pun/2024 िनधा"रण वष" / Assessment Year: 2012-13 Atul Vijay Madan, V The Dcit, 2 Pooja Apartment, Behind S Circle-1, Nashik. Karwa Mangal Karyalay, Sharanpur Road, Nashik-422002. Maharashtra. Pan: Appellant/ Assessee Respondent / Revenue Assessee By Shri Sanket M Joshi – Ar Revenue By Shri Ramnath P Murkunde– Dr Date Of Hearing 23/04/2025 Date Of Pronouncement 07/05/2025 आदेश/ Order Per Dr. Dipak P. Ripote, Am: This Appeal Filed By The Assessee Is Against The Order Of Ld.Commissioner Of Income Tax(Appeals)[Nfac], Passed Under Section 250 Of The Income Tax Act, 1961; Dated 13.05.2024 For Assessment Year 2012-13. The Assessee Has Raised The Following Grounds Of Appeal : “1. The Learned Cit(A) Erred In Confirming The Addition Of Rs.45,00,000 Made By The A.O. U/S 69 Towards Alleged Unexplained Loan

2. On verification of the sathe Khat agreement and purchase deed there is difference of Rs. 33 lacs which was paid in cash by Mr. Ramzan Kokani to the sellers of the land. In view of the above it is appears that Mr. Ramzan Kokani received loan of Rs. 45 lacs in cash from Mr. Atul Vijay Madan during

DEPUTY COMMISSIONER OF INCOME-TAX vs. SHRI MANSUKH T. TIMBADIA,, RAIGAD

In the result, appeal of assessee is allowed and the appeal of Revenue is dismissed

Bench: Shri S.S. Viswanethra Ravi & Shri G.D. Padmahshali

section saves the AO in a case where the notice issued and there is a discrepancy as regards the service of the notice. 6. The ld. DR, Shri Sardar Singh Meena submits that the said assessment reopened on an intimation received from Central Circle and the AO issued notice u/s. 148 of the Act on 12-06-2012 which

MANSUKH TIMBADIA,,RAIGAD vs. ASSISTANT COMMISSIONER OF INCOME-TAX,,

In the result, appeal of assessee is allowed and the appeal of Revenue is dismissed

Bench: Shri S.S. Viswanethra Ravi & Shri G.D. Padmahshali

section saves the AO in a case where the notice issued and there is a discrepancy as regards the service of the notice. 6. The ld. DR, Shri Sardar Singh Meena submits that the said assessment reopened on an intimation received from Central Circle and the AO issued notice u/s. 148 of the Act on 12-06-2012 which

INCOME TAX OFFICER, WARD-1, JALNA, JALNA vs. ASHISH OMPRAKASH MANTRI, JALNA

In the result, all the appeals filed by the Revenue are dismissed

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

153 taxmann.com 578 (Allahabad), he submitted that the Hon’ble High Court in the said decision has held that where AO disallowed exemption claimed by assessee under section 10(38) and made additions, alleging involvement in penny stock which were being misused for providing bogus accommodation of LTCG, however, there was lack of adverse comments from stock exchange and officials