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

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

153C. (1) Notwithstanding anything contained in section 139, section 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

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

153C. (1) Notwithstanding anything contained in section 139, section 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

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

153C. (1) Notwithstanding anything contained in section 139, section 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

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

153C. (1) Notwithstanding anything contained in section 139, section 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

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

153C. (1) Notwithstanding anything contained in section 139, section 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

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

2% on the amount of accommodation entry\ntaken of Rs.10,42,46,373/-, which comes to Rs.20,84,927/-. The same is also\nrequired to be added to the total income of the assessee.\n6.4 Interest Expenditure claimed thereon:\nFurther, it was also observed that the assessee has claimed interest expenditure on\nthese accommodation loan entries in its ITR returns

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

2% on the amount of accommodation entry\ntaken of Rs.10,42,46,373/-, which comes to Rs.20,84,927/-. The same is also\nrequired to be added to the total income of the assessee.\n6.4 Interest Expenditure claimed thereon:\nFurther, it was also observed that the assessee has claimed interest expenditure on\nthese accommodation loan entries in its ITR returns

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

LATE SHRI BABANLAL BHIKULAL AGRAWAL,,JALGAON vs. INCOME-TAX OFFICER,,

In the result, the appeal of the assessee is allowed

Bench: Shri D. Karunakara Rao, Am & Shri Laliet Kumar, Jm आयकर अपील सं. / Ita No.19/Pun/2015 िनधा"रण वष" / Assessment Year : 2003-04 Late Shri Babanlal Bhikulal Agrawal, Through L/H Shri Anil Babanlal Agrawal, 84-85, Main Road, Raver, Dist. Jalgaon-425508 .......अपीलाथ" / Appellant Pan : Aabha7676P बनाम / V/S. Ito, Ward-2(2), ……""यथ" / Respondent Jalgaon. Assessee By : Shri Sunil Ganoo Revenue By : Shri Vijay Netke सुनवाई क" तारीख / Date Of Hearing : 10.02.2020 घोषणा क" तारीख / Date Of Pronouncement : 12.02.2020 आदेश / Order Per D. Karunakara Rao, Am: This Appeal Filed By The Assessee Is Against The Order Of The Cit(A)-2, Nashik Dated 28.10.2014 For The Assessment Year 2003-04. 2. The Grounds Raised By The Assessee Are As Under :- “1] The Ld.Cit(A) Has Grossly Erred In Law & On Facts In Confirming Penalty Imposed Of Rs. 10,12,126/- U/S.271(1)(C) On Account Of Alleged Addition Made At Rs.32,13,100/(Inclusive Of Enhanced Income), Without Establishing Any Alleged Facts/Thing & Bringing Any Corroborative Evidence On Record, Even In Penalty Proceedings & Hence, Penalty Be Deleted 2] On The Facts & In The Prevailing Circumstances Of The Case, The Learned Cit(A) Has Grossly Erred In Confirming The Penalty U/S.271(1)(C) Of The I T Act, Without Rebutting Any Contention Of The Appellant Filed Before Him. Therefore

2) of section 143 has expired, or (c) assessment or reassessment, if any, has been made, before the date of receiving the books of account or documents or assets seized or requisitioned by the Assessing Officer having jurisdiction over such other person, such Assessing Officer shall issue the notice and assess or reassess total income of such other person

CHITRA NARENDRA PARMAR,PUNE vs. ASSISTANT COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-2(1), PUNE, PUNE

In the result, all the appeals filed by the respective assessees are allowed

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

147, section 140, 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

RAMLAL BHIKULAL SHAH,PUNE vs. ACIT, CENTRAL CIRCLE 2(1), PUNE , PUNE

In the result, all the appeals filed by the respective assessees are allowed

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

147, section 140, 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

RAMANLAL BHIKULAL SHAH,PUNE vs. ACIT, CENTRAL CIRCLE 2(1), PUNE , PUNE

In the result, all the appeals filed by the respective assessees are allowed

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

147, section 140, 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

CHITRA NARENDRA PARMAR ,PUNE vs. ACIT, CENTRAL CIRCLE 2(1), PUNE , PUNE

In the result, all the appeals filed by the respective assessees are allowed

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

147, section 140, 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

ASHOK BHARTI GOSWAMI,PUNE vs. ACIT, CENTRAL CIRCLE 2(1), PUNE , PUNE

In the result, all the appeals filed by the respective assessees are allowed

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

147, section 140, 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

DEEPAK KANTILAL JAIN ,PUNE vs. ACIT, CENTRAL CIRCLE 2(1), PUNE , PUNE

In the result, all the appeals filed by the respective assessees are allowed

2(3), Pune recorded the satisfaction dated\n22.04.2021 as per the provisions of section 153C of the Act in the case of the\nassessee. A notice u/s 153C of the Act was issued to the assessee for assessment\nyear 2016-17 on 30.04.2021 which was duly served through ITBA system. The\nassessee in response to the same did not file

ADISH SHANTILAL SOLANKI,PUNE vs. ASSISTANT COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-2(1), PUNE, PUNE

2(3), Pune recorded the satisfaction dated\n22.04.2021 as per the provisions of section 153C of the Act in the case of the\nassessee. A notice u/s 153C of the Act was issued to the assessee for assessment\nyear 2016-17 on 30.04.2021 which was duly served through ITBA system. The\nassessee in response to the same did not file