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

160/- have escaped from assessment. The case of assessee was also not selected for scrutiny as stipulated u/s 2(40) of the Act, for the said assessment year. Hence, the case needs to be opened under explanation 2(b) to the section 147 of the Act. 5. As the case is to be opened for A.Y 2012-13, which

SUNANDA CONSTRUCTIONS,PUNE vs. DCIT, CENTRAL CIRCLE 2(2), PUNE, PUNE

In the result, both the appeals filed by the assessee are allowed

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

160 of the paper book. He submitted that the Ld. CIT(A) while deciding the issue against the assessee on this issue has distinguished this decision of the Coordinate Bench of the Tribunal on the ground that the Ld. DR at the time of argument could not point out any contrary decision against the decision of Hon’ble Madras High

SUNAND CONSTRUCTIONS,PUNE vs. DCIT CENTRAL CIRCLE 2(2), PUNE, PUNE

In the result, both the appeals filed by the assessee are allowed

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

160 of the paper book. He submitted that the Ld. CIT(A) while deciding the issue against the assessee on this issue has distinguished this decision of the Coordinate Bench of the Tribunal on the ground that the Ld. DR at the time of argument could not point out any contrary decision against the decision of Hon’ble Madras High

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

reassessment proceedings under section 147, 148 and 148A of the Act, should be done in a faceless manner.\n4. During the course of assessment, the Ld. A. O. accepted the fact that the sale transaction was not of Rs.3,60,00,000/- as reported by the Insight Portal, but of Rs.1,20,00,000/- as per the document provided

JAIBHAGWAN BANARASIDAS JINDAL,JALNA vs. THE INCOME TAX OFFICER, WARD-1, JALNA

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

Bench: Shri R. K. Panda & Ms. Astha Chandraassessment Year : 2016-17

u/s 147 has to be quashed. 16. Referring to the decision of the Hon’ble Bombay High Court in the case of PCIT v. Shodiman Investments (P) Ltd, 93 taxmann.com 153, he submitted that the Hon’ble High Court in the said decision has held that where Assessing Officer had issued a reassessment notice on the basis of intimation from

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 of the Act and issuing notice under section 148 of the Act, without complying with the various jurisdictional preconditions and statutory safeguards under Income Tax Act, rendering the reassessment proceedings bad in law and liable to be quashed. 3. On the facts and in the circumstances of the case and without prejudice to any other grounds, the learned Jurisdictional

NARENDRA KACHRULAL ABAD,JALNA vs. INCOME-TAX OFFICER, WARD - 1,, JALNA

In the result, appeal of the assessee partly allowed

Bench: Dr.Dipak P. Ripote & Shri Vinay Bhamoreआयकर अपऩल सं. / Ita No.866/Pun/2019 निर्धारण वषा / Assessment Year: 2009-10 Shri Narendra Kachrulal Abad, V The Income Tax Officer, Abad House, Nal Galli, S Ward-1, Jalna. Kadrabad, Jalna – 431203. Maharashtra. Pan: Acspa9531C Appellant/ Assessee Respondent / Revenue Assessee By Shri Hari Krishan – Ar Revenue By Shri Arvind Renge –Addl.Cit(Dr) Date Of Hearing 28/07/2025 Date Of Pronouncement 06/10/2025 आदेश/ Order Per Dr. Dipak P. Ripote, Am: This Is An Appeal Filed By Assessee Against The Order Of Ld.Commissioner Of Income Tax(Appeal)-1, Aurangabadpassed Under Section 250 Of The Income Tax Act, 1961 For The A.Y.2009-10 Dated 30.03.2019, Emanating From Order U/S.143(3) R.W.S 147Of The Income Tax Act, 1961, Dated 03.11.2017. The Assessee Has Raised The Following Concise Grounds Of Appeal :

section 250 of the Income Tax Act, 1961 for the A.Y.2009-10 dated 30.03.2019, emanating from order u/s.143(3) r.w.s 147of the Income Tax Act, 1961, dated 03.11.2017. The Assessee has raised the following concise grounds of appeal : ITA No.866/PUN/2025 [A] “The following grounds of appeal are taken independently and without prejudice to one another. 1. The reopening of assessment

DEPUTY COMMISSIONER OF INCOME TAX, JALGAON vs. TARADEVI RATANLAL BAFNA, JALGAON

147 are applicable to\nfacts of this case and the assessment year under consideration is deemed to be case where income chargeable\nto tax has escaped assessment.\n\nPlease acknowledge receipt of this letter\n\nBHARAT DEVRAJ SHEGAONKAR\nACIT CEN CIR 2, NASHIK\n\n5. He, therefore, issued notice u/s 148 of the Act on 19.03.2020. The assessee\nin response

AMBALAL GORAKH CHOUDHARI,PRAKASHA vs. INCOME TAX OFFICER, WARD-1, DHULE, DHULE

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

Bench: Shri Manish Borad & Shri Vinay Bhamoreआयकर अपील सं. / Ita No.1422/Pun/2025 िनधा"रण वष" / Assessment Year : 2013-14 Ambalal Gorakh Choudhari Vs. Ito, Ward-1, Dhule. Legal Heir Anita Ambalal Chaudhari, Mukteshwar Mandir, At Post Prakasha, Taluka Shahada, Dist. Nandurbar- 425409. Pan : Afrpc1304D Appellant Respondent Assessee By : Shri Sandeep Rathi Revenue By : Shri Harshit Bari Date Of Hearing : 19.08.2025 Date Of Pronouncement : 14.10.2025 आदेश / Order Per Vinay Bhamore, Jm: This Appeal Filed By The Assessee Is Directed Against The Order Dated 31.03.2025 Passed By Ld. Addl./Jcit(A)-2, Gurugram [‘Ld. Cit(A)’] For The Assessment Year 2013-14. 2. The Appellant Has Raised The Following Grounds Of Appeal :- “1. On The Facts & In The Circumstances Of The Case, Learned Assessing Officer & The Cit(A) Is Not Justified In Making/Confirming Additions Of Rs. 1020740/- To Returned Income U/S.69A Of The Act, As Said Section Is Applicable Only When In Any Financial Year The Assessee Is Found To Be Owner Of Any Money, Bullion, Jewellery Or Any Other

reassessment. The court held that the petitioner's communication about the death of the assessee cannot be considered as participation in the proceedings, and thus, the notice issued under section 148 was deemed invalid. (ii) Vipin Walia v. Income-tax Officer [2016] 67 taxmanın.com 56 (Delhi) The High Court of Delhi dealt with a situation where a notice under

ASSISTANT COMMISSIONER OF INCOME TAX, JALGAON vs. SIDHARTH RATANLAL BAFNA, JALGAON

147 are applicable to\nfacts of this case and the assessment year under consideration is deemed to be case where income chargeable\nto tax has escaped assessment.\nPlease acknowledge receipt of this letter\n\nBHARAT DEVRAJ SHEGAONKAR\nACIT CEN CIR 2, NASHIK\n\n5. He, therefore, issued notice u/s 148 of the Act on 19.03.2020. The assessee\nin response

ASSISTANT COMMISSIONER OF INCOME TAX, JALGAON vs. SIDHARTH RATANLAL BAFNA, JALGAON

147 are applicable to\nfacts of this case and the assessment year under consideration is deemed to be case where income chargeable\nto tax has escaped assessment.\n\nPlease acknowledge receipt of this letter\n\nBHARAT DEVRAJ SHEGAONKAR\nACIT CEN CIR 2, NASHIK\n\n5. He, therefore, issued notice u/s 148 of the Act on 19.03.2020. The assessee\nin response

JASMINE ZUBIN SHROFF,PUNE vs. ITO, WARD-7(1), PUNE, PUNE

In the result, appeal of the Assessee is allowed

Bench: Dr.Dipak P. Ripote & Shri Vinay Bhamoreआयकर अपऩल सं. / Ita No.2380/Pun/2025 निर्धारण वषा / Assessment Year: 2012-13 Mrs.Jasmine Zubin Shroff V The Income Tax (Through Legal Heir Zubin K S Officer, Shroff), Ward-7(1), Pune. 826/C No.5, Anklesharia Blocks, Dastur Meher Road, Camp, Pune - 411001. Pan:Basps7144E Appellant/ Assessee Respondent /Revenue Assessee By Shri B C Malakar Revenue By Shri Sandeep Sathe - Jcit Date Of Hearing 08/12/2025 Date Of Pronouncement 28/01/2026 आदेश/ Order Per Dr. Dipak P. Ripote, Am: This Is An Appeal Filed By The Legal Heir Of Late Jasmine Z. Shroff 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.2012-13 Dated 19.12.2023 Emanating From The Assessment Order Passed Under Section 144 Of The

160 (Bom-HC) n this case delay of 198 days in filing the appeal was condoned. vi. AUTOSER (P.) Ltd. [1998] 101 Taxman 70 (Coch.) (Mag) vii. N. Balakrishnan Vs. M. Krishnamurthy (1998} 7 SCC 123, 1998 (9) TMI 602 SC; 6 ITA No.2380/PUN/2025 [A] Condonation of Delay : 3. Assessee was admitted for treatment of Cancer, unfortunately she died. Legal

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 :

u/s 148 and the reassessment is bad in law. He took us through the paper book. Submission of ld.DR : 3. Ld.DR for the Revenue relied on the order of Assessing Officer and ld.CIT(A). Findings & Analysis : 4. We have heard both the parties and perused the records. In this case, Assessing Officer issued notice u/s.148 of the Act, for A.Y.2013-14

DEPUTY COMMISSIONER OF INCOME-TAX vs. THE JAWAHARLAL NEHRU PORT TRUST,, RAIGAD

In the result, all the three appeals filed by the Revenue are dismissed and all the three appeals filed by the assessee are partly allowed

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

reassessment proceedings even the income which has escaped assessment has to be computed in accordance with the provisions of the Act which will include section 11 as is in the present case. It will not be correct to say that while computing income under section 148 the entire gross receipts are to be taxed. Further, it is not the case

JAWAHAR LAL NEHRU PORT TRUST,NAVI MUMBAI vs. ACIT PANVEL, PANVEL

In the result, all the three appeals filed by the Revenue are dismissed and all the three appeals filed by the assessee are partly allowed

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

reassessment proceedings even the income which has escaped assessment has to be computed in accordance with the provisions of the Act which will include section 11 as is in the present case. It will not be correct to say that while computing income under section 148 the entire gross receipts are to be taxed. Further, it is not the case

JAWAHAR LAL NEHRU PORT TRUST,NAVI MUMBAI vs. ACIT PANVEL, PANVEL

In the result, all the three appeals filed by the Revenue are dismissed and all the three appeals filed by the assessee are partly allowed

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

reassessment proceedings even the income which has escaped assessment has to be computed in accordance with the provisions of the Act which will include section 11 as is in the present case. It will not be correct to say that while computing income under section 148 the entire gross receipts are to be taxed. Further, it is not the case

JAWAHAR LAL NEHRU PORT TRUST,NAVI MUMBAI vs. ACIT PANVEL, PANVEL

In the result, all the three appeals filed by the Revenue are dismissed and all the three appeals filed by the assessee are partly allowed

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

reassessment proceedings even the income which has escaped assessment has to be computed in accordance with the provisions of the Act which will include section 11 as is in the present case. It will not be correct to say that while computing income under section 148 the entire gross receipts are to be taxed. Further, it is not the case

DEPUTY COMMISSIONER OF INCOME-TAX vs. THE JAWAHARLAL NEHRU PORT TRUST,, RAIGAD

In the result, all the three appeals filed by the Revenue are dismissed and all the three appeals filed by the assessee are partly allowed

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

reassessment proceedings even the income which has escaped assessment has to be computed in accordance with the provisions of the Act which will include section 11 as is in the present case. It will not be correct to say that while computing income under section 148 the entire gross receipts are to be taxed. Further, it is not the case