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7 results for “reassessment u/s 147”+ Section 172clear

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Key Topics

Section 143(3)8Section 1488Section 143(2)5Section 1475Section 685Addition to Income5Section 54F4Section 69A4Reopening of Assessment

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

ITA 688/PUN/2024[2017-18]Status: DisposedITAT Pune19 Aug 2024AY 2017-18

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

For Appellant: Shri Prasad BhandariFor Respondent: Shri Keyur Patel, CIT
Section 1Section 132Section 132(4)Section 143(3)

147 was not valid and the proper course of action that should have been taken by the Assessing Officer was u/s 153C as the provisions of section 153C of the Act are clearly applicable to the facts of the case. We, therefore, uphold the order of the CIT(A) / NFAC on the issue of validity of re-assessment proceedings

4
Section 2503
Reassessment3
Disallowance3

AADHUNIK INFRASTRUCTURE DEVELOPMENT PRIVATE LIMITED,JALGAON vs. THE DEPUTY COMMISSIONER OF INCOME TAX, CIRCLE-1, JALGAON

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

ITA 439/PUN/2023[2012-13]Status: DisposedITAT Pune18 Sept 2024AY 2012-13

Bench: Shri R. K. Panda & Shri Vinay Bhamoreassessment Year : 2012-13

For Appellant: Shri Kishor B PhadkeFor Respondent: Shri Ramnath P Murkunde
Section 143(3)Section 14ASection 271(1)(c)Section 68

reassessment proceedings. Thus there was no borrowed satisfaction on the part of the AO. There was independent application of mind on the part of the AO. Further reliance is placed upon clause (b) of explanation 2 to provisions of section 147 of the Act as on the basis of the facts of the case the AO had the basis

NAVJYOTI FARMING PRIVATE LIMITED,BELAPUR vs. ITO, WARD -3 , PANVEL

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

ITA 1020/PUN/2024[2012-13]Status: DisposedITAT Pune30 Dec 2024AY 2012-13

Bench: Shri R. K. Panda & Ms. Astha Chandraassessment Year : 2012-13

For Appellant: Shri Ashwani KumarFor Respondent: Shri Amol Khairnar, CIT-DR
Section 142(1)Section 143(1)Section 143(2)Section 143(3)Section 147Section 148Section 250Section 68

reassessment proceedings and issuing notice under section 148 of the Act. 2 That the order dated 28.03.2024 passed u/s 250 of the "Act" by the National Faceless Appeal Centre (NFAC), Delhi is against law and facts on the file in as much as he was not justified to uphold the action of the Learned Income Tax Officer, Ward -3 Panvel

AYOKI FABRICON PVT. LTD.,,PUNE vs. DEPUTY COMMISSIONER OF INCOME-TAX,,

In the result, the appeal of the assessee is allowed

ITA 2155/PUN/2016[2009-10]Status: DisposedITAT Pune31 Dec 2018AY 2009-10

Bench: Shri D. Karunakara Rao, Am & Shri Vikas Awasthy, Jm आयकर अपील सं. / Ita No.2155/Pun/2016 िनधा"रण वष" / Assessment Year : 2009-10 Ayoki Fabricon Pvt. Ltd., 137 To 139, Akshay Complex, Dhole Patil Road, Pune. Pan : Aabca5780F .......अपीलाथ" / Appellant बनाम / V/S. Dcit, Circle- 1(1), ……""यथ" / Respondent Pune. Assessee By : Shri Nikhil Pathak & Shri Nimit Gujarathi Revenue By : Shri Yogesh Kamat, Addl.Cit सुनवाई क" तारीख / Date Of Hearing : 20.12.2018 घोषणा क" तारीख / Date Of Pronouncement : 31.12.2019 आदेश / Order Per D. Karunakara Rao, Am : This Appeal Is Filed By The Assessee Against The Order Of Cit(A)-1, Pune Dated 14.06.2016 For The Assessment Year 2009-10. 2. The Grounds Raised By The Assessee Are As Under :- “1. The Learned Cit(A) Erred In Confirming The Disallowance Of Additional Depreciation Of Rs.1,10,53,748/- U/S 32(1)(Iia) On New Plant & Machinery On The Ground That The Assessee Was Not Engaged In The Business Of Manufacture Or Production Of Any Article Or Thing. 2. The Learned Cit(A) Erred In Ignoring The Fact That – I) The Details Furnished To The Assessing Officer By The Assessee During The Assessment Proceedings U/S 143(3) R.W.S. 147 Were Same As Were Furnished During The Assessment Proceedings U/S 143(3) & Therefore.

For Appellant: Shri Nikhil Pathak &For Respondent: Shri Yogesh Kamat, Addl.CIT
Section 143(3)Section 148Section 271(1)(c)Section 32Section 32(1)(iia)

section 147 of the Act. 5 8. Explaining the background facts of the case, ld. Counsel for the assessee submitted that the assessment proceedings were finalized by the Assessing Officer, who passed the well reasoned order for the earlier assessment years 2008-09, 2010-11 and 2011-12. In these assessment years, the assessee made a similar claim of additional

BABABHAI SADARBHAI SHAIKH,AHMEDNAGAR vs. ITO WARD 1, AHMEDNAGAR, AHMEDNAGAR

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

ITA 144/PUN/2025[2015-16]Status: DisposedITAT Pune23 Oct 2025AY 2015-16

Bench: Shri R. K. Panda & Ms. Astha Chandraassessment Year : 2015-16 Bababhai Sadarbhai Shaikh Ito, Ward 1, Nr Goraba Takies Jamkhed, Vs. Ahmednagar Ahmednagar – 413201 Pan: Hozps1445M (Appellant) (Respondent) Assessee By : Shri Suhas P Bora Department By : Shri Ratnakar Bhimrao Shelake Date Of Hearing : 10-09-2025 Date Of Pronouncement : 23-10-2025 O R D E R Per R.K. Panda, Vp:

For Appellant: Shri Suhas P BoraFor Respondent: Shri Ratnakar Bhimrao Shelake
Section 142(1)Section 143(2)Section 144Section 144BSection 147Section 148Section 69A

reassessment proceedings are initiated on the basis of incriminating material found in the search of 3rd party then the provisions of section 153C of the Act are applicable which override the applicability of sections 147 and 148 of the Act.” 7. The Learned Counsel for the assessee referring to the above additional ground submitted that the additional ground raised

R B DIAMOND HOUSE,JALGAON vs. PNE-C-1, RANGE -25, CIRCLE -1, OFFICE OF THE COMMISSIONER OF INCOME TAX- JALGAON

In the result, the appeal of the assessee is allowed for statistical\npurposes

ITA 1948/PUN/2025[2016-17]Status: DisposedITAT Pune19 Dec 2025AY 2016-17
For Appellant: \nShri Sanjay T. TupeFor Respondent: \nSmt. Indira R. Adakil
Section 250(6)Section 69A

Section 69A.\nGround No. 6: Interest Disallowance Rs.1,54,43,569/-\n6.\nOn the facts and in the circumstances of the case and in law, the\nlearned Commissioner of Income Tax (Appeals) ought to have\nconsidered and deleted the disallowance of Rs.1,54,43,569/-\nbeing\ninterest on Cash Credit facility as the Cash Credit facility was\nproperly reflected

TEJASHREE ATUL PATIL,PUNE vs. PR.CIT - 2, PUNE

In the result, appeal of the assessee is dismissed

ITA 927/PUN/2025[2015-16]Status: DisposedITAT Pune08 Sept 2025AY 2015-16

Bench: Dr.Manish Borad & Shri Vinay Bhamore

For Appellant: Shri C.V.DeshpandeFor Respondent: Shri Amit Bobde
Section 147Section 148Section 263Section 54F

reassessment proceedings were initiated and concluded. Ld. Counsel for the assessee submitted that the issues raised in the show cause notice u/s.263 of the Act was not the subject matter and reasons recorded for reopening the assessment proceedings. Therefore, ld. PCIT erred in assuming jurisdiction. 6 Tejashree Atul Patil Referring to the following decisions, he claimed that ld. PCIT cannot