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11 results for “reassessment u/s 147”+ Section 245clear

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Key Topics

Section 14831Section 14722Section 69A19Section 143(2)18Addition to Income10Reassessment8Section 2505Section 1445Section 251(2)

ADVIK HI TECH PVT LTD,PUNE vs. DY.COMM..OF INCOMETAX, CIRCLE 8, PUNE

In the result, appeal of the assessee is allowed

ITA 1344/PUN/2024[2017-18]Status: DisposedITAT Pune05 Dec 2024AY 2017-18

Bench: Shri Rama Kanta Panda & Ms. Astha Chandra

For Appellant: Shri Sharad A. ShahFor Respondent: Shri Ramnath P. Murkunde
Section 139(1)Section 147Section 148Section 2Section 270ASection 270A(10)Section 270A(7)

reassessment order u/s 147 of the Act in comparison to the income declared by the appellant in the return u/s 139(1) of the Act. The appellant contended that the return filed u/s 139(1) of the Act was neither processed u/s 143(1) nor scrutinized u/s 143(3) in earlier occasion. In support of this, the appellant 5 ITA.No

4
Section 44A4
Condonation of Delay4
Rectification u/s 1544

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

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

ITA 72/PUN/2016[2008-09]Status: DisposedITAT Pune22 Jul 2022AY 2008-09

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

For Appellant: Smt. Hiral SejpalFor Respondent: Shri Sardar Singh Meena
Section 143(1)Section 143(2)Section 147Section 148Section 292B

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

ITA 1713/PUN/2015[2008-09]Status: DisposedITAT Pune22 Jul 2022AY 2008-09

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

For Appellant: Smt. Hiral SejpalFor Respondent: Shri Sardar Singh Meena
Section 143(1)Section 143(2)Section 147Section 148Section 292B

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

UNUS ABDULGAFAR SHAIKH,PUNE vs. ITO WARD 14(3), PUNE, PUNE

In the result, appeal of the assessee in ITA No

ITA 652/PUN/2025[2014-15]Status: DisposedITAT Pune14 May 2025AY 2014-15

Bench: Dr.Dipak P. Ripote & Shri Vinay Bhamoreआयकर अपील सं. / Ita Nos.652 To 655/Pun/2025 िनधा"रण वष" / Assessment Years: 2014-15 To 2017-18 Unusabdulgafar Shaikh, V The Income Tax Officer, Talwadiuruli Kanchan, Pune- S. Ward-14(3), Pune. Solapur Road, Haveli, Pune – 412202. Maharashtra. Pan: Aceps8721Q Appellant/ Assessee Respondent / Revenue Assessee By Shri Suhas Bora – Ar Revenue By Shri Vinod Pawar – Addl.Cit(Dr) Date Of Hearing 08/05/2025 Date Of Pronouncement 14/05/2025 आदेश/ Order Per Dr. Dipak P. Ripote, Am: These Four Appeals Filed By The Assessee Are Against The Separate Orders Of Ld.Commssioner Of Income Tax(Appeal)[Nfac] Passed Under Section 250 Of The Act, 1961, Respectively. For The Sake Of Convenience, These Four Appeals Were Heard Together & Are Being Disposed Of By This Common Order.We Treat Appeal In Ita No.652/Pun/2025 As “Lead Case”. The Assessee Has Raised The Following Grounds Of Appeal :

Section 144Section 147Section 148Section 153CSection 250Section 251(2)Section 44ASection 69A

245/- u/s 69A of the Act was incorrect, as the appellant was not liable to maintain the books of accounts as per section 44AA of the Act and section 69A applies only when amounts are not recorded in books. Erroneous assumption of jurisdiction u/s 147 of the Act 5. The reassessment

UNUS ABDULGAFAR SHAIKH,PUNE vs. ITO WARD 14(3), PUNE, PUNE

In the result, appeal of the assessee in ITA No

ITA 653/PUN/2025[2015-16]Status: DisposedITAT Pune14 May 2025AY 2015-16

Bench: Dr.Dipak P. Ripote & Shri Vinay Bhamoreआयकर अपील सं. / Ita Nos.652 To 655/Pun/2025 िनधा"रण वष" / Assessment Years: 2014-15 To 2017-18 Unusabdulgafar Shaikh, V The Income Tax Officer, Talwadiuruli Kanchan, Pune- S. Ward-14(3), Pune. Solapur Road, Haveli, Pune – 412202. Maharashtra. Pan: Aceps8721Q Appellant/ Assessee Respondent / Revenue Assessee By Shri Suhas Bora – Ar Revenue By Shri Vinod Pawar – Addl.Cit(Dr) Date Of Hearing 08/05/2025 Date Of Pronouncement 14/05/2025 आदेश/ Order Per Dr. Dipak P. Ripote, Am: These Four Appeals Filed By The Assessee Are Against The Separate Orders Of Ld.Commssioner Of Income Tax(Appeal)[Nfac] Passed Under Section 250 Of The Act, 1961, Respectively. For The Sake Of Convenience, These Four Appeals Were Heard Together & Are Being Disposed Of By This Common Order.We Treat Appeal In Ita No.652/Pun/2025 As “Lead Case”. The Assessee Has Raised The Following Grounds Of Appeal :

Section 144Section 147Section 148Section 153CSection 250Section 251(2)Section 44ASection 69A

245/- u/s 69A of the Act was incorrect, as the appellant was not liable to maintain the books of accounts as per section 44AA of the Act and section 69A applies only when amounts are not recorded in books. Erroneous assumption of jurisdiction u/s 147 of the Act 5. The reassessment

UNUS ABDULGAFAR SHAIKH,PUNE vs. ITO WARD 14(3), PUNE, PUNE

In the result, appeal of the assessee in ITA No

ITA 655/PUN/2025[2017-18]Status: DisposedITAT Pune14 May 2025AY 2017-18

Bench: Dr.Dipak P. Ripote & Shri Vinay Bhamoreआयकर अपील सं. / Ita Nos.652 To 655/Pun/2025 िनधा"रण वष" / Assessment Years: 2014-15 To 2017-18 Unusabdulgafar Shaikh, V The Income Tax Officer, Talwadiuruli Kanchan, Pune- S. Ward-14(3), Pune. Solapur Road, Haveli, Pune – 412202. Maharashtra. Pan: Aceps8721Q Appellant/ Assessee Respondent / Revenue Assessee By Shri Suhas Bora – Ar Revenue By Shri Vinod Pawar – Addl.Cit(Dr) Date Of Hearing 08/05/2025 Date Of Pronouncement 14/05/2025 आदेश/ Order Per Dr. Dipak P. Ripote, Am: These Four Appeals Filed By The Assessee Are Against The Separate Orders Of Ld.Commssioner Of Income Tax(Appeal)[Nfac] Passed Under Section 250 Of The Act, 1961, Respectively. For The Sake Of Convenience, These Four Appeals Were Heard Together & Are Being Disposed Of By This Common Order.We Treat Appeal In Ita No.652/Pun/2025 As “Lead Case”. The Assessee Has Raised The Following Grounds Of Appeal :

Section 144Section 147Section 148Section 153CSection 250Section 251(2)Section 44ASection 69A

245/- u/s 69A of the Act was incorrect, as the appellant was not liable to maintain the books of accounts as per section 44AA of the Act and section 69A applies only when amounts are not recorded in books. Erroneous assumption of jurisdiction u/s 147 of the Act 5. The reassessment

UNUS ABDULGAFAR SHAIKH,PUNE vs. ITO WARD 14(3), PUNE, PUNE

In the result, appeal of the assessee in ITA No

ITA 654/PUN/2025[2016-17]Status: DisposedITAT Pune14 May 2025AY 2016-17

Bench: Dr.Dipak P. Ripote & Shri Vinay Bhamoreआयकर अपील सं. / Ita Nos.652 To 655/Pun/2025 िनधा"रण वष" / Assessment Years: 2014-15 To 2017-18 Unusabdulgafar Shaikh, V The Income Tax Officer, Talwadiuruli Kanchan, Pune- S. Ward-14(3), Pune. Solapur Road, Haveli, Pune – 412202. Maharashtra. Pan: Aceps8721Q Appellant/ Assessee Respondent / Revenue Assessee By Shri Suhas Bora – Ar Revenue By Shri Vinod Pawar – Addl.Cit(Dr) Date Of Hearing 08/05/2025 Date Of Pronouncement 14/05/2025 आदेश/ Order Per Dr. Dipak P. Ripote, Am: These Four Appeals Filed By The Assessee Are Against The Separate Orders Of Ld.Commssioner Of Income Tax(Appeal)[Nfac] Passed Under Section 250 Of The Act, 1961, Respectively. For The Sake Of Convenience, These Four Appeals Were Heard Together & Are Being Disposed Of By This Common Order.We Treat Appeal In Ita No.652/Pun/2025 As “Lead Case”. The Assessee Has Raised The Following Grounds Of Appeal :

Section 144Section 147Section 148Section 153CSection 250Section 251(2)Section 44ASection 69A

245/- u/s 69A of the Act was incorrect, as the appellant was not liable to maintain the books of accounts as per section 44AA of the Act and section 69A applies only when amounts are not recorded in books. Erroneous assumption of jurisdiction u/s 147 of the Act 5. The reassessment

DCIT-CIRCLE 7 PUNE, BODHI TOWER SALISBURY PARK PUNE vs. TRIO CHEMSUCROTECH ENG. PROJECTS PVT. LTD, PUNE

ITA 1047/PUN/2024[2010-11]Status: DisposedITAT Pune21 Feb 2025AY 2010-11
Section 143(3)

245\nAsian Steel\n54,53,932\nVitarag Trading Company\n48,44,403\nHiten Enterprises\n43,05,542\nBhagwati Trading Co.\n42,04,075\nSiddhi Vinayak Steel\n31,38,487\nEvershine Enterprise\n19,10,969\nRidhi Sales Corporation\n5,13,339\nShree Traders\n48,15,757\nGanesh Metals\n1,38,03,045\nManusha Enterprises\n88,00,722\nQST

RANAJIT SURESH RAJAMANE,SOLAPUR vs. ITO, WARD 1, PANDHARPUR, PANDHARPUR

In the result, the appeal of the assessee is allowed

ITA 1678/PUN/2024[2014-15]Status: DisposedITAT Pune13 Jan 2026AY 2014-15

Bench: Dr. Manish Borad & Ms. Astha Chandraआयकर अपील सं. / Ita No.1678/Pun/2024 धििाारण वर्ा / Assessment Year: 2014-15 Ranajit Suresh Rajamane, Vs Ito Ward 1, Shukrawar Peth, Pandharpur Tembhurni Madha Solapur- 413211 Maharashtra Pan-Bmepr3878N Appellant Respondent

For Appellant: Smt. Deepa KhareFor Respondent: Shri Aviyogi Ambadkar
Section 139Section 147Section 148Section 250Section 54Section 548Section 54BSection 54B(1)Section 69A

147 r.w.s 144 of the Act dated 21.12.2018. 2. Assessee has raised following grounds of appeal:- (i) The Id CIT(A) erred in law and on facts in confirming addition of Rs 1,14.25,000/- u/s 69A as unexplained money in respect of 50% of sale consideration on sale of property. 2 (ii)The Id CIT(A) erred

ASHOK HIRACHAND SHAH,PANVEL vs. ASSESSING OFFICER WARD 2, PANVEL

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

ITA 812/PUN/2025[2011-12]Status: DisposedITAT Pune17 Dec 2025AY 2011-12

Bench: Shri R.K. Panda & Ms. Astha Chandraआयकर अपील सं. / Ita No.812/Pun/2025 धििाारण वर्ा / Assessment Year : 2011-12 Ashok Hirachand Shah, Assessing Officer, Plot No. 4, Mangal Bunglow, Ward – 2, Panvel Road No. 5, Sector No. 19, Vs. New Panvel, Tal.-Panvel-410206 Pan : Acdps4800M अपीलार्थी / Appellant प्रत्यर्थी / Respondent Assessee By : Shri Ajinkya Shah Department By : Shri Rajesh Gawali Date Of Hearing : 09-12-2025 Date Of 17-12-2025 Pronouncement : आदेश / Order Per Astha Chandra, Jm : The Appeal Filed By The Assessee Is Directed Against The Order Dated 20.01.2025 Of The Ld. Commissioner Of Income Tax (Appeals), Nfac, Delhi [“Cit(A)/Nfac”] Pertaining To Assessment Year (“Ay”) 2011-12. 2. The Assessee Has Raised The Following Grounds Of Appeal :- “1. Denial Of Natural Justice & Proper Opportunity The Learned Commissioner Of Income Tax (Appeals) Erred In Dismissing The Appeal Without Considering That The Appellant Was Denied Proper Opportunity & Natural Justice During The Assessment Proceedings. The Assessing Officer Called For Information At The Far End Of The Assessment Proceedings On 19/11/2018 & Despite The Appellant'S Authorized Representative Submitting The Details On 19/12/2018, The Ao Failed To Discuss Or Consider The Same. The Matter Ought To Have Been Remanded Back For Fresh Adjudication To Allow Proper Analysis Of The Transactions. 2. Addition Without Specifying The Section The Cit(A) Erred In Upholding The Addition Of Rs. 1,49,05,289/- Made By The Ao Without Specifying The Section Under Which The Addition Was Made. The Non-Mention Of The Specific Section Renders The Assessment Order Bad In Law, As It Violates The Principles Of Natural Justice & Transparency In Taxation. 3. Failure To Discharge Onus Under Section 69A

For Appellant: Shri Ajinkya ShahFor Respondent: Shri Rajesh Gawali
Section 147Section 69A

147 of the Income Tax Act, 1961 (the “Act”) by issue of notice u/s 148 of the Act. Statutory notice u/s 142(1) of the Act was accordingly issued and served upon the assessee on 25.08.2018, followed by issue of show cause notice on 19.11.2018. The assessee filed its reply on 19.12.2018 providing explanation to the above issues raised