CAPGEMINI TECHNOLOGY SERVICES INDIA LIMITED ( SUCCESSOR OF ARICENT TECHNOLOGIES HOLDINGS LIMITED),PUNE vs. ASSISTANT COMMISSIONER OF INCOME TAX, CIRCLE 1(1), PUNE, PUNE

In the result, the appeal of the assessee is allowed

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

264 shall be admissible against the order of assessment or reassessment, referred to in clause (a) of sub-section (1), in a case where an order under sub- section (4) has been made accepting the application." 20. Sub-section (18) of Section 155 of the Income Tax Act is inserted vide Finance Act, 2022 w.e.f. 01.04.2022. The above referred provisions

RAJARSHI SHAHU SHIKSHAN SANSTHA INAM DHAMANI,SANGLI vs. ITO EXEMPTION, KOLHAPUR

In the result, all the appeals filed by the assessee are partly allowed as per terms indicated hereinabove

Bench: Dr.Manish Borad & Shri Vinay Bhamoreआयकर अपील सं. / Ita Nos.1121 To 1126/Pun/2024 Assessment Years : 2012-13 To 2017-18

147 order, appears to have proceeded on the analogy that, some taxable income has escaped assessment. As against, vide Section 115BBC, mere rate of tax is differentiated from normal income. As stated earlier, entire charge of the learned AO at the stage of formation of belief of 'escapement of income' by resorting to Section

RAJARSHI SHAHU SHIKSHAN SANSTHA INAM DHAMANI,SANGLI vs. ITO EXEMPTION, KOLHAPUR, KOLHAPUR

In the result, all the appeals filed by the assessee are partly allowed as per terms indicated hereinabove

Bench: Dr.Manish Borad & Shri Vinay Bhamoreआयकर अपील सं. / Ita Nos.1121 To 1126/Pun/2024 Assessment Years : 2012-13 To 2017-18

147 order, appears to have proceeded on the analogy that, some taxable income has escaped assessment. As against, vide Section 115BBC, mere rate of tax is differentiated from normal income. As stated earlier, entire charge of the learned AO at the stage of formation of belief of 'escapement of income' by resorting to Section

RAJARSHI SHAHU SHIKSHAN SANSTHA INAM DHAMANI,SANGLI vs. ITO EXEMPTION, KOLHAPUR, KOLHAPUR

In the result, all the appeals filed by the assessee are partly allowed as per terms indicated hereinabove

Bench: Dr.Manish Borad & Shri Vinay Bhamoreआयकर अपील सं. / Ita Nos.1121 To 1126/Pun/2024 Assessment Years : 2012-13 To 2017-18

147 order, appears to have proceeded on the analogy that, some taxable income has escaped assessment. As against, vide Section 115BBC, mere rate of tax is differentiated from normal income. As stated earlier, entire charge of the learned AO at the stage of formation of belief of 'escapement of income' by resorting to Section

RAJARSHI SHAHU SHIKSHAN SANSTHA INAM DHAMANI,SANGLI vs. ITO EXEMPTION , KOLHAPUR, KOLHAPUR

In the result, all the appeals filed by the assessee are\npartly allowed as per terms indicated hereinabove

147 order, appears to have proceeded on the\nanalogy that, some taxable income has escaped assessment. As\nagainst, vide Section 115BBC, mere rate of tax is differentiated from\nnormal income. As stated earlier, entire charge of the learned AO at\nthe stage of formation of belief of 'escapement of income' by resorting\nto Section

RAJARSHI SHAHU SHIKSHAN SANSTHA INAM DHAMANI,SANGLI vs. ITO EXEMPTION, KOLHAPUR, KOLHAPUR

In the result, all the appeals filed by the assessee are\npartly allowed as per terms indicated hereinabove

147 order, appears to have proceeded on the\nanalogy that, some taxable income has escaped assessment. As\nagainst, vide Section 115BBC, mere rate of tax is differentiated from\nnormal income. As stated earlier, entire charge of the learned AO at\nthe stage of formation of belief of 'escapement of income' by resorting\nto Section

RAJARSHI SHAHU SHIKSHAN SANSTHA INAM DHAMANI,SANGLI vs. ITO EXEMPTION, KOLHAPUR

In the result, all the appeals filed by the assessee are\npartly allowed as per terms indicated hereinabove

147 order, appears to have proceeded on the\nanalogy that, some taxable income has escaped assessment. As\nagainst, vide Section 115BBC, mere rate of tax is differentiated from\nnormal income. As stated earlier, entire charge of the learned AO at\nthe stage of formation of belief of 'escapement of income' by resorting\nto Section

GOPAL EXTRUSIONS PVT LTD,,JALGAON vs. INCOME-TAX OFFICER, WARD - 1(2),, JALGAON

Bench: Dr.Manish Borad & Shri Vinay Bhamoreआयकर अपील सं. / Ita. No.1633/Pun/2017 Assessment Year : 2008-09

REASSESSMENT: a. No reasons are recorded The proposal for reopening as part of the Approval has been placed on record. The said document states that it is a proposal for recording reasons for initiating action u/s 147 and not the reasons recorded by AO. In the said document, there is no whisper about reason to believe

MRINALINI JAYANT PURANIK,PUNE vs. ITO, WARD-2(2), PUNE, PUNE

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

Bench: Shri R. K. Panda & Ms. Astha Chandraassessment Year : 2019-20 Mrinalini Jayant Puranik Ito, Ward 2(2), Pune Flat 14, Khagol Coop Society, Vs. S.No.38/1, Panchavati, Pashan, Pune – 411008 Pan: Almpp5163E (Appellant) (Respondent) Assessee By : Shri Suhas Kulkarni Department By : Shri A D Kulkarni Date Of Hearing : 26-11-2025 Date Of Pronouncement : 28-11-2025 O R D E R Per R.K. Panda, Vp:

u/s 270A of the Act and levied penalty of Rs.10,96,347/- being the penalty @ 50% of tax payable for under- reporting of income as per provisions of section 270A of the Act. We find the Ld. CIT(A) / NFAC confirmed the penalty levied by the Assessing Officer, the reasons of which have already been reproduced in the preceding paragraphs

MOTIWALA AUTO PVT. LTD.,AURANGABAD vs. ITO, WARD1(1), AURANABAD, AURANGABAD

In the result, the appeal of the assessee is allowed

147 rws 144\nby the AO and there are issues which need to be further examined and\ninvestigated by the AO. In view of the above facts and changes in the Act, as\nenumerated above, in my considered opinion the submissions filed by the\nappellant in the appellate proceedings, are germane to the correct appreciation of\nthe issues under deliberation

ASSTT. COMMISSIONER OF INCOME TAX (EXEMPTIONS), CIRCLE, PUNE, PUNE vs. THE SHETKARI SHIKSHAN MANDAL, PUNE

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

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

u/s 147, the AO has power to re-assess and not no power to review. That is to say, he cannot revisit issues already considered in an earlier assessment. The appellant has not established that the AO had considered and decided the issues that were taken up in reassessment. Therefore, the assessment is valid. Ground 1 is dismissed. Loan repayment

M/S. SHANTI CONSTRUCTION COMPANY,RATNAGIRI vs. INCOME-TAX OFFICER, WARD-2, RATNAGIRI

Bench: Shri Ss Viswanethra Ravi & Shri G. D. Padmahshaliआयकर अपीऱ सं. / Ita No. 374 & 375/Pun/2020 निर्धारण वर्ा / Assessment Year : 1999-2000 M/S Shanti Construction Company Ram Lane, Ratnagiri. . . . . . . . अपीऱधर्थी / Appellant Pan : Abhfs1628N बनाम / V/S. Income Tax Officer, . . . . . . . प्रत्यर्थी / Respondent Ward-2, Ratnagiri. द्वारा / Appearances Assessee By : None For The Assessee. Revenue By : Shri M. G. Jasnani. सुनवाई की तारीख / Date Of Conclusive Hearing : 08/09/2022 घोषणा की तारीख / Date Of Pronouncement : 08/09/2022 आदेश / Order Per G. D. Padmahshali, Am; Two Appeals Of The Assessee Are Assailed Against The Orders Of The Commissioner Of Income Tax (Appeals)-2, Kolhapur [For Short “Cit(A)”] Dt. 30/01/2020 Passed U/S 250 Of The Income-Tax Act, 1961 [For Short “The Act”], Which Ascended Out Of Separate Orders Of Income Tax Officer Ward-2, Ratnagiri [For Short “Ao”] Dt. 26/12/2011 & 11/09/2015 Passed U/S 143(3) & 220(2) Respectively, For Assessment Year [For Short “Ay”] 1999-2000. Itat-Pune Page 1 Of 16

147 of the Act. Therefore Tribunal set aside the order of the CIT(A) and restored the same to the file of the A.O. with directions. The Hon’ble Tribunal vide its order dt. 20th August 2010 issued the direction to the A.O. when the A.O. had lost his jurisdiction over the case. In view of this the assessment order

M/S. SHANTI CONSTRUCTION COMPANY,RATNAGIRI vs. INCOME-TAX OFFICER, WARD-2, RATNAIRI

Bench: Shri Ss Viswanethra Ravi & Shri G. D. Padmahshaliआयकर अपीऱ सं. / Ita No. 374 & 375/Pun/2020 निर्धारण वर्ा / Assessment Year : 1999-2000 M/S Shanti Construction Company Ram Lane, Ratnagiri. . . . . . . . अपीऱधर्थी / Appellant Pan : Abhfs1628N बनाम / V/S. Income Tax Officer, . . . . . . . प्रत्यर्थी / Respondent Ward-2, Ratnagiri. द्वारा / Appearances Assessee By : None For The Assessee. Revenue By : Shri M. G. Jasnani. सुनवाई की तारीख / Date Of Conclusive Hearing : 08/09/2022 घोषणा की तारीख / Date Of Pronouncement : 08/09/2022 आदेश / Order Per G. D. Padmahshali, Am; Two Appeals Of The Assessee Are Assailed Against The Orders Of The Commissioner Of Income Tax (Appeals)-2, Kolhapur [For Short “Cit(A)”] Dt. 30/01/2020 Passed U/S 250 Of The Income-Tax Act, 1961 [For Short “The Act”], Which Ascended Out Of Separate Orders Of Income Tax Officer Ward-2, Ratnagiri [For Short “Ao”] Dt. 26/12/2011 & 11/09/2015 Passed U/S 143(3) & 220(2) Respectively, For Assessment Year [For Short “Ay”] 1999-2000. Itat-Pune Page 1 Of 16

147 of the Act. Therefore Tribunal set aside the order of the CIT(A) and restored the same to the file of the A.O. with directions. The Hon’ble Tribunal vide its order dt. 20th August 2010 issued the direction to the A.O. when the A.O. had lost his jurisdiction over the case. In view of this the assessment order

DY. COMMISSIONER OF INCOME TAX (EXEMPTIONS), CIRCLE, PUNE, SWARGATE, PUNE vs. DR D Y PATIL UNITECH SOCIETY, PUNE

In the result, the appeal filed by the Revenue is dismissed

Bench: Shri R. K. Panda & Ms. Astha Chandraassessment Year : 2013-14 Dcit (Exemption) Dr D Y Patil Unitech Society Circle, Pune Flat No.101, Shree Motisagar Vs. Apartment, G G Thakkar Road, S No.173A, Pune – 411001 Pan: Aabtd1482A (Appellant) (Respondent) Assessee By : Shri Nikhil S Pathak Department By : Shri Amol Khairnar, Cit-Dr Date Of Hearing : 27-10-2025 Date Of Pronouncement : 04-11-2025 O R D E R Per R.K. Panda, Vp:

147 of the Act, reopened the assessment. Accordingly notice u/s 148 of the Act was issued to the assessee on 28.03.2018. 4. The assessee in response to the same filed the return of income on 26.04.2018. The reasons for reopening the assessment were also sought which were provided to the assessee. Subsequently, statutory notices u/s