MR. CHITTARANJAN TRIMBAK GAIKWAD,PUNE vs. THE ASST. COMMISSIONER OF INCOME TAX, CIRCLE-4, PUNE, PUNE

In the result, the appeal of the assessee is allowed

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

u/s. 271(1)(c) of the Act was attracted in the case of the assessee for such income declared in the Revised Return of Income and so also owing to the assessment order passed u/s.143(3) r.w.s. 147 of the Act on 22/01/2014 accepting such income declared in the Revised Return of Income filed. The penalty therefore so levied

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

c) where an action has been taken under section 132 or section 132A, after the expiry of one month from the date on which he was served with a notice under sub-section (1) of section 153A or sub-section (2) of section 153C or after the completion of the assessment, whichever is earlier.] 6.2 This has been upheld

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

c) where an action has been taken under section 132 or section 132A, after the expiry of one month from the date on which he was served with a notice under sub-section (1) of section 153A or sub-section (2) of section 153C or after the completion of the assessment, whichever is earlier.] 6.2 This has been upheld

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

c) where an action has been taken under section 132 or section 132A, after the expiry of one month from the date on which he was served with a notice under sub-section (1) of section 153A or sub-section (2) of section 153C or after the completion of the assessment, whichever is earlier.] 6.2 This has been upheld

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

c) where an action has been taken under section 132 or section 132A, after the expiry of one month from the date on which he was served with a notice under sub-section (1) of section 153A or sub-section (2) of section 153C or after the completion of the assessment, whichever is earlier.] 6.2 This has been upheld

DEPUTY COMMISSIONER OF INCOME TAX CIRCLE 7 PUNE, PUNE vs. KOLTE PATIL INTEGRATED TOWNSHIPS LIMITED, PUNE

In the result, both the appeals filed by the Revenue are dismissed

271[1][c] of the Income Tax Act 1961\nfor concealment of income is initiated separately.\nDisallowance of interest u/s 36 of the I.T. Act of Rs.15,11,87,548/-" 6.\nBefore the Ld. CIT(A) / NFAC the assessee apart from challenging the\naddition on merit challenged the validity of reopening of the assessment. The Ld.\nCIT(A) / NFAC

SOMNATH RAMDAS JADHAV,AHMEDNAGAR vs. ITO WARD 2, AHMEDNAGAR

In the result, the appeal filed by the assessee in ITA\nNo

c)\nwhere an action has been taken under section 132 or\nsection 132A, after the expiry of one month from the date\non which he was served with a notice under sub-section\n(1) of section 153A or sub-section (2) of section 153C or\nafter the completion of the assessment, whichever is\nearlier.]\n6.2 This has been upheld

SOMNATH RAMDAS JADHAV,AHMEDNAGAR vs. ITO WARD 2, AHMEDNAGAR, AHMEDNAGAR

In the result, the appeal filed by the assessee in ITA\nNo

c) where an action has been taken under section 132 or\nsection 132A, after the expiry of one month from the date\non which he was served with a notice under sub-section\n(1) of section 153A or sub-section (2) of section 153C or\nafter the completion of the assessment, whichever is\nearlier.]\n6.2 This has been upheld

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

Section 80IA/IB of the Act.\nIt must follow that there is due application of mind by the Assessing\nOfficer to the issue raised.\nThe above observations apply on all fours to this Petition, so far as the\nRevenue's submission of no change of opinion is concerned.\n11. The further submission of Mr. Walve that in the absence

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

Section 80IA/IB of the Act.\nIt must follow that there is due application of mind by the Assessing\nOfficer to the issue raised.\nThe above observations apply on all fours to this Petition, so far as the\nRevenue's submission of no change of opinion is concerned.\n11. The further submission of Mr. Walve that in the absence

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

147, as the case may be, has been paid within the period specified in such notice of demand; and (b) no appeal against the order referred to in clause (a) has been filed. 8 ITA No.1260/PUN/2025, AY 2020-21 (2) An application referred to in sub-section (1) shall be made within one month from the end of the month

SATYAPREM RAJABHAU DHOLE,BEED vs. ITO, WARD-1(5), AURANGABAD, AURANGABAD

In the result, the appeal of the assessee is allowed

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

u/s 148 was issued to the assessee on 07.04.2022 which is clearly beyond the time limit prescribed under the said provisions of the Act. We find that the Revenue has also conceded before the Hon’ble Supreme Court in the case of Rajeev Bansal (supra) that the provisions of Taxation and Other Laws (Relaxation and Amendment of Certain Provisions

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

271(1)(c)/270A, etc. As against, no any Penalty per se, is applicable for taxation u/s 115BBC As such, forming 'reasons' for one phenomenon, and taxing the same for some different phenomenon, is completely conflicting. Learned AO is incorrect is starting the 147 proceedings for S. 68, continuing the same for S. 68; and concluding the matter

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

271(1)(c)/270A, etc. As against, no any Penalty per se, is applicable for taxation u/s 115BBC As such, forming 'reasons' for one phenomenon, and taxing the same for some different phenomenon, is completely conflicting. Learned AO is incorrect is starting the 147 proceedings for S. 68, continuing the same for S. 68; and concluding the matter

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

271(1)(c)/270A, etc. As against, no any Penalty per se, is applicable for taxation u/s 115BBC As such, forming 'reasons' for one phenomenon, and taxing the same for some different phenomenon, is completely conflicting. Learned AO is incorrect is starting the 147 proceedings for S. 68, continuing the same for S. 68; and concluding the matter

MEERA ANIRUDHA MIRGUNDE,PUNE vs. THE INCOME TAX OFFICER,WARD-6(1), PUNE, PUNE

In the result, the appeal of assessee is allowed

Bench: Shri R.S. Syal & Shri S.S. Viswanethra Ravi

147 of the Act. The AO initiated penalty proceedings u/s. 271(1)(c) of the Act treating the returned income in response to the notice u/s. 148 of the Act as concealment of income, accordingly imposed penalty of Rs.1,50,000/- u/s. 271(1)(c) of the Act. The NFAC, Delhi confirmed the same. 4. Before

SACHIN BADRINARAYAN SOMANI,PUNE vs. ITO WARD , HINGOLI

In the result, both the appeals of the assessee are allowed for statistical purposes

Bench: Dr. Manish Borad & Shri Vinay Bhamoreआयकर अपील सं./Ita No. 2112 & 2113/Pun/2025 धििेंारण वर्ा /Assessment Year: 2013-14 Sachin Badrinarayan Somani, Ito Ward, Hingoli Rathi Rathi & Co., 501-504, Akshay Landmarks, Oppo. Pu Vs. La Garden, Sinhagad Road, Pune-411030 Maharashtra Pan-Cncps2724N अपीलेंर्थी / Appellant प्रत्यर्थी / Respondent Assessee By: Shri Nemin Shah Department By: Shri Ganesh B. Budruk-Addl. Cit Date Of Hearing: 18-12-2025 Date Of Pronouncement: 23-12-2025 आदीश /Order

u/s 271(1)(c) of the Act. 6. We note that the assessee is an individual and in the reassessment proceedings carried out by Ld. AO based on the information about cash deposit in saving bank account with M/s Shri Renuka Mata Multi State Urban Co-operative Society Ltd. to the tune of Rs. 2,32,53,205/-, the assessee

SACHIN BADRINARAYAN SOMANI,PUNE vs. ITO WARD , HINGOLI

In the result, both the appeals of the assessee are allowed for statistical purposes

Bench: Dr. Manish Borad & Shri Vinay Bhamoreआयकर अपील सं./Ita No. 2112 & 2113/Pun/2025 धििेंारण वर्ा /Assessment Year: 2013-14 Sachin Badrinarayan Somani, Ito Ward, Hingoli Rathi Rathi & Co., 501-504, Akshay Landmarks, Oppo. Pu Vs. La Garden, Sinhagad Road, Pune-411030 Maharashtra Pan-Cncps2724N अपीलेंर्थी / Appellant प्रत्यर्थी / Respondent Assessee By: Shri Nemin Shah Department By: Shri Ganesh B. Budruk-Addl. Cit Date Of Hearing: 18-12-2025 Date Of Pronouncement: 23-12-2025 आदीश /Order

u/s 271(1)(c) of the Act. 6. We note that the assessee is an individual and in the reassessment proceedings carried out by Ld. AO based on the information about cash deposit in saving bank account with M/s Shri Renuka Mata Multi State Urban Co-operative Society Ltd. to the tune of Rs. 2,32,53,205/-, the assessee

TEJAS SHIVAJI ADSUL,KOLHAPUR vs. INCOME TAX OFFICER WARD 1(1), KOLHAPUR, KOLHAPUR

In the result, appeal of the assessee is allowed

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

c) the income reassessed is greater than the income assessed or reassessed immediately before such reassessment; 5 ITA No.59/PUN/2025, AY 2018-19 (d) the amount of deemed total income assessed or reassessed as per the provisions of section 115JB or section 115JC, as the case may be, is greater than the deemed total income determined in the return processed under