INCOME TAX OFFICER, PUNE vs. SAGAR CONSTRUCTION COMPANY, PUNE

In the result, the appeal filed by the Revenue is dismissed and the CO filed by the assessee is allowed

Bench: Shri R. K. Panda & Ms. Astha Chandraassessment Year : 2017-18

reassessment in respect of all 6 years can be made even if original returns are already processed u/s 143(1)(a) and the Assessing Officer has power u/s 153A to make assessment for all six years and compute total income of assessee, including undisclosed income, notwithstanding that returns for these years have already been processed u/s

ASHOK DHANRAJ CHORDIA ,PUNE vs. PCIT, PUNE-1, PUNE

31 March, 2021, the Assessing Officer shall have\njurisdiction to issue notice to such person to furnish the return of income as\nspecified in the notice or assess or reassess the total income as provided by the\nprovision. Section 153C also begins with a non-obstante 18 February, 2025\nWP3057_2019.DOC clause, when it provides that notwithstanding anything\ncontained in Section

SATISH VISHNU THOMBARE, INCOME TAX OFFICER, WARD-1, AHMEDNAGAR, AHMEDNAGAR vs. VARSHA PRAFULLA ZENDE, AHMEDNAGAR

In the result, the appeal of the Revenue is dismissed

Bench: Shri R.K. Panda & Ms. Astha Chandraआयकर अपील सं. / Ita No.1656/Pun/2024 धििाारण वर्ा / Assessment Year : 2010-11 Satish Vishnu Thombare, Varsha Prafulla Zende, Income Tax Officer, Prop Of Bleach Chem Enterprises, Ward-1, Ahmednagar Vs. Industrial Estate, Shrirampur, Maharashtra-413709 Pan : Aabpz2541C अपीलार्थी / Appellant प्रत्यर्थी / Respondent Assessee By : Miss Shivani Shah (Virtual) Department By : Shri Akhilesh Srivastva Date Of Hearing : 06-08-2025 Date Of 29-10-2025 Pronouncement : आदेश / Order

reassess such income and also any other income chargeable to tax, which has escaped assessment and which comes to his notice subsequently in the course of the proceedings under the section. The first proviso to section 147 has no application in the facts of this case. The basic postulate which underlines section 147 is the formation of the belief

DEPUTY COMMISSIONER OF INCOME-TAX vs. CLARION TECHNOLOGIES PVT. LTD.,, PUNE

In the result, the appeal of assessee is allowed

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

section 153 of the Act explains that no order of assessment, reassessment or recomputation shall be made u/s. 12 ITA Nos.331 & 421/PUN/2016, A.Y. 2009-10 147 of the Act after the expiry of one year from the end of the financial year in which the notice u/s. 148 of the Act was served. In the present case, we note that

CLARION TECHNOLOGIES PVT. LTD.,,PUNE vs. DEPUTY COMMISSIONER OF INCOME-TAX,,

In the result, the appeal of assessee is allowed

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

section 153 of the Act explains that no order of assessment, reassessment or recomputation shall be made u/s. 12 ITA Nos.331 & 421/PUN/2016, A.Y. 2009-10 147 of the Act after the expiry of one year from the end of the financial year in which the notice u/s. 148 of the Act was served. In the present case, we note that

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

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

31,47,670/-. This case was not subjected to Scrutiny assessment u/s. 143(3) of the Act. 2. Brief details of information collected/received by AO : In this case information in respect of Shri NARENDRA SAMPATLAL BAFNA, being Cash loan of Rs.6,20,00,000/- was received from DCIT Central Circle 1(1) Pune through the Insight Portal. The Information

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

147.\nAs per the decision of Hon'ble Supreme Court in the case of Rajeev Bansal [167\ntaxmann.com 70], the notice under the new provision of section 148 have to be\nseen considering the proviso to section 149. We find in the instant case for both\nthe assessment years the Assessing Officer had initially issued notice u/s 148 in\nJune

A.C.I.T ,WARDHA CIRCLE , WARDHA , WARDHA vs. M/S KAPIL SOLVEX PVT .LTD , YAVATMAL

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

Bench: Shri R. K. Panda & Ms Astha Chandraassessment Year : 2009-10

31. Therefore, these amounts are considered as unexplained cash credits u/s 68 of the Act. An addition of Rs.4,55,00,000/- is therefore made to the income of the assessee. [Addition: Rs. 4,55,00,000/-] 6. Before the CIT(A) the assessee, apart from challenging the addition on merit, challenged the validity of reopening of the assessment

SACHIN MOHANLAL CHORDIA,PUNE vs. INCOME TAX OFFICER WARD 5(1), PUNE

Appeal of the assessee is partly allowed as we do not intend to adjudicate other grounds raised by the assessee

Bench: Ms. Astha Chandra & Dr. Dipak P. Ripoteआयकर अपील सं. / Ita Nos.3280 & 3281/Pun/2025 िनधा"रण वष" / Assessment Years: 2016-17 & 2017-18 Sachin Mohanlal Chordia, V The Income Tax Officer, B-101, Isha Emerald, S. Ward-5(1), Pune. Bibwewdi, Kondhwa Road, Marketyard, Pune- 411037. Pan: Aanpc8554C Appellant Respondent Assessee By Shri Abhilash Hiran Revenue By Shri Amit Bobade & Shri Sanjay Dhivare (Virtual) Date Of Hearing 05/03/2026 Date Of Pronouncement 30/03/2026 आदेश/ Order Per Bench : These Are Two Appeals Filed By Assessee Against The Separate Orders Of Commissioner Of Income Tax (Appeal) (Nfac) U/S 250 Of The Income Tax Act 1961 For Ay 2016-17, 2017-18 Passed On 22/10/2025 Emanating From Separate Assessment Orders U/S 147 Rws 144 Dated 11/05/2023 & 23/05/2023. 2. The Grounds Of Appeal Raised By The Assessee Are As Under:

u/s 148 issued between 01.04.2021 and June 30,2021 under old regime 4.4 The notification issued by the Central Government under section 3(1) of TOLA contained an explanation that provisions of section 147 to 151 of the Act prior to April 1, 2021 (herein after referred to as “old regime”) shall be applied to reassessment proceedings initiated under them

SACHIN MOHANLAL CHORDIA,PUNE vs. INCOME TAX OFFICER WARD 5(1), PUNE

Appeal of the assessee is partly allowed as we do not intend to adjudicate other grounds raised by the assessee

Bench: Ms. Astha Chandra & Dr. Dipak P. Ripoteआयकर अपील सं. / Ita Nos.3280 & 3281/Pun/2025 िनधा"रण वष" / Assessment Years: 2016-17 & 2017-18 Sachin Mohanlal Chordia, V The Income Tax Officer, B-101, Isha Emerald, S. Ward-5(1), Pune. Bibwewdi, Kondhwa Road, Marketyard, Pune- 411037. Pan: Aanpc8554C Appellant Respondent Assessee By Shri Abhilash Hiran Revenue By Shri Amit Bobade & Shri Sanjay Dhivare (Virtual) Date Of Hearing 05/03/2026 Date Of Pronouncement 30/03/2026 आदेश/ Order Per Bench : These Are Two Appeals Filed By Assessee Against The Separate Orders Of Commissioner Of Income Tax (Appeal) (Nfac) U/S 250 Of The Income Tax Act 1961 For Ay 2016-17, 2017-18 Passed On 22/10/2025 Emanating From Separate Assessment Orders U/S 147 Rws 144 Dated 11/05/2023 & 23/05/2023. 2. The Grounds Of Appeal Raised By The Assessee Are As Under:

u/s 148 issued between 01.04.2021 and June 30,2021 under old regime 4.4 The notification issued by the Central Government under section 3(1) of TOLA contained an explanation that provisions of section 147 to 151 of the Act prior to April 1, 2021 (herein after referred to as “old regime”) shall be applied to reassessment proceedings initiated under them

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

RAJDEEP BUILDCON PRIVAT LIMITED, AHMEDNAGAR,AHMEDNAGAR vs. DY. COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE 1(2), PUNE, PUNE

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

Bench: SHRI R. K. PANDA (Vice President), SHRI VINAY BHAMORE (Judicial Member)

31-5-2003, assessment has to be made under section 153A. [Para 8] Section 1534(1) contains non obstante clause and, hence, provisions of this section will override the provisions of sections 139, 147, 148, 149, 151 and 153. Under section 1534(1), the Assessing Officer is empowered to issue notices to the assexsee searched for a period

RAJDEEP BUILDCON PVT LTD, AHMEDNAGAR,AHMEDNAGAR vs. DY. COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE 1(2), PUNE, PUNE

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

Bench: SHRI R. K. PANDA (Vice President), SHRI VINAY BHAMORE (Judicial Member)

31-5-2003, assessment has to be made under section 153A. [Para 8] Section 1534(1) contains non obstante clause and, hence, provisions of this section will override the provisions of sections 139, 147, 148, 149, 151 and 153. Under section 1534(1), the Assessing Officer is empowered to issue notices to the assexsee searched for a period

RAJDEEP BUILDCOM PRIVATE LIMITED,AHMEDNAGAR vs. DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE - 1(2), PUNE, PUNE

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

Bench: SHRI R. K. PANDA (Vice President), SHRI VINAY BHAMORE (Judicial Member)

31-5-2003, assessment has to be made under section 153A. [Para 8] Section 1534(1) contains non obstante clause and, hence, provisions of this section will override the provisions of sections 139, 147, 148, 149, 151 and 153. Under section 1534(1), the Assessing Officer is empowered to issue notices to the assexsee searched for a period

SUBHASH RUNWAL,BIBWEWADI, PUNE vs. INCOME TAX OFFICER WARD 5(4) PUNE, PUNE

The appeal of the assessee is ALLOWED

Bench: Hon’Ble Shri G. D. Padmahshali & Hon’Ble Shri Vinay Bhamoreassessment Year : 2012-13 Subhash Runwal 204, Solitari-5, Nr. Kalyan Bhel, Bibwewadi Rd., Pune-411037. Pan: Adbpr7670R. . . . . . . . Appellant

reassessment order u/s 144 r.w.s. 147 was passed, the Ld. ITAT-Pune Page 8 of 16 Subhash Runwal Vs ITO ITA No. 1279/PUN/2024 AY: 2012-13 AO besides making a token addition of interest income of out of the reasons recorded was also made two bullet additions which newly came to his notice during such reopened proceedings; (1) ₹10Lakhs

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

147 read with 144B of the Income Tax Act 1961. Assessee was requested to submit response through registered e-filing account at www.incometax.gov.in by 11:00 hours of 11/10/2023. The assessee did not comply with the notice on stipulated date and time even as on date. Show cause under clause (xii) (b) of section 144B of the Income

INCOME TAX OFFICER, WARD-1, JALNA, JALNA vs. OMPRAKASH ASARAM MANTRI, JALNA

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

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

31. We do not find any infirmity in the order of the Ld. CIT(A) on this issue. Admittedly the original assessment was completed u/s 143(3) r.w.s. 153A of the Act. It is also an admitted fact that during the course of assessment proceedings the Assessing Officer has raised specific queries on the issue of long term capital gain

INCOME TAX OFFICER, WARD-1, JALNA, JALNA vs. ASHISH OMPRAKASH MANTRI, JALNA

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

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

31. We do not find any infirmity in the order of the Ld. CIT(A) on this issue. Admittedly the original assessment was completed u/s 143(3) r.w.s. 153A of the Act. It is also an admitted fact that during the course of assessment proceedings the Assessing Officer has raised specific queries on the issue of long term capital gain

INCOME TAX OFFICER, WARD -1, JALNA, JALNA vs. PRAMILA OMPRAKASH MANTRI, JALNA

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

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

31. We do not find any infirmity in the order of the Ld. CIT(A) on this issue. Admittedly the original assessment was completed u/s 143(3) r.w.s. 153A of the Act. It is also an admitted fact that during the course of assessment proceedings the Assessing Officer has raised specific queries on the issue of long term capital gain