DCIT CIRCLE 1 NASHIK, NASHIK vs. SHREE SAI PROPERTIES, NASHIK

In the result, appeal of the Revenue is dismissed

Bench: Dr. Manish Borad & Shri Vinay Bhamore

reassessment under Sections 139, 147, 148, 149, 151 & 153. 28. The language of explanation 2 to new Section 148 is akin to Section 153A and Section 153C Corollary being that after seizing of operational period of Section 153A to 153D. the cases being dealt thereunder were circumscribed in the scope of newly substituted Section 148." We are in complete agreement

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

reassessment notice under section 148 of the new regime. Thus, in this\nillustration, the time limit for issuance of a notice under section 148 of the new\nregime will end on 18 August 2022.\n22. He submitted that it is abundantly clear from the above decision that the time\nbetween the issue of original notice u/s 148 under

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

36(1)(va) of the Act treating as under reported under sub section (2) of Section 270A of the Act whereas disallowance of deduction of Health & education cess u/s 37 of the Act was considered under reported is in consequence of misreporting of income under section 270A(2) rws 270(9) of the Act. 5.2 For the purpose of evaluating

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

36 before the Hon'ble ITAT in support of the claim of the appellant that in view of the facts of the appellant's case as the income voluntarily declared in the Revised return of income had been accepted by the Assessing Officer and assessed as such in the assessment order, no penalty in assessee's u/s 271(1

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 by issuing notice u/s 148A(d) of the Act on 25.07.2022 by recording\nas under:\n“GOVERNMENT OF INDIA\nMINISTRY OF FINANCE\nINCOME TAX DEPARTMENT\nOFFICE OF THE ASSISTANT\nCOMMISSIONER OF INCOME TAX\nCIRCLE 7, PUNE\nTo\nKOLTE-PATIL\nINTEGRATED\nTOWNSHIPS\nLIMITED\nSURVEY NO. 74, MARUNJI HINJEWADI\nMARUNJI, KASARSAI ROAD, TAL MULSHI\nPUNE PUNE 411057, Maharashtra India\nPAN

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 is after expiry of the four years from the end of A.Y.2012-13 and therefore the reassessment proceeding are initiated beyond the time limit and are thus time barred and bad in law and not sustainable. 4. Learned CIT(A) has erred in fact and in law in confirming the addition made by A.O. without considering the fact that reassessment

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 is after expiry of the four years from the end of A.Y.2012-13 and therefore the reassessment proceeding are initiated beyond the time limit and are thus time barred and bad in law and not sustainable. 4. Learned CIT(A) has erred in fact and in law in confirming the addition made by A.O. without considering the fact that reassessment

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 is after expiry of the four years from the end of A.Y.2012-13 and therefore the reassessment proceeding are initiated beyond the time limit and are thus time barred and bad in law and not sustainable. 4. Learned CIT(A) has erred in fact and in law in confirming the addition made by A.O. without considering the fact that reassessment

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

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

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

36. 5. Ground Nos. 1 and 2 raised by the assessee challenging the action of CIT(A) in holding the assessment passed u/s. 143(3) r.w.s. 144A r.w.s. 147 of the Act dated 30-03-2015 is valid under law. 6. The brief facts of the case are that the assessee is a company engaged in the business of computer

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

36. 5. Ground Nos. 1 and 2 raised by the assessee challenging the action of CIT(A) in holding the assessment passed u/s. 143(3) r.w.s. 144A r.w.s. 147 of the Act dated 30-03-2015 is valid under law. 6. The brief facts of the case are that the assessee is a company engaged in the business of computer

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

In the result, appeal of the assessee is allowed

Bench: Shri Rama Kanta Panda & Ms. Astha Chandra

36,98,30,710/- and subsequently filed return against notice issued u/s 148 of the Act declaring income at Rs. 38,31,53,640/- and reassessed completed at the same. income. So the total income has been increased in reassessment order u/s 147 of the Act in comparison to the income declared by the appellant in the return u/s

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)

1. Whether on facts and in law, disallowance u/s 14A of the Income Tax Act can be made on expenditure incurred for earning exempt income where the interest free funds were sufficient and available to make investment earning exempt income? 2. Whether on facts and in law, disallowance u/s 14A of the Income Tax Act can be made on expenditure

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)

1. Whether on facts and in law, disallowance u/s 14A of the Income Tax Act can be made on expenditure incurred for earning exempt income where the interest free funds were sufficient and available to make investment earning exempt income? 2. Whether on facts and in law, disallowance u/s 14A of the Income Tax Act can be made on expenditure

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)

1. Whether on facts and in law, disallowance u/s 14A of the Income Tax Act can be made on expenditure incurred for earning exempt income where the interest free funds were sufficient and available to make investment earning exempt income? 2. Whether on facts and in law, disallowance u/s 14A of the Income Tax Act can be made on expenditure

ASHOK BHARTI GOSWAMI,PUNE vs. ACIT, CENTRAL CIRCLE 2(1), PUNE , PUNE

In the result, all the appeals filed by the respective assessees are allowed

Bench: Shri R. K. Panda & Shri Vinay Bhamore

147, section 140, section 149, section 151 and section 153, where the Assessing Officer is satisfied that- (a) any money, bullion, jewellery or other valuable article or thing, seized or requisitioned, belongs to or (b) any books of account or documents, seized or requisitioned, pertains or pertain to, or any information contained therein, relates to, a person other than

CHITRA NARENDRA PARMAR,PUNE vs. ASSISTANT COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-2(1), PUNE, PUNE

In the result, all the appeals filed by the respective assessees are allowed

Bench: Shri R. K. Panda & Shri Vinay Bhamore

147, section 140, section 149, section 151 and section 153, where the Assessing Officer is satisfied that- (a) any money, bullion, jewellery or other valuable article or thing, seized or requisitioned, belongs to or (b) any books of account or documents, seized or requisitioned, pertains or pertain to, or any information contained therein, relates to, a person other than

RAMLAL BHIKULAL SHAH,PUNE vs. ACIT, CENTRAL CIRCLE 2(1), PUNE , PUNE

In the result, all the appeals filed by the respective assessees are allowed

Bench: Shri R. K. Panda & Shri Vinay Bhamore

147, section 140, section 149, section 151 and section 153, where the Assessing Officer is satisfied that- (a) any money, bullion, jewellery or other valuable article or thing, seized or requisitioned, belongs to or (b) any books of account or documents, seized or requisitioned, pertains or pertain to, or any information contained therein, relates to, a person other than

CHITRA NARENDRA PARMAR ,PUNE vs. ACIT, CENTRAL CIRCLE 2(1), PUNE , PUNE

In the result, all the appeals filed by the respective assessees are allowed

Bench: Shri R. K. Panda & Shri Vinay Bhamore

147, section 140, section 149, section 151 and section 153, where the Assessing Officer is satisfied that- (a) any money, bullion, jewellery or other valuable article or thing, seized or requisitioned, belongs to or (b) any books of account or documents, seized or requisitioned, pertains or pertain to, or any information contained therein, relates to, a person other than