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

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

reassessment under Sections 139, 147, 148, 149, 151 & 153.\n28. The language of explanation 2 to new Section 148 is akin to Section\n153A and Section 153C. Corollary being that after seizing of\noperational 18 February, 2025 WP3057_2019.DOC period of Section\n153A to 153D, the cases being dealt thereunder were circumscribed in the\nscope of newly substituted 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

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, section 148, 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

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

reassessment u/s 147 on the basis that assessment\nshould have been framed u/s 153A/153C of the Act.\nb. The DR has relied upon the decision of Hon'ble SC in the case of Rajesh\nJhaveri Stock Brokers (P) Ltd that there should be only ‘reason to believe'.\nHowever, the following decisions delivered after above decision have analyzed\nthe term “reason

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

reassessment u/s 147 on the basis that assessment\nshould have been framed u/s 153A/153C of the Act.\nb. The DR has relied upon the decision of Hon'ble SC in the case of Rajesh\nJhaveri Stock Brokers (P) Ltd that there should be only ‘reason to believe'.\nHowever, the following decisions delivered after above decision have analyzed\nthe term “reason

M/S. RAJLAXMI PETROCHEM PVT.LTD,,LATUR vs. INCOME-TAX OFFICER, WARD - 1,, LATUR

Appeals are allowed in above terms

Bench: Shri Satbeer Singh Godara & Dr. Dipak P. Ripote

u/s. 263 of the Income Tax Act, 1961 (in short "the Act"). 2. Heard both the parties. Case files perused. 3. It emerges during the course of hearing that relevant facts in assessee’s former twin appeals hardly require us to delve deeper in the relevant factual matrix so far as its first and foremost substantive grievance challenging correctness

M/S. RAJLAXMI PETROCHEM PVT.LTD,,LATUR vs. INCOME-TAX OFFICER, WARD - 1,, LATUR

Appeals are allowed in above terms

Bench: Shri Satbeer Singh Godara & Dr. Dipak P. Ripote

u/s. 263 of the Income Tax Act, 1961 (in short "the Act"). 2. Heard both the parties. Case files perused. 3. It emerges during the course of hearing that relevant facts in assessee’s former twin appeals hardly require us to delve deeper in the relevant factual matrix so far as its first and foremost substantive grievance challenging correctness

M/S. RAJLAXMI PETROCHEM PVT.LTD,,LATUR vs. PRINCIPAL COMMISSIONER OF INCOME-TAX, , NASHIK

Appeals are allowed in above terms

Bench: Shri Satbeer Singh Godara & Dr. Dipak P. Ripote

u/s. 263 of the Income Tax Act, 1961 (in short "the Act"). 2. Heard both the parties. Case files perused. 3. It emerges during the course of hearing that relevant facts in assessee’s former twin appeals hardly require us to delve deeper in the relevant factual matrix so far as its first and foremost substantive grievance challenging correctness

SHRI SHANTINATH BHAGWAN JAIN SHWETAMBAR MURTIPUJAK SANGH,PUNE vs. CIT, EXEMPTION,, PUNE

Appeal is allowed

Bench: Shri S.S. Godara & Shri G.D. Padmahshali

u/s. 263 of the Income Tax Act, 1961; in short “the Act”. Heard both the parties. Case file perused. 2 ITA No.203/PUN/2021, A.Y. 2010-11 2. It emerges at the outset that the CIT(E)’s impugned order exercising section 263 revision jurisdiction terms the corresponding assessment /reassessment herein dated 29-09-2017 as an erroneous one causing prejudice

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

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.‖. 5.3 Before leaping to section 270A of the Act, we first consider section 270AA of the Act in order to find out whether the Form 68 filed by the Assessee Company on 06/10/2022

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

147, section 148, 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

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

147, section 148, 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

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

147, section 148, 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

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

147, section 148, 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

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

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

reassess the income of the other person in accordance\nwith the provisions of section 153A of the Act (emphasis supplied\nby us).\n19. In the instant case, the reopening of the assessment was\nbased on the basis of information that emerged from the\nstatement of Shri Sachin Nahar u/s 132(4) and on the basis of\ndetails of notings

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

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

147.\nAccordingly, this Additional Ground is not maintainable and dismissed.\n7. Decision on Ground Nos.1 to 4:\n7.1 As discussed earlier, the appellant did not file any return of\nincome in response to the notice issued u/s 148 of the IT Act. If we go\nthrough the grounds of appeal, it is seen that the appellant did not\ndispute

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

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