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

45 (Rajasthan) [ref para 62] & the Karnataka High Court decision in Pr. CIT v. VSL Mining Company (P.) Ltd. [2024] 167 taxmann.com 373 (Karnataka) [ref para 64]. 2. Amar Jewellers Ltd vs Paras 46, 47, 48, 49, 52, 53, 55, 76 & 84. ACIT (2022) 444 ITR 97 Even assessments completed u/s 153A (Guj) dtd 31-01-2022 were reopened u/s

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

45,690/-\n7.\nThe assessee filed an appeal before the Ld. CIT(A) against this order also.\nThe Ld. CIT(A) in the consolidated order dated 10.10.2023 passed the order i.e. in\nrespect of order passed u/s 143(3) r.w.s.147 and u/s 143(3) r.w.s.263 of the Act\nand dismissed both the appeals.\n8.\nAggrieved with such order

DEPUTY DIRECTOR OF INCOME-TAX,, PUNE vs. SANDVIK A B.,, PUNE

Bench: Ms. Sushma Chowla, Jm & Shri D. Karunakara Rao, Am आयकर अपीऱ सं. / Ita No.608/Pun/2014 यििाारण वषा / Assessment Year :2006-07

u/s. 148 are explicit and good enough to make out a fit case for re-opening of the assessment. 5. On the facts and circumstances of the present case, the learned DRP erred in not following the decision of the Hon'ble jurisdictional ITAT, Pune in the case of Cummins Inc. in ITA Nos.73&74/PN/2011 dtd. 8/08/2013 wherein the assessee

DEPUTY DIRECTOR OF INCOME-TAX vs. SANDVIK A B.,, PUNE

Bench: Ms. Sushma Chowla, Jm & Shri D. Karunakara Rao, Am आयकर अपीऱ सं. / Ita No.608/Pun/2014 यििाारण वषा / Assessment Year :2006-07

u/s. 148 are explicit and good enough to make out a fit case for re-opening of the assessment. 5. On the facts and circumstances of the present case, the learned DRP erred in not following the decision of the Hon'ble jurisdictional ITAT, Pune in the case of Cummins Inc. in ITA Nos.73&74/PN/2011 dtd. 8/08/2013 wherein the assessee

DEPUTY COMMISSIONER OF INCOME-TAX,, PUNE vs. M/S. SECO TOOLS INDIA PVT. LTD.,, PUNE

In the result, the Cross Objections of assessee are allowed and appeals of Revenue are dismissed

Bench: Ms. Sushma Chowla, Jm & Shri Anil Chaturvedi, Am आयकर अपीऱ सं. / Ita Nos.812 & 813/Pun/2017 यििाारण वषा / Assessment Years : 2002-03 & 2003-04

45. Further, the learned Authorized Representative for the assessee referred to reasons recorded for reopening of assessment dated 26.07.2013 in the case of Sandvik Australia Pty Ltd., relating to assessment year 2008-09 along with Note filed in the computation of income and relevant Annexure to Form No.3CEB, which are attached at pages 46 to 51 of Compilation No.II

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

45,890) after adjusting the incremental liability that may arise on disallowing health and education Cess. He, therefore, submitted that there is no basis for holding that the assessee has under-reported its income or done any act without good faith and due diligence and hence the provisions of section 270A of the Act do not apply 5 ITA No.1260/PUN/2025

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

KALYANCHAND MANAKCHAND LALWANI, HUF,,NASHIK vs. INCOME-TAX OFFICER,,

In the result, both the appeals filed by the assessees are partly allowed

Bench: Shri D. Karunakara Rao, Am

u/s 147 initiated by issue of notice/s served on 08/03/2011 after expiry of four years in absence of reason to believe that there was failure to disclose fully and truly all material facts necessary for his assessment within the meaning of first proviso to Section 147. 8. Before me, Ld. Counsel for the assessee brought my attention to the additional

KAMLESH KALYANCHAND LALWANI, HUF,,NASHIK vs. INCOME-TAX OFFICER,,

In the result, both the appeals filed by the assessees are partly allowed

Bench: Shri D. Karunakara Rao, Am

u/s 147 initiated by issue of notice/s served on 08/03/2011 after expiry of four years in absence of reason to believe that there was failure to disclose fully and truly all material facts necessary for his assessment within the meaning of first proviso to Section 147. 8. Before me, Ld. Counsel for the assessee brought my attention to the additional

MANGLESH KALYANCHAND LALWANI, HUF,,NASHIK vs. INCOME-TAX OFFICER,,

In the result, both the appeals filed by the assessees are partly allowed

Bench: Shri D. Karunakara Rao, Am

u/s 147 initiated by issue of notice/s served on 08/03/2011 after expiry of four years in absence of reason to believe that there was failure to disclose fully and truly all material facts necessary for his assessment within the meaning of first proviso to Section 147. 8. Before me, Ld. Counsel for the assessee brought my attention to the additional

DIMPLE RAJESH OSWAL,PUNE vs. INCOME TAX OFFICER WARD 5(1), PUNE

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

Bench: Shri R. K. Pandaassessment Year : 2016-17

u/s 143(3) r.w.s. 147 of the Act has determined the total income at Rs.19,60,971/-, however, in the computation statement he has determined the same at Rs.31,97,261/- which is not correct. 7. The second plank of his argument is that the assessee has purchased the property during the year 2012 for a consideration of Rs.46

MRS. VASUNDHARA SHAILESH JOSHI,,PUNE vs. DEPUTY COMMISSIONER OF INCOME-TAX,,

In the result, appeals in the case of Mrs

Bench: Ms. Sushma Chowla, Jm & Shri D. Karunakara Rao, Am आयकर अपीऱ सं. / Ita Nos.95 & 96/Pun/2016 यििाारण वषा / Assessment Years : 2009-10 & 2010-11

45 taxmann.com 144 (Kar), wherein it has been held that Chpter XIV-B does not preclude the Assessing Officer to proceed against the assessee by issuing notice under section 148 of the Act. He thus, stressed that after search proceedings carried out in the case of another person, it was open to the Assessing Officer either to proceed under Chapter

JOSHI WADEWALE SHEWALWADI,,PUNE vs. DEPUTY COMMISSIONER OF INCOME-TAX,,

In the result, appeals in the case of Mrs

Bench: Ms. Sushma Chowla, Jm & Shri D. Karunakara Rao, Am आयकर अपीऱ सं. / Ita Nos.95 & 96/Pun/2016 यििाारण वषा / Assessment Years : 2009-10 & 2010-11

45 taxmann.com 144 (Kar), wherein it has been held that Chpter XIV-B does not preclude the Assessing Officer to proceed against the assessee by issuing notice under section 148 of the Act. He thus, stressed that after search proceedings carried out in the case of another person, it was open to the Assessing Officer either to proceed under Chapter

JOSHI WADEWALE SHEWALWADI,,PUNE vs. DEPUTY COMMISSIONER OF INCOME-TAX,,

In the result, appeals in the case of Mrs

Bench: Ms. Sushma Chowla, Jm & Shri D. Karunakara Rao, Am आयकर अपीऱ सं. / Ita Nos.95 & 96/Pun/2016 यििाारण वषा / Assessment Years : 2009-10 & 2010-11

45 taxmann.com 144 (Kar), wherein it has been held that Chpter XIV-B does not preclude the Assessing Officer to proceed against the assessee by issuing notice under section 148 of the Act. He thus, stressed that after search proceedings carried out in the case of another person, it was open to the Assessing Officer either to proceed under Chapter

JOSHI WADEWALE PRABHAT CINEMA,,PUNE vs. DEPUTY COMMISSIONER OF INCOME-TAX,,

In the result, appeals in the case of Mrs

Bench: Ms. Sushma Chowla, Jm & Shri D. Karunakara Rao, Am आयकर अपीऱ सं. / Ita Nos.95 & 96/Pun/2016 यििाारण वषा / Assessment Years : 2009-10 & 2010-11

45 taxmann.com 144 (Kar), wherein it has been held that Chpter XIV-B does not preclude the Assessing Officer to proceed against the assessee by issuing notice under section 148 of the Act. He thus, stressed that after search proceedings carried out in the case of another person, it was open to the Assessing Officer either to proceed under Chapter

JOSHI WADEWALE HADAPSAR,,PUNE vs. DEPUTY COMMISSIONER OF INCOME-TAX,,

In the result, appeals in the case of Mrs

Bench: Ms. Sushma Chowla, Jm & Shri D. Karunakara Rao, Am आयकर अपीऱ सं. / Ita Nos.95 & 96/Pun/2016 यििाारण वषा / Assessment Years : 2009-10 & 2010-11

45 taxmann.com 144 (Kar), wherein it has been held that Chpter XIV-B does not preclude the Assessing Officer to proceed against the assessee by issuing notice under section 148 of the Act. He thus, stressed that after search proceedings carried out in the case of another person, it was open to the Assessing Officer either to proceed under Chapter

MRS. VASUNDHARA SHAILESH JOSHI,,PUNE vs. DEPUTY COMMISSIONER OF INCOME-TAX,,

In the result, appeals in the case of Mrs

Bench: Ms. Sushma Chowla, Jm & Shri D. Karunakara Rao, Am आयकर अपीऱ सं. / Ita Nos.95 & 96/Pun/2016 यििाारण वषा / Assessment Years : 2009-10 & 2010-11

45 taxmann.com 144 (Kar), wherein it has been held that Chpter XIV-B does not preclude the Assessing Officer to proceed against the assessee by issuing notice under section 148 of the Act. He thus, stressed that after search proceedings carried out in the case of another person, it was open to the Assessing Officer either to proceed under Chapter