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

3) Nothing contained in this section shall apply in relation to a search initiated under section 132 or books of account, other documents or any assets requisitioned under section 132A on or after the 1st day of April, 2021. 16. On a plain reading of Section 153A, it is clear that it begins with a 'non- obstante' clause, when

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

45,000\n60,000\n9\n1500\n1500000\nASHOK C\nASHOK D CHORDIYA\n1,75,500\n45,000\n14.\nReferring to the papers enclosed with the chart submitted by the ACIT,\nCentral Circle 1(1), Pune, the details of which are placed at pages 8 to 13 of the\npaper book, the Ld. Counsel for the assessee drew the attention

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

SHRI 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

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

ITO, WARD-1(1), SOLAPUR, SOLAPUR vs. MS. KSHIRSAGAR FABRICS, SOLAPUR

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

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

reassessment notice as the AO has not established that new facts material or information came the knowledge of the AO which was not on record and available at the time of assessment. It is clear that on account of the audit objection that a remedial action of reopening the assessment by an action u/s 148 of the Act was taken

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

3 lines) ..........................The assessee could not prove the sources of the donations received during the year...................................................... 9. Show-Cause Notice before conclusion of 147 proceedings-Learned AO also issued a SCN on 17/9/2019 and, a final opportunity of being herd vide notice / letter dated 23/10/2019. The final opportunity notice is reproduced in the 147 order at Page-33 to page

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

3 lines) ..........................The assessee could not prove the sources of the donations received during the year...................................................... 9. Show-Cause Notice before conclusion of 147 proceedings-Learned AO also issued a SCN on 17/9/2019 and, a final opportunity of being herd vide notice / letter dated 23/10/2019. The final opportunity notice is reproduced in the 147 order at Page-33 to page

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

3 lines) ..........................The assessee could not prove the sources of the donations received during the year...................................................... 9. Show-Cause Notice before conclusion of 147 proceedings-Learned AO also issued a SCN on 17/9/2019 and, a final opportunity of being herd vide notice / letter dated 23/10/2019. The final opportunity notice is reproduced in the 147 order at Page-33 to page

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)

45) in respect of each of the assessment falling within such six assessment years that is required to be aggregated with the income already assessed in cases of completed assessments, moreso when section 132 comprehends action to search of a person in possession of undisclosed income or property. In those cases where assessments are pending at the lime of initiation

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)

45) in respect of each of the assessment falling within such six assessment years that is required to be aggregated with the income already assessed in cases of completed assessments, moreso when section 132 comprehends action to search of a person in possession of undisclosed income or property. In those cases where assessments are pending at the lime of initiation

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)

45) in respect of each of the assessment falling within such six assessment years that is required to be aggregated with the income already assessed in cases of completed assessments, moreso when section 132 comprehends action to search of a person in possession of undisclosed income or property. In those cases where assessments are pending at the lime of initiation

RAJARSHI SHAHU SHIKSHAN SANSTHA INAM DHAMANI,SANGLI vs. ITO EXEMPTION, KOLHAPUR, KOLHAPUR

In the result, all the appeals filed by the assessee are\npartly allowed as per terms indicated hereinabove

3 lines)\n.The assessee could not prove the sources of the\ndonations received during the year.......\n9. Show-Cause Notice before conclusion of 147 proceedings-Learned\nAO also issued a SCN on 17/9/2019 and, a final opportunity of\nbeing herd vide notice / letter dated 23/10/2019. The final\nopportunity notice is reproduced in the 147 order at Page-33 to page

RAJARSHI SHAHU SHIKSHAN SANSTHA INAM DHAMANI,SANGLI vs. ITO EXEMPTION , KOLHAPUR, KOLHAPUR

In the result, all the appeals filed by the assessee are\npartly allowed as per terms indicated hereinabove

3 lines)\n.The assessee could not prove the sources of the\ndonations received during the year.......\n9. Show-Cause Notice before conclusion of 147 proceedings-Learned\nAO also issued a SCN on 17/9/2019 and, a final opportunity of\nbeing herd vide notice / letter dated 23/10/2019. The final\nopportunity notice is reproduced in the 147 order at Page-33 to page

RAJARSHI SHAHU SHIKSHAN SANSTHA INAM DHAMANI,SANGLI vs. ITO EXEMPTION, KOLHAPUR

In the result, all the appeals filed by the assessee are\npartly allowed as per terms indicated hereinabove

3 lines)\n.The assessee could not prove the sources of the\ndonations received during the year.......\n9. Show-Cause Notice before conclusion of 147 proceedings-Learned\nAO also issued a SCN on 17/9/2019 and, a final opportunity of\nbeing herd vide notice / letter dated 23/10/2019. The final\nopportunity notice is reproduced in the 147 order at Page-33 to page

PADMAKAR VISHWAS DATE,BHOSARI vs. INCOME TAX E ASSESSMENT, PUNE

In the result, appeal of the assessee is dismissed

Bench: Shri S.S.Godara & Dr. Dipak P. Ripoteआयकर अपील सं. / Ita Nos.929, 930 & 931/Pun/2023 िनधा"रण वष" / Assessment Years : 2013-14, 2014-15 & 2015-16 Padmakar Vishwas Date, The Income Tax Officer S.No.218, Near Shri Krishn V –Tds(2), Pune. Mandir, Alandi Road, S Bhosari, Pune – 411038. Pan: Anhpd3804B Appellant/ Assessee Respondent /Revenue Assessee By None Revenue By Shri Sourabh Nayak – Addl.Cit(Dr) Date Of Hearing 15/02/2024 Date Of Pronouncement 16/02/2024 आदेश/ Order Per Dr. Dipak P. Ripote, Am: These Three Appeals Filed By The Assessee Are Against The Separate Orders Of Ld.Commissioner Of Income Tax(Appeals)[Nfac], Passed Under Section 250 Of The Income Tax Act, 1961 All Dated 26.06.2023. Since Issue Involved Is Same, All These Appeals Were Heard Together & Decided By This Consolidated Order. We Treat Appeal In Ita No.929/Pun/2023 For A.Y.2013-14

u/s 234 had been charged. 3. The Department of Income Tax, through its Officers send such letters and intimidate the Assessee, leading him to spend money on the proceedings besides causing mental anguish. The ITD may be directed to pay and amount of Rs.25,000/- to the Indian Army Welfare Fund as compensation for this frivolous action. ITA No.929/PUN/2023

PADMAKAR VISHWAS DATE,BHOSARI vs. INCOME TAX E ASSESSMENT , PUNE

In the result, appeal of the assessee is dismissed

Bench: Shri S.S.Godara & Dr. Dipak P. Ripoteआयकर अपील सं. / Ita Nos.929, 930 & 931/Pun/2023 िनधा"रण वष" / Assessment Years : 2013-14, 2014-15 & 2015-16 Padmakar Vishwas Date, The Income Tax Officer S.No.218, Near Shri Krishn V –Tds(2), Pune. Mandir, Alandi Road, S Bhosari, Pune – 411038. Pan: Anhpd3804B Appellant/ Assessee Respondent /Revenue Assessee By None Revenue By Shri Sourabh Nayak – Addl.Cit(Dr) Date Of Hearing 15/02/2024 Date Of Pronouncement 16/02/2024 आदेश/ Order Per Dr. Dipak P. Ripote, Am: These Three Appeals Filed By The Assessee Are Against The Separate Orders Of Ld.Commissioner Of Income Tax(Appeals)[Nfac], Passed Under Section 250 Of The Income Tax Act, 1961 All Dated 26.06.2023. Since Issue Involved Is Same, All These Appeals Were Heard Together & Decided By This Consolidated Order. We Treat Appeal In Ita No.929/Pun/2023 For A.Y.2013-14

u/s 234 had been charged. 3. The Department of Income Tax, through its Officers send such letters and intimidate the Assessee, leading him to spend money on the proceedings besides causing mental anguish. The ITD may be directed to pay and amount of Rs.25,000/- to the Indian Army Welfare Fund as compensation for this frivolous action. ITA No.929/PUN/2023

PADMAKAR VISHWAS DATE,,BHOSARI vs. INCOME TAX E ASSESSMENT, PUNE

In the result, appeal of the assessee is dismissed

Bench: Shri S.S.Godara & Dr. Dipak P. Ripoteआयकर अपील सं. / Ita Nos.929, 930 & 931/Pun/2023 िनधा"रण वष" / Assessment Years : 2013-14, 2014-15 & 2015-16 Padmakar Vishwas Date, The Income Tax Officer S.No.218, Near Shri Krishn V –Tds(2), Pune. Mandir, Alandi Road, S Bhosari, Pune – 411038. Pan: Anhpd3804B Appellant/ Assessee Respondent /Revenue Assessee By None Revenue By Shri Sourabh Nayak – Addl.Cit(Dr) Date Of Hearing 15/02/2024 Date Of Pronouncement 16/02/2024 आदेश/ Order Per Dr. Dipak P. Ripote, Am: These Three Appeals Filed By The Assessee Are Against The Separate Orders Of Ld.Commissioner Of Income Tax(Appeals)[Nfac], Passed Under Section 250 Of The Income Tax Act, 1961 All Dated 26.06.2023. Since Issue Involved Is Same, All These Appeals Were Heard Together & Decided By This Consolidated Order. We Treat Appeal In Ita No.929/Pun/2023 For A.Y.2013-14

u/s 234 had been charged. 3. The Department of Income Tax, through its Officers send such letters and intimidate the Assessee, leading him to spend money on the proceedings besides causing mental anguish. The ITD may be directed to pay and amount of Rs.25,000/- to the Indian Army Welfare Fund as compensation for this frivolous action. ITA No.929/PUN/2023

AADHUNIK INFRASTRUCTURE DEVELOPMENT PRIVATE LIMITED,JALGAON vs. THE DEPUTY COMMISSIONER OF INCOME TAX, CIRCLE-1, JALGAON

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

Bench: Shri R. K. Panda & Shri Vinay Bhamoreassessment Year : 2012-13

reassessment proceedings. Thus there was no borrowed satisfaction on the part of the AO. There was independent application of mind on the part of the AO. Further reliance is placed upon clause (b) of explanation 2 to provisions of section 147 of the Act as on the basis of the facts of the case the AO had the basis