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

69A of the Act. Relying on\nvarious other decisions, the details of which are placed in the paper book, he\nsubmitted that the assessment should have been framed u/s 153C and not u/s 147\nof the Act. Therefore, once the proceedings u/s 147 are held to be void-ab-initio,\nthe Ld. PCIT could not have passed the order u/s

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 of the Income Tax Act, 1961 and the addition made of Rs.6,20,00,000 under section 69A of the Income Tax Act on account of unexplained cash loans availed from various parties through Sh. Sachin M. Nahar. All these grounds of appeal are taken up together for adjudication. An analysis of letter No.Pn/DCIT. Cen. Cir.1(1)/Sharing

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

reassessment proceedings by challenging the assumption of jurisdiction in spite of knowing that it is not maintainable in accordance with law. This attitude of the appellant clearly demonstrated that he had evaded tax by not filing the return of income within the due date specified u/s 139(1) of the IT Act and also after receipt of notice u/s

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

reassessment proceedings by challenging the assumption of jurisdiction in spite of knowing that it is not maintainable in accordance with law. This attitude of the appellant clearly demonstrated that he had evaded tax by not filing the return of income within the due date specified u/s 139(1) of the IT Act and also after receipt of notice u/s

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

reassessment proceedings by challenging the assumption of jurisdiction in spite of knowing that it is not maintainable in accordance with law. This attitude of the appellant clearly demonstrated that he had evaded tax by not filing the return of income within the due date specified u/s 139(1) of the IT Act and also after receipt of notice u/s

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

reassessment proceedings by challenging the assumption of jurisdiction in spite of knowing that it is not maintainable in accordance with law. This attitude of the appellant clearly demonstrated that he had evaded tax by not filing the return of income within the due date specified u/s 139(1) of the IT Act and also after receipt of notice u/s

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

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

147 of the Act after recording\nreasons which have already been reproduced earlier. Since the\nassessee could not give any satisfactory explanation regarding\nthe loan of Rs.6,20,00,000/- provided by Shri Sachin Nahar, the\nAssessing Officer, invoking the provisions of section 69A of the\nAct read with section 115BBE made addition to the total income\nof the assessee

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

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

147 of the Act after recording\nreasons which have already been reproduced earlier. Since the\nassessee could not give any satisfactory explanation regarding\nthe loan of Rs.6,20,00,000/- provided by Shri Sachin Nahar, the\nAssessing Officer, invoking the provisions of section 69A of the\nAct read with section 115BBE made addition to the total income\nof the assessee

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

69A were made by invoking explanation 3 to section 147 of the Act. Therefore in adjudicating the legal issue under challenge, we have to deal with relevant fraction of provisions of section 139, section 147, and 149 of the Act. 8. In terms of section 139(1)(b) of the Act, a person being other than company or firm

BORA AGRO FOODS,PUNE vs. DCIT, CIR-5, PUNE, PUNE

In the result, all the appeals filed by the Assessee are partly\nallowed

reassessment under Section 147 of the Act\nwould become impermissible\nThe assumption that provisions of Section 153C of the Act precludes\nany proceeding under Section 147 of the Act by virtue of the non\nobstante clause. is unpersuasive. The scheme of Sections 153C of the\nAct indicates that the said provision was enacted to simplify the\nprocedure, while maintaining

BORA AGRO FOODS,PUNE vs. DCIT, CIR-5, PUNE, PUNE

In the result, all the appeals filed by the Assessee are partly\nallowed

reassessment under Section 147 of the Act\nwould become impermissible\nThe assumption that provisions of Section 153C of the Act precludes\nany proceeding under Section 147 of the Act by virtue of the non\nobstante clause. is unpersuasive. The scheme of Sections 153C of the\nAct indicates that the said provision was enacted to simplify the\nprocedure, while maintaining

BORA AGRO FOODS,PUNE vs. DCIT, CIR-5, PUNE, PUNE

In the result, all the appeals filed by the Assessee are partly\nallowed

reassessment under Section 147 of the Act\nwould become impermissible\nThe assumption that provisions of Section 153C of the Act precludes\nany proceeding under Section 147 of the Act by virtue of the non\nobstante clause. is unpersuasive. The scheme of Sections 153C of the\nAct indicates that the said provision was enacted to simplify the\nprocedure, while maintaining

VIJAYKUMAR MANGILALJI CHORDIYA,NASHIK vs. NATIONAL FACELESS ASSESSMENT CENTRE, DELHI

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

Bench: Shri R. K. Panda & Shri S.S. Godaraassessment Year : 2013-14

69A of the Act read with section 115BBE made addition to the total income of the assessee. We find the CIT(A) / NFAC quashed the re-assessment proceedings holding that the proper course of action before the Assessing Officer should have been u/s 153C of the Act. He also deleted the addition on merit by holding that the said addition

GULAMAHEMAD HAMIDULLA KHAN,PUNE vs. ITO WARD 14(3), PUNE

In the result, the appeal of the assessee is allowed for statistical purposes

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

reassessment proceeding under the new provisions of section 147 as inserted by finance act 2021, on the basis of information gathered during the search conducted on M/s Renukamata Multistate Urban Co-operative Credit Society, therefore the action is illegal as the proceedings ought to have been initiated u/s 153C, therefore consequential order passed is bad in law and deserves

M/S MANILAL P. SAVLA & COMPANY,PUNE vs. ACIT, CIRCLE 5, PUNE

In the result, the appeal of the assessee is allowed

69A of the Act by\nthe Ld. AO and also raised an additional ground before the Ld. CIT(A)/NFAC\nthat “the reassessment order u/s 147 is without jurisdiction and bad in law\nbecause the assessing officer has wrongly invoked the provisions of section

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 r.w.s. 144 r.w.s. 144B of the Act determining the total income of the assessee at Rs.75,11,045/- by making an addition on account of – (i) Rs.69,47,776/- as unexplained money u/s 69A of the Act and (ii) saving bank interest of Rs.17,389/- as income from other sources. 3. Aggrieved, the assessee filed an appeal before

AMBALAL GORAKH CHOUDHARI,PRAKASHA vs. INCOME TAX OFFICER, WARD-1, DHULE, DHULE

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

Bench: Shri Manish Borad & Shri Vinay Bhamoreआयकर अपील सं. / Ita No.1422/Pun/2025 िनधा"रण वष" / Assessment Year : 2013-14 Ambalal Gorakh Choudhari Vs. Ito, Ward-1, Dhule. Legal Heir Anita Ambalal Chaudhari, Mukteshwar Mandir, At Post Prakasha, Taluka Shahada, Dist. Nandurbar- 425409. Pan : Afrpc1304D Appellant Respondent Assessee By : Shri Sandeep Rathi Revenue By : Shri Harshit Bari Date Of Hearing : 19.08.2025 Date Of Pronouncement : 14.10.2025 आदेश / Order Per Vinay Bhamore, Jm: This Appeal Filed By The Assessee Is Directed Against The Order Dated 31.03.2025 Passed By Ld. Addl./Jcit(A)-2, Gurugram [‘Ld. Cit(A)’] For The Assessment Year 2013-14. 2. The Appellant Has Raised The Following Grounds Of Appeal :- “1. On The Facts & In The Circumstances Of The Case, Learned Assessing Officer & The Cit(A) Is Not Justified In Making/Confirming Additions Of Rs. 1020740/- To Returned Income U/S.69A Of The Act, As Said Section Is Applicable Only When In Any Financial Year The Assessee Is Found To Be Owner Of Any Money, Bullion, Jewellery Or Any Other

69A Issue:- Source of money disclosed and additions unjustified Without prejudice to the above 7. The appellant craves leave to add, alter, amend or withdraw any of the ground of appeal. Relevant Section:-246A 4 Issue:- Addition, alteration or deletion of any ground of appeal.” 3. The appellant has also raised following additional ground of appeal :- (BEFORE ITAT

GANESH SHANKAR PUJARE,SINDHUDURG vs. INCOME TAX OFFICER, WARD, KUDAL, KUDAL

In the result appeal filed by the assessee stands allowed for the statistical purposes

Bench: Shri R. K. Panda & Shri Vinay Bhamoreआयकर अपील सं. / Ita No.40/Pun/2024 िनधा"रण वष" / Assessment Year: 2014-15 Ganesh Shankar Pujare, Vs. Ito, Ward, Kudal. Bidyewadi, At Post Kalmath, Taluka Kankavli, Sindhudurg- 416602. Pan : Anipp5657R Appellant Respondent Assessee By Shri Tanzil R. Padvekar : Revenue By : Shri Ramnath P. Murkunde Date Of Hearing : 17.04.2024 Date Of Pronouncement : 18.04.2024 आदेश / Order Per Vinay Bhamore, Jm: This Appeal Is Filed By The Assessee Assailing The Order Dated 08.11.2023 Passed By Ld Cit(A) [‘Nfac’] For The Assessment Year 2014-15. 2. The Appellant Raised The Following Grounds Of Appeal :- “I. Legality & Validity Of Reassessment Proceeding; 1. On The Facts & In Law, The Re-Assessment Proceeding Initiated By The Ld. Assessing Officer Under Section 147 Of The Act Is Bad In Law As The Same Is Based On Suspicious & Incorrect Information. Hence, As The Formation Of Belief Is Based On Incorrect, Suspicious & Vague Facts Same Is Unsus Tainable In Eye Of Law. 2. On The Facts & In Law, There Is Serious Jurisdictional Requirement In The Reasons Recorded By The Assessing Officer As He

reassessment proceeding under Section 147 of the Act. That as per reasons recorded by Ld. A. O., information only on alleged suspicious transactions in Bank account, without mentioning name of a Bank, is given as justification which cannot be equated with expression “reason to belief’ as contemplated in Section 147 of the Act. 9. On the facts

M/S MANILAL P. SAVLA & COMPANY,PUNE vs. ACIT, CIRCLE 5 , PUNE

In the result, the appeal of the assessee is allowed

69A of the Act by\nthe Ld. AO and also raised an additional ground before the Ld. CIT(A)/NFAC\nthat “the reassessment order u/s 147 is without jurisdiction and bad in law\nbecause the assessing officer has wrongly invoked the provisions of section