SACHIN MOHANLAL CHORDIA,PUNE vs. INCOME TAX OFFICER WARD 5(1), PUNE

Appeal of the assessee is partly allowed as we do not intend to adjudicate other grounds raised by the assessee

Bench: Ms. Astha Chandra & Dr. Dipak P. Ripoteआयकर अपील सं. / Ita Nos.3280 & 3281/Pun/2025 िनधा"रण वष" / Assessment Years: 2016-17 & 2017-18 Sachin Mohanlal Chordia, V The Income Tax Officer, B-101, Isha Emerald, S. Ward-5(1), Pune. Bibwewdi, Kondhwa Road, Marketyard, Pune- 411037. Pan: Aanpc8554C Appellant Respondent Assessee By Shri Abhilash Hiran Revenue By Shri Amit Bobade & Shri Sanjay Dhivare (Virtual) Date Of Hearing 05/03/2026 Date Of Pronouncement 30/03/2026 आदेश/ Order Per Bench : These Are Two Appeals Filed By Assessee Against The Separate Orders Of Commissioner Of Income Tax (Appeal) (Nfac) U/S 250 Of The Income Tax Act 1961 For Ay 2016-17, 2017-18 Passed On 22/10/2025 Emanating From Separate Assessment Orders U/S 147 Rws 144 Dated 11/05/2023 & 23/05/2023. 2. The Grounds Of Appeal Raised By The Assessee Are As Under:

73 to para 81 of the Rajeev Bansal case. Particularly, the example given in para 78 makes it clear that as far as notices u/s 148 for (AY 2016-17 &) AY 2017-18 issued in pursuance of the Ashish Agarwal case (supra) are considered, since their completion falls for completion during the period 20th March, 2020 to 30th June

SACHIN MOHANLAL CHORDIA,PUNE vs. INCOME TAX OFFICER WARD 5(1), PUNE

Appeal of the assessee is partly allowed as we do not intend to adjudicate other grounds raised by the assessee

Bench: Ms. Astha Chandra & Dr. Dipak P. Ripoteआयकर अपील सं. / Ita Nos.3280 & 3281/Pun/2025 िनधा"रण वष" / Assessment Years: 2016-17 & 2017-18 Sachin Mohanlal Chordia, V The Income Tax Officer, B-101, Isha Emerald, S. Ward-5(1), Pune. Bibwewdi, Kondhwa Road, Marketyard, Pune- 411037. Pan: Aanpc8554C Appellant Respondent Assessee By Shri Abhilash Hiran Revenue By Shri Amit Bobade & Shri Sanjay Dhivare (Virtual) Date Of Hearing 05/03/2026 Date Of Pronouncement 30/03/2026 आदेश/ Order Per Bench : These Are Two Appeals Filed By Assessee Against The Separate Orders Of Commissioner Of Income Tax (Appeal) (Nfac) U/S 250 Of The Income Tax Act 1961 For Ay 2016-17, 2017-18 Passed On 22/10/2025 Emanating From Separate Assessment Orders U/S 147 Rws 144 Dated 11/05/2023 & 23/05/2023. 2. The Grounds Of Appeal Raised By The Assessee Are As Under:

73 to para 81 of the Rajeev Bansal case. Particularly, the example given in para 78 makes it clear that as far as notices u/s 148 for (AY 2016-17 &) AY 2017-18 issued in pursuance of the Ashish Agarwal case (supra) are considered, since their completion falls for completion during the period 20th March, 2020 to 30th June

ASSISTANT COMMISSIONER OF INCOME-TAX, CIRCLE-7, PUNE vs. PAN INTERNATIONAL, PUNE

Bench: Hon’Ble Shri S. S. Viswanethra Ravi & Shri G. D. Padmahshaliआयकर अपील सं. / Ita No.175/Pun/2020 & Co No. 23/Pun/2022 धििाारण वर्ा / Assessment Year : 2008-2009 Dy. Commissioner Of Income Tax, Circle-7, Pune . . . . . . . अपीलार्थी / Appellant बिाम / V/S. Pan International, 347, Afl House, Off Dhole Patil Rd, Behind Hotel Meru, Pune – 411 001 . . . . . . . प्रत्यर्थी / Respondent Pan: Aabfp4234F & Cross Objector द्वारा / Appearances Assessee By : Shri Sharad Vaze Revenue By : Shri M. G. Jasnani सुनवाई की तारीख / Date Of Conclusive Hearing : 09/12/2022 घोषणा की तारीख / Date Of Pronouncement : 09/12/2022 आदेश / Order Per G. D. Padmahshali, Am; The Revenue Challenges The Order Of Commissioner Of Income Tax (Appeals)-8, Pune [For Short “Cit(A)”] Dt. 06/11/2019 Passed U/S 250 Of The Income-Tax Act, 1961 [For Short “The Act”] Quashing The Order Of Assessment Dt. 10/03/2014 Passed U/S 143(3) R.W.S. 147 By The Dy. Commissioner Of Income Tax, Circle 1(2), Pune[For Short “Ao”] For The Assessment Year [For Short “Ay”] 2008-09 On Technical-Cum-Legal Ground.

147 of the Act at ₹2,73,20,830/-. 3.3 Aggrieved thereby the assessee challenged the addition on legal as well meritare grounds before the first appellate authority [for short “FAA”], who in turn finding force in the contention of the assessee, based on the remand report confirming the non-issuance of notice u/s 143(2) in reassessment proceedings, adjudicated

INCOME TAX OFFICER, WARD-1(5), AURANGABAD., AURANGABAD, MAHARASHTRA vs. ROYAL ESTATES, AURANGABAD, MAHARASHTRA

In the result, the appeals of Revenue for AYs 2011-12 and 2012-13

Bench: Ms. Astha Chandra & Shree G.D. Padmahshali

73,76,220/- 1,44,27,092/- 70,50,872/- 2010-11 2,57,21,478/- 5,03,08,440/- 2,45,86,962/- 2011-12 3,95,75,541/- 7,74,05,494/- 3,78,29,953/- 2012-13 6,70,456/- 13,11,340/- 6,40,884/- Total

INCOME TAX OFFICER WARD-1(5), AURANGABAD, AURANGABAD, MAHARASHTRA vs. ROYAL ESTATES, AURANGABAD, MAHARASHTRA

In the result, the appeals of Revenue for AYs 2011-12 and 2012-13

Bench: Ms. Astha Chandra & Shree G.D. Padmahshali

73,76,220/- 1,44,27,092/- 70,50,872/- 2010-11 2,57,21,478/- 5,03,08,440/- 2,45,86,962/- 2011-12 3,95,75,541/- 7,74,05,494/- 3,78,29,953/- 2012-13 6,70,456/- 13,11,340/- 6,40,884/- Total

DATTAPRASAD RADHAKISAN REVGADE,HIVARGAON vs. ITO WARD 2, AHMEDNAGAR

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

Bench: Ms.Astha Chandra, Judicialmember & Dr.Dipak P. Ripoteआयकर अपऩल सं. / Ita No.1897/Pun/2025 निर्धारण वषा / Assessment Year: 2018-19 Dattaprasad Radhakisan V The Income Tax Officer, Revgade, S Ward-2, Ahmednagar. At Hivargaon Post Dongargaon, Tal Aklole, Ahmednagar – 422609. Pan: Cddpr8213C Appellant/ Assessee Respondent / Revenue Assessee By Shri Piyush Bafna – Ar Revenue By Shri Ambarnath Khule – Jcit(Dr) Date Of Hearing 03/09/2025 Date Of Pronouncement 26/09/2025 आदेश/ Order Per Dr. Dipak P. Ripote, Am: This Appeal Filed By The Assessee Against The Order Of Ld.Commissioner Of Income Tax Appeal(Nfac) Passed Under Section 250 Of The Income Tax Act, 1961 For A.Y.2018-19 Dated 23.06.2025 Emanating From The Assessment Order Under Section 147 R.W.S 144 Read With Section 144B Of The Income Tax Act, 1961

reassessment proceedings initiated pursuant to such defective notice are liable to be quashed. 9. On the facts and in the circumstances of the case and in law and without prejudice to other grounds, the assessment order passed under section 147 r.ws 144 of the Income-tax Act, 1961 is bad in law and void 3 ITA No.1897/PUN/2025 [A] ab initio

GOPAL EXTRUSIONS PVT LTD,,JALGAON vs. INCOME-TAX OFFICER, WARD - 1(2),, JALGAON

Bench: Dr.Manish Borad & Shri Vinay Bhamoreआयकर अपील सं. / Ita. No.1633/Pun/2017 Assessment Year : 2008-09

147, the impugned assessment proceedings are not valid in law. 13 Gopal Extrusions Pvt. Ltd. Without prejudice to the above: c. Approval mechanical: The Approval is mechanical and does not show any application of mind on escapement of income and the material so as to show escapement of income. The approval is granted on the proposal and further directs

MOTIWALA AUTO PVT. LTD.,AURANGABAD vs. ITO, WARD1(1), AURANABAD, AURANGABAD

In the result, the appeal of the assessee is allowed

reassessment proceedings on the ground that\nthe notice issued under Section 148 is barred by limitation. After considering\nthe submissions and documentation furnished by the assessee and in the\nunique facts and circumstances of the case, the Ld. CIT(A)/NFAC opined that\nthe order passed by the Ld. AO under Section 147 read with Section 144 of the\nAct

GOURISHANKAR EDUCATION SOCIETY,SATARA vs. CIT EXEMPTION, PUNE

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

Bench: Shri R. K. Panda & Shri Vinay Bhamoreआयकर अपील सं. / Ita Nos.1234 & 1235/Pun/2024 िनधा"रण वष" / Assessment Years : 2013-14 & 2014-15 Gourishankar Education Vs. Cit, Exemption, Pune. Society, Panchganga Apartment, Opp. Axis Bank, Radhika Road, Satara- 415001. Pan : Aaatg6668A Appellant Respondent Assessee By : Shri Kishor B. Phadke Revenue By : Shri Amol Khairnar Date Of Hearing : 21.11.2024 Date Of Pronouncement 10.01.2025 : आदेश / Order Per Vinay Bhamore, Jm: These Appeals Filed By The Assessee Are Directed Against The Separate Orders Dated 30.03.2024 Passed By Ld. Cit, Exemption, Pune U/S 263 Of The It Act For The Assessment Years 2013-14 & 2014-15 Respectively. 2. Since Identical Facts & Common Issues Are Involved In Both The Above Captioned Appeals Of The Assessee, Therefore, We Proceed To Dispose Of The Same By This Common Order. 3. First, We Shall Take Up The Appeal Of The Assessee In Ita No.1234/Pun/2024 For A.Y. 2013-14 For Adjudication.

73,473/-. The above loss (deficit income) was disclosed after considering the interest income of Rs.14,55,213/- received from various banks. Subsequently, a survey action u/s 133A of the IT Act was conducted on 02.05.2019 in the case of Gourishanker Educational & Charitable Trust. During the course of survey proceedings, it was found that the assessee trust has advanced interest

GOURISHANKAR EDUCATION SOCIETY,SATARA vs. CIT EXEMPTION, PUNE

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

Bench: Shri R. K. Panda & Shri Vinay Bhamoreआयकर अपील सं. / Ita Nos.1234 & 1235/Pun/2024 िनधा"रण वष" / Assessment Years : 2013-14 & 2014-15 Gourishankar Education Vs. Cit, Exemption, Pune. Society, Panchganga Apartment, Opp. Axis Bank, Radhika Road, Satara- 415001. Pan : Aaatg6668A Appellant Respondent Assessee By : Shri Kishor B. Phadke Revenue By : Shri Amol Khairnar Date Of Hearing : 21.11.2024 Date Of Pronouncement 10.01.2025 : आदेश / Order Per Vinay Bhamore, Jm: These Appeals Filed By The Assessee Are Directed Against The Separate Orders Dated 30.03.2024 Passed By Ld. Cit, Exemption, Pune U/S 263 Of The It Act For The Assessment Years 2013-14 & 2014-15 Respectively. 2. Since Identical Facts & Common Issues Are Involved In Both The Above Captioned Appeals Of The Assessee, Therefore, We Proceed To Dispose Of The Same By This Common Order. 3. First, We Shall Take Up The Appeal Of The Assessee In Ita No.1234/Pun/2024 For A.Y. 2013-14 For Adjudication.

73,473/-. The above loss (deficit income) was disclosed after considering the interest income of Rs.14,55,213/- received from various banks. Subsequently, a survey action u/s 133A of the IT Act was conducted on 02.05.2019 in the case of Gourishanker Educational & Charitable Trust. During the course of survey proceedings, it was found that the assessee trust has advanced interest

M/S ACCORD MEDIPLUS PVT LTD,PUNE vs. INCOME TAX OFFICER, WARD-1(1), PUNE, PUNE

u/s 147 of the I.T Act was as per Law\napplying necessary jurisprudence.\nIn Ideal Associates v. Assistant Commissioner of Income tax K.R.\nSHRIRAM AND N.R. BORKAR, JJ. WRIT PETITION NO. 879 OF 2022\nAPRIL 7, 2022 of HIGH COURT OF BOMBAY, [2023] 146\ntaxmann.com 225 (Bombay) it is observed and decision delivered by\nHon'ble Judges\n- Whether

M/S ACCORD MEDIPLUS PVT LTD,PUNE vs. INCOME TAX OFFICER, WARD-1(1), PUNE, PUNE

Bench: Dr.Manish Borad & Shri Vinay Bhamore

reassessment order as well as additions made therein may please be quashed. M/s. Accord Mediplus Pvt. Ltd. 7. On the facts and in the circumstances of the case, Ld. CIT- Appeal as well as Ld. AO have erred in law and on facts, in sustaining/making the addition of Rs. 8,96,41,183/- without appreciating the real intent behind introduction

M/S ACCORD MEDIPLUS PVT LTD,PUNE vs. INCOME TAX OFFICER, WARD-1(1), PUNE, PUNE

Bench: Dr.Manish Borad & Shri Vinay Bhamore

reassessment order as well as additions made therein may please be quashed. M/s. Accord Mediplus Pvt. Ltd. 7. On the facts and in the circumstances of the case, Ld. CIT- Appeal as well as Ld. AO have erred in law and on facts, in sustaining/making the addition of Rs. 8,96,41,183/- without appreciating the real intent behind introduction

M/S ACCORD MEDIPLUS PVT LTD,PUNE vs. INCOME TAX OFFICER, WARD-1(1), PUNE, PUNE

Bench: Dr.Manish Borad & Shri Vinay Bhamore

reassessment order as well as additions made therein may please be quashed. M/s. Accord Mediplus Pvt. Ltd. 7. On the facts and in the circumstances of the case, Ld. CIT- Appeal as well as Ld. AO have erred in law and on facts, in sustaining/making the addition of Rs. 8,96,41,183/- without appreciating the real intent behind introduction

M/S ACCORD MEDIPLUS PVT LTD,PUNE vs. INCOME TAX OFFICER, WARD-1(1), PUNE, PUNE

Bench: Dr.Manish Borad & Shri Vinay Bhamore

reassessment order as well as additions made therein may please be quashed. M/s. Accord Mediplus Pvt. Ltd. 7. On the facts and in the circumstances of the case, Ld. CIT- Appeal as well as Ld. AO have erred in law and on facts, in sustaining/making the addition of Rs. 8,96,41,183/- without appreciating the real intent behind introduction

VIKAS MARUTI NALAWADE,SANGLI vs. INCOME TAX OFFICER, SANGLI

In the result, appeal of the assessee is partly allowed

Bench: Dr. Manish Borad & Shri Vinay Bhamoreआयकर अपील सं./Ita No. 737/Pun/2025 धििेंारण वर्ा /Assessment Year: 2017-18 Vikas Maruti Nalawade, Ito, Ward-1, Sangli Vikas Hitech Nursary, Sangli Islampur Road, Near Sootgirni Vs. Tung, Sangli-416301 Maharashtra Pan-Alppn6432M अपीलेंर्थी / Appellant प्रत्यर्थी / Respondent Assessee By: Shri Pramod S Shingte Department By: Shri Amit Bobde-Cit Date Of Hearing: 09-12-2025 Date Of Pronouncement: 16-12-2025 आदीश /Order Per Dr. Manish Borad:- This Appeal At The Instance Of Assessee Is Directed Against The Order Of Ld. Cit(A) Nfac, Delhi Passed U/S 250 Of The Income-Tax Act, 1961 Dated 05.03.2025 Which Is Arising Out Of Assessment Order Passed U/S 147 R.W.S. 144B Of The Act Dated 29.03.2022. 2. Assessee Has Raised Following Grounds Of Appeal:- 1. On The Facts & Circumstances Of The Case & In Law, The 2 Assessment Order, Having Being Passed Without Following The Principles Of Natural Justice, As Narrated In The Statement Of Facts, The Same Is Bad In Law & Hence Needs To Be Quashed.

147 of the Act. The assessee furnished return in compliance to the notice u/s 148 of the Act declaring total taxable income at Rs. 7,960/- and 3 also declared exempt Agricultural income at Rs. 1,54,54,912/- In the course of the reassessment proceedings various details called for by the Ld. AO were furnished based on which

NARENDRA KACHRULAL ABAD,JALNA vs. INCOME-TAX OFFICER, WARD - 1,, JALNA

In the result, appeal of the assessee partly allowed

Bench: Dr.Dipak P. Ripote & Shri Vinay Bhamoreआयकर अपऩल सं. / Ita No.866/Pun/2019 निर्धारण वषा / Assessment Year: 2009-10 Shri Narendra Kachrulal Abad, V The Income Tax Officer, Abad House, Nal Galli, S Ward-1, Jalna. Kadrabad, Jalna – 431203. Maharashtra. Pan: Acspa9531C Appellant/ Assessee Respondent / Revenue Assessee By Shri Hari Krishan – Ar Revenue By Shri Arvind Renge –Addl.Cit(Dr) Date Of Hearing 28/07/2025 Date Of Pronouncement 06/10/2025 आदेश/ Order Per Dr. Dipak P. Ripote, Am: This Is An Appeal Filed By Assessee Against The Order Of Ld.Commissioner Of Income Tax(Appeal)-1, Aurangabadpassed Under Section 250 Of The Income Tax Act, 1961 For The A.Y.2009-10 Dated 30.03.2019, Emanating From Order U/S.143(3) R.W.S 147Of The Income Tax Act, 1961, Dated 03.11.2017. The Assessee Has Raised The Following Concise Grounds Of Appeal :

section 147 of the Act by the AO and upheld by the Ld. CIT(A) are nonest in law, without jurisdiction and without applying his mind and AO issued notice without confronting the Appraisal Report of the Investigation Wing. Hence, the reassessment is quashed and accordingly I allow the legal ground no. 1 to 1.1 raised by the assessee

JAYANT KANERIA,,PUNE vs. DEPUTY COMMISSIONER OF INCOME-TAX, CIRCLE - 2,, PUNE

Appeal is allowed in above terms

Bench: Shri S.S.Godara, Jm & Shri Dr. Dipak P. Ripote, Am आयकर अपीऱ सं. / Ita No.1719/Pun/2019 ननधधारण वषा / Assessment Year : 2007-08

reassessed based on the ratio laid down in the above case laws, i.e. deemed dividend, if any, needs to be taxed in the hands of beneficial shareholder and not at the hands of the firm. The ratio laid down in the above judgments can be applied to the case of Shri Jayant Kaneria by observing the following facts: The payment

SHRI UPASANI KANYAKUMARI SANSTHAN,RAHATA vs. ITO EXEMPTION WARD 1(1), NASHIK

In the result, appeal of the assessee is allowed

Bench: Dr.Manish Borad & Shri Vinay Bhamore

73,150/-. Details called for in the notice u/s.142(1) of the Act were examined by the ld. Assessing Officer including the source of cash deposit, time deposit, investment in mutual funds, interest income other 2 Shri Upasani Kanyakumari Sansthan than interest on securities u/s.194A. After being satisfied with the details filed by the assessee, ld. AO concluded the assessment