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

SUNIL KANHAIYALAL GIDWANI (HUF),,SANGLI vs. ASSISTANT COMMISSIONER OF INCOME TAX,, SANGLI

In the result, the appeal of the assessee in ITA No

Bench: Shri D. Karunakara Rao, Am आयकर अपील सं. / Ita No.325/Pun/2017 िनधा"रण वष" / Assessment Year : 2009-10 Sunil Kanhaiyalal Gidwani, C.S. No.34, Laxmi Bunglow, Revenue Colony, South Shivaji Nagar, Sangli-416416. .......अपीलाथ" / Appellant Pan : Afdpg9973Q बनाम / V/S. Acit, Circle-1, ……""यथ" / Respondent Sangli. आयकर अपील सं. / Ita No.327/Pun/2017 िनधा"रण वष" / Assessment Year : 2009-10 Sunil Kanhaiyalal Gidwani (Huf), C.S. No.34, Laxmi Bunglow, Revenue Colony, South Shivaji Nagar, Sangli-416416. .......अपीलाथ" / Appellant Pan : Aahhs9603Q बनाम / V/S. Acit, Circle-1, ……""यथ" / Respondent Sangli. Assessee By : Shri Sunil Ganoo Revenue By : Shri S. P. Walimbe सुनवाई क" तारीख / Date Of Hearing : 28.01.2020 घोषणा क" तारीख / Date Of Pronouncement : 07.02.2020 आदेश / Order Per D. Karunakara Rao, Am: There Are Two Appeals Under Consideration. Both The Appeals Are Directed Against The Separate Orders Of The Cit(A)-1, Kolhapur Dated

73,400/- in the individual capacity. At the end of the assessment u/s 143(3) r.w.s. 147 of the Act, the Assessing Officer made the additions u/s 68 of the Act. The CIT(A) confirmed the action of the Assessing Officer and dismissed the appeal of the assessee. 4. Aggrieved with the above decision of the CIT(A), the assessee

SUNIL KANHAIYALAL GIDWANI,,SANGLI vs. ASSISTANT COMMISSIONER OF INCOME TAX,, SANGLI

In the result, the appeal of the assessee in ITA No

Bench: Shri D. Karunakara Rao, Am आयकर अपील सं. / Ita No.325/Pun/2017 िनधा"रण वष" / Assessment Year : 2009-10 Sunil Kanhaiyalal Gidwani, C.S. No.34, Laxmi Bunglow, Revenue Colony, South Shivaji Nagar, Sangli-416416. .......अपीलाथ" / Appellant Pan : Afdpg9973Q बनाम / V/S. Acit, Circle-1, ……""यथ" / Respondent Sangli. आयकर अपील सं. / Ita No.327/Pun/2017 िनधा"रण वष" / Assessment Year : 2009-10 Sunil Kanhaiyalal Gidwani (Huf), C.S. No.34, Laxmi Bunglow, Revenue Colony, South Shivaji Nagar, Sangli-416416. .......अपीलाथ" / Appellant Pan : Aahhs9603Q बनाम / V/S. Acit, Circle-1, ……""यथ" / Respondent Sangli. Assessee By : Shri Sunil Ganoo Revenue By : Shri S. P. Walimbe सुनवाई क" तारीख / Date Of Hearing : 28.01.2020 घोषणा क" तारीख / Date Of Pronouncement : 07.02.2020 आदेश / Order Per D. Karunakara Rao, Am: There Are Two Appeals Under Consideration. Both The Appeals Are Directed Against The Separate Orders Of The Cit(A)-1, Kolhapur Dated

73,400/- in the individual capacity. At the end of the assessment u/s 143(3) r.w.s. 147 of the Act, the Assessing Officer made the additions u/s 68 of the Act. The CIT(A) confirmed the action of the Assessing Officer and dismissed the appeal of the assessee. 4. Aggrieved with the above decision of the CIT(A), the assessee

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

DEPUTY COMMISSIONER OF INCOME TAX vs. M/S. DEEPAK FOODS,, JALGAON

In the result, the appeal of Revenue is dismissed

Bench: Shri R.S. Syal & Shri S.S. Viswanethra Raviननधधारण वषा / Assessment Year : 2008-09

73,777/- respectively, totaling to Rs.45,05,47,554/- as goodwill. These facts were not disclosed by the assessee firm in its return of income nor in the notes accompanying the Balance Sheet or in the audit report in Form No.3CD. Further, he submits the fact of retirement of the above three persons and the payment of goodwill were

JOHNSON MATTHEY CHEMICALS INDIA PRIVATE LTD.,,RAIGAD vs. ASSISTANT COMMISSIONER OF INCOME-TAX,,

In the result, appeal of the Revenue for assessment year 2009-10 is

Bench: Shri D. Karunakara Rao, Am & Shri Vikas Awasthy, Jm

147 of the Act is bad in law and be quashed. Ground 2: without prejudice to Ground 1- Not following Rule of Consistency IV. erred in disallowing depreciation on Know-how, Patents, Trade-marks amounting to Rs.11,58,25,529/-. V. failed to appreciate the fact that the rule of consistency which states that the legal position accepted in preceding

JOHNSON MATTHEY CHEMICALS INDIA PRIVATE LTD.,,RAIGAD vs. ADDITIONAL COMMISSIONER OF INCOME-TAX,,

In the result, appeal of the Revenue for assessment year 2009-10 is

Bench: Shri D. Karunakara Rao, Am & Shri Vikas Awasthy, Jm

147 of the Act is bad in law and be quashed. Ground 2: without prejudice to Ground 1- Not following Rule of Consistency IV. erred in disallowing depreciation on Know-how, Patents, Trade-marks amounting to Rs.11,58,25,529/-. V. failed to appreciate the fact that the rule of consistency which states that the legal position accepted in preceding

JOHNSON MATTHEY CHEMICALS INDIA PRIVATE LTD.,,RAIGAD vs. ASSISTANT COMMISSIONER OF INCOME-TAX,,

In the result, appeal of the Revenue for assessment year 2009-10 is

Bench: Shri D. Karunakara Rao, Am & Shri Vikas Awasthy, Jm

147 of the Act is bad in law and be quashed. Ground 2: without prejudice to Ground 1- Not following Rule of Consistency IV. erred in disallowing depreciation on Know-how, Patents, Trade-marks amounting to Rs.11,58,25,529/-. V. failed to appreciate the fact that the rule of consistency which states that the legal position accepted in preceding

DEPUTY COMMISSIONER OF INCOME-TAX vs. M/S. JOHNSON MATTHEY CHEMICALS (I) PVT. LTD.,, RAIGAD

In the result, appeal of the Revenue for assessment year 2009-10 is

Bench: Shri D. Karunakara Rao, Am & Shri Vikas Awasthy, Jm

147 of the Act is bad in law and be quashed. Ground 2: without prejudice to Ground 1- Not following Rule of Consistency IV. erred in disallowing depreciation on Know-how, Patents, Trade-marks amounting to Rs.11,58,25,529/-. V. failed to appreciate the fact that the rule of consistency which states that the legal position accepted in preceding

DEPUTY COMMISSIONER OF INCOME-TAX vs. M/S. JOHNSON MATTHEY CHEMICALS (I) PVT. LTD.,, RAIGAD

In the result, appeal of the Revenue for assessment year 2009-10 is

Bench: Shri D. Karunakara Rao, Am & Shri Vikas Awasthy, Jm

147 of the Act is bad in law and be quashed. Ground 2: without prejudice to Ground 1- Not following Rule of Consistency IV. erred in disallowing depreciation on Know-how, Patents, Trade-marks amounting to Rs.11,58,25,529/-. V. failed to appreciate the fact that the rule of consistency which states that the legal position accepted in preceding

JOHN DEERE INDIA PVT.LTD,,PUNE vs. DEPUTY COMMISSIONER OF INCOME TAX,, PUNE

In the result, both the appeals of assessee are allowed as indicated above

Bench: Ms. Sushma Chowla, Jm & Shri Anil Chaturvedi, Am आयकर अपीऱ सं. / Ita No.1163/Pun/2017 यििाारण वषा / Assessment Year : 2008-09 John Deere Equipment Pvt. Ltd., (Now Merged With John Deere India Pvt. Ltd.) Tower Xiv, Cybercity, Magarpatta City, Hadapsar, अऩीऱाथी/Appellant Pune – 411028 …. Pan: Aaacl7331A Vs. The Dy. Commissioner Of Income Tax, …. प्रत्यथी / Respondent Circle 14, Pune

reassessment u/s. 147 be declared null and void. 2] The learned CIT(A) erred in confirming the disallowance of Rs.12,837,828/- u/s. 40(a)(i) of the Act in respect of information system charges and telecommunication expenses debited by the assessee without appreciating that no disallowance was warranted on facts of the case. ITA Nos.1163 & 1164/PUN/2017 3 John Deere

JOHN DEERE EQUIPMENT PVT.LTD,,PUNE vs. DEPUTY COMMISSIONER OF INCOME TAX,, PUNE

In the result, both the appeals of assessee are allowed as indicated above

Bench: Ms. Sushma Chowla, Jm & Shri Anil Chaturvedi, Am आयकर अपीऱ सं. / Ita No.1163/Pun/2017 यििाारण वषा / Assessment Year : 2008-09 John Deere Equipment Pvt. Ltd., (Now Merged With John Deere India Pvt. Ltd.) Tower Xiv, Cybercity, Magarpatta City, Hadapsar, अऩीऱाथी/Appellant Pune – 411028 …. Pan: Aaacl7331A Vs. The Dy. Commissioner Of Income Tax, …. प्रत्यथी / Respondent Circle 14, Pune

reassessment u/s. 147 be declared null and void. 2] The learned CIT(A) erred in confirming the disallowance of Rs.12,837,828/- u/s. 40(a)(i) of the Act in respect of information system charges and telecommunication expenses debited by the assessee without appreciating that no disallowance was warranted on facts of the case. ITA Nos.1163 & 1164/PUN/2017 3 John Deere

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