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

9. So far as the validity of the assessment u/s 147 of the Act is concerned, the Ld. CIT(A) / NFAC did not adjudicate the same since he has deleted the addition on merit by observing as under: 10. Aggrieved with such order of the Ld. CIT(A) / NFAC the Revenue is in appeal before the Tribunal by raising

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

9 of the chart enclosed with the seized papers do not represent\nany cash transactions with the assessee, the Assessing Officer dropped the\nproceedings.\n15.\nHe submitted that the Assessing Officer in the instant case has issued notice\nu/s 148 of the Act after recording the reasons on the basis of material supplied by\nthe ACIT, Central Circle

SATISH VISHNU THOMBARE, INCOME TAX OFFICER, WARD-1, AHMEDNAGAR, AHMEDNAGAR vs. VARSHA PRAFULLA ZENDE, AHMEDNAGAR

In the result, the appeal of the Revenue is dismissed

Bench: Shri R.K. Panda & Ms. Astha Chandraआयकर अपील सं. / Ita No.1656/Pun/2024 धििाारण वर्ा / Assessment Year : 2010-11 Satish Vishnu Thombare, Varsha Prafulla Zende, Income Tax Officer, Prop Of Bleach Chem Enterprises, Ward-1, Ahmednagar Vs. Industrial Estate, Shrirampur, Maharashtra-413709 Pan : Aabpz2541C अपीलार्थी / Appellant प्रत्यर्थी / Respondent Assessee By : Miss Shivani Shah (Virtual) Department By : Shri Akhilesh Srivastva Date Of Hearing : 06-08-2025 Date Of 29-10-2025 Pronouncement : आदेश / Order

9. Section 147 provides that if the Assessing Officer has reason to believe that any income chargeable to tax has escaped assessment for any assessment year, he may subject to the provisions of sections 148 to 163, assess or reassess such income and also any other income chargeable to tax, which has escaped assessment and which comes to his notice

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

reassessment, referred to in clause (a) of sub-section (1), in a case where an order under sub-section (4) has been made accepting the application.‖. 5.3 Before leaping to section 270A of the Act, we first consider section 270AA of the Act in order to find out whether the Form 68 filed by the Assessee Company on 06/10/2022

SHRI SHANTINATH BHAGWAN JAIN SHWETAMBAR MURTIPUJAK SANGH,PUNE vs. CIT, EXEMPTION,, PUNE

Appeal is allowed

Bench: Shri S.S. Godara & Shri G.D. Padmahshali

u/s. 263 of the Income Tax Act, 1961; in short “the Act”. Heard both the parties. Case file perused. 2 ITA No.203/PUN/2021, A.Y. 2010-11 2. It emerges at the outset that the CIT(E)’s impugned order exercising section 263 revision jurisdiction terms the corresponding assessment /reassessment herein dated 29-09-2017 as an erroneous one causing prejudice

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

147 of the Act is valid when the original\nassessment was completed u/s 143(3) of the Act, the reasons recorded do not\ncontain any allegation by the Assessing Officer of any failure on the part of\nassessee to disclose fully and truly all material facts necessary for completion of\nthe assessment and such reopening is beyond a period

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

147 of the Act is valid when the original\nassessment was completed u/s 143(3) of the Act, the reasons recorded do not\ncontain any allegation by the Assessing Officer of any failure on the part of\nassessee to disclose fully and truly all material facts necessary for completion of\nthe assessment and such reopening is beyond a period

M/S. RAJLAXMI PETROCHEM PVT.LTD,,LATUR vs. INCOME-TAX OFFICER, WARD - 1,, LATUR

Appeals are allowed in above terms

Bench: Shri Satbeer Singh Godara & Dr. Dipak P. Ripote

u/s. 263 of the Income Tax Act, 1961 (in short "the Act"). 2. Heard both the parties. Case files perused. 3. It emerges during the course of hearing that relevant facts in assessee’s former twin appeals hardly require us to delve deeper in the relevant factual matrix so far as its first and foremost substantive grievance challenging correctness

M/S. RAJLAXMI PETROCHEM PVT.LTD,,LATUR vs. INCOME-TAX OFFICER, WARD - 1,, LATUR

Appeals are allowed in above terms

Bench: Shri Satbeer Singh Godara & Dr. Dipak P. Ripote

u/s. 263 of the Income Tax Act, 1961 (in short "the Act"). 2. Heard both the parties. Case files perused. 3. It emerges during the course of hearing that relevant facts in assessee’s former twin appeals hardly require us to delve deeper in the relevant factual matrix so far as its first and foremost substantive grievance challenging correctness

M/S. RAJLAXMI PETROCHEM PVT.LTD,,LATUR vs. PRINCIPAL COMMISSIONER OF INCOME-TAX, , NASHIK

Appeals are allowed in above terms

Bench: Shri Satbeer Singh Godara & Dr. Dipak P. Ripote

u/s. 263 of the Income Tax Act, 1961 (in short "the Act"). 2. Heard both the parties. Case files perused. 3. It emerges during the course of hearing that relevant facts in assessee’s former twin appeals hardly require us to delve deeper in the relevant factual matrix so far as its first and foremost substantive grievance challenging correctness

TEJAS SHIVAJI ADSUL,KOLHAPUR vs. INCOME TAX OFFICER WARD 1(1), KOLHAPUR, KOLHAPUR

In the result, appeal of the assessee is allowed

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

147 passed for the year. Therefore, as per provisions of section 270A(3)(1)(b)(A), quantum of „Under reported income' in hands of appellant will be „Income assessed‟ i,e Rs 24,70,490/- in the present case. 7.7 It is noticed that AO has levied penalty for misreporting of income u/s 270A(9). Section 270A(9) prescribes instances

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 was not valid and the proper course of action that should have been taken by the Assessing Officer was u/s 153C as the provisions of section 153C of the Act are clearly applicable to the facts of the case. We, therefore, uphold the order of the CIT(A) / NFAC on the issue of validity of re-assessment proceedings

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, 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 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

CLARION TECHNOLOGIES PVT. LTD.,,PUNE vs. DEPUTY COMMISSIONER OF INCOME-TAX,,

In the result, the appeal of assessee is allowed

Bench: Shri R.S. Syal & Shri S.S. Viswanethra Ravi

sections 148 to 153, assess or reassess such income and also any other income chargeable to tax which has escaped assessment and which comes to his notice subsequently. He submits that if an assessment was made u/s. 143(3) of the Act and no action can be taken u/s. 147 of the Act after the expiry of four years from

DEPUTY COMMISSIONER OF INCOME-TAX vs. CLARION TECHNOLOGIES PVT. LTD.,, PUNE

In the result, the appeal of assessee is allowed

Bench: Shri R.S. Syal & Shri S.S. Viswanethra Ravi

sections 148 to 153, assess or reassess such income and also any other income chargeable to tax which has escaped assessment and which comes to his notice subsequently. He submits that if an assessment was made u/s. 143(3) of the Act and no action can be taken u/s. 147 of the Act after the expiry of four years from

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 is after expiry of the four years from the end of A.Y.2012-13 and therefore the reassessment proceeding are initiated beyond the time limit and are thus time barred and bad in law and not sustainable. 4. Learned CIT(A) has erred in fact and in law in confirming the addition made by A.O. without considering the fact that reassessment