DEPUTY COMMISSIONER OF INCOME-TAX,, PUNE vs. M/S. SECO TOOLS INDIA PVT. LTD.,, PUNE

In the result, the Cross Objections of assessee are allowed and appeals of Revenue are dismissed

Bench: Ms. Sushma Chowla, Jm & Shri Anil Chaturvedi, Am आयकर अपीऱ सं. / Ita Nos.812 & 813/Pun/2017 यििाारण वषा / Assessment Years : 2002-03 & 2003-04

vi) & 9(1)(vii) of the Act. The Assessing Officer further holds that on examination of nature of payments made to the assessee as per agreement dated 01.04.2002, it could be concluded that the payments received by the assessee constitute royalty and fees for technical services, as per sections of the Act as well as Article 12 of the DTAA

DEPUTY DIRECTOR OF INCOME-TAX,, PUNE vs. SANDVIK A B.,, PUNE

Bench: Ms. Sushma Chowla, Jm & Shri D. Karunakara Rao, Am आयकर अपीऱ सं. / Ita No.608/Pun/2014 यििाारण वषा / Assessment Year :2006-07

vi) & 9(1)(vii) of the Act. The Assessing Officer further holds that on examination of nature of payments made to the assessee as per agreement dated 01.04.2002, it could be concluded that the payments received by the assessee constitute royalty and fees for technical services, CO Nos.20 & 28/PUN/2015 as per sections of the Act as well as Article

DEPUTY DIRECTOR OF INCOME-TAX vs. SANDVIK A B.,, PUNE

Bench: Ms. Sushma Chowla, Jm & Shri D. Karunakara Rao, Am आयकर अपीऱ सं. / Ita No.608/Pun/2014 यििाारण वषा / Assessment Year :2006-07

vi) & 9(1)(vii) of the Act. The Assessing Officer further holds that on examination of nature of payments made to the assessee as per agreement dated 01.04.2002, it could be concluded that the payments received by the assessee constitute royalty and fees for technical services, CO Nos.20 & 28/PUN/2015 as per sections of the Act as well as Article

DCIT CIRCLE 1 NASHIK, NASHIK vs. SHREE SAI PROPERTIES, NASHIK

In the result, appeal of the Revenue is dismissed

Bench: Dr. Manish Borad & Shri Vinay Bhamore

reassessment, proceedings must be initiated under Section 153C, not Section 147. The Hon. Court held that the AO lacked jurisdiction under Section 147, rendering the notice invalid. Consequently, the court quashed and set aside the notice under Section 148 and allowed the petition of the assessee. (Relevant paragraphs 16 to 24). • In the case of Shyam Sunder Khandelwal vs. ACIT

MR. CHITTARANJAN TRIMBAK GAIKWAD,PUNE vs. THE ASST. COMMISSIONER OF INCOME TAX, CIRCLE-4, PUNE, PUNE

In the result, the appeal of the assessee is allowed

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

reassessment, if any, relating to any assessment year falling within the period of six assessment years referred to in this sub-section pending on the date of initiation of the search under Section 132 or making of requisition under Section 1324, as the case may be, shall abate." What is clear from this is that Section 153A

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

reassessment order, the A.O has initiated penalty u/s 270A on a vague charge of furnishing inaccurate particulars of income' also in the notice u/s 274 r.w.s 270A, the exact limb of section 270A(9) which has been allegedly violated by the assessee has not been specified and hence, the 7 ITA No.59/PUN/2025, AY 2018-19 penalty order passed u/s 270A

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

Accordingly, the appeals of assessee for assessment years 2009-10, 2010-11 and 2011-12 are partly allowed for statistical purposes

Bench: Shri D. Karunakara Rao, Am & Shri Vikas Awasthy, Jm आयकर अपील सं. / Ita Nos. 431 To 434/Pun/2016 "नधा"रण वष" / Assessment Years: 2008-09 To 2011-12

u/s. 201(1) was passed. The ld. DR further contended that in view of the amendments brought by the Finance Act, 2012 to section 9 and 195, the Assessing Officer has rightly invoked the provisions of section 148 r.w.s 147 of the Act. The ld. DR prayed for upholding the order of Commissioner of Income Tax (Appeals) and dismissing

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

Accordingly, the appeals of assessee for assessment years 2009-10, 2010-11 and 2011-12 are partly allowed for statistical purposes

Bench: Shri D. Karunakara Rao, Am & Shri Vikas Awasthy, Jm आयकर अपील सं. / Ita Nos. 431 To 434/Pun/2016 "नधा"रण वष" / Assessment Years: 2008-09 To 2011-12

u/s. 201(1) was passed. The ld. DR further contended that in view of the amendments brought by the Finance Act, 2012 to section 9 and 195, the Assessing Officer has rightly invoked the provisions of section 148 r.w.s 147 of the Act. The ld. DR prayed for upholding the order of Commissioner of Income Tax (Appeals) and dismissing

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

Accordingly, the appeals of assessee for assessment years 2009-10, 2010-11 and 2011-12 are partly allowed for statistical purposes

Bench: Shri D. Karunakara Rao, Am & Shri Vikas Awasthy, Jm आयकर अपील सं. / Ita Nos. 431 To 434/Pun/2016 "नधा"रण वष" / Assessment Years: 2008-09 To 2011-12

u/s. 201(1) was passed. The ld. DR further contended that in view of the amendments brought by the Finance Act, 2012 to section 9 and 195, the Assessing Officer has rightly invoked the provisions of section 148 r.w.s 147 of the Act. The ld. DR prayed for upholding the order of Commissioner of Income Tax (Appeals) and dismissing

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

Accordingly, the appeals of assessee for assessment years 2009-10, 2010-11 and 2011-12 are partly allowed for statistical purposes

Bench: Shri D. Karunakara Rao, Am & Shri Vikas Awasthy, Jm आयकर अपील सं. / Ita Nos. 431 To 434/Pun/2016 "नधा"रण वष" / Assessment Years: 2008-09 To 2011-12

u/s. 201(1) was passed. The ld. DR further contended that in view of the amendments brought by the Finance Act, 2012 to section 9 and 195, the Assessing Officer has rightly invoked the provisions of section 148 r.w.s 147 of the Act. The ld. DR prayed for upholding the order of Commissioner of Income Tax (Appeals) and dismissing

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

9. Ld. Counsel for the assessee referred and relied on following decisions : i. CIT Vs. Jet Airways (I) Ltd. (2010) 195 Taxman 117 (Bom.) ii. PCIT Vs. Lark Chemicals (P) Ltd. (2018) 99 taxmann.com 312 (SC) iii. Dhruv Parulbhai Patel Vs. ACIT (2014) 45 taxmann.com 20 (Gujarat) iv. Hindustan Lever Ltd. Vs. R.B. Wadkar 268 ITR 332 (Bombay

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

9. Ld. Counsel for the assessee referred and relied on following decisions : i. CIT Vs. Jet Airways (I) Ltd. (2010) 195 Taxman 117 (Bom.) ii. PCIT Vs. Lark Chemicals (P) Ltd. (2018) 99 taxmann.com 312 (SC) iii. Dhruv Parulbhai Patel Vs. ACIT (2014) 45 taxmann.com 20 (Gujarat) iv. Hindustan Lever Ltd. Vs. R.B. Wadkar 268 ITR 332 (Bombay

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

9. Ld. Counsel for the assessee referred and relied on following decisions : i. CIT Vs. Jet Airways (I) Ltd. (2010) 195 Taxman 117 (Bom.) ii. PCIT Vs. Lark Chemicals (P) Ltd. (2018) 99 taxmann.com 312 (SC) iii. Dhruv Parulbhai Patel Vs. ACIT (2014) 45 taxmann.com 20 (Gujarat) iv. Hindustan Lever Ltd. Vs. R.B. Wadkar 268 ITR 332 (Bombay

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

VI-A of the Income Tax Act, 1961 (hereinafter referred to as ‘the Act’). The Assessing Officer in this case obtained information that the assessee had made cash deposit of Rs.6,09,74,438/- as a member of the society in the account maintained with M/s. Shri Renuka Mata Multistate Credit Society Ltd. during the impugned assessment year. After

DEEPAK KANTILAL JAIN,PUNE vs. ACIT, CENTRAL CIRCLE 2(1), PUNE , PUNE

The appeal stands dismissed

Bench: Shri R. K. Panda & Shri Vinay Bhamore

vi. Further, the statement of Shri Yuvaraj Dhamale was also recorded U/s 132(4) of the Act, wherein he had also accepted that these documents were being maintained by Shri Umakant Kuwar as per his directions and these seized sheets contain details of transactions w.r.t. sale of flat, mode of payment and accounting treatment given to such payment

CHITRA NARENDRA PARMAR,PUNE vs. ASSISTANT COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-2(1), PUNE, PUNE

In the result, all the appeals filed by the respective assessees are allowed

Bench: Shri R. K. Panda & Shri Vinay Bhamore

vi. Further, the statement of Shri Yuvaraj Dhamale was also recorded U/s 132(4) of the Act, wherein he had also accepted that these documents were being maintained by Shri Umakant Kuwar as per his directions and these seized sheets contain details of transactions w.r.t. sale of flat, mode of payment and accounting treatment given to such payment

RAMANLAL BHIKULAL SHAH,PUNE vs. ACIT, CENTRAL CIRCLE 2(1), PUNE , PUNE

In the result, all the appeals filed by the respective assessees are allowed

Bench: Shri R. K. Panda & Shri Vinay Bhamore

vi. Further, the statement of Shri Yuvaraj Dhamale was also recorded U/s 132(4) of the Act, wherein he had also accepted that these documents were being maintained by Shri Umakant Kuwar as per his directions and these seized sheets contain details of transactions w.r.t. sale of flat, mode of payment and accounting treatment given to such payment

RAMLAL BHIKULAL SHAH,PUNE vs. ACIT, CENTRAL CIRCLE 2(1), PUNE , PUNE

In the result, all the appeals filed by the respective assessees are allowed

Bench: Shri R. K. Panda & Shri Vinay Bhamore

vi. Further, the statement of Shri Yuvaraj Dhamale was also recorded U/s 132(4) of the Act, wherein he had also accepted that these documents were being maintained by Shri Umakant Kuwar as per his directions and these seized sheets contain details of transactions w.r.t. sale of flat, mode of payment and accounting treatment given to such payment

CHITRA NARENDRA PARMAR ,PUNE vs. ACIT, CENTRAL CIRCLE 2(1), PUNE , PUNE

In the result, all the appeals filed by the respective assessees are allowed

Bench: Shri R. K. Panda & Shri Vinay Bhamore

vi. Further, the statement of Shri Yuvaraj Dhamale was also recorded U/s 132(4) of the Act, wherein he had also accepted that these documents were being maintained by Shri Umakant Kuwar as per his directions and these seized sheets contain details of transactions w.r.t. sale of flat, mode of payment and accounting treatment given to such payment