RAJDEEP BUILDCON PRIVAT LIMITED, AHMEDNAGAR,AHMEDNAGAR vs. DY. COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE 1(2), PUNE, PUNE

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

Bench: SHRI R. K. PANDA (Vice President), SHRI VINAY BHAMORE (Judicial Member)

147 i.e. reassessment, to the extent that these proceedings are for the benefit of revenue and not that of the assessee. Therefore, assessee could not be permitted to convert such reassessment proceedings as his appeal or revision in disguise and seek relief in respect of depreciation earlier not claimed in original return of income. 17. Thus, the law is clear

ITO, WARD-1(1), SOLAPUR, SOLAPUR vs. MS. KSHIRSAGAR FABRICS, SOLAPUR

In the result, the appeal filed by the Revenue is dismissed

Bench: Shri R. K. Panda & Ms Astha Chandraassessment Year : 2009-10

reassessment notice as the AO has not established that new facts material or information came the knowledge of the AO which was not on record and available at the time of assessment. It is clear that on account of the audit objection that a remedial action of reopening the assessment by an action u/s 148 of the Act was taken

NAVJYOTI FARMING PRIVATE LIMITED,BELAPUR vs. ITO, WARD -3 , PANVEL

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

Bench: Shri R. K. Panda & Ms. Astha Chandraassessment Year : 2012-13

section 147 of the Act and in absence of any recording by the Assessing Officer of any failure on the part of the assessee to disclose fully and truly all material facts necessary for completion of assessment, such reopening of assessment is not valid. For the above proposition, he relied on the following decisions: (i) SABH Infrastructure Ltd. vs. ACIT

VILSON ROOFING PRODUCTS PRIVATE LIMITED,KOLHAPUR vs. THE ASSISTANT COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE, KOLHAPUR

The appeal of the assessee is DISMISSED

Bench: Shri Partha Sarathi Chaudhury & Shri G. D. Padmahshaliआयकर अपऩल सं. / Ita No. 956/Pun/2023 निर्धारण वर्ा / Assessment Year : 2009-10 Vilson Roofing Products Pvt. Ltd., 1St Lane, Opp. Prataprao Jagdale Hall, Rajarampuri, Kolhapur, Pin – 416 008 . . . . . . . अपऩलधथी / Appellant Pan: Aaccv0661M

section 147(a) is that the Assessing Officer had when he assumed jurisdiction some prims facie grounds for thinking that there has been some non-disclosure of material facts. Whether these grounds were adequate or not for arriving at such conclusion would not be open for the Courts‟ Investigation. Clearly it-is the duty of the assessee who wants

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

In the result, the appeal of the assessee is allowed

section 189 of\nthe Act and upholding the impugned assessment order in case of a dissolved\nfirm for the relevant AY 2017-18 i.e. post dissolution when the firm is not even\nin existence.\n6.\nThe Ld. DR, on the other hand, strongly supported the order of the Ld.\nAO and the Ld. CIT(A)/NFAC.\n7.\nWe have heard

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

In the result, the appeal of the assessee is allowed

section 189 of\nthe Act and upholding the impugned assessment order in case of a dissolved\nfirm for the relevant AY 2017-18 i.e. post dissolution when the firm is not even\nin existence.\n6. The Ld. DR, on the other hand, strongly supported the order of the Ld.\nAO and the Ld. CIT(A)/NFAC.\n7. We have heard

DHOOT COMPACK PRIVATE LIMITED,AHMEDNAGAR vs. THE DEPUTY COMMISSIONER OF INCOME TAX, AHMEDNAGAR CIRCLE, AHMEDNAGAR

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

Bench: SHRI R. K. PANDA (Vice President), SHRI VINAY BHAMORE (Judicial Member)

section 148. Hence the reassessment becomes bad in law and accordingly the addition made of Rs. 726485/- may please be deleted. Without prejudice to the above ground following grounds may please be considered. 2. On the facts and in the prevailing circumstances of the case and in law the Resp. CIT(A)-NFAC erred in confirming the addition made

KAY POWER AND PAPER LIMITED,SATARA vs. INCOME TAX OFFICER, WARD-2, SATARA

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

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

reassessment then the same would equally apply for issuance of notice under Section 148 of the Act. (iii) The conclusion at the bottom of page 2 in paragraph 3 of the Office Memorandum that "Therefore, as provided in the scheme the notice under section 148 of the Act is issued on automated allocation of cases to the Assessing Officer based

KAY POWER AND PAPER LIMITED,SATARA vs. INCOME TAX OFFICER, WARD-2, SATARA

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

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

reassessment then the same would equally apply for issuance of notice under Section 148 of the Act. (iii) The conclusion at the bottom of page 2 in paragraph 3 of the Office Memorandum that "Therefore, as provided in the scheme the notice under section 148 of the Act is issued on automated allocation of cases to the Assessing Officer based

DEPUTY COMMISSIONER OF INCOME TAX, AURANGABAD vs. SURYACHANDRA LALMANI DUBEY, AURANGABAD

In the result, appeal of the Revenue is allowed

Bench: SHRI SATBEER SINGH GODARA, JUDICIAL MEMBER AND DR.DIPAK P. RIPOTE (Accountant Member)

reassessment proceedings. The AO made addition of Rs.2,04,80,489/-. Aggrieved by the Order the Assessee filed appeal before the Ld.CIT(A). The 2 Suryachandra Lalmani Dubey [R] Ld.CIT(A) held that the AO had recorded the reasons for reopening as “needs to be verified”, which is outside the purview of section 147.Accordingly,Ld.CIT(A) allowed the Legal ground

DEPUTY COMMISSIONER OF INCOME TAX, JALGAON vs. TARADEVI RATANLAL BAFNA, JALGAON

91, PO R C Bafna Jewellers,\n| | | Nayantara, Subhash Chowk,\n| | | Jalgaon – 425001\n| | | PAN : AADPB9424E\n| | | (Respondent)\n\nAssessee by\n: S/Shri Suchek Anchaliya and\nTushar Nagori\nDepartment by\n: Shri Amit Bobde, CIT\nDate of hearing\n: 12-08-2025\nDate of pronouncement\n: 27-10-2025\n\nORDER\n\nPER R.K. PANDA, VP:\n\nITA Nos.1555/PUN/2024 & 1560/PUN/2024

RATANLAL C. BAFNA,,JALGAON vs. DEPUTY COMMISSIONER OF INCOME-TAX,, JALGAON

Accordingly. These assessee’s three appeals raising the above stated identical issues as partly allowed for statistical purposes in above terms

Bench: Shri S.S.Godara, Jm & Shri Dr. Dipak P. Ripote, Am आयकर अपील सं. / Ita No.01 To 03/Pun/2016 धनधाारण वषा / Assessment Year : 2005-06 To 2007-08

u/s. 143(3) r.w.s. 147 of the Income Tax Act, 1961; in short "the Act”. Heard both the parties. Case files perused. A.Y. : 2005-06 to 2007-08 Shri Ratanlal C. Bafna, 2. It emerges at the outset that the assessee’s instant three appeals raise identical issue(s) of validity of the impugned section 148/147 proceedings followed

RATANLAL C. BAFNA,,JALGAON vs. DEPUTY COMMISSIONER OF INCOME-TAX,, JALGAON

Accordingly. These assessee’s three appeals raising the above stated identical issues as partly allowed for statistical purposes in above terms

Bench: Shri S.S.Godara, Jm & Shri Dr. Dipak P. Ripote, Am आयकर अपील सं. / Ita No.01 To 03/Pun/2016 धनधाारण वषा / Assessment Year : 2005-06 To 2007-08

u/s. 143(3) r.w.s. 147 of the Income Tax Act, 1961; in short "the Act”. Heard both the parties. Case files perused. A.Y. : 2005-06 to 2007-08 Shri Ratanlal C. Bafna, 2. It emerges at the outset that the assessee’s instant three appeals raise identical issue(s) of validity of the impugned section 148/147 proceedings followed

RATANLAL C. BAFNA,,JALGAON vs. DEPUTY COMMISSIONER OF INCOME-TAX,, JALGAON

Accordingly. These assessee’s three appeals raising the above stated identical issues as partly allowed for statistical purposes in above terms

Bench: Shri S.S.Godara, Jm & Shri Dr. Dipak P. Ripote, Am आयकर अपील सं. / Ita No.01 To 03/Pun/2016 धनधाारण वषा / Assessment Year : 2005-06 To 2007-08

u/s. 143(3) r.w.s. 147 of the Income Tax Act, 1961; in short "the Act”. Heard both the parties. Case files perused. A.Y. : 2005-06 to 2007-08 Shri Ratanlal C. Bafna, 2. It emerges at the outset that the assessee’s instant three appeals raise identical issue(s) of validity of the impugned section 148/147 proceedings followed

RATHOD JEWELLERS,PUNE vs. ACIT, CENTRAL CIRCLE -2(3), PUNE

In the result, appeal of the assessee is dismissed

Bench: Shri Rama Kanta Panda & Ms. Astha Chandra

91,23,140/- The case was selected for scrutiny under CASS and the assessment was completed u/s 143(3) of the Income Tax Act, 1961 (“The Act”) on 16.11.2019 accepting income returned by the assessee. Subsequently, based on the information available with the “Ld. Assessing Officer (“AO”), the case of the assessee was re-opened by issue of notice u/s

DEPUTY COMMISSIONER OF INCOME TAX, CIRCLE-1, AURANGABAD, AURANGABAD vs. ENDURANCE TECHNOLOGIES LIMITED, AURANGABAD

In the result, all the appeals filed by the Revenue are dismissed

147 of the Act on\nthe ground that the assessee has wrongly claimed deduction u/s 35(2AB) of the Act\nwhich tantamount to concealment of income and which came to light as a result of\ninformation gathered from DSIR. We find the Assessing Officer, rejecting the\nvarious explanations given by the assessee and observing that the assessee has not\nobtained

ASSISTANT COMMISSIONER OF INCOME TAX, JALGAON vs. SIDHARTH RATANLAL BAFNA, JALGAON

91, PO R C Bafna Jewellers, |\n| | | Nayantara, Subhash Chowk, |\n| | | Jalgaon – 425001 |\n| | | PAN : AADPB9424E |\n| | | (Respondent)\n\nAssessee by\nDepartment by\n: S/Shri Suchek Anchaliya and\nTushar Nagori\n: Shri Amit Bobde, CIT\nDate of hearing\n: 12-08-2025\nDate of pronouncement : 27-10-2025\n\nORDER\nPER R.K. PANDA, VP:\n\nITA Nos.1555/PUN/2024 & Ors\nCO Nos.2

ASSISTANT COMMISSIONER OF INCOME TAX, JALGAON vs. SIDHARTH RATANLAL BAFNA, JALGAON

91, PO R C Bafna Jewellers,\n| | Nayantara, Subhash Chowk,\n| | Jalgaon – 425001\n| | PAN : AADPB9424E\n(Appellant) | | (Respondent)\n\nAssessee by : S/Shri Suchek Anchaliya and\nTushar Nagori\nDepartment by : Shri Amit Bobde, CIT\nDate of hearing : 12-08-2025\nDate of pronouncement : 27-10-2025\n\nORDER\n\nPER R.K. PANDA, VP:\n\nITA Nos.1555/PUN/2024 & Ors\nCO Nos.2