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 order, appears to have proceeded on the analogy that, some taxable income has escaped assessment. As against, vide Section 115BBC, mere rate of tax is differentiated from normal income. As stated earlier, entire charge of the learned AO at the stage of formation of belief of 'escapement of income' by resorting to Section 68

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

147 order, appears to have proceeded on the analogy that, some taxable income has escaped assessment. As against, vide Section 115BBC, mere rate of tax is differentiated from normal income. As stated earlier, entire charge of the learned AO at the stage of formation of belief of 'escapement of income' by resorting to Section 68

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

147 order, appears to have proceeded on the analogy that, some taxable income has escaped assessment. As against, vide Section 115BBC, mere rate of tax is differentiated from normal income. As stated earlier, entire charge of the learned AO at the stage of formation of belief of 'escapement of income' by resorting to Section 68

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

147; it makes no distinction between an order passed under section 143(3) and the intimation issued under section 143(1). Therefore it is not permissible to adopt different standards while interpreting the words “reason to believe” vis-à-vis Section 143(1) and Section 143(3). We are unable to appreciate what permits the Revenue

RAJARSHI SHAHU SHIKSHAN SANSTHA INAM DHAMANI,SANGLI vs. ITO EXEMPTION , KOLHAPUR, KOLHAPUR

In the result, all the appeals filed by the assessee are\npartly allowed as per terms indicated hereinabove

147 order, appears to have proceeded on the\nanalogy that, some taxable income has escaped assessment. As\nagainst, vide Section 115BBC, mere rate of tax is differentiated from\nnormal income. As stated earlier, entire charge of the learned AO at\nthe stage of formation of belief of 'escapement of income' by resorting\nto Section 68

RAJARSHI SHAHU SHIKSHAN SANSTHA INAM DHAMANI,SANGLI vs. ITO EXEMPTION, KOLHAPUR, KOLHAPUR

In the result, all the appeals filed by the assessee are\npartly allowed as per terms indicated hereinabove

147 order, appears to have proceeded on the\nanalogy that, some taxable income has escaped assessment. As\nagainst, vide Section 115BBC, mere rate of tax is differentiated from\nnormal income. As stated earlier, entire charge of the learned AO at\nthe stage of formation of belief of 'escapement of income' by resorting\nto Section 68

RAJARSHI SHAHU SHIKSHAN SANSTHA INAM DHAMANI,SANGLI vs. ITO EXEMPTION, KOLHAPUR

In the result, all the appeals filed by the assessee are\npartly allowed as per terms indicated hereinabove

147 order, appears to have proceeded on the\nanalogy that, some taxable income has escaped assessment. As\nagainst, vide Section 115BBC, mere rate of tax is differentiated from\nnormal income. As stated earlier, entire charge of the learned AO at\nthe stage of formation of belief of 'escapement of income' by resorting\nto Section 68

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

68 of the Act amounting to Rs.2,58,67,123/- vide order dated 30.12.2017 passed u/s 147 r.w.s. 143(3) of the Act. Before the 2 ITA No.1656/PUN/2024, AY 2010-11 Ld. CIT(A)/NFAC, the assessee challenged the above addition made by the Ld. AO on legal ground as well as on the merits of the case

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

147 of the Act on 26.03.2018 by recording the\nfollowing reasons:\n“02. In response to notices issued, Shri H.G. Sharma, CA Authorized\nRepresentatives attended from time to time and explained the return. During the\ncourse of assessment proceeding, the assessee has requested to provide the\nreasons for reopening of the case u/s 148 of the Act. The reasons recorded

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

147 of the Act on 26.03.2018 by recording the\nfollowing reasons:\n“02. In response to notices issued, Shri H.G. Sharma, CA Authorized\nRepresentatives attended from time to time and explained the return. During the\ncourse of assessment proceeding, the assessee has requested to provide the\nreasons for reopening of the case u/s 148 of the Act. The reasons recorded

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

68 of the Income Tax Act. [4] On the facts and in the prevailing circumstances of the case as well as in law, the learned CIT(A) has failed to appreciate the facts of case and in confirming the addition of Rs.8,40,00,000/-, u/s.68 of the IT Act, for the following reasons: (a) Merely on doubt, assumption, presumption

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

68,24, 174/-.\nIn view of the above facts, the provisions of clause (c) of explanation 2 to section 147

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

68,24, 174/-.\n\nIn view of the above facts, the provisions of clause (c) of explanation 2 to section 147

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

68,24, 174/-.\n\nIn view of the above facts, the provisions of clause (c) of explanation 2 to section 147

AADHUNIK INFRASTRUCTURE DEVELOPMENT PRIVATE LIMITED,JALGAON vs. THE DEPUTY COMMISSIONER OF INCOME TAX, CIRCLE-1, JALGAON

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

Bench: Shri R. K. Panda & Shri Vinay Bhamoreassessment Year : 2012-13

147 of the Act. 8. In this case, more than four years have lapsed from the end of assessment year under consideration. Hence necessary sanction to issue notice u/s 148 has to be obtained as per the provisions of section u/s 151 of the IT Act from the Pr. Commissioner of Income Tax.-2, Nashik. Therefore, necessary sanction

JAIBHAGWAN BANARASIDAS JINDAL,JALNA vs. THE INCOME TAX OFFICER, WARD-1, JALNA

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

Bench: Shri R. K. Panda & Ms. Astha Chandraassessment Year : 2016-17

147 is squarely applicable in the case of the assessee. Applicability of the provisions of section 147/151 to the facts of the case:- In this case more than four years have not lapsed from the end of the assessment year under consideration. Hence the approval of the Jt. Commissioner of Income Tax-27(1), Mumbai is hereby sought

MADANLAL LALCHAND JAIN,NANDURBAR vs. ACIT CENTRAL CIRCLE 2, NASHIK

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

Bench: Shri R. K. Panda & Ms. Astha Chandraassessment Year : 2021-22 Madanlal Lalchand Jain Acit, Central Circle-2, Vibhare Building, Nashik Near City Police Station, Vs. Hat Darwaja Station Road, Nandurbar – 425412 Pan: Abkpj3633K (Appellant) (Respondent) Assessment Year : 2021-22 Acit, Central Circle-2, Madanlal Lalchand Jain Nashik Vibhare Building, Vs. Near City Police Station, Hat Darwaja Station Road, Nandurbar – 425412 Pan: Abkpj3633K (Appellant) (Respondent) Co No.42/Pun/2025 Assessment Year : 2021-22 Madanlal Lalchand Jain Acit, Central Circle-2, Vibhare Building, Nashik Near City Police Station, Vs. Hat Darwaja Station Road, Nandurbar – 425412 Pan: Abkpj3633K (Appellant) (Respondent) Assessment Year : 2022-23 Madanlal Lalchand Jain Acit, Central Circle-2, Vibhare Building, Nashik Near City Police Station, Vs. Hat Darwaja Station Road, Nandurbar – 425412 Pan: Abkpj3633K (Appellant) (Respondent) : Shri Nikhil S Pathak Department By : Shri Amol Khairnar, Cit-Dr Date Of Hearing : 03-11-2025 Date Of Pronouncement : 21-11-2025 O R D E R Per Bench:

147 was valid without appreciating that the approval for completion of asst. was given mechanically and therefore, the reasst order ought to have been held to be null and void. 2] The learned CIT(A) erred in confirming the action of the learned A.O in taxing the amount of Rs.2,36,00,000/- u/s 68 r.w.s. 115BBE

ASST. COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-2, NASHIK, NASHIK vs. MADANLAL LALCHAND JAIN, NANDURBAR

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

Bench: Shri R. K. Panda & Ms. Astha Chandraassessment Year : 2021-22 Madanlal Lalchand Jain Acit, Central Circle-2, Vibhare Building, Nashik Near City Police Station, Vs. Hat Darwaja Station Road, Nandurbar – 425412 Pan: Abkpj3633K (Appellant) (Respondent) Assessment Year : 2021-22 Acit, Central Circle-2, Madanlal Lalchand Jain Nashik Vibhare Building, Vs. Near City Police Station, Hat Darwaja Station Road, Nandurbar – 425412 Pan: Abkpj3633K (Appellant) (Respondent) Co No.42/Pun/2025 Assessment Year : 2021-22 Madanlal Lalchand Jain Acit, Central Circle-2, Vibhare Building, Nashik Near City Police Station, Vs. Hat Darwaja Station Road, Nandurbar – 425412 Pan: Abkpj3633K (Appellant) (Respondent) Assessment Year : 2022-23 Madanlal Lalchand Jain Acit, Central Circle-2, Vibhare Building, Nashik Near City Police Station, Vs. Hat Darwaja Station Road, Nandurbar – 425412 Pan: Abkpj3633K (Appellant) (Respondent) : Shri Nikhil S Pathak Department By : Shri Amol Khairnar, Cit-Dr Date Of Hearing : 03-11-2025 Date Of Pronouncement : 21-11-2025 O R D E R Per Bench:

147 was valid without appreciating that the approval for completion of asst. was given mechanically and therefore, the reasst order ought to have been held to be null and void. 2] The learned CIT(A) erred in confirming the action of the learned A.O in taxing the amount of Rs.2,36,00,000/- u/s 68 r.w.s. 115BBE

MADANLAL LALCHAND JAIN,NANDURBAR vs. ACIT CENTRAL CIRCLE 2, NASHIK

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

Bench: Shri R. K. Panda & Ms. Astha Chandraassessment Year : 2021-22 Madanlal Lalchand Jain Acit, Central Circle-2, Vibhare Building, Nashik Near City Police Station, Vs. Hat Darwaja Station Road, Nandurbar – 425412 Pan: Abkpj3633K (Appellant) (Respondent) Assessment Year : 2021-22 Acit, Central Circle-2, Madanlal Lalchand Jain Nashik Vibhare Building, Vs. Near City Police Station, Hat Darwaja Station Road, Nandurbar – 425412 Pan: Abkpj3633K (Appellant) (Respondent) Co No.42/Pun/2025 Assessment Year : 2021-22 Madanlal Lalchand Jain Acit, Central Circle-2, Vibhare Building, Nashik Near City Police Station, Vs. Hat Darwaja Station Road, Nandurbar – 425412 Pan: Abkpj3633K (Appellant) (Respondent) Assessment Year : 2022-23 Madanlal Lalchand Jain Acit, Central Circle-2, Vibhare Building, Nashik Near City Police Station, Vs. Hat Darwaja Station Road, Nandurbar – 425412 Pan: Abkpj3633K (Appellant) (Respondent) : Shri Nikhil S Pathak Department By : Shri Amol Khairnar, Cit-Dr Date Of Hearing : 03-11-2025 Date Of Pronouncement : 21-11-2025 O R D E R Per Bench:

147 was valid without appreciating that the approval for completion of asst. was given mechanically and therefore, the reasst order ought to have been held to be null and void. 2] The learned CIT(A) erred in confirming the action of the learned A.O in taxing the amount of Rs.2,36,00,000/- u/s 68 r.w.s. 115BBE