MRS. VASUNDHARA SHAILESH JOSHI,,PUNE vs. DEPUTY COMMISSIONER OF INCOME-TAX,,

In the result, appeals in the case of Mrs

Bench: Ms. Sushma Chowla, Jm & Shri D. Karunakara Rao, Am आयकर अपीऱ सं. / Ita Nos.95 & 96/Pun/2016 यििाारण वषा / Assessment Years : 2009-10 & 2010-11

153C of the Act was specific provision relating to assessment of income of third party on the basis of evidence found with the person searched; whereas provisions of section 147 and 148 of the Act were general. 16. We have heard the rival contentions and perused the record. In the facts of appeals in ITA Nos.95 & 96/PUN/2016, the assessee

JOSHI WADEWALE PRABHAT CINEMA,,PUNE vs. DEPUTY COMMISSIONER OF INCOME-TAX,,

In the result, appeals in the case of Mrs

Bench: Ms. Sushma Chowla, Jm & Shri D. Karunakara Rao, Am आयकर अपीऱ सं. / Ita Nos.95 & 96/Pun/2016 यििाारण वषा / Assessment Years : 2009-10 & 2010-11

153C of the Act was specific provision relating to assessment of income of third party on the basis of evidence found with the person searched; whereas provisions of section 147 and 148 of the Act were general. 16. We have heard the rival contentions and perused the record. In the facts of appeals in ITA Nos.95 & 96/PUN/2016, the assessee

JOSHI WADEWALE HADAPSAR,,PUNE vs. DEPUTY COMMISSIONER OF INCOME-TAX,,

In the result, appeals in the case of Mrs

Bench: Ms. Sushma Chowla, Jm & Shri D. Karunakara Rao, Am आयकर अपीऱ सं. / Ita Nos.95 & 96/Pun/2016 यििाारण वषा / Assessment Years : 2009-10 & 2010-11

153C of the Act was specific provision relating to assessment of income of third party on the basis of evidence found with the person searched; whereas provisions of section 147 and 148 of the Act were general. 16. We have heard the rival contentions and perused the record. In the facts of appeals in ITA Nos.95 & 96/PUN/2016, the assessee

MRS. VASUNDHARA SHAILESH JOSHI,,PUNE vs. DEPUTY COMMISSIONER OF INCOME-TAX,,

In the result, appeals in the case of Mrs

Bench: Ms. Sushma Chowla, Jm & Shri D. Karunakara Rao, Am आयकर अपीऱ सं. / Ita Nos.95 & 96/Pun/2016 यििाारण वषा / Assessment Years : 2009-10 & 2010-11

153C of the Act was specific provision relating to assessment of income of third party on the basis of evidence found with the person searched; whereas provisions of section 147 and 148 of the Act were general. 16. We have heard the rival contentions and perused the record. In the facts of appeals in ITA Nos.95 & 96/PUN/2016, the assessee

JOSHI WADEWALE SHEWALWADI,,PUNE vs. DEPUTY COMMISSIONER OF INCOME-TAX,,

In the result, appeals in the case of Mrs

Bench: Ms. Sushma Chowla, Jm & Shri D. Karunakara Rao, Am आयकर अपीऱ सं. / Ita Nos.95 & 96/Pun/2016 यििाारण वषा / Assessment Years : 2009-10 & 2010-11

153C of the Act was specific provision relating to assessment of income of third party on the basis of evidence found with the person searched; whereas provisions of section 147 and 148 of the Act were general. 16. We have heard the rival contentions and perused the record. In the facts of appeals in ITA Nos.95 & 96/PUN/2016, the assessee

JOSHI WADEWALE SHEWALWADI,,PUNE vs. DEPUTY COMMISSIONER OF INCOME-TAX,,

In the result, appeals in the case of Mrs

Bench: Ms. Sushma Chowla, Jm & Shri D. Karunakara Rao, Am आयकर अपीऱ सं. / Ita Nos.95 & 96/Pun/2016 यििाारण वषा / Assessment Years : 2009-10 & 2010-11

153C of the Act was specific provision relating to assessment of income of third party on the basis of evidence found with the person searched; whereas provisions of section 147 and 148 of the Act were general. 16. We have heard the rival contentions and perused the record. In the facts of appeals in ITA Nos.95 & 96/PUN/2016, the assessee

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

1) and Section 153D leave no room for doubt that approval with respect to "each assessment year" is to be obtained by the Assessing Officer on the draft assessment order before passing the assessment order under Section 153A." [Emphasis supplied] 12. It is observed that the Court in the case of Sapna Gupta (supra) refused to interdict

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

1) and Section 153D leave no room for doubt that approval with respect to "each assessment year" is to be obtained by the Assessing Officer on the draft assessment order before passing the assessment order under Section 153A." [Emphasis supplied] 12. It is observed that the Court in the case of Sapna Gupta (supra) refused to interdict

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

1) and Section 153D leave no room for doubt that approval with respect to "each assessment year" is to be obtained by the Assessing Officer on the draft assessment order before passing the assessment order under Section 153A." [Emphasis supplied] 12. It is observed that the Court in the case of Sapna Gupta (supra) refused to interdict

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

1) and Section 153D leave no room for doubt that approval with respect to "each assessment year" is to be obtained by the Assessing Officer on the draft assessment order before passing the assessment order under Section 153A." [Emphasis supplied] 12. It is observed that the Court in the case of Sapna Gupta (supra) refused to interdict

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

The appeal stands dismissed

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

153C by recording satisfaction when the jurisdiction was ceased with the Assessing Officer has not been considered by the JCIT. A perusal of the order passed u/s 127 of the Act shows that the jurisdiction was transferred to Central Circle 2(3), Pune for a coordinated investigation with Dhamale group of cases. It is also an admitted fact that

ASHOK BHARTI GOSWAMI,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

1) and Section 153D leave no room for doubt that approval with respect to "each assessment year" is to be obtained by the Assessing Officer on the draft assessment order before passing the assessment order under Section 153A." [Emphasis supplied] 12. It is observed that the Court in the case of Sapna Gupta (supra) refused to interdict

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

The appeal stands dismissed

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

153C by recording satisfaction when the jurisdiction was ceased with the Assessing Officer has not been considered by the JCIT. A perusal of the order passed u/s 127 of the Act shows that the jurisdiction was transferred to Central Circle 2(3), Pune for a coordinated investigation with Dhamale group of cases. It is also an admitted fact that

KRISH WINES,JALGAON vs. ACIT CIRCLE 1,, JALGAON

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

68,15,700/- during the demonization period out of which an amount of Rs.13,56,000/- was Specified Bank Notes deposited in the account maintained with the Hasti Co-op. Bank Ltd., Chalisgaon and an amount of Rs.20,10,000/- SBN deposited in the bank account maintained with Godavari Laxmi Co-op. Ltd., Jalgaon. Thus, the total cash deposited

WOCKHARDT LIMITED,AURANGABAD vs. THE ASSISTANT COMMISSIONER OF INCOME TAX CENTRAL CIRCLE 2(1), PUNE

In the result, the appeal of the assessee is partly allowed

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

68,000/- appearing in the ledger as provided to IFMER is added back as inadmissible expenditure under section 37(1) of the Act.” 3. Aggrieved, the assessee preferred an appeal before the Ld. CIT(A). Before the Ld. CIT(A), the assessee challenged the validity of the impugned assessment order passed by the Ld. AO being

WOCKHARDT LIMITED,AURANGABAD vs. THE ASSISTANT COMMISSIONER OF INCOME TAX CENTRAL CIRCLE 2(1), PUNE

In the result, the appeal of the assessee is partly allowed

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

68,000/- appearing in the ledger as provided to IFMER is added back as inadmissible expenditure under section 37(1) of the Act.” 3. Aggrieved, the assessee preferred an appeal before the Ld. CIT(A). Before the Ld. CIT(A), the assessee challenged the validity of the impugned assessment order passed by the Ld. AO being

WOCKHARDT LIMITED,AURANGABAD vs. THE ASSISTANT COMMISSIONER OF INCOME TAX CENTRAL CIRCLE-2(1), PUNE

In the result, the appeal of the assessee is partly allowed

68,000/- appearing in the ledger as\nprovided to IFMER is added back as inadmissible expenditure under section\n37(1) of the Act.\n3. Aggrieved, the assessee preferred an appeal before the Ld. CIT(A).\nBefore the Ld. CIT(A), the assessee challenged the validity of the impugned\nassessment order passed by the Ld. AO being

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

1. Accommodation loan entries\n9\nITA No.1178/PUN/2023\nITA No.2017/PUN/2024\n6.2.1 The AO passed the assessment order under section 143(3) rws 148 of the act\non 28/12/2018 by making a total addition of Rs 2,79,78,912/-. The addition of this\namount has been made by the assessing officer by arriving at the figure of net\ncredit

DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-2, NASHIK, NASHIK vs. ABHAYRAJ FATTEHRAJ CHORDIYA, C/O LAXMI OIL MIL

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 : 2014-15

1) of the Act namely the existence of an undisclosed asset of Rs.50 lakhs or more, unaccounted and unearthed during the search is not satisfied in the present case. In absence of such a foundational jurisdictional fact, the invocation of section 153C proceedings for the extended assessment years i.e. assessment years 2014-15 cannot be sustained in law. Therefore