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

Section 153D of the Act cannot be merely a ritualistic formality or rubber stamping by the authority, rather it must reflect an appropriate application of mind. 16. In the present case, the ITAT, while specifically noting that the approval was granted on the same day when the draft assessment orders were sent, has observed as under:- "10. We have

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

Section 153D of the Act cannot be merely a ritualistic formality or rubber stamping by the authority, rather it must reflect an appropriate application of mind. 16. In the present case, the ITAT, while specifically noting that the approval was granted on the same day when the draft assessment orders were sent, has observed as under:- "10. We have

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

Section 153D of the Act cannot be merely a ritualistic formality or rubber stamping by the authority, rather it must reflect an appropriate application of mind. 16. In the present case, the ITAT, while specifically noting that the approval was granted on the same day when the draft assessment orders were sent, has observed as under:- "10. We have

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

Section 153D of the Act cannot be merely a ritualistic formality or rubber stamping by the authority, rather it must reflect an appropriate application of mind. 16. In the present case, the ITAT, while specifically noting that the approval was granted on the same day when the draft assessment orders were sent, has observed as under:- "10. We have

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

Section 153D of the Act\ncannot be merely a ritualistic formality or rubber stamping by the authority,\nrather it must reflect an appropriate application of mind.\n16. In the present case, the ITAT, while specifically noting that the approval was\ngranted on the same day when the draft assessment orders were sent, has observed\nas under

ADISH SHANTILAL SOLANKI,PUNE vs. ASSISTANT COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-2(1), PUNE, PUNE

Section 153D of the Act\ncannot be merely a ritualistic formality or rubber stamping by the authority,\nrather it must reflect an appropriate application of mind.\n16. In the present case, the ITAT, while specifically noting that the approval was\ngranted on the same day when the draft assessment orders were sent, has observed\nas under

ASHISH RAMESH OSWAL,PUNE vs. ACIT, CENTRAL CIRCLE 2(1), PUNE , PUNE

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

Section 153D of the Act\ncannot be merely a ritualistic formality or rubber stamping by the authority,\nrather it must reflect an appropriate application of mind.\n\n16. In the present case, the ITAT, while specifically noting that the approval was\ngranted on the same day when the draft assessment orders were sent, has observed\nas under

ASHISH RAMESH OSWAL,PUNE vs. ACIT, CENTRAL CIRCLE 2(1), PUNE, PUNE

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

Section 153D of the Act\ncannot be merely a ritualistic formality or rubber stamping by the authority,\nrather it must reflect an appropriate application of mind.\n16. In the present case, the ITAT, while specifically noting that the approval was\ngranted on the same day when the draft assessment orders were sent, has observed\nas under

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

Section 153D of the Act\ncannot be merely a ritualistic formality or rubber stamping by the authority,\nrather it must reflect an appropriate application of mind.\n16. In the present case, the ITAT, while specifically noting that the approval was\ngranted on the same day when the draft assessment orders were sent, has observed\nas under

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

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

Section 153D of the Act\ncannot be merely a ritualistic formality or rubber stamping by the authority,\nrather it must reflect an appropriate application of mind.\n16. In the present case, the ITAT, while specifically noting that the approval was\ngranted on the same day when the draft assessment orders were sent, has observed\nas under

MEENAMANI GANGA BUILDER LLP ,PUNE vs. PCIT (CENTRAL), PUNE , PUNE

In the result, the appeal of the assessee is dismissed

68 of the\nAct. In response to which the Appellant furnished details available.\n2. 3. 12. Consequently, notice u/s 263 of the Act was received by the\nAppellant on the grounds that order passed under section 153A of\nthe Act is prejudicial to the interest of the revenue, so far as the\ngenuniness, Identity and creditworthiness of the lenders

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

section 153C for each assessment year, therefore, where a consolidated satisfaction note has been recorded for different assessment years the same vitiates the entire assessment proceedings. He submitted that the SLP filed by the Revenue against the above decision has been dismissed by the Hon’ble Supreme Court as reported in (2024) 68 taxmann.com 77 (SC). 13 CO No.36/PUN/2024

MOHAMMAD OSMAN MOHAMMAF HAROONMOTIWALA,AURANGANBAD vs. PCIT- NASHIK 1, NASHIK

In the result, the appeal of the assessee is allowed

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

68/ 69 etc. 13.1 Significantly, the PCIT, while seeking to set aside the action of AO and remitting the matter back for further enquiries, did not bring any definite material to show any incorrect assumption of such facts on this score. Besides, no observations are found in the impugned revisional order suggesting a course to be adopted towards manner

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

68 r.w.s. 115BBE of the Act and also made further 26 CO No.43/PUN/2025 addition of the interest paid of Rs.17,80,059/- by invoking the provisions of section 37 of the Act. We find before the Ld. CIT(A) / NFAC the assessee, apart from challenging the addition on merit, challenged the validity of reopening of the assessment

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

68, 69, 69A, 69B, 69C & 69D. 18. It is necessary to refer to Explanation 5A which reads as under: ―Explanation 5A – Where, in the course of a search initiated under section 132 on or before the 1st day of June 2007, the assessee is found to be the owner of (i) Any money, bullion, jeweler or other valuable article

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

68, 69, 69A, 69B, 69C & 69D. 18. It is necessary to refer to Explanation 5A which reads as under: ―Explanation 5A – Where, in the course of a search initiated under section 132 on or before the 1st day of June 2007, the assessee is found to be the owner of (i) Any money, bullion, jeweler or other valuable article

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

68, 69, 69A, 69B, 69C & 69D. 18. It is necessary to refer to Explanation 5A which reads as under: ―Explanation 5A – Where, in the course of a search initiated under section 132 on or before the 1st day of June 2007, the assessee is found to be the owner of (i) Any money, bullion, jeweler or other valuable article

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

68, 69, 69A, 69B, 69C & 69D. 18. It is necessary to refer to Explanation 5A which reads as under: ―Explanation 5A – Where, in the course of a search initiated under section 132 on or before the 1st day of June 2007, the assessee is found to be the owner of (i) Any money, bullion, jeweler or other valuable article