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66 results for “section 68”+ Section 251(1)(a)clear

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Key Topics

Section 6865Addition to Income50Section 143(3)34Section 25025Section 92C(3)24Section 153C22Section 142(1)21Section 14A21Section 14420Disallowance

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

ITA 1265/PUN/2024[2016-17]Status: DisposedITAT Pune14 Jul 2025AY 2016-17
Section 131Section 132Section 142(1)Section 143(1)Section 153C

251 (Del), he submitted that the Hon'ble\nHigh Court in the said decision has held that where ACIT granted approval under\nsection 153D without noticing discrepancy in assessment order or search material,\nsuch a mechanical approval without application of mind would be invalid in eyes\nof law.\n30. He submitted that when the Revenue challenged the above decision

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

ITA 1270/PUN/2024[2017-18]Status: DisposedITAT Pune14 Jul 2025

Showing 1–20 of 66 · Page 1 of 4

17
Transfer Pricing13
Cash Deposit12
AY 2017-18
Section 131Section 132Section 142(1)Section 143(1)Section 153C

251 (Del), he submitted that the Hon'ble\nHigh Court in the said decision has held that where ACIT granted approval under\nsection 153D without noticing discrepancy in assessment order or search material,\nsuch a mechanical approval without application of mind would be invalid in eyes\nof law.\n30. He submitted that when the Revenue challenged the above decision

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

ITA 1268/PUN/2024[2017-18]Status: DisposedITAT Pune14 Jul 2025AY 2017-18

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

For Appellant: S/Shri Kishor B Phadke &For Respondent: S/Shri Sandeep Sengupta, CIT &
Section 131Section 132Section 142(1)Section 143(1)Section 153C

251 (Del), he submitted that the Hon’ble High Court in the said decision has held that where ACIT granted approval under section 153D without noticing discrepancy in assessment order or search material, such a mechanical approval without application of mind would be invalid in eyes of law. 30. He submitted that when the Revenue challenged the above decision

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

ITA 1272/PUN/2024[2018-19]Status: DisposedITAT Pune14 Jul 2025AY 2018-19

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

For Appellant: S/Shri Kishor B Phadke &For Respondent: S/Shri Sandeep Sengupta, CIT &
Section 131Section 132Section 142(1)Section 143(1)Section 153C

251 (Del), he submitted that the Hon’ble High Court in the said decision has held that where ACIT granted approval under section 153D without noticing discrepancy in assessment order or search material, such a mechanical approval without application of mind would be invalid in eyes of law. 30. He submitted that when the Revenue challenged the above decision

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

ITA 1269/PUN/2024[2017-18]Status: DisposedITAT Pune14 Jul 2025AY 2017-18

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

For Appellant: S/Shri Kishor B Phadke &For Respondent: S/Shri Sandeep Sengupta, CIT &
Section 131Section 132Section 142(1)Section 143(1)Section 153C

251 (Del), he submitted that the Hon’ble High Court in the said decision has held that where ACIT granted approval under section 153D without noticing discrepancy in assessment order or search material, such a mechanical approval without application of mind would be invalid in eyes of law. 30. He submitted that when the Revenue challenged the above decision

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

ITA 1264/PUN/2024[2016-17]Status: DisposedITAT Pune14 Jul 2025AY 2016-17

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

For Appellant: S/Shri Kishor B Phadke &For Respondent: S/Shri Sandeep Sengupta, CIT &
Section 131Section 132Section 142(1)Section 143(1)Section 153C

251 (Del), he submitted that the Hon’ble High Court in the said decision has held that where ACIT granted approval under section 153D without noticing discrepancy in assessment order or search material, such a mechanical approval without application of mind would be invalid in eyes of law. 30. He submitted that when the Revenue challenged the above decision

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

ITA 1262/PUN/2024[2016-17]Status: DisposedITAT Pune14 Jul 2025AY 2016-17

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

For Appellant: S/Shri Kishor B Phadke &For Respondent: S/Shri Sandeep Sengupta, CIT &
Section 131Section 132Section 142(1)Section 143(1)Section 153C

251 (Del), he submitted that the Hon’ble High Court in the said decision has held that where ACIT granted approval under section 153D without noticing discrepancy in assessment order or search material, such a mechanical approval without application of mind would be invalid in eyes of law. 30. He submitted that when the Revenue challenged the above decision

KUMAR URBAN DEVELOPMENT PVT. LTD (SUCCESSOR KUMAR HOUSING CORPORATION PVT LTD),PUNE vs. DCIT CIRCLE 14, PUNE

ITA 2874/PUN/2024[2014-15]Status: DisposedITAT Pune18 Aug 2025AY 2014-15
For Appellant: Shri Nikhil S PathakFor Respondent: Shri Ramnath P Murkunde
Section 143(2)Section 32Section 36(1)(iii)

68, to the concept of taxation on\nrevenue recognition as expressed in item no. 1 above, this notice may be treated as\na notice in terms of section 251

M/S. CAPSTONE SECURITIES ANALYSIS PVT LTD,,PUNE vs. DEPUTY COMMISSIONER OF INCOME TAX,, PUNE

In the result, the appeal is allowed

ITA 251/PUN/2017[2012-13]Status: DisposedITAT Pune04 Sept 2019AY 2012-13

Bench: Shri R.S. Syal & Shri Partha Sarathi Chaudhuryआयकर अपील सं. / Ita No.251/Pun/2017 िनधा"रण वष" / Assessment Year : 2012-13

Section 143(3)Section 144C

68,43,110/-. Certain international transactions were reported by the assessee in Form No. 3CEB. The AO referred the matter of determination of the Arm’s Length Price (ALP) of such transactions to the Transfer Pricing Officer (TPO). Vide order dated 18-01-2016, the TPO recommended transfer pricing adjustment of Rs.5,35,19,469/-. The AO passed the draft

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

ITA 1266/PUN/2024[2016-17]Status: DisposedITAT Pune14 Jul 2025AY 2016-17
Section 131Section 132Section 142(1)Section 143(1)Section 153C

251 (Del), he submitted that the Hon'ble\nHigh Court in the said decision has held that where ACIT granted approval under\nsection 153D without noticing discrepancy in assessment order or search material,\nsuch a mechanical approval without application of mind would be invalid in eyes\nof law.\n30. He submitted that when the Revenue challenged the above decision

BVG INDIA LIMITED,PUNE vs. DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-1(2), PUNE, PUNE

In the result, the appeal of the assessee is allowed

ITA 516/PUN/2023[2020-21]Status: DisposedITAT Pune19 Oct 2023AY 2020-21

Bench: Shri S.S. Viswanethra Ravi & Shri G.D. Padmahshali

For Appellant: Shri Vijay Mehta & Sneha M. PadhiarFor Respondent: S/Shri Ajay Kumar Kesari & Abdhesh Kumar
Section 132Section 142(1)Section 144Section 153ASection 153D

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. 21. In the instant case, the draft assessment order in 85 cases, i.e. for 85 assessment years placed before

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

ITA 1267/PUN/2024[2017-18]Status: DisposedITAT Pune14 Jul 2025AY 2017-18
Section 131Section 132Section 142(1)Section 143(1)Section 153C

251 (Del), he submitted that the Hon'ble\nHigh Court in the said decision has held that where ACIT granted approval under\nsection 153D without noticing discrepancy in assessment order or search material,\nsuch a mechanical approval without application of mind would be invalid in eyes\nof law.\n30. He submitted that when the Revenue challenged the above decision

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

ITA 1271/PUN/2024[2017-18]Status: DisposedITAT Pune14 Jul 2025AY 2017-18
Section 131Section 132Section 142(1)Section 143(1)Section 153C

251 (Del), he submitted that the Hon'ble\nHigh Court in the said decision has held that where ACIT granted approval under\nsection 153D without noticing discrepancy in assessment order or search material,\nsuch a mechanical approval without application of mind would be invalid in eyes\nof law.\n\n30.\nHe submitted that when the Revenue challenged the above decision

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

ITA 1263/PUN/2024[2016-17]Status: DisposedITAT Pune14 Jul 2025AY 2016-17
Section 131Section 132Section 142(1)Section 143(1)Section 153C

251 (Del), he submitted that the Hon'ble\nHigh Court in the said decision has held that where ACIT granted approval under\nsection 153D without noticing discrepancy in assessment order or search material,\nsuch a mechanical approval without application of mind would be invalid in eyes\nof law.\n30. He submitted that when the Revenue challenged the above decision

MAHLE BEHR INDIA PVT. LTD.,,PUNE vs. DEPUTY COMMISSIONER OF INCOME-TAX,, PUNE

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

ITA 795/PUN/2017[2012-13]Status: DisposedITAT Pune15 Jan 2025AY 2012-13
Section 143(3)Section 35Section 35(1)

68,113/- and Capital WIP Rs.2,30,14,228/-. The DRP has denied claim for\nweighted deduction. The said testing and validation was carried out at the parent\ncompany's facilities in Germany and claim has been made u/s 35 (1) (iv) on the\nbasis of incurrence of capital expenses. Proposition for claim u/s 35 (1) (iv) has\nbeen upheld

BILIDEVALAYA LAKSHMI NARASIMHA MURTHY,SINDHUDURG vs. INCOME TAX OFFICE, KUDAL

Appeal of the assessee is allowed for statistical purpose

ITA 701/PUN/2024[2020-2021]Status: DisposedITAT Pune28 Aug 2024AY 2020-2021

Bench: Shri Satbeer Singh Godara & Dr. Dipak P. Ripoteआयकर अपील सं. / Ita No.701/Pun/2024 निर्धारण वर्ा / Assessment Year: 2020-21 Bilidevalaya Lakshmi Narasimha Murthy, Vs The Income Tax Officer, S-7 Vinayak Apartment, Vaishyawada, Kudal Sawantwadi, Maharashtra-416510 Pan : Acgpb9237N Appellant/ Assessee Respondent / Revenue Assessee By None Revenue By Shri Ramnath P. Murkunde Date Of Hearing 26/08/2024 Date Of Pronouncement 28/08/2024 आदेश/ Order Per Dr. Dipak P. Ripote, Am: This Appeal Filed By The Assessee Against The Order Of Ld. Commissioner Of Income Tax(Appeals) [Nfac], Passed Under Section 250 Of The Income Tax Act, 1961 Dated 01.03.2024 For The A.Y. 2020-21. 2. The Assessee Has Raised The Following Grounds Of Appeal : “1. On The Facts & Circumstances Of The Case & In Law The Ld. Cit(A), Nfac, Erred In Confirming The Addition Made By The Ao Of Rs.1,35,52,006/- (Sundry Creditors Rs.41,42,506 & Unsecured Loans Bilidevalaya Lakshmi Narasimha Murthy

Section 115BSection 246ASection 250Section 250(4)Section 250(6)Section 251Section 251(1)(a)Section 68

1. On the facts and circumstances of the case and in law the Ld. CIT(A), NFAC, erred in confirming the addition made by the AO of Rs.1,35,52,006/- (Sundry Creditors Rs.41,42,506 and Unsecured Loans Bilidevalaya Lakshmi Narasimha Murthy Rs.94,09,500) being additions u/s 68. The appellant craves leave to add to, amend, alter, delete

KUMAR URBAN DEVELOPMENT PVT. LTD (SUCCESSOR KUMAR HOUSING CORPN. PVT LTD),PUNE vs. DCIT CIRCLE 14, PUNE

In the result, both the appeals filed by the assessee are allowed and the appeal filed by the Revenue is dismissed

ITA 2875/PUN/2024[2013-14]Status: DisposedITAT Pune18 Aug 2025AY 2013-14

Bench: Shri R. K. Panda & Ms. Astha Chandraassessment Year : 2013-14

For Appellant: Shri Nikhil S PathakFor Respondent: Shri Ramnath P Murkunde
Section 143(2)Section 32Section 36(1)(iii)

68, to the concept of taxation on revenue recognition as expressed in item no. 1 above, this notice may be treated as a notice in terms of section 251

DY COMMISSIONER OF INCOME TAX CIRCLE 7 PUNE, PUNE vs. KUMAR HOUSING CORPORATION PRIVATE LIMITED, PUNE

In the result, both the appeals filed by the assessee are allowed and the appeal filed by the Revenue is dismissed

ITA 341/PUN/2025[2013-14]Status: DisposedITAT Pune18 Aug 2025AY 2013-14

Bench: Shri R. K. Panda & Ms. Astha Chandraassessment Year : 2013-14

For Appellant: Shri Nikhil S PathakFor Respondent: Shri Ramnath P Murkunde
Section 143(2)Section 32Section 36(1)(iii)

68, to the concept of taxation on revenue recognition as expressed in item no. 1 above, this notice may be treated as a notice in terms of section 251

HAVELI TALUKA VEEJ KAMGAR SAHAKARI PATHSANSTHA MARYADIT,PUNE vs. INCOME TAX OFFICER WARD 6 (1) PUNE, PMT BUILDING, SWARGATE

In the result, the appeal of the assessee is allowed

ITA 1428/PUN/2024[2017-18]Status: DisposedITAT Pune15 Jan 2025AY 2017-18
For Appellant: \nDepartment by
Section 143(3)Section 80PSection 80P(2)(a)Section 80P(2)(d)

68 and the Hon'ble\nKolkata High Court in the case of CIT Vs. Southern Eastern Employees\nCooperative Credit Society Ltd. 390 ITR 524 took a view that the income\narising on the surplus invested in short term deposits and securities cannot\nbe attributed to the activities of the society and, therefore, not eligible for\nexemption u/s.80P

JITENDRA NANASAHEB THORAT,NASHIK vs. INCOME TAX OFFICER, WARD 2(4), NASHIK

In the result, appeal of the assessee is allowed for statistical purpose

ITA 2307/PUN/2025[2011-12]Status: DisposedITAT Pune30 Jan 2026AY 2011-12

Bench: Dr.Dipak P. Ripote & Shri Vinay Bhamoreआयकर अपऩल सं. / Ita No.2307/Pun/2025 निर्धारण वषा / Assessment Year: 2011-12 Jitendra Nanasaheb Thorat, V Income Tax Officer, A-7, Chaitrapalavi Apartment, S Ward-2(4), Nashik. Ashok Marg, Near Bank Of Maharashtra, Behind Fame Cinema, Nashik – 422006. Pan: Afypt8886Q Appellant/ Assessee Respondent / Revenue Assessee By Shri Sanket Joshi (Through Virtual) Revenue By Shri Ajitesh Kumar Meema –Addl.Cit Date Of Hearing 29/01/2026 Date Of Pronouncement 30/01/2026 आदेश/ Order Per Dr. Dipak P. Ripote, Am: This Is An Appeal Filed By The Assessee Against The Order Of Ld.Commissioner Of Income Tax(Appeal)[Nfac] Passed Under Section 250 Of The Income Tax Act, 1961 For The A.Y.2011-12 Dated 28.07.2023 Emanating From The Assessment Order Passed Under Section 143(3) R.W.S 147 Of The Act, Dated 27.12.2017. The Assessee Has Raised The Following Grounds Of Appeal :

Section 143(2)Section 143(3)Section 147Section 148Section 151Section 250Section 68

1 above, the assessee submits that the notices of hearing u/s 250 issued by the CIT(A) were served on email id of the appellant and not by post, whereas the appellant had specifically chosen "No" for the option of receiving notices/communications over email as the appellant was not acquainted with using emails and therefore, there was a reasonable cause