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

section 68 of the Act. However, so far as the issue of assumption of jurisdiction u/s.147 of the Act is concerned, there is no specific finding by ld.CIT(A). 8. Now the assessee is in appeal before this Tribunal raising various issues including the legal issue and claimed that in view of judgment of Hon’ble Apex Court

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

section 68 of the Act. However, so far as the issue of assumption of jurisdiction u/s.147 of the Act is concerned, there is no specific finding by ld.CIT(A). 8. Now the assessee is in appeal before this Tribunal raising various issues including the legal issue and claimed that in view of judgment of Hon’ble Apex Court

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

section 68\nof the Act. However, so far as the issue of assumption of\njurisdiction u/s.147 of the Act is concerned, there is no\nspecific finding by ld.CIT(A).\n8. Now the assessee is in appeal before this Tribunal raising\nvarious issues including the legal issue and claimed that in\nview of judgment of Hon'ble Apex Court

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

section 68\nof the Act. However, so far as the issue of assumption of\njurisdiction u/s.147 of the Act is concerned, there is no\nspecific finding by ld.CIT(A).\n8. Now the assessee is in appeal before this Tribunal raising\nvarious issues including the legal issue and claimed that in\nview of judgment of Hon'ble Apex Court

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

section 68\nof the Act. However, so far as the issue of assumption of\njurisdiction u/s.147 of the Act is concerned, there is no\nspecific finding by ld.CIT(A).\n8. Now the assessee is in appeal before this Tribunal raising\nvarious issues including the legal issue and claimed that in\nview of judgment of Hon'ble Apex Court

KALPESH RATILAL GARDHARIA,KOLHAPUR vs. ITO WARD- 2(3), KOLHAPUR

In the result, the grounds on merit are allowed for statistical purposes

Bench: Shri Partha Sarathi Chaudhury

254 (Guh) in support of the contention of the appellant that the addition made u/s. 68 by the AO could not be sustained. Some other cases have also been referred to in the Rejoinder, which mostly dealt with the non-application of the provisions of section

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

Section 68 as amended wef from 2013. The said amendment provides that the in case of closely held Company the explanation given by such company shall be deemed to be not satisfactory unless the resident shareholder offers an explanation offers an explanation about the nature and source of such sum and such explanation is found to be satisfactory

KAPIL ALCOTECH LLP,AURANGABAD vs. DEPUTY COMMISSIONER OF INCOME TAX CIRCLE - 1, AURANGABAD

In the result, the appeal filed by the assessee is partly allowed for statistical purposes

Bench: Shri R. K. Panda & Ms Astha Chandraassessment Year : 2020-21

section 68 are absent, the addition made is 9 prima facie unjustified. He submitted that the CIT(A) / NFAC without understanding the evidence on record in a very cryptic order has sustained the addition made by the Assessing Officer which is not correct. 16. The Ld. DR on the other hand heavily relied on the orders of the Assessing

SANGEETA ARUN DESHMUKH,SATARA vs. ITO, WARD-5, SATARA

Appeal is dismissed in above terms

Bench: Shri S.S.Godara, Jm & Shri G.D. Padmahshali, Am आयकर अपील सं. / Ita No.172/Pun/2020 धनधाारण वषा / Assessment Year : 2014-15

section 68 unexplained cash credits of Rs.55,46,254/- and Rs.84,74,000/-; respectively, made in the course of assessment

SATYARAJ OIL COMPANY PVT. LTD.,,SOLAPUR vs. DEPUTY COMMISSIONER OF INCOME-TAX,,

Bench: Shri S.S. Godara & Dr. Dipak P. Ripotem/S. Satyaraj Oil Company Deputy Commissioner Of Pvt. Ltd. Income Tax 9/639, Station Road Vs. Ichalaranji Circile Ichalkaranji Ichalkaranji Dist. Kolhpur Pan – Aaics2911D Appellant Respondent Appellant By: Shri Pramod S. Shingte Respondent By: Shri S.P. Walimbe Date Of Hearing: 29.04.2022 Date Of Pronouncement: 06.05.2022 O R D E R Per S.S. Godara, Jm This Assessee’S Appeal For Ay 2000-01 Is Directed Against The Cit(A)-2, Kolhapur’S Order Dated 02.03.2016 Passed In Case No. Ich/527/11-12 Involving Proceedings Under Section 143(3) R.W.S. 254 Of The Income Tax Act, 1961 (In Short The Act).

68, no addition is called for under this section in respect of share application money. The appellant company prays that DCIT be directed to delete the addition. The Appellant craves leave to add to, amend, alter, modify, change or delete all or any of the grounds of appeal or add new ground of appeal before or at the time

DEPUTY COMMISSIONER OF INCOME TAX, AURANGABAD vs. VISTA NIRMAN PVT. LTD., MUMBAI

Bench: Shri R. K. Panda & Ms Astha Chandraassessment Year : 2011-12

section which bars issue of notice u/s 148 of the Act after expiry of four years from the end of relevant assessment year, clearly apply to the facts of the present case and therefore, notice was barred by limitation. 22. Referring to the following decisions, he submitted that similar view has been taken by various Courts, according to which

JAYNA ENTERPRISES PRIVATE LIMITED,,PUNE vs. DEPUTY COMMISSIONER OF INCOME TAX,, PUNE

In the result, the appeal of the assessee in ITA

Bench: Ms. Sushma Chowla, Jm & Shri Anil Chaturvedi, Am

68 of the Act is wrong. 4. Without prejudice submissions (Relevant to Ground no.2 & 3 of the appeal form): 4.1. The Ld AO has relied upon the replies received from the stock exchange stating that no transactions were carried out by the appellant group on the stock exchange. Further, the AO has stated that even the broker has denied

SHRI GANESH SSK LTD,AHMEDNAGAR vs. D.C.I.T, AHMEDNAGAR, CIRCLE-AHMEDNAGAR, AHMEDNAGAR

254 and section\n144B of the Act vide his order dated 30.09.2021 thereby making addition(s)\non account of (i) sale of sugar at concessional rate to its members at\nRs.1,05,81,183/- and (ii) excess sugarcane payment to the farmers of\nRs.21,83,24,806/-.\n3. Aggrieved by such order of the Ld. AO, the carried

SHRI GANESH SSK LTD,AHMEDNAGAR vs. D.C.I.T, AHMEDNAGAR, CIRCLE-AHMEDNAGAR, AHMEDNAGAR

254 and section\n144B of the Act vide his order dated 30.09.2021 thereby making addition(s)\non account of (i) sale of sugar at concessional rate to its members at\nRs.1,05,81,183/- and (ii) excess sugarcane payment to the farmers of\nRs.21,83,24,806/-.\n3.\nAggrieved by such order of the Ld. AO, the carried

SHRI GANESH SAHAKARI SAKHAR KHARKHANA LIMITED,AHMEDNAGAR vs. DCIT AHMEDNAGAR CIRCLE, AHMEDNAGAR

254 and section\n144B of the Act vide his order dated 30.09.2021 thereby making addition(s)\non account of (i) sale of sugar at concessional rate to its members at\nRs.1,05,81,183/- and (ii) excess sugarcane payment to the farmers of\nRs.21,83,24,806/-.\n3.\nAggrieved by such order of the Ld. AO, the carried

SHRI GANESH SSK LTD,AHMEDNAGAR vs. D.C.I.T, AHMEDNAGAR, CIRCLE-AHMEDNAGAR, AHMEDNAGAR

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

254 and section 144B of the Act vide his order dated 30.09.2021 thereby making addition(s) on account of – (i) sale of sugar at concessional rate to its members at Rs.1,05,81,183/- and (ii) excess sugarcane payment to the farmers of Rs.21,83,24,806/-. 3. Aggrieved by such order of the Ld. AO, the carried

DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE - 1, , AURANGABAD vs. M/S PARTHA MULTITRADE INDIA PVT LTD, MUMBAI

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

Bench: Shri Inturi Rama Rao & Shri S. S. Viswanethra Raviआयकर अपील सं. / Ita Nos.682 To 685/Pun/2022 िनधा"रण वष" / Assessment Years : 2009-10 To 2011-12 & 2013-14 Dcit, Central Circle-1, Vs. M/S. Partha Multitrade Aurangabad. India Pvt. Ltd. (Earlier Known As Swift Ventures Pvt. Ltd.), Flat No.1/5, A. S. Yadav Chawl Pada, Nr. Mahakali Mandir, Dahisar, Mumbai-400068. Pan : Aalcs3668L Appellant Respondent Revenue By : Shri Ajay Kumar Kesari Assessee By : None Date Of Hearing : 12.10.2023 Date Of Pronouncement : 30.11.2023 आदेश / Order Per Inturi Rama Rao, Am: These Are The Appeals Filed By The Revenue Directed Against The Common Order Of Ld. Commissioner Of Income Tax (Appeals)-12, Pune [‘The Cit(A)’] Dated 30.06.2022 For The Assessment Years 2009-10 To 2011-12 & 2013-14 Respectively. 2. Since The Identical Facts & Common Issues Are Involved In All The Above Captioned Four Appeals Of The Revenue, We Proceed To Dispose Of The Same By This Common Order. 3. For The Sake Of Convenience & Clarity, The Facts Relevant To The Appeal Of The Revenue In Ita No.685/Pun/2022 For The Assessment Year 2013-14 Are Stated Herein.

section 68 of the Act. In the circumstances, the ld. CIT(A) had upheld the action of the Assessing Officer in bringing to tax the amount of money found to consideration of investments received from the said five companies. However, the ld. CIT(A) had fell in serious error in holding that the Assessing Officer made addition on protective

DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE- 1, AURANGABAD, AURANGABAD vs. M/S PARTHA MULTRITRADE INDIA PVT LTD (EARLIER KNOWN AS SWIFT VENTURES PVT LTD., MUMBAI

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

Bench: Shri Inturi Rama Rao & Shri S. S. Viswanethra Raviआयकर अपील सं. / Ita Nos.682 To 685/Pun/2022 िनधा"रण वष" / Assessment Years : 2009-10 To 2011-12 & 2013-14 Dcit, Central Circle-1, Vs. M/S. Partha Multitrade Aurangabad. India Pvt. Ltd. (Earlier Known As Swift Ventures Pvt. Ltd.), Flat No.1/5, A. S. Yadav Chawl Pada, Nr. Mahakali Mandir, Dahisar, Mumbai-400068. Pan : Aalcs3668L Appellant Respondent Revenue By : Shri Ajay Kumar Kesari Assessee By : None Date Of Hearing : 12.10.2023 Date Of Pronouncement : 30.11.2023 आदेश / Order Per Inturi Rama Rao, Am: These Are The Appeals Filed By The Revenue Directed Against The Common Order Of Ld. Commissioner Of Income Tax (Appeals)-12, Pune [‘The Cit(A)’] Dated 30.06.2022 For The Assessment Years 2009-10 To 2011-12 & 2013-14 Respectively. 2. Since The Identical Facts & Common Issues Are Involved In All The Above Captioned Four Appeals Of The Revenue, We Proceed To Dispose Of The Same By This Common Order. 3. For The Sake Of Convenience & Clarity, The Facts Relevant To The Appeal Of The Revenue In Ita No.685/Pun/2022 For The Assessment Year 2013-14 Are Stated Herein.

section 68 of the Act. In the circumstances, the ld. CIT(A) had upheld the action of the Assessing Officer in bringing to tax the amount of money found to consideration of investments received from the said five companies. However, the ld. CIT(A) had fell in serious error in holding that the Assessing Officer made addition on protective

DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE- 1, AURANGABAD, AURANGABAD vs. M/S PARTHA MULTITRADE INDIA PVT LTD (EARLIER KNOWN AS SWIFT VENTURES PVT LTD), MUMBAI

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

Bench: Shri Inturi Rama Rao & Shri S. S. Viswanethra Raviआयकर अपील सं. / Ita Nos.682 To 685/Pun/2022 िनधा"रण वष" / Assessment Years : 2009-10 To 2011-12 & 2013-14 Dcit, Central Circle-1, Vs. M/S. Partha Multitrade Aurangabad. India Pvt. Ltd. (Earlier Known As Swift Ventures Pvt. Ltd.), Flat No.1/5, A. S. Yadav Chawl Pada, Nr. Mahakali Mandir, Dahisar, Mumbai-400068. Pan : Aalcs3668L Appellant Respondent Revenue By : Shri Ajay Kumar Kesari Assessee By : None Date Of Hearing : 12.10.2023 Date Of Pronouncement : 30.11.2023 आदेश / Order Per Inturi Rama Rao, Am: These Are The Appeals Filed By The Revenue Directed Against The Common Order Of Ld. Commissioner Of Income Tax (Appeals)-12, Pune [‘The Cit(A)’] Dated 30.06.2022 For The Assessment Years 2009-10 To 2011-12 & 2013-14 Respectively. 2. Since The Identical Facts & Common Issues Are Involved In All The Above Captioned Four Appeals Of The Revenue, We Proceed To Dispose Of The Same By This Common Order. 3. For The Sake Of Convenience & Clarity, The Facts Relevant To The Appeal Of The Revenue In Ita No.685/Pun/2022 For The Assessment Year 2013-14 Are Stated Herein.

section 68 of the Act. In the circumstances, the ld. CIT(A) had upheld the action of the Assessing Officer in bringing to tax the amount of money found to consideration of investments received from the said five companies. However, the ld. CIT(A) had fell in serious error in holding that the Assessing Officer made addition on protective