RAJENDRA CHANDRAKANT CHINCHNIKAR,PUNE vs. CIT(A)-11, PUNE

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

Bench: Justice (Retd.) C V Bhadang & Shri R. K. Pandaassessment Year : 2019-20 Rajendra Chandrakant Chinchnikar Acit, Central Circle, 2165, B Ward, Koshti Galli, Vs. Kolhapur Mangalwar Peth, Pune – 416012 Pan: Acppc3559D (Appellant) (Respondent) Assessee By : Shri Tanzil Padvekar Department By : Shri Milind Debaje, Jcit Date Of Hearing : 25-08-2025 Date Of Pronouncement : 29-09-2025 O R D E R Per R.K. Panda, Vp:

section 270A(9)(e) and therefore, 3 initiated penalty proceedings u/s 270A and issued show cause notice u/s 274 r.w.s. 270A. 5. The assessee in response to the notice issued u/s 270A by the Ld. CIT(A) submitted that he has declared the additional income voluntarily and in a transparent manner by revising the return of income after

SILVER OAK BUILDCON PVT. LTD.,PUNE vs. ACIT-6, PUNE, PUNE

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

Bench: Shri R. K. Panda & Shri Vinay Bhamoreassessment Year : 2017-18

section 270A of the Act. 7. Before the Ld. CIT(A) / NFAC, it was submitted that the addition made by the Assessing Officer was on account of mis-match of disallowance u/s 43B of the Act reported in the tax audit report which was by mistake not added back to the total income of the assessee while filing

KISHOR DIGAMBAR PATIL,NASHIK vs. INCOME TAX OFFICER,WARD-2(1),NASHIK, NASHIK

Appeals are allowed in above terms

Bench: Hon’Ble Shri S. S. Godara & Shri G. D. Padmahshaliआयकर अपऩल सं. / Ita No. 54 & 55/Pun/2023 निर्धारण वषा / Assessment Year : 2017-18 & 2018-19 Kishor Digambar Patil, 03, Saras Apartment, Patil Lane 04, College Rd., Nashik – 422005 Pan: Aarpp2052J . . . . . . . अपऩलधर्थी / Appellant

section 270A proceedings in issue. The Assessing Officer’s twin penalty orders, both dated 14.01.2022, rejected the assessee’s stand to impose these penalties of Rs.1,64,392/- i.e., @ 200% of the tax sought to be evaded of Rs.82,196/- holding “under reporting of income which is in consequence of misreporting of income” amounting to ITAT-Pune Page

KISHOR DIGAMBAR PATIL,NASHIK vs. INCOME TAX OFFICER, WARD-2(1), NASHIK, NASHIK

Appeals are allowed in above terms

Bench: Hon’Ble Shri S. S. Godara & Shri G. D. Padmahshaliआयकर अपऩल सं. / Ita No. 54 & 55/Pun/2023 निर्धारण वषा / Assessment Year : 2017-18 & 2018-19 Kishor Digambar Patil, 03, Saras Apartment, Patil Lane 04, College Rd., Nashik – 422005 Pan: Aarpp2052J . . . . . . . अपऩलधर्थी / Appellant

section 270A proceedings in issue. The Assessing Officer’s twin penalty orders, both dated 14.01.2022, rejected the assessee’s stand to impose these penalties of Rs.1,64,392/- i.e., @ 200% of the tax sought to be evaded of Rs.82,196/- holding “under reporting of income which is in consequence of misreporting of income” amounting to ITAT-Pune Page

RAJU BHAUSAHEB ANAP,NASHIK vs. INCOME TAX OFFICER, NASHIK

In the result, appeal of the assessee is allowed

Bench: Shri S.S.Godara & Dr. Dipak P. Ripoteआयकर अपील सं. / Ita No.467/Pun/2023 िनधा"रण वष" / Assessment Year : 2018-19 Raju Bhausaheb Anap, The Income Tax Officer, 01 Rajshree Samartha Sankul, V Nashik. Near Kalawati Mata Mandi, S Kalanagar, Indira Nagar, Nashik – 422009. Pan: Anrpa 7092 E Appellant / Assessee Respondent / Revenue Assessee By None. Revenue By Shri M.G.Jasnani – Dr Date Of Hearing 17/05/2023 Date Of Pronouncement 26/07/2023 आदेश/ Order Per Dr. Dipak P. Ripote, Am: This Appeal Filed By The Assessee Is Directed Against The Order Of Ld.Commissioner Of Income Tax (Appeal)National Faceless Appeal Centre, Delhi Dated 20.02.2023 Emanating From The Penalty Order Dated 11.01.2022 Under Section 270A Of The Income Tax Act, 1961 For The A.Y.2018-19. The Assessee Has Raised The Following Grounds Of Appeal : Raju Bhausaheb Anap [A]

270A was not justified in view of the explanation offered by the assesses.” Brief facts of the case : 2. In this case, assessee is an individual salaried employee of BSNL, Nashik and earning income assessable to tax under the head Salaries. He filed Original Return of Income for A.Y.2018- 19 on 03.07.2018 declaring total income of Rs.4,76,110/- after

THE MAYANI URBAN CO OP BANK LTD,SATARA vs. DCIT, CIRCLE SATARA

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

Bench: Shri Manish Borad & Shri Vinay Bhamoreआयकर अपील सं. / Ita No.1930/Pun/2025 िनधा"रण वष" / Assessment Year : 2017-18 The Mayani Urban Co-Op. Vs. Ito, Ward-3, Satara. Bank Ltd., Tal: Khatav Dist.: Satara, Mayani, A/P Mayani- 415102. Pan : Aaaat7489H Appellant Respondent Assessee By : Smt. Deepa Khare Revenue By : Shri Harish Bist (Virtual) Date Of Hearing : 17.09.2025 Date Of Pronouncement : 24.11.2025 आदेश / Order Per Vinay Bhamore, Jm: This Appeal Filed By The Assessee Is Directed Against The Order Dated 11.07.2025 Passed By Ld. Cit(A)/Nfac For The Assessment Year 2017-18. 2. The Appellant Has Raised The Following Grounds Of Appeal :- “1. The Cit(A) Has Erred In Confirming Penalty U/S 270A(9) Of Rs.151140/- Without Appreciating The Facts & Circumstances Of The Case. 2. On The Facts & Circumstances Of The Case Penalty U/S 270A Is Not Justified At 200%.

section 270AA was filed and no appeal was furnished against the assessment order. Ld. AR submitted that while imposing the penalty, the penalty officer pointed out that Form 68 was not furnished hence the immunity from penalty cannot be granted. Ld. AR also submitted that Ld. CIT(A)/NFAC also without verifying the above facts of the case dismissed

VEDANT PROPERTIES,PUNE vs. ITO WARD 3(1) PUNE, PUNE

In the result, the appeal filed by the assessee is

Bench: Shri Rama Kanta Panda & Ms. Astha Chandra

68,178/- which according to him are un- proved and pretentious for which he reduced the same from the capital work-in-progress. Since the assessee did not file any appeal, he initiated penalty proceedings u/sec.270A of the Act for misreporting of income. Since the assessee did not respond to the notice issued by him while deciding the penalty proceedings

DY COMMISSIONER OF INCOME TAX CIRCLE 5 PUNE, PUNE vs. DIPTI NARENDRA LULLA, PUNE

sections": [ "143(2)", "142(1)", "133(6)", "68", "115BBE", "271AAC", "69", "270A", "131", "46A", "250(4)" ], "issues": "Whether the CIT(A) erred

KOTHARI AGRITECH PRIVATE LIMITED,SOLAPUR vs. DCIT CIRCLE-1, SOLAPUR

In the result, the both appeals of the assessee in ITA Nos

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

68,26,650/- 11 ITA Nos.2392 & 2455/PUN/2024, AY 2018-19 It is noted that JAO has also passed the detailed rectification order u/s 154 r.w.s. 143(3) vide order number ITBA/REC/S/154-1/2023- 24/1054089997(1) dated 03.07.2023 and elaborately discussion relevant and applicable case laws, has remarked that Para no. 6.4.3" in the rectification order as under:- 6.4.3 Based on the above

KOTHARI AGRITECH PVT. LTD,,SOLAPUR vs. THE DCIT, CIRCLE-1, SOLAPUR

In the result, the both appeals of the assessee in ITA Nos

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

68,26,650/- 11 ITA Nos.2392 & 2455/PUN/2024, AY 2018-19 It is noted that JAO has also passed the detailed rectification order u/s 154 r.w.s. 143(3) vide order number ITBA/REC/S/154-1/2023- 24/1054089997(1) dated 03.07.2023 and elaborately discussion relevant and applicable case laws, has remarked that Para no. 6.4.3" in the rectification order as under:- 6.4.3 Based on the above

DR. PRATAP PANDHIRANATH PATIL,PUNE vs. PCIT - 2, PUNE

In the result, the appeal filed by the assessee is allowed as per terms indicated above

Bench: Dr.Manish Borad & Shri Vinay Bhamore

270A of the Act for underreporting of income is hereby initiated separately.” 18. From going through the above details, we notice that the only issue referred in the show cause notice by ld. PCIT is that ld. AO ought to have made the addition of Rs.42,83,244/- by invoking section 68

CHAITALI HOTELS,KOLHAPUR vs. CIT(A)-11, PUNE, PUNE

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

Bench: Shri R. K. Panda & Ms. Astha Chandraassessment Year : 2017-18 Chaitali Hotels Cit(A)-11, Pune 257, Kadamwadi Road, Vs. Kolhapur – 416005 Pan: Aagfc8348F (Appellant) (Respondent) Assessee By : None Department By : Shri Ramnath P Murkunde Date Of Hearing : 04-06-2025 Date Of Pronouncement : 10-06-2025 O R D E R

68 of the Act. During the appeal proceedings, this income was held to be taxable as suppressed business income and therefore, penalty proceedings were separately initiated by issue of a Notice u/s 274 r.w.s. 270A of the Act on 05/04/2024. It is also seen that the assessing officer had separately initiated penalty proceedings u/s 270A on some other addition. Thus

LEAR INDIA ENGINEERINGLLP,PUNE vs. ASSISTANT DIRECTOR OF INCOME TAX, CPC, PUNE

Bench: Shri Satbeer Singh Godara & Dr. Dipak P. Ripote

68,646/- (supra) in very terms. Necessary computation shall follow as per law. The assessee’s instant quantum appeal ITA No. 870/Pun./2023 stands partly accepted. 3 ITA.No.870 & 890/PUN./2023 Lear india Engineering LLP 5. Next comes the assessee’s latter penalty appeal ITA No. 890/Pun./2023 challenging correctness of both the lower authorities’ action invoking Section 270A

LEAR INDIA ENGINEERING LLP,PUNE vs. DEPUTY COMMISSIONER OF INCOME TAX,CIRCLE-8, PUNE, PUNE

Bench: Shri Satbeer Singh Godara & Dr. Dipak P. Ripote

68,646/- (supra) in very terms. Necessary computation shall follow as per law. The assessee’s instant quantum appeal ITA No. 870/Pun./2023 stands partly accepted. 3 ITA.No.870 & 890/PUN./2023 Lear india Engineering LLP 5. Next comes the assessee’s latter penalty appeal ITA No. 890/Pun./2023 challenging correctness of both the lower authorities’ action invoking Section 270A

LIQUIDHUB ANALYTICS PVT. LTD. (NOW MERGED WITH CAPGEMINI TECHNOLOGY SERVICES INDIA LTD),PUNE vs. NFAC, PUNE

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

Bench: Shri R. K. Panda & Shri Vinay Bhamoreassessment Year : 2020-21

68,72,632 to the taxable income of the Appellant including an adjustment of INR 2,10,10,000/- on account of transfer pricing matters and INR 58,62,632/- on account of corporate tax matters. 4 2. The Ld AO has erred in not providing a copy of the Central Board of Direct Taxes (Board) approval for transferring

SPRINGER NATURE TECHNOLOGY AND PUBLISHING SOLUTIONS PRIVATE LIMITED,PUNE vs. THE DEPUTY COMMISSIONER OF INCOME-TAX, CIRCLE 5, PUNE, PUNE

In the result, both the appeals of the assessee are allowed for statistical purposes

Bench: Dr.Manish Borad & Shri Vinay Bhamore

68,200, Employers Contribution to Provident Fund of INR 43,55,286, Employers Contribution to ESIC of INR 1,35,555 and Bonus of INR 5,07,95,670 made under the intimation order under section 143(1), without assigning any reason whatsoever, 9. The learned AO has failed to appreciate the fact that the said amount has been

SPRINGER NATURE TECHNOLOGY AND PUBLISHING SOLUTIONS PRIVATE LIMITED,PUNE vs. THE ASSESSMENT UNIT, INCOME TAX DEPARTMENT AND THE DEPUTY COMMISSIONER OF INCOME-TAX, CIRCLE 5, PUNE, PUNE

In the result, both the appeals of the assessee are allowed for statistical purposes

Bench: Dr.Manish Borad & Shri Vinay Bhamore

68,200, Employers Contribution to Provident Fund of INR 43,55,286, Employers Contribution to ESIC of INR 1,35,555 and Bonus of INR 5,07,95,670 made under the intimation order under section 143(1), without assigning any reason whatsoever, 9. The learned AO has failed to appreciate the fact that the said amount has been

SANCHIT KANTILAL GANORE,BHAGUR vs. ITO WARD 1(1), NASHIK, NASHIK

In the result, appeal of the assessee is partly allowed

Bench: Dr.Dipak P. Ripote & Shri Vinay Bhamoreआयकर अपऩल सं. / Ita No.1767/Pun/2025 निर्धारण वषा / Assessment Year: 2017-18 Sanchit Kantilal Ganore, V The Income Tax Officer, 21, Main Road, Bhagur, S. Ward-1(1), Nashik. Nashik - 422502. Pan: Aprpg4907J Appellant/ Assessee Respondent / Revenue Assessee By Shri Piyush Bafna Revenue By Shri Aviyogi Ambadkar– Add.Cit(Dr) Date Of Hearing 09/09/2025 Date Of Pronouncement 19/09/2025 आदेश/ Order Per Dr. Dipak P. Ripote, Am: This Appeal Is 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 A.Y.2017-18, Dated 29.05.2025 Emanating From Assessment Order U/S.147 R.W.S 144 Of The I.T.Act, Dated 21.05.2023. The Assessee Has Raised Following Grounds Of Appeal : “1. On The Facts & In The Circumstances Of The Case & In Law & Without Prejudice To Other Grounds, Ld. Nfac Has Erred In Passing A

68 by Ld. NaFAC without appreciating the valid submission filed by the Appellant and 5 ITA No.1767/PUN/2025 [A] hence, the same is bad in law and thus, the impugned addition may please be deleted. 15. On the facts and in the circumstances of the case and in law and without prejudice to other grounds, Ld. NFAC has erred in upholding

ARIHANT VASTUSHILP PROPCON PRIVATE LIMITED,PUNE vs. ITO WARD 1(1), PUNE

In the result, all the 3 appeals filed by the assessee are allowed for statistical purposes

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

270A of the Act. For the sake of convenience, these appeals were heard together and are being disposed of by this common order. 2. Facts of the case, in brief, are that the assessee is a company engaged in the business of purchase, sale and letting of leased residential and non-residential buildings. It filed its original return of income