MADANLAL LALCHAND JAIN,NANDURBAR vs. ACIT CENTRAL CIRCLE 2, NASHIK

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

Bench: Shri R. K. Panda & Ms. Astha Chandraassessment Year : 2021-22 Madanlal Lalchand Jain Acit, Central Circle-2, Vibhare Building, Nashik Near City Police Station, Vs. Hat Darwaja Station Road, Nandurbar – 425412 Pan: Abkpj3633K (Appellant) (Respondent) Assessment Year : 2021-22 Acit, Central Circle-2, Madanlal Lalchand Jain Nashik Vibhare Building, Vs. Near City Police Station, Hat Darwaja Station Road, Nandurbar – 425412 Pan: Abkpj3633K (Appellant) (Respondent) Co No.42/Pun/2025 Assessment Year : 2021-22 Madanlal Lalchand Jain Acit, Central Circle-2, Vibhare Building, Nashik Near City Police Station, Vs. Hat Darwaja Station Road, Nandurbar – 425412 Pan: Abkpj3633K (Appellant) (Respondent) Assessment Year : 2022-23 Madanlal Lalchand Jain Acit, Central Circle-2, Vibhare Building, Nashik Near City Police Station, Vs. Hat Darwaja Station Road, Nandurbar – 425412 Pan: Abkpj3633K (Appellant) (Respondent) : Shri Nikhil S Pathak Department By : Shri Amol Khairnar, Cit-Dr Date Of Hearing : 03-11-2025 Date Of Pronouncement : 21-11-2025 O R D E R Per Bench:

68 r.w.s. 115BBE of the Act cannot be attracted to the additional income declared during the course of search. 26. Even otherwise also the assessee during the course of search in his statement recorded u/s 132(4) of the Act has stated to have obtained loans from various persons as per the seized document. 27. We find the Pune Bench

MADANLAL LALCHAND JAIN,NANDURBAR vs. ACIT CENTRAL CIRCLE 2, NASHIK

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

Bench: Shri R. K. Panda & Ms. Astha Chandraassessment Year : 2021-22 Madanlal Lalchand Jain Acit, Central Circle-2, Vibhare Building, Nashik Near City Police Station, Vs. Hat Darwaja Station Road, Nandurbar – 425412 Pan: Abkpj3633K (Appellant) (Respondent) Assessment Year : 2021-22 Acit, Central Circle-2, Madanlal Lalchand Jain Nashik Vibhare Building, Vs. Near City Police Station, Hat Darwaja Station Road, Nandurbar – 425412 Pan: Abkpj3633K (Appellant) (Respondent) Co No.42/Pun/2025 Assessment Year : 2021-22 Madanlal Lalchand Jain Acit, Central Circle-2, Vibhare Building, Nashik Near City Police Station, Vs. Hat Darwaja Station Road, Nandurbar – 425412 Pan: Abkpj3633K (Appellant) (Respondent) Assessment Year : 2022-23 Madanlal Lalchand Jain Acit, Central Circle-2, Vibhare Building, Nashik Near City Police Station, Vs. Hat Darwaja Station Road, Nandurbar – 425412 Pan: Abkpj3633K (Appellant) (Respondent) : Shri Nikhil S Pathak Department By : Shri Amol Khairnar, Cit-Dr Date Of Hearing : 03-11-2025 Date Of Pronouncement : 21-11-2025 O R D E R Per Bench:

68 r.w.s. 115BBE of the Act cannot be attracted to the additional income declared during the course of search. 26. Even otherwise also the assessee during the course of search in his statement recorded u/s 132(4) of the Act has stated to have obtained loans from various persons as per the seized document. 27. We find the Pune Bench

ASST. COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-2, NASHIK, NASHIK vs. MADANLAL LALCHAND JAIN, NANDURBAR

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

Bench: Shri R. K. Panda & Ms. Astha Chandraassessment Year : 2021-22 Madanlal Lalchand Jain Acit, Central Circle-2, Vibhare Building, Nashik Near City Police Station, Vs. Hat Darwaja Station Road, Nandurbar – 425412 Pan: Abkpj3633K (Appellant) (Respondent) Assessment Year : 2021-22 Acit, Central Circle-2, Madanlal Lalchand Jain Nashik Vibhare Building, Vs. Near City Police Station, Hat Darwaja Station Road, Nandurbar – 425412 Pan: Abkpj3633K (Appellant) (Respondent) Co No.42/Pun/2025 Assessment Year : 2021-22 Madanlal Lalchand Jain Acit, Central Circle-2, Vibhare Building, Nashik Near City Police Station, Vs. Hat Darwaja Station Road, Nandurbar – 425412 Pan: Abkpj3633K (Appellant) (Respondent) Assessment Year : 2022-23 Madanlal Lalchand Jain Acit, Central Circle-2, Vibhare Building, Nashik Near City Police Station, Vs. Hat Darwaja Station Road, Nandurbar – 425412 Pan: Abkpj3633K (Appellant) (Respondent) : Shri Nikhil S Pathak Department By : Shri Amol Khairnar, Cit-Dr Date Of Hearing : 03-11-2025 Date Of Pronouncement : 21-11-2025 O R D E R Per Bench:

68 r.w.s. 115BBE of the Act cannot be attracted to the additional income declared during the course of search. 26. Even otherwise also the assessee during the course of search in his statement recorded u/s 132(4) of the Act has stated to have obtained loans from various persons as per the seized document. 27. We find the Pune Bench

ASSTT. COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-1, NASHIK, NASHIK vs. YOGI COTEX PRIVATE LIMITED, MUMBAI

In the result appeal of the revenue is dismissed

Bench: Dr. Manish Borad & Shri Vinay Bhamoreआयकर अपील सं / Ita No.2058/Pun/2025 धििाारण वर्ा / Assessment Year: 2018-19 Vs Yogi Cotex Private Acit, Central Circle-1, Nashik Limited, 4A, Vikas Centre, S V Road, Santacruz West, Mumbai-400054 Maharashtra Pan-Aaacy5355P Appellant Respondent

68 results in unjust double taxation, as the amount forms part of the aggregate sum of Rs. 5,00,01,614/- that was voluntarily disclosed and offered to tax by the Deesan Group across its constituent entities during the course of post-search compliance. It was submitted that the group entities, including the appellant, had disclosed unaccounted income from scrap

JAIBHAGWAN BANARASIDAS JINDAL,JALNA vs. THE INCOME TAX OFFICER, WARD-1, JALNA

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

Bench: Shri R. K. Panda & Ms. Astha Chandraassessment Year : 2016-17

section 68 of the Act, where any sum is found credited in the book of the assessee for any previous year, the same may be charged to income-tax as the income of the assessee of that previous year if the explanation offered by the assessee about the nature and source thereof is, in the opinion of the assessing

ASSISTANT COMMISSIONER OF INCOME-TAX, CIRCLE - 1, , NASHIK vs. SMT. PRIYA K. JAGTIYANI, LEGAL HEIR OF LATE SHRI KISHOR C. JAGTIYANI, NASHIK

In the result, the appeal of Revenue is dismissed

Bench: Ms. Sushma Chowla, Jm & Shri Anil Chaturvedi, Am आयकर अपीऱ सं. / Ita No.336/Pun/2016 यििाारण वषा / Assessment Year : 2011-12 The Asst. Commissioner Of Income Tax, अऩीऱाथी/Appellant Circle – 1, Nashik …. Vs. Smt. Priya K. Jagtiyani L/H Of Late Kishor Chelaram Jagtiyani Office No.1, Shalimar Towers, Shalimar Chowk, Shivaji Road, …. प्रत्यथी / Respondent Nashik – 422001 Pan: Adepj7743C

68 of the Act being loan taken from wife. 5) The appellant prays the order of the Assessing Officer may be restored. 6) The appellant prays to adduce such further evidence to substantiate his case. 3. The issue raised in the present appeal vide ground of appeal No.1 is against deletion of addition of ₹ 98,96,077/- by invoking

INCOME-TAX OFFICER vs. AKASH FARMS PVT. LTD.,, AURANGABAD

In the result, the appeal of the Revenue is dismissed

Bench: Shri D. Karunakara Rao, Am & Shri Vikas Awasthy, Jm आयकर अपील सं. / Ita No.1482/Pun/2016 िनधा"रण वष" / Assessment Year : 2012-13 Ito, Ward-1(1), .......अपीलाथ" / Appellant Aurangabad. बनाम / V/S. M/S. Akash Farms Llp, Nath House, Paithan Road, Aurangabad. ……""यथ" / Respondent Pan : Aadca3303J Revenue By : Smt. Shabana Parveen Assessee By : Shri N. R. Agarwal सुनवाई क" तारीख / Date Of Hearing : 15.05.2019 घोषणा क" तारीख / Date Of Pronouncement : 12.07.2019 आदेश / Order Per D. Karunakara Rao, Am: This Appeal Is Filed By The Revenue Against The Order Of The Cit(A)- 1, Aurangabad Dated 29.04.2016 For The Assessment Year 2012-13. 2. The Revised Grounds Raised By The Revenue Are As Under :- “1. The Ld. Commissioner Of Income-Tax (A)-1 Erred In Passing The Order Both On The Facts Of The Case & In Law. 2. The Ld. Commissioner Of Income-Tax (A)-1 Erred In Failing To Give To The A.O. Reasonable Opportunity Required To Be Given To The A.O. As Per Rule 46A(3) As Only Seven Days Were Given To The A.O. For Examining & Rebutting The Considerable Additional Evidence Produced By The Assessee & For Submitting The Remand Report & The Order Was Passed By Cit(A) On The Very Next Day After The Remand Report Was Due. 3. The Ld. Commissioner Of Income-Tax (A)-1 Erred In Not Upholding The Addition Of Rs.42608528/- In Light Of The Decision By The Hon’Ble Supreme Court In The Case Of Pcit Vs Nra Iron & Steel (P) Ltd. (Reported In 103 Taxmann.Com 48) As In The Instant Case The Investor Company Was In Loss Of Rs.65,459/- & Had Negative Figures Of Reserve & Surplus Of Rs.3.60 Crores.

section 68 of the Act. Respectfully following the above decisions and facts of the present case, I direct the AO to delete the addition of Rs.4,26,08,528/- made by him. These grounds of appeal are allowed.” Sources of Funds of the Kagliwals: Further, we examined the 16. sources of funds amounting to Rs.4,26,08,528/- invested

INDRAPRASTHA NAGARI SAHAKARI PATSANSTHA LTD.,,SANGLI vs. INCOME-TAX OFFICER, WARD -5,, SANGLI

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

Bench: Shri R. K. Panda & Shri Vinay Bhamoreआयकर अपील सं. / Ita No.184/Pun/2022 िनधा"रण वष" / Assessment Year : 2018-19 Indraprastha Nagari Sahakari Vs. Ito, Ward-5, Sangli. Patsanstha Ltd., Islampur, Walwa, Sangli- 415409. Pan : Aaaai0626B Appellant Respondent Assessee By : Shri Sarang Gudhate Revenue By : Shri Uma Shankar Prasad Date Of Hearing : 21.11.2024 Date Of Pronouncement : 30.01.2025 आदेश / Order Per Vinay Bhamore, Jm: It Is A Recalled Matter. This Appeal Filed By The Assessee Is Directed Against The Order Dated 14.03.2022 Passed By Ld. Cit(A)/Nfac For The Assessment Year 2018-19. 2. The Appellant Has Raised The Following Modified Grounds Of Appeal :- “Ground No. 1: Under The Facts & Circumstances Of The Case & In Law, Ld. Cit(A) / Nfac Is Erred In Disallowing Deduction U/S 80P Of Rs. 65,81,336/-.

68 of the IT Act as undisclosed income. However, from perusal of the impugned order of Ld. CIT(A), we find that the assessee in the first appellate proceedings has only challenged the addition of Rs.3,57,44,782/- u/s 80P(2)(a)(i) of the IT Act, which was made by the AO under the provisions of section

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. In view of above discussion addition of Rs.1,18,82,797/- made by the AO stand confirmed. These grounds are therefore dismissed.” 39. The Ld. Counsel for the assessee referring to page 173 of the paper book submitted that the amount of Rs.1,18,82,797/- was credited to the capital account of the partner by debiting

RAHUL NEMGONDA PATIL,KOLHAPUR vs. INCOME TAX OFFICER, ICHALKARANJI

In the result, the appeal of the assessee is partly allowed for\nstatistical purposes

section 60A in case of other deposits into bank\naccounts. Where the Assessing Officer has, mistakenly, treated unexplained\ndeposits in bank as income u/s 68, the Commissioner (Appeals) can direct\nthe Assessing Officer to charge the relevant sums u/s 69/69A instead of s\n08 on the basis of general principles.\n5.7 The findings regarding sources for making bank deposits

DCIT, CENTRAL CIRCLE-1, AURANGABAD, AURANGABAD vs. SMT. ASHA BHAGWANRAO KADAM, PUNE

In the result, all the appeals filed by the Revenue as well as the assessee are allowed for statistical purposes

Bench: Shri R. K. Panda & Ms. Astha Chandrait(Ss)A Nos.39 & 40/Pun/2024 Assessment Year : 2019-20

68 itself declares that the credited sum would have to be included in the income of the assessee in the absence of explanation, or in the event of explanation being not satisfactory, it naturally follows that the material submitted by the assessee with his explanation must itself be wholesome or not 24 IT(SS)A Nos.39 & 40/PUN/2024 ITA Nos.1894

SMT ASHA BHAGWANRAO KADAM,PUNE vs. DCIT CENTRAL CIRCLE 1, AURANGABAD

In the result, all the appeals filed by the Revenue as well as the assessee are allowed for statistical purposes

Bench: Shri R. K. Panda & Ms. Astha Chandrait(Ss)A Nos.39 & 40/Pun/2024 Assessment Year : 2019-20

68 itself declares that the credited sum would have to be included in the income of the assessee in the absence of explanation, or in the event of explanation being not satisfactory, it naturally follows that the material submitted by the assessee with his explanation must itself be wholesome or not 24 IT(SS)A Nos.39 & 40/PUN/2024 ITA Nos.1894

SMT ASHA BHAGWANRAO KADAM,PUNE vs. DCIT CENTRAL CIRCLE 1, AURANGABAD

In the result, all the appeals filed by the Revenue as well as the assessee are allowed for statistical purposes

Bench: Shri R. K. Panda & Ms. Astha Chandrait(Ss)A Nos.39 & 40/Pun/2024 Assessment Year : 2019-20

68 itself declares that the credited sum would have to be included in the income of the assessee in the absence of explanation, or in the event of explanation being not satisfactory, it naturally follows that the material submitted by the assessee with his explanation must itself be wholesome or not 24 IT(SS)A Nos.39 & 40/PUN/2024 ITA Nos.1894

SMT ASHA BHAGWANRAO KADAM,PUNE vs. DCIT CENTRAL CIRCLE 1, AURANGABAD

In the result, all the appeals filed by the Revenue as well as the assessee are allowed for statistical purposes

Bench: Shri R. K. Panda & Ms. Astha Chandrait(Ss)A Nos.39 & 40/Pun/2024 Assessment Year : 2019-20

68 itself declares that the credited sum would have to be included in the income of the assessee in the absence of explanation, or in the event of explanation being not satisfactory, it naturally follows that the material submitted by the assessee with his explanation must itself be wholesome or not 24 IT(SS)A Nos.39 & 40/PUN/2024 ITA Nos.1894

SMT ASHA BHAGWANRAO KADAM,PUNE vs. DCIT CENTRAL CIRCLE 1, PUNE

In the result, all the appeals filed by the Revenue as well as the assessee are allowed for statistical purposes

Bench: Shri R. K. Panda & Ms. Astha Chandrait(Ss)A Nos.39 & 40/Pun/2024 Assessment Year : 2019-20

68 itself declares that the credited sum would have to be included in the income of the assessee in the absence of explanation, or in the event of explanation being not satisfactory, it naturally follows that the material submitted by the assessee with his explanation must itself be wholesome or not 24 IT(SS)A Nos.39 & 40/PUN/2024 ITA Nos.1894

SMT ASHA BHAGWANRAO KADAM,PUNE vs. DCIT CENTRAL CIRCLE 1, AURANGABAD

In the result, all the appeals filed by the Revenue as well as the assessee are allowed for statistical purposes

Bench: Shri R. K. Panda & Ms. Astha Chandrait(Ss)A Nos.39 & 40/Pun/2024 Assessment Year : 2019-20

68 itself declares that the credited sum would have to be included in the income of the assessee in the absence of explanation, or in the event of explanation being not satisfactory, it naturally follows that the material submitted by the assessee with his explanation must itself be wholesome or not 24 IT(SS)A Nos.39 & 40/PUN/2024 ITA Nos.1894

DCIT, CENTRAL CIRCLE-1, AURANGABAD vs. SMT. ASHA BHAGWANRAO KADAM, PUNE

In the result, all the appeals filed by the Revenue as well as the assessee are allowed for statistical purposes

Bench: Shri R. K. Panda & Ms. Astha Chandrait(Ss)A Nos.39 & 40/Pun/2024 Assessment Year : 2019-20

68 itself declares that the credited sum would have to be included in the income of the assessee in the absence of explanation, or in the event of explanation being not satisfactory, it naturally follows that the material submitted by the assessee with his explanation must itself be wholesome or not 24 IT(SS)A Nos.39 & 40/PUN/2024 ITA Nos.1894

DCIT, CENTRAL CIRCLE-1, AURANGABAD vs. SMT. ASHA B. KADAM, PUNE

In the result, all the appeals filed by the Revenue as well as the assessee are allowed for statistical purposes

Bench: Shri R. K. Panda & Ms. Astha Chandrait(Ss)A Nos.39 & 40/Pun/2024 Assessment Year : 2019-20

68 itself declares that the credited sum would have to be included in the income of the assessee in the absence of explanation, or in the event of explanation being not satisfactory, it naturally follows that the material submitted by the assessee with his explanation must itself be wholesome or not 24 IT(SS)A Nos.39 & 40/PUN/2024 ITA Nos.1894