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

5% of the total donations or ₹1.00 lakh and the amount of income tax with which the assessee would have been chargeable had his total income being reduced by the aggregate of Anonymous donations received in excess of the amounts referred in sub- clause (a) and sub-clause (b) of section 115BBC(1)(i) of the Act. It therefore

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

5% of the total donations or ₹1.00 lakh and the amount of income tax with which the assessee would have been chargeable had his total income being reduced by the aggregate of Anonymous donations received in excess of the amounts referred in sub- clause (a) and sub-clause (b) of section 115BBC(1)(i) of the Act. It therefore

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

5% of\nthe total donations or ₹1.00 lakh and the amount of income\ntax with which the assessee would have been chargeable had\nhis total income being reduced by the aggregate of Anonymous\ndonations received in excess of the amounts referred in sub-\nclause (a) and sub-clause (b) of section 115BBC(1)(i) of the Act.\nIt therefore

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

5%\nof the total donations or ₹1.00 lakh and the amount of income\ntax with which the assessee would have been chargeable had\nhis total income being reduced by the aggregate of Anonymous\ndonations received in excess of the amounts referred in sub-\nclause (a) and sub-clause (b) of section 115BBC(1)(i) of the Act.\nIt therefore

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

5%\nof the total donations or ₹1.00 lakh and the amount of income\ntax with which the assessee would have been chargeable had\nhis total income being reduced by the aggregate of Anonymous\ndonations received in excess of the amounts referred in sub-\nclause (a) and sub-clause (b) of section 115BBC(1)(i) of the Act.\nIt therefore

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

45,612/- interalia disallowing the claim of deduction under section 80IA of the Act for the reason that Form 10CCB was not filed within the due date. The assessee being aggrieved by the said intimation order, filed an application for rectification u/s 154 of the Act before the Ld. Jurisdictional Assessing Officer (“JAO”). Subsequently, the case of the assessee

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

45,612/- interalia disallowing the claim of deduction under section 80IA of the Act for the reason that Form 10CCB was not filed within the due date. The assessee being aggrieved by the said intimation order, filed an application for rectification u/s 154 of the Act before the Ld. Jurisdictional Assessing Officer (“JAO”). Subsequently, the case of the assessee

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

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

CAPGEMINI TECHNOLOGY SERVICES INDIA LTD,,PUNE vs. DEPUTY COMMISSIONER OF INCOME-TAX, CIRCLE - 11,, PUNE

In the result, both the appeals are partly allowed

Bench: Shri R.S. Syal & Shri Partha Sarathi Chaudhury

45,55,209/-. Thereafter, the return was revised twice. The assessee claimed deduction u/s.10AA. The assessment was completed by determining the total income, under the regular provisions of the Act, at Rs.766,09,96,530/-. I. SET OFF OF LONG TERM CAPITAL LOSS OF AMALGAMATING COMPANY 3. The first major issued raised by the assessee, through ground

ASSISTANT COMMISSIONER OF INCOME-TAX, CIRCLE -11,, PUNE vs. CAPGEMINI TECHNOLOGY SERVICES INDIA LIMITED , (FORMERLY IGATE GLOBAL SOLUTIONS LTD.),, PUNE

In the result, both the appeals are partly allowed

Bench: Shri R.S. Syal & Shri Partha Sarathi Chaudhury

45,55,209/-. Thereafter, the return was revised twice. The assessee claimed deduction u/s.10AA. The assessment was completed by determining the total income, under the regular provisions of the Act, at Rs.766,09,96,530/-. I. SET OFF OF LONG TERM CAPITAL LOSS OF AMALGAMATING COMPANY 3. The first major issued raised by the assessee, through ground

AADHUNIK INFRASTRUCTURE DEVELOPMENT PRIVATE LIMITED,JALGAON vs. THE DEPUTY COMMISSIONER OF INCOME TAX, CIRCLE-1, JALGAON

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

Bench: Shri R. K. Panda & Shri Vinay Bhamoreassessment Year : 2012-13

68 of the Income Tax Act, 1961 and added to the Total Income of the assessee. Penalty proceedings are separately initiated u/s 271(1)(c) of the Act for furnishing inaccurate particulars of income.” 6. Aggrieved with such order of the Assessing Officer, the assessee filed appeal before the CIT(A) / NFAC challenging the validity of re-assessment proceedings

DEPUTY COMMISSIONER OF INCOME TAX, AURANGABAD vs. JHAVERI FLEXO INDIA PVT LTD, AURANGABAD

In the result, the appeal filed by the Revenue stands dismissed

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

section 69C made on account of unexplained purchases. 3. Whether on the facts and in the circumstances of the case and in law, the Ld CIT (A) has erred in law and in facts by deleting the addition of Rs. 3,45,68,794/- made on account of additional income declared during the search action. 4. The appellant craves

M/S. BILCARE LIMITED,PUNE vs. DEPUTY COMMISSIONER OF INCOME TAX CENTRAL CIRCLE-2(2), PUNE

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

Bench: Shri Inturi Rama Rao & Shri S. S. Viswanethra Raviआयकर अपीऱ सं. / Ita No.273/Pun/2021 निर्धारण वर्ा / Assessment Year: 2016-17 Dcit, Central Circle-2(2), Vs. M/S. Bilcare Limited, Pune. 601, Icc Trade Tower, Pune- 411016. Pan : Aabcb2242F Appellant Respondent आयकर अपीऱ सं. / Ita No.334/Pun/2021 निर्धारण वर्ा / Assessment Year: 2016-17 M/S. Bilcare Limited, Vs. Dcit, Central Circle- 6Th Floor, B Wing, Icc 2(2), Pune. Trade Tower, Senapati Bapat Road, Pune- 411006. Pan : Aabcb2242F Appellant Respondent

45. The ld. CIT-DR contends that the revised return of income is not valid in law, the ld. CIT(A) ought not to have applied the ratio of the decision of the Hon‟ble Bombay High Court in the case of CIT vs. M/s Prithvi Brokers & Shareholders, 23 Taxman.com 23 (Bombay) to the facts of case, as it relates

DEPUTY COMMISSIONER OF INCOME TAX CENTRAL CIRCLE-2(2), PUNE vs. M/S. BILCARE LIMITED, PUNE

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

Bench: Shri Inturi Rama Rao & Shri S. S. Viswanethra Raviआयकर अपीऱ सं. / Ita No.273/Pun/2021 निर्धारण वर्ा / Assessment Year: 2016-17 Dcit, Central Circle-2(2), Vs. M/S. Bilcare Limited, Pune. 601, Icc Trade Tower, Pune- 411016. Pan : Aabcb2242F Appellant Respondent आयकर अपीऱ सं. / Ita No.334/Pun/2021 निर्धारण वर्ा / Assessment Year: 2016-17 M/S. Bilcare Limited, Vs. Dcit, Central Circle- 6Th Floor, B Wing, Icc 2(2), Pune. Trade Tower, Senapati Bapat Road, Pune- 411006. Pan : Aabcb2242F Appellant Respondent

45. The ld. CIT-DR contends that the revised return of income is not valid in law, the ld. CIT(A) ought not to have applied the ratio of the decision of the Hon‟ble Bombay High Court in the case of CIT vs. M/s Prithvi Brokers & Shareholders, 23 Taxman.com 23 (Bombay) to the facts of case, as it relates

M/S MAULI MAHILA NAGARI SAHAKARI PATH SANSTHA LIMITED,LATUR vs. INCOME TAX OFFICER, WARD-1, LATUR, LATUR

In the result, the appeal of assessee is allowed

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

68 of the Act by recording its findings in paras 3, 4, 5 and 6 as under : “3. Both the learned representatives next invited our attention to the learned NFAC’s detailed discussion reversing the Assessing Officer’s findings making sec.68 unexplained cash credit addition in question of Rs.1,20,45,000/- as under : ITA No.1351/PUN/2023

DY.COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-1, AURANGABAD, AURANGABAD vs. SHRI. BALAJI RAMCHANDRA ANDE, LATUR

In the result, appeal of the Revenue dismissed

Bench: Shri Rama Kanta Panda & Ms. Astha Chandra

45,687/- should not be treated as deemed income u/sec.69C of the Act. Rejecting the various explanations given by the assessee, the Assessing Officer invoked the provisions of sec.69C r.w.s.115BBE to the above income. 2.3. He also invoked provisions of sec.69A r.w.s.115BBE being excess cash of Rs.4,50,540/- on the ground that assessee could not explain the source

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

Section 68. 45. The appeal is disposed of in above terms.” 18. Respectfully following the decision of Hon’ble Delhi High Court cited (supra), we deem it proper to restore the issue to the file of the Ld. CIT(A) with a direction to adjudicate the issue afresh and in accordance with law after obtaining the remand report from