ASSISTANT COMMISSIONER OF INCOME TAX, JALGAON vs. SIDHARTH RATANLAL BAFNA, JALGAON

In the result, all the above 6 appeals filed by the Revenue are dismissed and

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

section 148 could be issued. 46. Referring to the decision of the Hon'ble Gujarat High Court in the case of Aaspas Multimedia Ltd. vs. DCIT (2018) 405 ITR 512 (Guj), he submitted that where reassessment was made on basis of information received from Principal DIT (Investigation) that assessee was beneficiary of accommodation entries by way of share application

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:

section 68 r.w.s. 115BBE of the Act to the additional income declared amounting to Rs.1,24,26,820/-. 52. After hearing both sides we find the above grounds are identical to the ground Nos.2 to 6 raised by the assessee in ITA No.1403/PUN/2025. We have already decided the issue and the grounds raised by the assessee have been allowed

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:

section 68 r.w.s. 115BBE of the Act to the additional income declared amounting to Rs.1,24,26,820/-. 52. After hearing both sides we find the above grounds are identical to the ground Nos.2 to 6 raised by the assessee in ITA No.1403/PUN/2025. We have already decided the issue and the grounds raised by the assessee have been allowed

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:

section 68 r.w.s. 115BBE of the Act to the additional income declared amounting to Rs.1,24,26,820/-. 52. After hearing both sides we find the above grounds are identical to the ground Nos.2 to 6 raised by the assessee in ITA No.1403/PUN/2025. We have already decided the issue and the grounds raised by the assessee have been allowed

DEPUTY COMMISSIONER OF INCOME TAX, JALGAON vs. TARADEVI RATANLAL BAFNA, JALGAON

In the result, all the above 6 appeals filed by the Revenue are dismissed and

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

section 148 could be issued. 46. Referring to the decision of the Hon'ble Gujarat High Court in the case of Aaspas Multimedia Ltd. vs. DCIT (2018) 405 ITR 512 (Guj), he submitted that where reassessment was made on basis of information received from Principal DIT (Investigation) that assessee was beneficiary of accommodation entries by way of share application

DCIT CIRCLE 7, BODHI TOWER SALISBURY PARK vs. L B KUNJIR, PUNE

In the result, the two appeals filed by the assessee are allowed and the three appeals filed by Revenue are dismissed

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

68 and 69 to 69D. Since, I have already upheld that the additional income corresponding to excess stock is taxable u/s 69B of the Act, therefore, as per provisions of section 115BBE(2), no deduction for this amount can be allowed to the appellant in any assessment year. Accordingly, the contention raised by the appellant is rejected. The grounds

M/S. L.B. KUNJIR,PUNE vs. DEPUTY COMMISSIONER OF INCOME TAX, CIRCLE 7, PUNE, PUNE

In the result, the two appeals filed by the assessee are allowed and the three appeals filed by Revenue are dismissed

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

68 and 69 to 69D. Since, I have already upheld that the additional income corresponding to excess stock is taxable u/s 69B of the Act, therefore, as per provisions of section 115BBE(2), no deduction for this amount can be allowed to the appellant in any assessment year. Accordingly, the contention raised by the appellant is rejected. The grounds

DCIT, PUNE vs. L B KUNJIR, PUNE

In the result, the two appeals filed by the assessee are allowed and the three appeals filed by Revenue are dismissed

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

68 and 69 to 69D. Since, I have already upheld that the additional income corresponding to excess stock is taxable u/s 69B of the Act, therefore, as per provisions of section 115BBE(2), no deduction for this amount can be allowed to the appellant in any assessment year. Accordingly, the contention raised by the appellant is rejected. The grounds

M/S. L.B. KUNJIR,PUNE vs. DEPUTY COMMISSIONER OF INCOME TAX, CIRCLE 7, PUNE, PUNE

In the result, the two appeals filed by the assessee are allowed and the three appeals filed by Revenue are dismissed

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

68 and 69 to 69D. Since, I have already upheld that the additional income corresponding to excess stock is taxable u/s 69B of the Act, therefore, as per provisions of section 115BBE(2), no deduction for this amount can be allowed to the appellant in any assessment year. Accordingly, the contention raised by the appellant is rejected. The grounds

DEPUTY COMMISSIONER OF INCOME TAX, CIRCLE-7, PUNE vs. LB KUNJIR, PUNE

In the result, the two appeals filed by the assessee are allowed and the three appeals filed by Revenue are dismissed

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

68 and 69 to 69D. Since, I have already upheld that the additional income corresponding to excess stock is taxable u/s 69B of the Act, therefore, as per provisions of section 115BBE(2), no deduction for this amount can be allowed to the appellant in any assessment year. Accordingly, the contention raised by the appellant is rejected. The grounds

PATEL GOYAL ASSOCIATES,,PUNE vs. INCOME-TAX OFFICER,,

In the result, the appeal of the assessee is partly allowed

Bench: Ms. Sushma Chowla, Jm & Shri D. Karunakara Rao, Am आयकर अपील सं. / Ita No.132/Pun/2016 िनधा"रण वष" / Assessment Year : 2008-09 Patel Goyal Associates, 501, Fortune House, Prabhat Road, Erandwane, Pune-411004. अपीलाथ"/Appellant Pan : Aahfp0519N …. Vs. Ito, Judicial (Hq), …. ""यथ" / Respondent Pune. अपीलाथ" क" ओर से / Appellant By : Shri Nikhil Pathak & Shri Kailash Agarwal ""थ" की ओर से / Respondent By : Shri Sanjeev Ghai सुनवाई क" तारीख / घोषणा क" तारीख / Date Of Hearing : 24.01.2019 Date Of Pronouncement: 20.03.2019 आदेश / Order Per D. Karunakara Rao, Am : This Appeal Is Filed By The Assessee Against The Order Of Cit(A)-3, Pune Dated 24.11.2015 For The Assessment Year 2008-09. 2. The Grounds Raised By The Assessee Are As Under :- “1. Disallowance Of Interest Of Rs.29,65,196/- U/S 57(Iii) In The Facts & Circumstances Of The Case The Learned Cit(A) Erred In Confirming The Disallowance Of Interest U/S 57(Iii). 2. In The Facts & Circumstances Of The Case, Interest Paid Ought To Have Been Allowed U/S 57(Iii). For That Learned Cit(A) Failed To Appreciate That When The Learned A.O. Has Recorded A Clear Cut Finding In The Assessment Order & Affirmed The Position Taken By The Appellant In Return Of Income That When Interest Is Not Claimed & Also Not Allowable U/S 36(1)(Iii), It Has To Be Allowed U/S 57(Iii). 3. For That In The Facts & Circumstances Of The Case, The Learned Cit(A) Failed To Appreciate The Fact That When Borrowed Funds Were Not Required For Business Purposes Due To Availability Of Surplus Funds In Regular Business, Interest Is Paid Only To Earn Interest Income & Hence Interest Cannot Be Disallowed U/S 57(Iii).

section 57 of the Act. He further submitted that the sum of Rs.95,86,721/- was offered as ‘income from other sources’ and the expenditure of Rs.29,65,196/- was claimed as an expenditure u/s 57(iii) of the Act. Further, he relied on the argumentative grounds raised in the present appeal. Mentioning that the similar deductions were claimed

UPPAL SHAH PROP-J K SUGARS,,KOLHAPUR vs. ASSISTANT COMMISSIONER OF INCOME-TAX, CIRCLE - 2,, KOLHAPUR

In the result, the cross appeal of the Revenue in ITA

Bench: Shri Inturi Rama Rao & Shri S. S. Viswanethra Ravisl.

section 68 of the Act. The Assessing Officer also brought to tax unpaid sundry creditors u/s 41(1) in respect of M/s Arpit Enterprises of Rs.16,14,500/- and in respect of M/s. V.S.N. Trading Co. of Rs.12,35,500/-. The factual background of the above additions is as under : During the previous year relevant to the assessment year

ASSISTANT COMMISSIONER OF INCOME-TAX, CIRCLE - 2,, KOLHAPUR vs. UPPAL JITENDRA SHAH,, KOLHAPUR

In the result, the cross appeal of the Revenue in ITA

Bench: Shri Inturi Rama Rao & Shri S. S. Viswanethra Ravisl.

section 68 of the Act. The Assessing Officer also brought to tax unpaid sundry creditors u/s 41(1) in respect of M/s Arpit Enterprises of Rs.16,14,500/- and in respect of M/s. V.S.N. Trading Co. of Rs.12,35,500/-. The factual background of the above additions is as under : During the previous year relevant to the assessment year

DASHRATH KISHANRAO CHOUDHARY,GANGAKHED vs. THE INCOME TAX OFFICER, WARD-1, JALNA

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

Bench: Shri Manish Borad & Ms. Astha Chandra

57,980/- by making an addition of Rs.40,99,500/- to the returned income of Rs. 17,58,480/- as unexplained money covered under section 68

ANANT KESHAV RAJEGAONKAR,NASHIK vs. THE ASSTT. COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE - 2, NASHIK, NASHIK

Bench: Dr.Manish Borad & Shri Vinay Bhamoreआयकर अपील सं. / Ita Nos.1249 To 1252/Pun/2024 Assessment Years : 2013-14, 2014-15 & 2015-16

section 68 of the Act, which were taxed by the AO as business profit, particularly when no notice u/s. 251(2) was issued by the CIT(A). 5. On the basis of facts and in the circumstances of the case and as per law, the Commissioner of Income Tax (Appeals) is not justified in confirming the addition of Rs.7

ANANT KESHAV RAJEGAONKAR,NASHIK vs. THE ASSTT. COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE - 2, NASHIK, NASHIK

Bench: Dr.Manish Borad & Shri Vinay Bhamoreआयकर अपील सं. / Ita Nos.1249 To 1252/Pun/2024 Assessment Years : 2013-14, 2014-15 & 2015-16

section 68 of the Act, which were taxed by the AO as business profit, particularly when no notice u/s. 251(2) was issued by the CIT(A). 5. On the basis of facts and in the circumstances of the case and as per law, the Commissioner of Income Tax (Appeals) is not justified in confirming the addition of Rs.7

ANANT KESHAV RAJEGAONKAR,NASHIK vs. THE ASSTT. COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE - 2, NASHIK, NASHIK

Bench: Dr.Manish Borad & Shri Vinay Bhamoreआयकर अपील सं. / Ita Nos.1249 To 1252/Pun/2024 Assessment Years : 2013-14, 2014-15 & 2015-16

section 68 of the Act, which were taxed by the AO as business profit, particularly when no notice u/s. 251(2) was issued by the CIT(A). 5. On the basis of facts and in the circumstances of the case and as per law, the Commissioner of Income Tax (Appeals) is not justified in confirming the addition of Rs.7

ANANT KESHAV RAJEGAONKAR,NASHIK vs. THE ASSTT. COMMISSIONER OF OF INCOME TAX , CENTRAL CIRCLE - 2, NASHIK, NASHIK

Bench: Dr.Manish Borad & Shri Vinay Bhamoreआयकर अपील सं. / Ita Nos.1249 To 1252/Pun/2024 Assessment Years : 2013-14, 2014-15 & 2015-16

section 68 of the Act, which were taxed by the AO as business profit, particularly when no notice u/s. 251(2) was issued by the CIT(A). 5. On the basis of facts and in the circumstances of the case and as per law, the Commissioner of Income Tax (Appeals) is not justified in confirming the addition of Rs.7