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

BIZ SECURE LABS PVT.LTD,,PUNE vs. DEPUTY COMMISSIONER OF INCOME-TAX, CIRCLE - 1(1),, PUNE

In the result, the appeal of the Revenue is dismissed and that

Bench: Shri R.S. Syal & Shri Sonjoy Sarma"नधा"रण वष" / Assessment Year : 2012-13 Biz Secure Labs Pvt. Ltd., Vs. Dcit, 1206, Sadashiv Peth, Circle- 1(1), Pune 411 030 Pune Pan : Aadcb6188L Appellant Respondent

68,217/-. A mark up of 10% was added to such costs for finding out the market value of CD writing at Rs.98,65,039/-. In this manner, he computed excess profit of total sales to Pune unit at Rs.13.98 crore (Rs.14.97 crore minus Rs.98.65 lakh). The assessee was confronted with this calculation and called upon to explain its stand

BIZ SECURE LABS PRIVATE LIMITED,,PUNE vs. DEPUTY COMMISSIONER OF INCOME TAX,, PUNE

In the result, the appeal of the Revenue is dismissed and that

Bench: Shri R.S. Syal & Shri Sonjoy Sarma"नधा"रण वष" / Assessment Year : 2012-13 Biz Secure Labs Pvt. Ltd., Vs. Dcit, 1206, Sadashiv Peth, Circle- 1(1), Pune 411 030 Pune Pan : Aadcb6188L Appellant Respondent

68,217/-. A mark up of 10% was added to such costs for finding out the market value of CD writing at Rs.98,65,039/-. In this manner, he computed excess profit of total sales to Pune unit at Rs.13.98 crore (Rs.14.97 crore minus Rs.98.65 lakh). The assessee was confronted with this calculation and called upon to explain its stand

DEPUTY COMMISSIONER OF INCOME-TAX, CIRCLE - 1(1),, PUNE vs. BIZ SECURE LABS PVT.LTD,, PUNE

In the result, the appeal of the Revenue is dismissed and that

Bench: Shri R.S. Syal & Shri Sonjoy Sarma"नधा"रण वष" / Assessment Year : 2012-13 Biz Secure Labs Pvt. Ltd., Vs. Dcit, 1206, Sadashiv Peth, Circle- 1(1), Pune 411 030 Pune Pan : Aadcb6188L Appellant Respondent

68,217/-. A mark up of 10% was added to such costs for finding out the market value of CD writing at Rs.98,65,039/-. In this manner, he computed excess profit of total sales to Pune unit at Rs.13.98 crore (Rs.14.97 crore minus Rs.98.65 lakh). The assessee was confronted with this calculation and called upon to explain its stand

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

68 of the ITA, 1961. As against, the final\ntaxation is u/s 115BBC. Per se, no approval is sought for taxation\nu/s 148 for the said Section 115BBC. As an effect, it transpires that,\nthe entire taxation made by learned AO_u/s_115BBC is without\nsanction of higher authorities. Appellant relies on the following\ndecisions in this regard.\n16. Contention

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

68 of the ITA, 1961. As against, the final\ntaxation is u/s 115BBC. Per se, no approval is sought for taxation\nu/s 148 for the said Section 115BBC. As an effect, it transpires that,\nthe entire taxation made by learned AO_u/s_115BBC is without\nsanction of higher authorities. Appellant relies on the following\ndecisions in this regard.\n16. Contention

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

68 of the ITA, 1961. As against, the final\ntaxation is u/s 115BBC. Per se, no approval is sought for taxation\nu/s 148 for the said Section 115BBC. As an effect, it transpires that,\nthe entire taxation made by learned AO_u/s_115BBC is without\nsanction of higher authorities. Appellant relies on the following\ndecisions in this regard.\n16. Contention

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

68 as unexplained cash credit to section 69A as unexplained money of the assessee, then he must also give cogent and valid reasons and resort to the applicable provisions within the Act 15 ITA 1850 of 2019 Kalpesh R. Gardharia A.Y. 2010-11 itself. The ld. CIT(A) while re-adjudicating the issue shall comply with the principles

BHADANES HITECH TECHNOLOGY COMPUTER PVT.LTD,,NASHIK vs. INCOME-TAX OFFICER, WARD - 1(1),, NASHIK

Appeal is partly allowed in above terms

Bench: Shri S.S. Godara & Dr. Dipak P. Ripoteनिर्धारण वषा / Assessment Year : 2013-14 Bhadanes Hitech Technology Vs. Ito, Ward Computer Pvt. Ltd. 1(1), Nashik Flat No.10, Padmavishwa Plaza, Nashik Pune Road, Tagore Nagar, Nashik – 422006 Pan : Aadcb9102E Appellant Respondent

section 68 the onus is on the assessee to prove the three ingredients, i.e., identity and creditworthiness of the person from whom the monies were taken and the genuineness of the transaction. As to how the onus can he discharged would depend on the facts and circumstances of each case. It is expected of both the sides - The assessee

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 68 of the Act : 8. The assessing officer based on the findings of the survey conducted by the Investigation

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 68 of the Act : 8. The assessing officer based on the findings of the survey conducted by the Investigation

SOPAN BANDOBA CHAVAN,PUNE vs. INCOME TAX OFFICER WARD 6(1), PUNE

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

Bench: Shri R. K. Panda & Ms. Astha Chandraassessment Year : 2017-18

8 1 Non-applicability of section 68 as not recorded in books: In any case, the rough CHITS impounded

EATON TECHNOLOGIES PVT.LTD,,PUNE vs. DEPUTY COMMISSIONER OF INCOME-TAX, CIRCLE - 1(2),, PUNE

Appeal is partly allowed in above terms

Bench: Shri S. S. Godara, Jm & Shri Dr. Dipak P. Ripote, Am आयकर अपीऱ सं. / Ita No.3075/Pun/2017 ननधधारण वषा / Assessment Year : 2013-14 Eaton Technologies Pvt. Ltd. Cluster C, Wing 1, Eon Free Zone, Plot No.1, Sr. No.77, Midc Kharadi Knowledge Park, Kharadi ,Pune- 411 014. .......अपऩलधथी / Appellant Pan : Aabce4323Q बनधम / V/S. ……प्रत्यथी / Respondent Dcit, Circle-1(2), Pune Assessee By : Shri Vishal Karla Revenue By : Shri S. P. Walimbe

68, involving proceeding u/s.143(3) r.w.s.144C(13) of the I.T.ACT, 1961 ; in short "the Act. Heard both the parties. Case file perused. 2. The assessee raises the following substantive grounds in the instant appeal. ―1. That on facts and circumstances of the case and in law, the AO erred in assessing the income of the Appellant under the normal provisions

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

68 was to be confirmed; SLP dismissed 20 Gopal Extrusions Pvt. Ltd. 8 Konark Structural Engineers 73 to 80 Where assessee-company received 8 (P.) Ltd. Vs DCIT [2018] 90 certain amount as share capital from taxmann.com 56 (Bombay) various shareholders, in view of fact that summons served to shareholders under section

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 68 of the Act : 8. The assessing officer based on the findings of the survey conducted by the Investigation

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 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

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 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

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 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