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14 results for “transfer pricing”+ Search & Seizureclear

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Key Topics

Section 143(3)10Section 271A10Addition to Income9Section 1328Search & Seizure8Section 12A6Section 1475Section 1485Section 153A5Survey u/s 133A

SHRI MANOJ MADANLAL CHHAJED,PUNE vs. ASSISTANT COMMISSIONER OF INCOME TAX, CIRCLE -1(1)PUNE, PUNE

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

ITA 725/PUN/2022[2018-19]Status: DisposedITAT Pune28 Jun 2023AY 2018-19

Bench: Shri Inturi Rama Rao & Shri S. S. Viswanethra Raviआयकर अपील सं. / It(Ss)A Nos.91 To 96/Pun/2022 िनधा"रण वष" / Assessment Years : 2012-13 To 2017-18 Shri Manoj Madanlal Vs. Acit, Central Circle- Chhajed, 1(1), Pune. 601, A-8 Building, Karishma Housing Society, Near Sangam Press, Kothrud, Pune- 411029. Pan : Aalpc4991M Appellant Respondent आयकर अपील सं. / It(Ss)A Nos.97 & 98/Pun/2022 िनधा"रण वष" / Assessment Years : 2012-13 & 2015-16 Acit, Circle-1(1), Pune. Vs. Shri Manoj Madanlal Chhajed, 601, A-8 Building, Karishma Housing Society, Near Sangam Press, Kothrud, Pune- 411029. Pan : Aalpc4991M Appellant Respondent आयकर अपील सं. / Ita No.725/Pun/2022 िनधा"रण वष" / Assessment Year: 2018-19 Shri Manoj Madanlal Vs. Acit, Circle-1(1), Pune. Chhajed, 601, A-8 Building, Karishma Housing Society, Near Sangam Press, Kothrud, Pune- 411029. Pan : Aalpc4991M Appellant Respondent

For Appellant: Shri Ratan SamalFor Respondent: Shri Keyur Patel
Section 132(4)Section 139(1)

search and seizure operations. The findings given by us in relation to the grounds nos.(a), (b) and (c) that the statement given by the assessee does not amount to confession, has no evidentiary value and cannot form the basis for the addition equally holds good in relation to the present grounds of appeal also. Therefore, it may be concluded

5
Section 143(2)4
Disallowance4

DY COMMISSIONER OF INCOME-TAX, SANGLI CIRCLE,, SANGLI vs. ANAND DEVELOPERS, SANGLI

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

ITA 67/PUN/2021[2014-15]Status: DisposedITAT Pune20 Jun 2023AY 2014-15
For Appellant: Shri Kishor B. PhadkeFor Respondent: Shri Keyur Patel &
Section 143(3)Section 42

search and seizure operations in the case of M/s. Prarthana Infra i.e. buyer of the property such as ledger copy, Pen Drive showing the payments of on-money consideration for the period from 01.04.2013 to 08.12.2014 concluded that the cash of Rs.6,97,00,000/- had been paid to Mr. Anand Shah during previous year 2013-14 relevant

ANAND DEVELOPERS,SANGLI vs. INCOME-TAX OFFICER, WARD 2(1), SANGLI

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

ITA 458/PUN/2020[2014-15]Status: DisposedITAT Pune20 Jun 2023AY 2014-15
For Appellant: Shri Kishor B. PhadkeFor Respondent: Shri Keyur Patel &
Section 143(3)Section 42

search and seizure operations in the case of M/s. Prarthana Infra i.e. buyer of the property such as ledger copy, Pen Drive showing the payments of on-money consideration for the period from 01.04.2013 to 08.12.2014 concluded that the cash of Rs.6,97,00,000/- had been paid to Mr. Anand Shah during previous year 2013-14 relevant

DCIT CIRCLE 1 NASHIK, NASHIK vs. SHREE SAI PROPERTIES, NASHIK

In the result, appeal of the Revenue is dismissed

ITA 987/PUN/2025[2014-15]Status: DisposedITAT Pune27 Jan 2026AY 2014-15

Bench: Dr. Manish Borad & Shri Vinay Bhamore

For Appellant: Shri Subodh Ratnaparkhi, CAFor Respondent: Shri Amit Bobde, CIT
Section 132Section 143(2)Section 143(3)Section 147Section 148Section 250

search and seizure action in the case of respondent- assessee and its group companies, no material whatsoever was seized and found indicating payment of on-money consideration at the time of purchase of the lands. Reliance in this regard can be placed on the following decisions: i) Pr.CIT vs. Umesh Ishrani (2019) 108 taxmann.com 437 (Bom) ii) CIT vs. Atam

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

ITA 1952/PUN/2024[2020-21]Status: DisposedITAT Pune25 Mar 2025AY 2020-21

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

For Appellant: Shri Nikhil PathakFor Respondent: Smt Nilu Jaggi, CIT
Section 143Section 143(3)Section 144C(1)

Transfer Pricing Officer about the amalgamation between SPENI and SPNI under Sections 391 to 394 of the Companies Act effective from 1 April 2015 and that the Assessing Officer could not have proceeded to pass the assessment order against a non-existent entity. The Tribunal has in fact observed that apart from the first communication dated 02 January 2017, there

DEPUTY COMMISSIONER OF INCOME TAX, AURANGABAD vs. VISTA NIRMAN PVT. LTD., MUMBAI

ITA 1340/PUN/2023[2011-12]Status: DisposedITAT Pune05 Aug 2024AY 2011-12

Bench: Shri R. K. Panda & Ms Astha Chandraassessment Year : 2011-12

For Appellant: Shri Jaiprakash BairagraFor Respondent: Shri Ajay Kumar Keshari
Section 132Section 133(6)Section 133ASection 142(1)Section 143(3)Section 147Section 148Section 151(1)

seizure operation u/s 132 and survey operation u/s 133A of the Income Tax Act, 1961 was conducted at the various premises of Mittal Group on 31.10.2017. During the search and survey it was found that M/s VISTA NIRMAN PRIVATE LIMITED has received share premium from various Kolkata based companies, the creditworthiness of whom remained unexplained, amounting to Rs.24

M.M. PATEL PUBLIC CHARITABLE TRUST,SOLAPUR vs. PCIT- CENTRAL, PUNE, PUNE

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

ITA 1130/PUN/2024[-]Status: DisposedITAT Pune21 Feb 2025
Section 12Section 127Section 12ASection 12A(1)(ac)Section 132Section 143(3)Section 153A

transferring the jurisdiction of the person, the transferee Income-\ntax Authorities as mentioned in section 116 of the Act shall exercise all\nthe powers and perform the functions as stipulated in the Act in respect\nof all the proceedings which may be commenced after the date of such\norder in respect of any year and such power includes passing

ASST. COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-1(1), PUNE, PUNE vs. GIRIRAJ ENTERPRISES, PUNE

In the result, the appeal filed by the assessee is allowed and the appeal filed by the Revenue is dismissed

ITA 553/PUN/2025[2021-22]Status: DisposedITAT Pune24 Jul 2025AY 2021-22

Bench: Shri R. K. Panda & Ms. Astha Chandraassessment Year : 2021-22

For Appellant: Shri Nikhil S PathakFor Respondent: Shri Amol Khairnar, CIT-DR
Section 132Section 139Section 139(1)Section 143(3)Section 153ASection 271ASection 80I

seizure action the assessee firm admitted that it has made unaccounted sale of Gai Chap tobacco and other products. In response to the notice u/s 153A of the Act the assessee filed the return of income on 08.03.2022 declaring total income of Rs.81,73,67,960/- on account of unaccounted sale of Gai Chap tobacco and other products admitted

M/S GIRIRAJ ENTERPRISES,PUNE vs. DCIT, CC.1(1), PUNE, PUNE

In the result, the appeal filed by the assessee is allowed and the appeal filed by the Revenue is dismissed

ITA 427/PUN/2025[2021-22]Status: DisposedITAT Pune24 Jul 2025AY 2021-22

Bench: Shri R. K. Panda & Ms. Astha Chandraassessment Year : 2021-22

For Appellant: Shri Nikhil S PathakFor Respondent: Shri Amol Khairnar, CIT-DR
Section 132Section 139Section 139(1)Section 143(3)Section 153ASection 271ASection 80I

seizure action the assessee firm admitted that it has made unaccounted sale of Gai Chap tobacco and other products. In response to the notice u/s 153A of the Act the assessee filed the return of income on 08.03.2022 declaring total income of Rs.81,73,67,960/- on account of unaccounted sale of Gai Chap tobacco and other products admitted

SMT. KIRTI B. THORAT,,PUNE vs. INCOME-TAX OFFICER, WARD - 3 (3),, PUNE

In the result, appeal of the assessee is dismissed

ITA 463/PUN/2019[2014-15]Status: DisposedITAT Pune20 Sept 2023AY 2014-15

Bench: Shri Partha Sarathi Chaudhury & Shri G.D. Padmahshalismt. Kirti Bipin Thorat, Vs Ito, Ward-3(3), Sr.No.1, Plot No.1, Shriman Pune. Society, Karve Nagar, Pune. Pan: Aeopt 8890 B Appellant Respondent Assessee By : Shri Rishab Jain, Ca Revenue By : Shri Ganesh Budruk, Dr Date Of Hearing : 04/09/2023 Date Of Pronouncement : 20/09/2023 O R D E R Per Partha Sarathi Chaudhury, Jm:

For Appellant: Shri Rishab Jain, CAFor Respondent: Shri Ganesh Budruk, DR
Section 131Section 132Section 147

seizure action u/sec. 132 of the Act conducted upon Sinhgad group of cases on 06/08/2013, wherein one of the groups was Jay Shriram Sugar and Agro Products Ltd. (JSAPL), which was also searched. Certain loose papers were found and seized in the said premises, which contained some transactions related to the assessee and her family members, who were in fact

SMT. SUMANDEVI DINESHKUMAR TULSYAN,,NASHIK vs. INCOME-TAX OFFICER, WARD - 1(5),, NASHIK

ITA 814/PUN/2018[2014-15]Status: DisposedITAT Pune28 Nov 2025AY 2014-15
Section 10(38)Section 133ASection 142(1)Section 143(2)Section 144A

search and seizure action at the premises of entry operators, share\nbrokers and money launderers who were involved in providing accommodation\nentries of Long Term Capital Gains. It was found that the price of various listed\ncompanies including Mishka i.e. the shares under question were manipulated and\nthe unaccounted money of the investors was routed through share transactions,\nresulting

DINESHKUMAR RAMCHANDRA TULSYAN (HUF),,NASHIK vs. INCOME-TAX OFFICER, WARD - 1(5),, NASHIK

In the result, both the appeals filed by the assessee are partly allowed

ITA 813/PUN/2018[2014-15]Status: DisposedITAT Pune28 Nov 2025AY 2014-15

Bench: Shri R. K. Panda & Ms. Astha Chandraassessment Year : 2014-15 Dineshkumar Ramchandra Tulsyan (Huf) Ito, Ward 1(5), 214B, Laxmi Niwas, Mahatma Nagar, Vs. Nashik Nashik – 422007 Pan: Aachd5953R (Appellant) (Respondent) Assessment Year : 2014-15 Smt. Sumandevi Dineshkumar Tulsyan Ito, Ward 1(5), 214B, Laxmi Niwas, Mahatma Nagar, Vs. Nashik Nashik – 422007 Pan: Ackpt1322Q (Appellant) (Respondent)

For Appellant: Shri Pramod S ShingteFor Respondent: Shri Rajesh Haladkar (through virtual)
Section 10(38)Section 133ASection 142(1)Section 143(2)Section 144A

search and seizure action at the premises of entry operators, share brokers and money launderers who were involved in providing accommodation entries of Long Term Capital Gains. It was found that the price of various listed companies including Mishka i.e. the shares under question were manipulated and resulting in Long Term Capital Gains as the same were exempt. He noted

DEPUTY COMMISSIONER OF INCOME TAX, AURANGABAD vs. ASHISH JUGALKISHOR BHALA, JALNA

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

ITA 1238/PUN/2024[2021-22]Status: DisposedITAT Pune16 Jun 2025AY 2021-22

Bench: Shri R. K. Panda & Ms. Astha Chandraassessment Year : 2021-22 Dcit, Aurangabad Ashish Jugalkishor Bhala Mamta Hospital, Shivaji Putla Road, Vs. Bharat Nagar, Jalna – 431203 Maharashtra Pan: Ahmpb3683K (Appellant) (Respondent) Assessee By : Shri Anand Partani Department By : Shri Ramnath P Murkunde Date Of Hearing : 01-04-2025 Date Of Pronouncement : 16-06-2025 O R D E R

For Appellant: Shri Anand PartaniFor Respondent: Shri Ramnath P Murkunde
Section 56(2)(x)

search and seizure action u/s 132 of the Income Tax Act, 1961 (hereinafter referred to as „the Act‟) was carried out on 23.09.2021 in the case of Metarolls group of cases at Jalna and all other concerns related to this group of cases wherein the case of the assessee was also covered. The case was selected for scrutiny under

ASSISTANT COMMISSIONER OF INCOME TAX, KOLHAPUR vs. NATHMAL RUPCHAND JAIN, KOLHAPUR

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

ITA 1295/PUN/2024[2020-21]Status: DisposedITAT Pune27 Jan 2025AY 2020-21

Bench: Shri R. K. Panda & Ms. Astha Chandraassessment Year : 2020-21

For Appellant: Shri Suhas P BoraFor Respondent: Shri Amol Khairnar CIT-DR
Section 132Section 133(6)Section 143(2)Section 145(3)Section 69A

seizure operation u/s 132 of the Income Tax Act, 1961 (hereinafter referred to as „the Act‟) was conducted at the business premises of M/s. Rishabh Trading Company, proprietorship of Sri Ankit Jain on 07.11.2019. During the course of search operation conducted, the statement of Sri Ankit Jain was recorded on oath wherein he has confessed that he had made fictitious