IN THE INCOME TAX APPELLATE TRIBUNAL PUNE BENCH “A”, PUNE BEFORE SHRI R. K. PANDA, VICE PRESIDENT AND Ms. ASTHA CHANDRA, JUDICIAL MEMBER Assessment year : 2019-20 DCIT, Central Circle – 1, Smt. Asha Bhagwanrao Kadam Aurangabad A-3/201, Karishma Society, Opp.

Vs.

Karve Road, Kothrud, Pune –

411038 PAN: AARPK2868D (Appellant) (Respondent)

ITA Nos.1894, 1895 & 1896/PUN/2024 Assessment years : 2019-20, 2018-19 & 2018-19 DCIT, Central Circle – 1, Smt. Asha Bhagwanrao Kadam Aurangabad Vs. A-3/201, Karishma Society, Opp.

Karve Road, Kothrud, Pune – 411038 PAN: AARPK2868D (Appellant) (Respondent)

ITA Nos.607 to 611/PUN/2025 Assessment years : 2019-20 & 2018-19 Smt. Asha Bhagwanrao Kadam DCIT, Central Circle –

A-3/201, Karishma Society, Opp. Vs. 1, Aurangabad Karve Road, Kothrud, Pune – 411038 PAN: AARPK2868D (Appellant) (Respondent)

Assessee by : Shri Pramod S Shingte Department by : S/Shri Amol Khairnar, CIT-DR and Vidya Ratna Kishore Date of hearing : 16-12-2025 Date of pronouncement : 19-01-2026

O R D E R

PER BENCH:

IT(SS)A No.39/PUN/2024 filed by the Revenue and ITA No.607/PUN/2025 filed by the assessee are cross appeals and are directed against the order dated 16.07.2024 of the Ld. CIT(A), Pune-12 relating to assessment year 2019-2020. IT(SS)A No.40/PUN/2024 and ITA No.1895/PUN/2025 filed by the Revenue and ITA Nos.610/PUN/2025 and 609/PUN/2025 filed by the assessee are cross appeals and are directed against the common order dated 18.07.2024 of the Ld. CIT(A), Pune-12 deleting the penalty levied by the Assessing Officer u/s 271D of the Income Tax Act, 1961 (hereinafter referred to as ‘the Act’) relating to assessment years 2018-19 and 2019-2020 respectively and not deciding certain legal grounds. ITA Nos.1896/PUN/2025 and 1894/PUN/2025 filed by the Revenue and ITA Nos.611/PUN/2025 and 608/PUN/2025 filed by the assessee are cross appeals and are directed against the common order dated 18.07.2024 of the Ld. CIT(A), Pune- 12 deleting the penalty levied by the Assessing Officer u/s 271E of the Act relating to assessment years 2018-19 and 2019-2020 respectively but not deciding the legal grounds raised before him. For the sake of convenience, all the 10 appeals were heard together and are being disposed of by this common order.

2. There is a delay of 11 days in filing of these appeals before the Tribunal by the assessee for which the assessee has filed condonation applications along with affidavits explaining the reasons for such delay. After considering the contents of the condonation applications filed along with the affidavits and after hearing the Ld. DR, the delay in filing of these appeals is condoned and the appeals are admitted for adjudication.

3. First we take up IT(SS)A No.39/PUN/2024 filed by the Revenue and ITA No.607/PUN/2025 filed by the assessee for assessment year 2019-20. Facts of the case, in brief, are that the assessee is an individual engaged in the business of carrying on the role of an investor along with handling the household responsibilities. She filed her return of income on 16.10.2019 declaring total income of Rs.1,48,82,180/-. The return was revised on 19.11.2019 declaring total income of Rs.1,46,76,910/-. A search action u/s 132 of the Act was conducted in Disha (Kotgire) Group of Aurangabad, Pune and Kolkata on 21.01.2020. The Kotgire Group is headed by Shri Devanand Narayan Kotgire (DNK in short) of Aurangabad and the main concerns of the group are under the brand name of DISHA. The group is engaged in real estate activity involving plotting activity and construction and sale of flats and shops. The group has also entered into partnerships with many persons for real estate activity including persons of Manjeet (Rajpal) Group, Pride group and Loharuka group. The assessee was also covered in the said search action u/s 132 of the Act conducted at Aurangabad. A search warrant was issued u/s 132 of the Act in the name of the assessee. A notice u/s 153A of the Act was also issued on 10.02.2021. The assessee in response