ASHWINIKUMAR RAMKUMAR PODDAR,PUNE vs. THE ACIT, CENTRAL CIRCLE-1(2), PUNE

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

Bench: Shri R. K. Panda & Shri Vinay Bhamoreआयकर अपील सं. / Ita No.2757/Pun/2024 िनधा"रण वष" / Assessment Year : 2021-22 Ashwinikumar Ramkumar Vs. Acit, Central Circle-1(2), Poddar, Pune. Plot No.342, Sind Society, Baner Road, Aundh, Pune- 411007. Pan : Aarpp7606E Appellant Respondent आयकर अपील सं. / Ita No.2758/Pun/2024 िनधा"रण वष" / Assessment Year : 2021-22 Aditya Arunkumar Poddar, Vs. Acit, Central Circle-1(2), Plot No.130, Sind Society, Pune. Baner Road, Aundh, Pune- 411007. Pan : Ahspp3084G Appellant Respondent Assessee By : Shri Sarvesh Kandelwal Revenue By : Smt. Sonal L. Sonkavde Date Of Hearing : 02.02.2026 Date Of Pronouncement 10.04.2026 : आदेश / Order Per Vinay Bhamore, Jm: Both The Above Captioned Appeals Filed By The Two Different Assessees Are Directed Against The Separate Orders Dated 28.10.2024 Passed By Ld. Cit(A), Pune-11 [‘Ld. Cit(A)’] For The Assessment Year 2021-22 Respectively. 2. Since Identical Facts & Common Issues Are Involved In Both The Above Captioned Appeals Of The Two Different Assessee, Therefore, We Proceed To Dispose Of The Same By This Common Order. 3. First, We Shall Take Up The Appeal Of The Assessee In Ita No.2757/Pun/2025 For Adjudication As The Lead Case.

02 be calculated on the net debit balance which should be done after cumulatively taking into consideration the implied daily interest on the daily balances of current account maintained with the company - AEPL. 3. The appellant prays to be allowed to add, amend, modify, rectify, delete, and raise any grounds of appeal at the time of hearing.” 5. Facts

ADITYA ARUNKUMAR PODDAR,PUNE vs. THE ACIT, CENTRAL CIRCLE-1(2), PUNE

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

Bench: Shri R. K. Panda & Shri Vinay Bhamoreआयकर अपील सं. / Ita No.2757/Pun/2024 िनधा"रण वष" / Assessment Year : 2021-22 Ashwinikumar Ramkumar Vs. Acit, Central Circle-1(2), Poddar, Pune. Plot No.342, Sind Society, Baner Road, Aundh, Pune- 411007. Pan : Aarpp7606E Appellant Respondent आयकर अपील सं. / Ita No.2758/Pun/2024 िनधा"रण वष" / Assessment Year : 2021-22 Aditya Arunkumar Poddar, Vs. Acit, Central Circle-1(2), Plot No.130, Sind Society, Pune. Baner Road, Aundh, Pune- 411007. Pan : Ahspp3084G Appellant Respondent Assessee By : Shri Sarvesh Kandelwal Revenue By : Smt. Sonal L. Sonkavde Date Of Hearing : 02.02.2026 Date Of Pronouncement 10.04.2026 : आदेश / Order Per Vinay Bhamore, Jm: Both The Above Captioned Appeals Filed By The Two Different Assessees Are Directed Against The Separate Orders Dated 28.10.2024 Passed By Ld. Cit(A), Pune-11 [‘Ld. Cit(A)’] For The Assessment Year 2021-22 Respectively. 2. Since Identical Facts & Common Issues Are Involved In Both The Above Captioned Appeals Of The Two Different Assessee, Therefore, We Proceed To Dispose Of The Same By This Common Order. 3. First, We Shall Take Up The Appeal Of The Assessee In Ita No.2757/Pun/2025 For Adjudication As The Lead Case.

02 be calculated on the net debit balance which should be done after cumulatively taking into consideration the implied daily interest on the daily balances of current account maintained with the company - AEPL. 3. The appellant prays to be allowed to add, amend, modify, rectify, delete, and raise any grounds of appeal at the time of hearing.” 5. Facts

DCIT, CIRCLE 8 PUNE, PUNE vs. ALFA LAVAL INDIA PVT LTD, PUNE

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

section 40(a)(ia). He\nfurther submitted that from the books of account of the asssessee it was established\nthat these were actual expenses incurred during AY 2017-18 and not the\n\"provisions for expenses” on which TDS was not deducted. He submitted that the\nassessee failed to furnish any documentary evidence that TDS was deducted during\nthe assessment

SAMEER SHRIKANT PISE,PUNE vs. DCIT CIRCLE 12, PUNE

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

Bench: Dr. Manish Borad & Shri Vinay Bhamore

Section 154 of the Act. Hence, the Ld. JAO be directed not to give effect to the directions of the Ld. ADDL/JCIT(A) relating to TDS credit. The Appellant craves leave to add, amend, alter, substitute, withdraw all or any of the above Grounds of Appeal anytime either before or during the hearing of the Appeal.” 3 ITA.No.1078/PUN/2025

M/S KOLTE PATIL DEVELOPERS LTD,PUNE vs. DCIT,CIRCLE-7, PUNE, PUNE

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

Bench: Shri R. K. Panda & Shri Vinay Bhamoreassessment Year : 2014-15

02,250/- in respect of 8 flats on the ground that the market value of these flats was Rs.2,73,16,150/- whereas the assessee company has registered the flats for a consideration of Rs.2,48,13,900/- on the basis of agreement value and therefore, the provisions of section 43CA of the Act are applicable. We find

SIDHESH MOHAN RAIKAR,NASHIK vs. DEPUTY DIRECTOR OF INCOME TAX, CENTRALIZED PROCESSING CENTRE, BANGLORE

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

Bench: Dr.Manish Borad & Shri Vinay Bhamoreआयकर अपील सं. / Ita No.294/Pun/2025 Assessment Year : 2023-24

02 Total receipts as per Form 26AS from 2,33,06,642 various deductors (amounts appearing against TCS and 194N are not receipts, hence omitted 03 Credit of TDS claimed in the return 1,72,72,325 TDS credit allowable as per Rule 37BA 33,55,983 1/2*3 5.1.2 It has been contended by the Appellant that he being

INCOME TAX OFFICER,WARD-7(1), PUNE, PUNE vs. HEMANT BAGAREDDY MOTADOO, PUNE

In the result, the appeal filed by the Revenue is allowed for statistical purposes

Bench: Shri R. K. Panda & Shri Vinay Bhamoreassessment Year : 2013-14

02,430/- less TDS amount of Rs.1,33,243/-. Further, on account of failure of the assessee to deduct TDS on the payment of security charges to M/s. Shani Security & Allied Services, the Assessing Officer disallowed further amount of Rs.1,15,275/-. 4. The Assessing Officer similarly made addition of Rs.26,38,500/- by invoking the provisions of section

EATON TECHNOLOGIES PVT.LTD,,PUNE vs. PR. COMMISSIONER OF INCOME-TAX-1,, PUNE

Bench: Shri S.S.Godara & G.D.Padmahshaliआयकरअपीलसं. / Ita No.590/Pun/2018 िनधा"रण वष" / Assessment Year: 2014-15 Eaton Technologies Private Limited, Dcit, Circle-1(2), Cluster C, Wing 1, Eon Free Zone, Vs Pune Plot No.1, Sr.No.77, Midc Kharadi Knowledge Park, Kharadi, Pune 411 014 Pan : Aabce4323Q Appellant/ Assessee Respondent /Revenue आयकरअपीलसं. / Ita No.902/Pun/2018 िनधा"रण वष" / Assessment Year: 2011-12 Eaton Technologies Private Limited, Pr.Cit-1, Cluster C, Wing 1, Eon Free Zone, Vs Pune Plot No.1, Sr.No.77, Midc Kharadi Knowledge Park, Kharadi, Pune 411 014 Pan : Aabce4323Q Appellant/ Assessee Respondent /Revenue

02,868 to non-residents for purchase of software as ‘royalty’ for use of copyright, instead of purchase of copyrighted articles i.e. purchase of goods thereby, disallowing the payments made invoking provisions of section 40(a)(i) of the Act, for failure to deduct tax at source. 8. Notwithstanding and without prejudice to the above and on facts and circumstances

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

Bench: Shri S.S.Godara & G.D.Padmahshaliआयकरअपीलसं. / Ita No.590/Pun/2018 िनधा"रण वष" / Assessment Year: 2014-15 Eaton Technologies Private Limited, Dcit, Circle-1(2), Cluster C, Wing 1, Eon Free Zone, Vs Pune Plot No.1, Sr.No.77, Midc Kharadi Knowledge Park, Kharadi, Pune 411 014 Pan : Aabce4323Q Appellant/ Assessee Respondent /Revenue आयकरअपीलसं. / Ita No.902/Pun/2018 िनधा"रण वष" / Assessment Year: 2011-12 Eaton Technologies Private Limited, Pr.Cit-1, Cluster C, Wing 1, Eon Free Zone, Vs Pune Plot No.1, Sr.No.77, Midc Kharadi Knowledge Park, Kharadi, Pune 411 014 Pan : Aabce4323Q Appellant/ Assessee Respondent /Revenue

02,868 to non-residents for purchase of software as ‘royalty’ for use of copyright, instead of purchase of copyrighted articles i.e. purchase of goods thereby, disallowing the payments made invoking provisions of section 40(a)(i) of the Act, for failure to deduct tax at source. 8. Notwithstanding and without prejudice to the above and on facts and circumstances

CHANDRAKANT VITHTHAL BHOPI,RAIGAD vs. ITO WARD 1 , PANVEL

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

Bench: Shri R. K. Panda & Ms. Astha Chandraassessment Year : 2016-17 Chandrakant Viththal Bhopi Ito, Ward-1, Panvel At Chinchpada, Post Panvel, Tal. Vs. Panvel, Dist. Raigad – 410206 Pan: Bjdpb7610L (Appellant) (Respondent) Assessee By : Shri Nikhil S Pathak & Ajinkya M Vaishampayan Department By : Shri Ramnath P Murkunde Date Of Hearing : 05-05-2025 Date Of Pronouncement : 07-05-2025 O R D E R

TDS Return - Other Interest Rs 2,60,05,088/- (Section 194A) 8 Ongoing through office records, it has been found that the assessee has NOT filed return of income for the A.Y. 2016-17 and therefore, the income earned out of the transaction as tabulated above had not been disclosed by the assessee pertaining to above mentioned transaction. In view

SHRI SANTOSH T MURKUTE,NANDED vs. THE ASSESSING OFFICER , THE ACIT (CPC)-TDS, GHAZIZBAD, GHAZIABAD

Appeals are allowed

Bench: Shri R.S. Syal & Shri S.S. Godara

02-06-2022 Date of pronouncement 06-06-2022 आदेश / ORDER PER S.S. GODARA, JM : The instant batch of six appeals pertains to a single assessee herein Shri Santosh T. Murkute. All other relevant details thereof read as under: Sr. ITA No. A.Y. Order appealed against No. proceedings 1 133/PUN/2020 2013-14 (Qrt 3) CIT(A), Aurangabad‟s order dated

SHRI SANTOSH T MURKUTE,NANDED vs. THE ASSESSING OFFICER , THE ACIT (CPC)-TDS, GHAZIZBAD, GHAZIABAD

Appeals are allowed

Bench: Shri R.S. Syal & Shri S.S. Godara

02-06-2022 Date of pronouncement 06-06-2022 आदेश / ORDER PER S.S. GODARA, JM : The instant batch of six appeals pertains to a single assessee herein Shri Santosh T. Murkute. All other relevant details thereof read as under: Sr. ITA No. A.Y. Order appealed against No. proceedings 1 133/PUN/2020 2013-14 (Qrt 3) CIT(A), Aurangabad‟s order dated

SHRI SANTOSH T MURKUTE,NANDED vs. THE ASSESSING OFFICER , THE ACIT (CPC)-TDS, GHAZIZBAD, GHAZIABAD

Appeals are allowed

Bench: Shri R.S. Syal & Shri S.S. Godara

02-06-2022 Date of pronouncement 06-06-2022 आदेश / ORDER PER S.S. GODARA, JM : The instant batch of six appeals pertains to a single assessee herein Shri Santosh T. Murkute. All other relevant details thereof read as under: Sr. ITA No. A.Y. Order appealed against No. proceedings 1 133/PUN/2020 2013-14 (Qrt 3) CIT(A), Aurangabad‟s order dated

SANTOSH TRAMBAKRAO MURKUTE,NANDED vs. ASSISTANT COMMISSIONER OF INCOME-TAX, CPC,, GHAZIABAD

Appeals are allowed

Bench: Shri R.S. Syal & Shri S.S. Godara

02-06-2022 Date of pronouncement 06-06-2022 आदेश / ORDER PER S.S. GODARA, JM : The instant batch of six appeals pertains to a single assessee herein Shri Santosh T. Murkute. All other relevant details thereof read as under: Sr. ITA No. A.Y. Order appealed against No. proceedings 1 133/PUN/2020 2013-14 (Qrt 3) CIT(A), Aurangabad‟s order dated

SHRI SANTOSH T MURKUTE,NANDED vs. THE ASSESSING OFFICER , THE ACIT (CPC)-TDS, GHAZIZBAD, GHAZIABAD

Appeals are allowed

Bench: Shri R.S. Syal & Shri S.S. Godara

02-06-2022 Date of pronouncement 06-06-2022 आदेश / ORDER PER S.S. GODARA, JM : The instant batch of six appeals pertains to a single assessee herein Shri Santosh T. Murkute. All other relevant details thereof read as under: Sr. ITA No. A.Y. Order appealed against No. proceedings 1 133/PUN/2020 2013-14 (Qrt 3) CIT(A), Aurangabad‟s order dated

SHRI SANTOSH T MURKUTE,NANDED vs. ASSESSING OFFICER , ACIT (CPC) – TDS, GHAZIABAD

Appeals are allowed

Bench: Shri R.S. Syal & Shri S.S. Godara

02-06-2022 Date of pronouncement 06-06-2022 आदेश / ORDER PER S.S. GODARA, JM : The instant batch of six appeals pertains to a single assessee herein Shri Santosh T. Murkute. All other relevant details thereof read as under: Sr. ITA No. A.Y. Order appealed against No. proceedings 1 133/PUN/2020 2013-14 (Qrt 3) CIT(A), Aurangabad‟s order dated

NORTH AMERICAN COAL CORPORATION INDIA P LTD ,PUNE vs. ASST COMMISSIONER OF INCOME TAX , CIRCLE 2 , PUNE

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

TDS credit of Rs. 9,02,634/-. In this regard, the ld. CIT(A) has addressed the issue as follows: “8. GROUND NO. 3; In this regard the appellant has contended that the A.O erred in non-granting of INR 20,19,455/- calculated till July2019 on the above refund u/s 244A of the Income-tax Act, 1961. 8.1 DECISION

SHOBHA RAMKISAN DARGAD,SOLAPUR vs. INCOME TAX OFFICER, WARD-1(1), SOLAPUR, SOLAPUR

In the result, the appeal is partly allowed for statistical purposes

Bench: Shri R.S. Syal & Shri Partha Sarathi Chaudhuryassessment Year : 2003-04

02-02-2005 claiming benefit of TDS and also a rectification application. 4. Prior to substitution of sub-section (5) of section