JAWAHAR LAL NEHRU PORT TRUST,NAVI MUMBAI vs. ACIT PANVEL, PANVEL

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

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

TDS credit. The assessee also took an additional ground before the CIT(A)-I, Thane for allowance of exemption u/s 11. The CIT(A)-I, Thane rejected the additional ground taken by the assessee and exemption u/s 11 had not been allowed to the assessee. Against ITA Nos.1153, 1155 & 1154/MUM/2016 the order of the CIT(A), Thane, the assessee preferred

JAWAHAR LAL NEHRU PORT TRUST,NAVI MUMBAI vs. ACIT PANVEL, PANVEL

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

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

TDS credit. The assessee also took an additional ground before the CIT(A)-I, Thane for allowance of exemption u/s 11. The CIT(A)-I, Thane rejected the additional ground taken by the assessee and exemption u/s 11 had not been allowed to the assessee. Against ITA Nos.1153, 1155 & 1154/MUM/2016 the order of the CIT(A), Thane, the assessee preferred

DEPUTY COMMISSIONER OF INCOME-TAX vs. THE JAWAHARLAL NEHRU PORT TRUST,, RAIGAD

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

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

TDS credit. The assessee also took an additional ground before the CIT(A)-I, Thane for allowance of exemption u/s 11. The CIT(A)-I, Thane rejected the additional ground taken by the assessee and exemption u/s 11 had not been allowed to the assessee. Against ITA Nos.1153, 1155 & 1154/MUM/2016 the order of the CIT(A), Thane, the assessee preferred

DEPUTY COMMISSIONER OF INCOME-TAX vs. THE JAWAHARLAL NEHRU PORT TRUST,, RAIGAD

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

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

TDS credit. The assessee also took an additional ground before the CIT(A)-I, Thane for allowance of exemption u/s 11. The CIT(A)-I, Thane rejected the additional ground taken by the assessee and exemption u/s 11 had not been allowed to the assessee. Against ITA Nos.1153, 1155 & 1154/MUM/2016 the order of the CIT(A), Thane, the assessee preferred

DEPUTY COMMISSIONER OF INCOME-TAX vs. THE JAWAHARLAL NEHRU PORT TRUST,, RAIGAD

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

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

TDS credit. The assessee also took an additional ground before the CIT(A)-I, Thane for allowance of exemption u/s 11. The CIT(A)-I, Thane rejected the additional ground taken by the assessee and exemption u/s 11 had not been allowed to the assessee. Against ITA Nos.1153, 1155 & 1154/MUM/2016 the order of the CIT(A), Thane, the assessee preferred

DY. COMMISSIONER OF INCOME TAX, PUNE vs. DILIP MOTILALJI CHORDIA, PUNE

In the result, the appeal filed by the Revenue as well as\nthe Cross Objection filed by the assessee are allowed for\nstatistical purposes

TDS) v. Tushira Industries [2025] 168\ntaxmann.com 169 (Karnataka), wherein it was held that the income-\ntax exemption provided under Section 96 of the RFCTLARR Act is\nrestricted only to the compensation or awards made under the\nprovisions of the said Act itself. The Hon'ble Court observed that the\nwording of Section 96 \"made under this Act\" is explicit

EATON TECHNOLOGIES PRIVATE LIMITED,PUNE vs. PRINCIPAL COMMISSIONER OF INCOME TAX, PUNE

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

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

TDS statement filing 7. Deduction/Exemption u/s 10A/10AA 8. Income from house property 9. Reduction in profit due to ICDS 10. International transaction(s) 11. Loss from currency fluctuations 03. The assessment was completed u/s 143(3) r.w.s. 144C(13) r.w.s 144B of the Income Tax Act, 1961 on 26/02/2022 determining total income of Rs.455,25,53,250/- (Rs.722

DEPUTY COMMISSIONER OF INCOME-TAX CIRCLE -5, PUNE vs. SERUM INSTITUTE OF INDIA PVT LTD.,, PUNE

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

46,83,703/- made u/s 14A of the Act. (ii) As regards to the foreign travel expenditure, the ld. CIT(A) considering the fact that in the earlier assessment years i.e. A.Ys. 2011-12 and 2012-13 pursuant to the remand order passed by this Tribunal, the Assessing Officer for the assessment year 2011-12 had allowed this expenditure after

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 has been deducted under the PAN of the assessee Shri Chandrakant Vithal Bhopi under section 184A which represents interest other than Interest on securities. The assessee failed to submit any documentary evidence and confirmation from the other members/co-owners about receipt of payment to the extent of their share of compensation/enhanced compensation or the receipt of Interest payment. During

ASSISTANT COMMISSIONER OF INCOME-TAX, CIRCLE -11,, PUNE vs. CAPGEMINI TECHNOLOGY SERVICES INDIA LIMITED , (FORMERLY IGATE GLOBAL SOLUTIONS LTD.),, PUNE

In the result, both the appeals are partly allowed

Bench: Shri R.S. Syal & Shri Partha Sarathi Chaudhury

TDS credit and hence the carry forward of MAT credit of erstwhile company has to be allowed to the amalgamated company. 13. The upshot of the above discussion is that section 72A, like some other provisions distinctly dealing with the effects of amalgamation, exclusively applies to accumulated losses and unabsorbed depreciation of the amalgamating company in relation to the income

CAPGEMINI TECHNOLOGY SERVICES INDIA LTD,,PUNE vs. DEPUTY COMMISSIONER OF INCOME-TAX, CIRCLE - 11,, PUNE

In the result, both the appeals are partly allowed

Bench: Shri R.S. Syal & Shri Partha Sarathi Chaudhury

TDS credit and hence the carry forward of MAT credit of erstwhile company has to be allowed to the amalgamated company. 13. The upshot of the above discussion is that section 72A, like some other provisions distinctly dealing with the effects of amalgamation, exclusively applies to accumulated losses and unabsorbed depreciation of the amalgamating company in relation to the income

M/S PERSISTENT SYSTEMS LIMITED,PUNE vs. ASSESSMENT UNIT, INCOME-TAX DEPARTMENT, PUNE

In the result, appeal of the Assessee is Partly Allowed

Bench: Shri S.S.Godara & Dr. Dipak P. Ripoteआयकरअपीलसं. / Ita No.692/Pun/2022 िनधा"रणवष" / Assessment Year : 2018-19 M/S.Persistent Systems Assessment Unit, Income Limited, V Tax Department. “Bhageerath” 402, Senapati S Bapat Road, Pune – 411016. Pan: Aabcp 1209 Q Appellant/ Assessee Respondent /Revenue Assessee By Shri Dhanesh Bafna& Shriaditya Vaidya– Ar’S Revenue By Shri Suhas Kulkarni - Irs Addl Commissioner Of Income Tax Date Of Hearing 26/09/2023 Date Of Pronouncement 02/11/2023 आदेश/ Order Per Dr. Dipak P. Ripote, Am: This Appeal Filed By The Assessee Is Directed Against The Assessment Order, Dated 20.07.2022 Under Section 143(3) R.W.S. 144C(13) Read With Section 144B Of The Income Tax Act, 1961 For A.Y.2018-19. The Assessee Has Raised The Following Grounds Of Appeal: “Ground 1: Order Is Invalid / Non Est  On The Facts & In The Circumstances Of The Case & In Law, The Assessment Unit (‘Au’) Has Erred In Passing The Draft Assessment M/S.Persistent Systems Limited [A]

10(34) of the Act. The assessee has furnished computation of disallowance as per Rule 8D vide letter dated 23/11/2020, Annexure-13b. The assessee has submitted no disallowance u/s 14A of the Act be made directly applying Rule 8D due to there is no specific direct expenditure was incurred expect some administrative expenses. However, assessee has submitted computation of disallowance

BANSILAL RAMNATH AGARWAL CHARITABLE TRUST,PUNE vs. CIT (EXEMPTION), PUNE

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

Bench: Shri R. K. Panda & Ms. Astha Chandraassessment Year : 2020-21 Bansilal Ramnath Agarwal Charitable Trust Cit (Exemption), 251, Budhwar Peth, City Post Chowk, Vs. Pune Pune – 411002 Pan: Aaatb4383K (Appellant) (Respondent) Assessee By : Shri Kishor B Phadke Department By : Shri Amol Khairnar, Cit-Dr Date Of Hearing : 11-12-2025 Date Of Pronouncement : 28-01-2026 O R D E R Per R.K. Panda, V.P:

10. In view of the above, the Ld. CIT(Exemption) held that the Assessing Officer has failed to conduct proper inquiry and verification regarding the substantial payments made by the assessee trust to specified persons as per section 13(3) of the Act. The failure to conduct such an inquiry has resulted in an erroneous assessment order. Relying on various

WATERSHED ORGANISATION TRUST,AHMEDNAGAR vs. ACIT EXEMPTION CIRCLE, AURANGABAD

In the result, the appeal of the assessee is allowed for statistical\npurposes

TDS\nwhich clearly indicated that the assessee was involved in business\nactivity and that the assessee had not maintained separate books of\naccounts for business income, thereby violating section 11(4A) of the\nAct.\niii.\nadding to declared income Rs.8.53,50,000/- claimed by the assessee\nas deduction u/s 11(2) on account of accumulation of income out of\nthe

INCOME-TAX OFFICER, WARD - 6(3),, PUNE vs. SUBHASH & B.T. PATIL & SONS & N.V.KHAROTE CONSTRUCTIONS PVT.LTD,, PUNE

In the result, the appeal of the Revenue is dismissed

46,806/- and (ii) disallowance of payments made in violation of provisions of section 40(a)(ia) of the Income-tax Act, 1961 (hereinafter referred to as “the Act” for short). 3. The A.O during the assessment proceedings found that the assessee is a joint venture and was formed solely for the purpose of acquiring project works of construction

SONAL SANDEEP SATAV,PUNE vs. PCIT, PUNE-2, PUNE

In the result, the appeal of the assessee is dismissed

Bench: Ms. Astha Chandra & Shree G.D. Padmahshali

TDS on the commission paint was negligible. Paragraph 5 deals with the expenditure incurred fowants research and development Paragraph 6 deals with the issue of depreciation on UPS. Finally, paragraph 7 deals with computation on the basis of the opinion in paragraphs 4.5 and 6. Thus, on the issue of deduction under section 100 of the IT Act, there

VILAS KISAN PATIL,URAN vs. ASSESSING OFFICER, ASSESSMENT UNIT, ITD, PANVEL

In the result, appeal of the assessee is allowed

Bench: Dr.Dipak P. Ripote & Shri Vinay Bhamoreआयकर अपील सं. / Ita No.2178/Pun/2024 िनधा"रण वष" / Assessment Year : 2017-18 Vilas Kisan Patin, V The Assessing Officer, House No.82, Panje, S Assessment Unit, Itd, Uran,Tal.Panvel, Panvel. Dist-Raigad, Maharashtra – 400702. Pan: Ayipp1671N Appellant/ Assessee Respondent /Revenue Assessee By Shri Subodh Ratnaparkhi – Ar Revenue By Shri Arvind Desai – Addl.Cit(Dr) Date Of Hearing 24/12/2024 Date Of Pronouncement 24/12/2024 आदेश/ Order Per Dr. Dipak P. Ripote, Am: This Appeal Filed By The Assessee Directed Against The Order Of Ld.Commissioner Of Income Tax(Appeals)[Nfac] U/Sec.250 Of The Income Tax Act, 1961; Dated 29.08.2024 For The A.Y.2017-18. The Assessee Has Raised The Following Grounds Of Appeal : “1. The Hon. Cit(A) Erred In Upholding Addition Of Rs.1,92,72,028/- Made By Ld. Ao By Relying Upon The Provisions Of Section 56(2)(Viii) R.W.S 57(Iv) R.W.S. 145A(B) Of The I.T.Act, 1961, Not Appreciating That The Said Amount Was Interest Granted U/S 28 Of The Land Acquisition Act, 1894 & Thus Bore The Character Of Enhanced Compensation On Acquisition Of Agricultural Land Situated At Village Panje, Tal.Uran, Dist. Raigd, Maharashtra & Was Therefore Exempt From Tax & The Addition Is Required To Be Deleted. 2. The Appellant Craves Leave To Add, Later, Amend And/Or Vary The Grounds Of The Appeal At Any Time Before The Decision Of The Appeal.” Submission Of Ld.Ar : 2. Ld.Ar For The Assessee Filed A Paper Book Containing 54 Pages. Ld.Ar Filed A Written Submission. Ld.Ar Submitted That Assessee Had Received Rs.3,85,44,057/- As Interest Under Section 28 Of The Land Acquisition Act. Ld.Ar Submitted That Said Interest Is Not Taxable As Held By The Hon’Ble Bombay High Court. Ld.Ar Filed Copy Of The Judgment. Ld.Ar Also Relied On The Following

TDS @ 10% is deducted. 4.1 Assessee claimed that amount as exempt income, however Assessing Officer taxed it as under : “The reply submission of the assessee was considered and thoroughly perused. Considering the above mentioned amendment provision introduced w.e.f. 01/04/2010, the claimed of exemption of interest on enhanced compensation of Rs.3,85,44,057/- in the ITR filed by the assessee

VINAYAK HANUMANTRAO GHORPADE,PUNE vs. INCOME TAX OFFICER, PUNE

In the result, appeal in ITA No

Bench: Dr.Dipak P. Ripote & Shri Vinay Bhamoreआयकर अपऩल सं. / Ita Nos.1438 & 1439/Pun/2024 निर्धारण वषा / Assessment Years: 2019-20 & 2020-21 Vinayak Hanumantrao V Vaishnavi Satish Bankar, Ghorpade, S. Pune. F.No.7, Plot No.60/61, S.No.165/1B, Shivanjali, Near Central Circle-1(3), Pune. Mahadev Temple, Indira Nagar, Pune – 411033. Pan: Afdpg6919A Appellant/ Assessee Respondent / Revenue Assessee By Shri Pramod S Shingte Revenue By Shri Aviyogi Ambadkar –Addl.Cit Date Of Hearing 11/09/2025 Date Of Pronouncement 08/12/2025 आदेश/ Order Per Dr. Dipak P. Ripote, Am: These Two Appeals Filed By The Assessee Are Against The Common Order Of Ld.Commissioner Of Income Tax(Appeal), Pune-11 Passed Under Section 250 Of The Income Tax Act, 1961 For A.Y.2019-20 & 2020-21, Both Dated 02.05.2024 Emanating From Separate Assessment Order U/S.153A R.W.S 144 Of The I.T.Act, Both Dated 23.09.2021.For The Sake Of Convenience, These Two Appeals

10 ITA Nos.1438 & 1439/PUN/2024 [A] 12. We have perused the copy of the invoices which are at page no.190 to 194 of the paper book. It is observed that these invoices are simple print outs, claimed to have been issued by SHAILJA ROOPCHAND, HR CONSULTANT which is scanned as under : ITA Nos.1438 & 1439/PUN/2024 [A] 13. In the paper book, Assessee

VINAYAK HANUMANTRAO GHORPADE,PUNE vs. VAISHNAVI SATISH BANKAR, PUNE

In the result, appeal in ITA No

Bench: Dr.Dipak P. Ripote & Shri Vinay Bhamoreआयकर अपऩल सं. / Ita Nos.1438 & 1439/Pun/2024 निर्धारण वषा / Assessment Years: 2019-20 & 2020-21 Vinayak Hanumantrao V Vaishnavi Satish Bankar, Ghorpade, S. Pune. F.No.7, Plot No.60/61, S.No.165/1B, Shivanjali, Near Central Circle-1(3), Pune. Mahadev Temple, Indira Nagar, Pune – 411033. Pan: Afdpg6919A Appellant/ Assessee Respondent / Revenue Assessee By Shri Pramod S Shingte Revenue By Shri Aviyogi Ambadkar –Addl.Cit Date Of Hearing 11/09/2025 Date Of Pronouncement 08/12/2025 आदेश/ Order Per Dr. Dipak P. Ripote, Am: These Two Appeals Filed By The Assessee Are Against The Common Order Of Ld.Commissioner Of Income Tax(Appeal), Pune-11 Passed Under Section 250 Of The Income Tax Act, 1961 For A.Y.2019-20 & 2020-21, Both Dated 02.05.2024 Emanating From Separate Assessment Order U/S.153A R.W.S 144 Of The I.T.Act, Both Dated 23.09.2021.For The Sake Of Convenience, These Two Appeals

10 ITA Nos.1438 & 1439/PUN/2024 [A] 12. We have perused the copy of the invoices which are at page no.190 to 194 of the paper book. It is observed that these invoices are simple print outs, claimed to have been issued by SHAILJA ROOPCHAND, HR CONSULTANT which is scanned as under : ITA Nos.1438 & 1439/PUN/2024 [A] 13. In the paper book, Assessee