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

10B(7) r.w.s. 80IA(8) and 80IA(10) of the Act arose before the Tribunal in Spicer India Ltd. Vs. CIT (supra) and the Tribunal vide order dated 08-07-2015 in similar circumstances had reversed the order of the Commissioner passed under section 263 of the Act. 24. Where the Assessing Officer in his order considered the claim

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

Appeals are partly allowed for statistical purpose in above terms

Bench: Shri S.S.Godara & Dr. Dipak P. Ripoteआयकरअपीलसं. / Ita Nos.42 & 43/Pun/2021 िनधा"रणवष" / Assessment Years : 2015-16 & 16-17 Dcit, Circle-1(1), Pune. M/S.Eaton Technologies Pvt. Ltd., Vs Cluster C Wing-1, Eon Zone, Midc Kharadi, Knowledge Park, Plot No.1, Survey No.77, Kharadi, Pune – 411014. Pan: Aabce 4323 Q Appellant/ Assessee Respondent /Revenue Assessee By Shri Vishal Kalra & Shri Ss Tomar -Ar Revenue By Shri Sunil Kumar – Cit(Dr) Date Of Hearing 24/06/2022 Date Of Pronouncement 07/07/2022 आदेश/ Order Per S.S.Godara, Jm: These Revenue’S Twin Appeals For The Assessment Years 2015- 16 & 2016-17 Arise Against The Cit(A)-13, Pune’S Separate Orders; Both Dated 29.05.2020, Passed In Case No.Pn/Cit(A)-13/Dcit, Circle-1(2), Pune/10142/2019-20/02, Pn/Cit(A)-13/Dcit, Circle- 1(2), Pune/10142/2019-20/03 Respectively, Involving Proceedings Under Section 143(3) Of The Income Tax Act, 1961. Heard Both The Parties. Case Files Perused.

10B(7) r.w.s. 80IA(8) and 80IA(10) of the Act arose before the Tribunal in Spicer India Ltd. Vs. CIT (supra) and the Tribunal vide order dated 08-07-2015 in similar circumstances had reversed the order of the Commissioner passed under section 263 of the Act. 24. Where the Assessing Officer in his order considered the claim

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

Appeals are partly allowed for statistical purpose in above terms

Bench: Shri S.S.Godara & Dr. Dipak P. Ripoteआयकरअपीलसं. / Ita Nos.42 & 43/Pun/2021 िनधा"रणवष" / Assessment Years : 2015-16 & 16-17 Dcit, Circle-1(1), Pune. M/S.Eaton Technologies Pvt. Ltd., Vs Cluster C Wing-1, Eon Zone, Midc Kharadi, Knowledge Park, Plot No.1, Survey No.77, Kharadi, Pune – 411014. Pan: Aabce 4323 Q Appellant/ Assessee Respondent /Revenue Assessee By Shri Vishal Kalra & Shri Ss Tomar -Ar Revenue By Shri Sunil Kumar – Cit(Dr) Date Of Hearing 24/06/2022 Date Of Pronouncement 07/07/2022 आदेश/ Order Per S.S.Godara, Jm: These Revenue’S Twin Appeals For The Assessment Years 2015- 16 & 2016-17 Arise Against The Cit(A)-13, Pune’S Separate Orders; Both Dated 29.05.2020, Passed In Case No.Pn/Cit(A)-13/Dcit, Circle-1(2), Pune/10142/2019-20/02, Pn/Cit(A)-13/Dcit, Circle- 1(2), Pune/10142/2019-20/03 Respectively, Involving Proceedings Under Section 143(3) Of The Income Tax Act, 1961. Heard Both The Parties. Case Files Perused.

10B(7) r.w.s. 80IA(8) and 80IA(10) of the Act arose before the Tribunal in Spicer India Ltd. Vs. CIT (supra) and the Tribunal vide order dated 08-07-2015 in similar circumstances had reversed the order of the Commissioner passed under section 263 of the Act. 24. Where the Assessing Officer in his order considered the claim

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

10B(7) r.w.s. 80IA(8) and 80IA(10) of the Act arose before the Tribunal in Spicer India Ltd. Vs. CIT (supra) and the Tribunal vide order dated 08-07-2015 in similar circumstances had reversed the order of the Commissioner passed under section 263 of the Act. 24. Where the Assessing Officer in his order considered the claim

M/S. HONEYWELL AUTOMATION INDIA LTD.,,PUNE vs. DEPUTY COMMISSIONER OF INCOME-TAX,,

In the result, appeal of the assessee in ITA No

Bench: Shri R.S.Syal, Vp & Shri Partha Sarathi Chaudhury, Jm

10B(7) so as to reduce the eligible profits on the basis of the arm's length price computed by the Transfer Pricing Officer without showing how he determined that the assessee had shown more than "ordinary profits". As rightly argued by learned senior counsel the arm's length price is determined on the basis of the most appropriate method

DEPUTY COMMISSIONER OF INCOME-TAX vs. M/S. HONEYWELL AUTOMATION INDIA LTD.,, PUNE

In the result, appeal of the assessee in ITA No

Bench: Shri R.S.Syal, Vp & Shri Partha Sarathi Chaudhury, Jm

10B(7) so as to reduce the eligible profits on the basis of the arm's length price computed by the Transfer Pricing Officer without showing how he determined that the assessee had shown more than "ordinary profits". As rightly argued by learned senior counsel the arm's length price is determined on the basis of the most appropriate method

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

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

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

PRABHAKAR MANJAJI THAKRE vs. PRINCIPOAL C.I.T.-1, NAGPUR

In the result, the appeal of the assessee is dismissed

Bench: Shri Inturi Rama Rao, Am & Shri Sonjoy Sarma, Jm Assessment Year : 2011-12

section 54EC of the Act and as such the order passed by the A.O is not erroneous and prejudicial to the interest of revenue. 11. The ld. A.R further submits that the ld. Pr. CIT was also not justified in his finding that the assessment was erroneous and prejudicial to the interest of revenue as no tax was deducted

M/S. KPIT TECHNOLOGIES LIMITED,,PUNE vs. DEPUTY COMMISSIONER OF INCOME -TAX,,

In the result, the appeal is partly allowed

Bench: Shri R.S. Syal & Shri Vikas Awasthy, Jm

10B also. 7. Coming back to the issue in question, whereby the AO computed the disallowance u/s. 14A r.w. Rule 8D(2)(iii) of the Act amounting to Rs.3,16,221/-, the Ld. AR submitted that about 95% of its income is eligible for deduction u/s.10A of the Act and the disallowance u/s 14A should also be accordingly reduced. Following

DCIT, SWARGATE PUNE vs. CUMMINS INDIA LTD , PUNE

In the result, appeal of the assessee bearing ITA No

10B, the provision mandating\nrequirement of filing the return within the due date u/s 139(1)\nwas not there in section 10AA in the current AY 2018-19.This\nhas become mandatory by way of insertion of a proviso after\nclause (ii) of sub-section (1) of section 10AA by the Finance\nAct, 2023, w.e.f

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:

10B, the details of TDS on payments to the specified persons referred to section 13(3) of the Act, etc. Thus

DISCOVERY DIGITAL NETWORK PRIVATE LIMITED,NASHIK vs. ASSISTANT COMMISSIONER OF INCOME TAX, CIRCLE 1 , NASHIK

10B, 10BA and any\ndeduction under heading \"C\" of Chapter VIA, (2) Section 80 for carry forward and\nset off of losses u/s 72 to 74A. Therefore, it is submitted that whenever the\nlegislature intended to enforce an embargo on the assessee to make claims in the\nreturn of income itself. it has brought into the legislation explicit provisions

M/S. AQUATECH SYSTEMS (ASIA) PRIAVATE LTD.,,PUNE vs. DEPUTY COMMISSIONER OF INCOME-TAX,,

In the result, the appeal of assessee is partly allowed

Bench: Ms. Sushma Chowla, Jm & Shri Anil Chaturvedi, Am आयकर अपीऱ सं. / Ita No.610/Pun/2016 यििाारण वषा / Assessment Year : 2011-12

10B(1)(e) of the Rules is the most appropriate method for computation of arm's length price of Professional Fees'. The Appellant prays that the said adjustment is erroneous, unwarranted and ought to be deleted. 5. On the facts and in the circumstances of the case, the Ld. AO erred in initiating penalty proceeding under section 274 read with