SHREE BHASKARACHARYA PRATISHTHAN,CHH SAMBHAJINAGAR vs. LD. DEPUTY COMMISSIONER OF INCOME TAX, GHAZIABAD

In the result, both the bunch of appeals filed by the respective assessee’s in ITA Nos

Bench: Dr.Manish Borad & Shri Vinay Bhamoreआयकर अपील सं. / Ita Nos.476 To 480/Pun/2024 Chate Tutorials Pvt. Ltd., Vs. Acit,Tds Circle, Chate House, Plot No.4, Nashik Near N-2 Cricket Stadium, Cidco, Aurangabad – 431 003 Maharashtra Tan : Nskco1565E Appellant Respondent

13. We have heard the rival contentions and perused the record placed before us. We have also gone through the written submissions and case laws relied upon by both the parties. The interesting issue raised before us revolves around the words “tax payable or refund due” appearing in sub-section (2) of section 200A of the Act, however

SHRI BHASKARACHARYA PRATISHTHAN,CHH. SAMBHAJINAGAR vs. LD. DEPUTY COMMISSIONER OF INCOME TAX, CPC-TDS

In the result, both the bunch of appeals filed by the respective assessee’s in ITA Nos

Bench: Dr.Manish Borad & Shri Vinay Bhamoreआयकर अपील सं. / Ita Nos.476 To 480/Pun/2024 Chate Tutorials Pvt. Ltd., Vs. Acit,Tds Circle, Chate House, Plot No.4, Nashik Near N-2 Cricket Stadium, Cidco, Aurangabad – 431 003 Maharashtra Tan : Nskco1565E Appellant Respondent

13. We have heard the rival contentions and perused the record placed before us. We have also gone through the written submissions and case laws relied upon by both the parties. The interesting issue raised before us revolves around the words “tax payable or refund due” appearing in sub-section (2) of section 200A of the Act, however

SHREE BHASKARACHARYA PRATISHTHAN,CHH SAMBHAJINAGAR vs. LD. DEPUTY COMMISSIONER OF INCOME TAX, GHAZIABAD

In the result, both the bunch of appeals filed by the respective assessee’s in ITA Nos

Bench: Dr.Manish Borad & Shri Vinay Bhamoreआयकर अपील सं. / Ita Nos.476 To 480/Pun/2024 Chate Tutorials Pvt. Ltd., Vs. Acit,Tds Circle, Chate House, Plot No.4, Nashik Near N-2 Cricket Stadium, Cidco, Aurangabad – 431 003 Maharashtra Tan : Nskco1565E Appellant Respondent

13. We have heard the rival contentions and perused the record placed before us. We have also gone through the written submissions and case laws relied upon by both the parties. The interesting issue raised before us revolves around the words “tax payable or refund due” appearing in sub-section (2) of section 200A of the Act, however

CHATE TUTORIALS PVT. LTD.,AURANGABAD vs. LD. ASSISTANT COMMISSIONER OF INCOME TAX, TDS CIRCLE, NASHIK, NASHIK

In the result, both the bunch of appeals filed by the respective assessee’s in ITA Nos

Bench: Dr.Manish Borad & Shri Vinay Bhamoreआयकर अपील सं. / Ita Nos.476 To 480/Pun/2024 Chate Tutorials Pvt. Ltd., Vs. Acit,Tds Circle, Chate House, Plot No.4, Nashik Near N-2 Cricket Stadium, Cidco, Aurangabad – 431 003 Maharashtra Tan : Nskco1565E Appellant Respondent

13. We have heard the rival contentions and perused the record placed before us. We have also gone through the written submissions and case laws relied upon by both the parties. The interesting issue raised before us revolves around the words “tax payable or refund due” appearing in sub-section (2) of section 200A of the Act, however

SHREE BHASKARACHARYA PRATISHTHAN,CHH SAMBHAJINAGAR vs. LD. DEPUTY COMMISSIONER OF INCOME TAX CPC TDS, GHAZIABAD

In the result, both the bunch of appeals filed by the respective assessee’s in ITA Nos

Bench: Dr.Manish Borad & Shri Vinay Bhamoreआयकर अपील सं. / Ita Nos.476 To 480/Pun/2024 Chate Tutorials Pvt. Ltd., Vs. Acit,Tds Circle, Chate House, Plot No.4, Nashik Near N-2 Cricket Stadium, Cidco, Aurangabad – 431 003 Maharashtra Tan : Nskco1565E Appellant Respondent

13. We have heard the rival contentions and perused the record placed before us. We have also gone through the written submissions and case laws relied upon by both the parties. The interesting issue raised before us revolves around the words “tax payable or refund due” appearing in sub-section (2) of section 200A of the Act, however

SHREE BHASKARACHARYA PRATISHTHAN,CHH SAMBHAJINAGAR vs. LD. DEPUTY COMMISSIONER OF INCOME TAX, CPC-TDS

In the result, both the bunch of appeals filed by the respective assessee’s in ITA Nos

Bench: Dr.Manish Borad & Shri Vinay Bhamoreआयकर अपील सं. / Ita Nos.476 To 480/Pun/2024 Chate Tutorials Pvt. Ltd., Vs. Acit,Tds Circle, Chate House, Plot No.4, Nashik Near N-2 Cricket Stadium, Cidco, Aurangabad – 431 003 Maharashtra Tan : Nskco1565E Appellant Respondent

13. We have heard the rival contentions and perused the record placed before us. We have also gone through the written submissions and case laws relied upon by both the parties. The interesting issue raised before us revolves around the words “tax payable or refund due” appearing in sub-section (2) of section 200A of the Act, however

SHRI BHASKARACHARYA PRATISHTHAN,CHH. SAMBHAJINAGAR vs. LD. DEPUTY COMMISSIONER OF INCOME TAX, CPC-TDS

In the result, both the bunch of appeals filed by the\nrespective assessee's in ITA Nos

13]\nThe Legislature took note of the fact that a substantial number of\ndeductors were not furnishing their TDS return/statements within the\nprescribed time frame which was absolutely essential. This led to an\nadditional work burden upon the department due to the fault of the\ndeductor by not furnishing the information in time and which he was\nstatutorily bound

SHREE BHASKARACHARYA PRATISHTHAN,CHH SAMBHAJINAGAR vs. LD. DEPUTY COMMISSIONER OF INCOME TAX, CPC-TDS

In the result, both the bunch of appeals filed by the\nrespective assessee's in ITA Nos

13]\nThe Legislature took note of the fact that a substantial number of\ndeductors were not furnishing their TDS_return/statements within the\nprescribed time frame which was absolutely essential. This led to an\nadditional work burden upon the department due to the fault of the\ndeductor by not furnishing the information in time and which he was\nstatutorily bound

CHATE TUTORIALS PVT. LTD. AURANGABAD , AURANGABAD vs. LD. ASSISTANT COMMISSIONER OF INCOME TAX, TDS CIRCLE, NASHIK , NASHIK

In the result, both the bunch of appeals filed by the\nrespective assessee's in ITA Nos

13]\nThe Legislature took note of the fact that a substantial number of\ndeductors were not furnishing their TDS_return/statements within the\nprescribed time frame which was absolutely essential. This led to an\nadditional work burden upon the department due to the fault of the\ndeductor by not furnishing the information in time and which he was\nstatutorily bound

CHATE TUTORIALS PVT. LTD. ,AURANGABAD vs. LD. ASSISTANT COMMISSIONER OF INCOME TAX, TDS CIRCLE, NASHIK , NASHIK

In the result, both the bunch of appeals filed by the\nrespective assessee's in ITA Nos

13]\nThe Legislature took note of the fact that a substantial number of\ndeductors were not furnishing their TDS_return/statements within the\nprescribed time frame which was absolutely essential. This led to an\nadditional work burden upon the department due to the fault of the\ndeductor by not furnishing the information in time and which he was\nstatutorily bound

SHREE BHASKARACHARYA PRATISHTHAN,CHH SAMBHAJINAGAR vs. LD. DEPUTY COMMISSIONER OF INCOME TAX, GHAZIABAD

In the result, both the bunch of appeals filed by the\nrespective assessee's in ITA Nos

13]\nThe Legislature took note of the fact that a substantial number of\ndeductors were not furnishing their TDS_return/statements within the\nprescribed time frame which was absolutely essential. This led to an\nadditional work burden upon the department due to the fault of the\ndeductor by not furnishing the information in time and which he was\nstatutorily bound

SHREE BHASKARACHARYA PRATISHTHAN,CHH SAMBHAJINAGAR vs. LD. DEPUTY COMMISSIONER OF INCOME TAX, CPC-TDS

In the result, both the bunch of appeals filed by the\nrespective assessee's in ITA Nos

13]\nThe Legislature took note of the fact that a substantial number of\ndeductors were not furnishing their TDS return/statements within the\nprescribed time frame which was absolutely essential. This led to an\nadditional work burden upon the department due to the fault of the\ndeductor by not furnishing the information in time and which he was\nstatutorily bound

SHREE BHASKARACHARYA PRATISHTHAN,CHH SAMBHAJINAGAR vs. LD. DEPUTY COMMISSIONER OF INCOME TAX, GHAZIABAD

In the result, both the bunch of appeals filed by the\nrespective assessee's in ITA Nos

13]\nThe Legislature took note of the fact that a substantial number of\ndeductors were not furnishing their TDS_return/statements within the\nprescribed time frame which was absolutely essential. This led to an\nadditional work burden upon the department due to the fault of the\ndeductor by not furnishing the information in time and which he was\nstatutorily bound

SHRI BHASKARACHARYA PRATISHTHAN,CHH SAMBHAJINAGAR vs. LD. DEPUTY COMMISSIONER OF INCOME TAX, CPC-TDS, CPC TDS

In the result, both the bunch of appeals filed by the\nrespective assessee's in ITA Nos

13]\nThe Legislature took note of the fact that a substantial number of\ndeductors were not furnishing their TDS_return/statements within the\nprescribed time frame which was absolutely essential. This led to an\nadditional work burden upon the department due to the fault of the\ndeductor by not furnishing the information in time and which he was\nstatutorily bound

CHATE TUTORIALS PVT. LTD. ,AURANGABAD vs. LD. ASSISTANT COMMISSIONER OF INCOME TAX, TDS CIRCLE, NASHIK , NASHIK

In the result, both the bunch of appeals filed by the\nrespective assessee's in ITA Nos

13]\nThe Legislature took note of the fact that a substantial number of\ndeductors were not furnishing their TDS return/statements within the\nprescribed time frame which was absolutely essential. This led to an\nadditional work burden upon the department due to the fault of the\ndeductor by not furnishing the information in time and which he was\nstatutorily bound

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

13 substantive ground are accepted for statistical purposes therefore.” 5. There is hardly any dispute that the CIT(A) has followed various judicial precedents in assessee’s case(s) itself whilst deciding all these three issues of section 80IA(10) deduction section 40(a)(i), TDS deduction disallowance(s) on account of payment of alleged royalty and section 14A read

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

13 substantive ground are accepted for statistical purposes therefore.” 5. There is hardly any dispute that the CIT(A) has followed various judicial precedents in assessee’s case(s) itself whilst deciding all these three issues of section 80IA(10) deduction section 40(a)(i), TDS deduction disallowance(s) on account of payment of alleged royalty and section 14A read

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:

section 13(3) of the Act. 42. We find the assessee vide reply dated 08.12.2021 addressed to the Addl./ Joint/Deputy/ACIT, National e-Asst. Centre, Delhi at para 8 of the submission has given the details of payments made to the specified persons which are as under: 25 26 27 28 29 30 31 32 43. Similarly, we find the assessee