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

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]

144B of the Income Tax Act, 1961 (‘the Act’) with regard to granting an opportunity for personal hearing via video conference and without providing an opportunity to the Appellant to file a written submission in response to the Show-cause notice. Dispute Resolution Panel (‘Ld. DRP’) erred in upholding the same by contending that there was no denial of opportunity

VAISHALI KESHAV KULKARNI,PUNE vs. ITO WARD 13(2), PUNE

In the result the Grounds Numbers 2, 3 and 4 raised by the assessee are allowed

section 144B of the Act, the appellant presents this appeal before Your Honor.\"\n5.1 Inspite of providing documentary evidence that assessee is not the owner of the impugned property, her father is owner and her father has paid entire tax, copy of the return of income filed by her father u/s.139(1), theld.CIT(A) has confirmed the addition.\n5.2 Assessing

M/S. VISHAY COMPONENTS INDIA PRIVATE LIMITED,,PUNE vs. ASSISTANT COMMISSIONER OF INCOME-TAX, CIRCLE - 12, PUNE

The appeal of the assessee is partly allowed for statistical purposes

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

section 144B of the Income-tax Act, 1961 ('the Act') in pursuance of the directions dated 25 January 2022(received on 25 January 2022) issued by the Honorable Dispute Resolution Panel-3, Mumbai (hereinafter referred to as 'Hon'ble DRP') on the following grounds which are independent and without prejudice to each other: On the facts and in the circumstances

AUTOCOMP CORPORATION PANSE PRIVATE LIMITED ,PUNE vs. ASST. COMMISSIONER OF INCOME TAX, CIRCLE 1(1), PUNE

In the result, both the appeals filed by the assessee are allowed for statistical purposes

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

144B. It is prayed that the order passed by the CIT(A) be set aside and the appeal be restored with direction for fresh disposal by CIT(A) on merits of the case. Grounds on merits of the issues Against reopening of original assessment made u/s 143 (3) 3. The learned CITA failed to consider the submissions made against

AUTOCOMP CORPORATION PANSE PRIVATE LIMITED ,PUNE vs. ASST. COMMISSIONER OF INCOME TAX, PUNE

In the result, both the appeals filed by the assessee are allowed for statistical purposes

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

144B. It is prayed that the order passed by the CIT(A) be set aside and the appeal be restored with direction for fresh disposal by CIT(A) on merits of the case. Grounds on merits of the issues Against reopening of original assessment made u/s 143 (3) 3. The learned CITA failed to consider the submissions made against

BANK OF MAHARASHRA,PUNE vs. THE PR. COMMISSIONER OF INCOME TAX, PUNE, PUNE

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

Bench: Shri R. K. Panda & Ms Astha Chandraassessment Year : 2018-19

TDS & Disallowance for such Default vii. Refund Claim viii. Business Loss ix. ICDS Compliance and Adjustment x. Disallowance u/s 40A(7) (Gratuity provision) xi. Expenses incurred for Earning Exempt Income xii. Excess Contribution to Provident Fund, Superannuation Fund or Gratuity Fund xiii. Capital Gains/Income on Sale of Property xiv. Business Expenses 3. The Assessing Officer completed the assessment

PROCESSIA PLM PRIVATE LIMITED,PUNE vs. NATIONAL FACELESS ASSESSMENT CENTER, DELHI

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

Bench: Shri Manish Borad & Shri Vinay Bhamoreआयकर अपील सं. / Ita No.2007/Pun/2025 िनधा"रण वष" / Assessment Year : 2018-19 Processia Plm Private Vs. Income Tax Department, Limited, National E-Assessment First Floor, Office No.102, Centre, Delhi. Amar Apex Building, Amar Apex Condominium, Baner, Pune-411045. Pan : Aaact6811H Appellant Respondent Assessee By : Ms. Nidhi Agarwal (Virtual) Revenue By : Shri Harshit Bari Date Of Hearing : 17.12.2025 Date Of Pronouncement : 05.01.2026 आदेश / Order Per Vinay Bhamore, Jm: This Appeal Filed By The Assessee Is Directed Against The Order Dated 12.06.2025 Passed By Ld. Cit(A)/Nfac For The Assessment Year 2018-19. 2. The Appellant Has Raised The Following Grounds Of Appeal :- “Ground No. 1: On The Facts & In The Circumstances Of The Case & In Law, The Order Under Section 250 Of The Income-Tax Act,1961 ('The Act') Passed By The Learned Commissioner Of Income Tax (Appeals) ['Ld. Cit(A)'] On 12 June 2025 Is Bad In Law.

section 244A of the Act without considering the credit of taxes deducted at source amounting to INR 15,18,619. Ground No 4: The Appellant craves leave to add to and/or to alter, amend, rescind, modify the grounds herein below or produce further documents before or at the time of hearing of this Appeal.” 3. Facts of the case

RUPAL CHEMICALS,RATNAGIRI vs. ITO WARD 1, RATNAGIRI

In the result Appeal of the assessee is allowed for statistical purposes

Bench: Dr. Manish Borad & Shri Vinay Bhamoreआयकर अपीऱ सं./Ita No.2588/Pun/2025 नििाारण वर्ा / Assessment Year: 2021-2022 Vs Ito, Ward 1, Rupal Chemicals, D/13, Midc, Lote Ratnagiri Parashuram, Taluka Khed, District Ratnagiri-415722 Maharashtra Pan-Aabfr7940R Appellant Respondent

section 144B of the IT Act and determined total income at Rs 2,15,56,510/- as against the income of ₹ 1,65,94,510/- returned by the assessee. The above assessed income includes addition of ₹ 49,62,000/- on account of disallowance of commission expenses of ₹ 49,62,000/-. 4 4. Being aggrieved with the above assessment order

MAHARASHTRA GRAMIN BANK,AURANGABAD vs. COMMISSIONER OF INCOME TAX (APPEALS), DELHI

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

Bench: Shri R. K. Panda & Shri Vinay Bhamoreआयकर अपील सं. / Ita No.1485/Pun/2024 िनधा"रण वष" / Assessment Year : 2020-21 Maharashtra Gramin Bank, Vs. Cit(A), Delhi. Plot No.42, Gut No.33 (Part) Village- Golwadi, Growth Centre, Waluj Mahanagar Iv, Cidco, Aurangabad- 431010. Pan : Aacam8494M Appellant Respondent Assessee By : Shri Ramesh Magar Revenue By : Shri Uma Shankar Prasad Date Of Hearing : 21.11.2024 Date Of Pronouncement : 20.12.2024 आदेश / Order Per Vinay Bhamore, Jm: This Appeal Filed By The Assessee Is Directed Against The Order Dated 14.05.2024 Passed By Ld. Cit(A)/Nfac For The Assessment Year 2020-21. 2. The Appellant Has Raised The Following Grounds Of Appeal :- “1 Erroneous Addition Of Rs. 87,73,904/- I. The Ld. Assessing Officer & The Commissioner (Appeals) Erred In Making & Upholding The Addition Of Rs. 87,73,904/- Without Considering The Appellant'S Explanation That This Amount Is Already Included Under The Head Income From Business Or Profession. The Addition Is Based Solely On The Tds Schedule Without Verifying The Classification Of Income In The Itr, Which Was Incorrectly Classified Due To A Software Error. In The Complex Labyrinth Of Income Tax Law, The Principle Of Finality Serves As A Cornerstone

section 144B of the Income Tax Act, 1961. 5 5. The appellant reserves the right to add. amend or alter any of the grounds of appeal before or at the time of hearing. 6. 6. In the light of the facts and circumstances mentioned above, the appellant respectfully requests the Honorable Income Tax appellate Tribunal (ITAT) Pune to – Set aside

KALPANA VIJAY KADAM,PUNE vs. ITO, WARD 2(2), PUNE, PUNE

In the result, appeal of the assessee is Partly Allowed

Bench: Dr.Dipak P. Ripote & Shri Vinay Bhamoreआयकर अपील सं. / Ita No.841/Pun/2025 िनधा"रण वष" / Assessment Year: 2016-17 Kalpana Vijay Kadam, V The Income Tax Officer, Fi 13, Janki Heights, S.No.250, S. Ward-2(2), Pune. Baner D P Road, Aundh, Pune – 411007. Maharashtra. Pan: Axzpk4350P Appellant/ Assessee Respondent / Revenue Assessee By Shri Suhas P. Bora – Ar Revenue By Shri Manish Mehta – Addl.Cit(Dr) Date Of Hearing 15/05/2025 Date Of Pronouncement 23/05/2025 आदेश/ Order Per Dr. Dipak P. Ripote, Am: This Appeal Filed By The Assessee Is Directed Against The Order Of Ld.Commissioner Of Income Tax(Appeals)[Nfac], Under Section 250 Of The Income Tax Act, 1961 (Hereinafter Referred To As ‘The Act’), Dated 06.02.2025 For The A.Y.2016-17. The Assessee Has Raised The Following Grounds Of Appeal : “1. On The Facts & In Law, The Learned Commissioner Of Income Tax (Appeals) [Cit(A)] Erred In Passing An Ex-Parte Order Without Affording A Reasonable Opportunity To The Appellant. The Order Was Solely Based On The Observations Of The Assessing Officer (Ao) In The

144B of the Income-tax Act, 1961 ("the Act"), is bad in law and void ab initio for the following reasons: i. The alleged escaped income is less than Rs. 50 lakhs, rendering the reassessment proceedings invalid. ii. The reopening was based on mere presumption and surmises, as it was initiated on borrowed satisfaction without independent application of mind

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

144B of the Act and determined the income of the assessee at Rs.1,30,02,544/- by observing as under: ―3.7 Conclusion drawn: Firstly, it is concluded that the payment of Rs 2,60,05,088/- is interest on enhanced compensation on compulsory land acquisition. Assessee was asked to submit details of co-owners, but assessee failed to submit information

VINEET TIWARI,BENGALURU vs. CIRCLE 12, PUNE, PUNE

In the result, both the appeals filed by the assessee are allowed for statistical purposes

Bench: Shri R. K. Panda & Shri Vinay Bhamore

TDS Form 63,57,095/- 24Q, Section 192) AIR-002 Credit Card bills Paid Rs.2,00,000 or more 8,51,621/- against Credit Card bills Total 72,44,455/- 3. The Assessing Officer, therefore, after recording reasons reopened the assessment and accordingly a notice u/s 148 of the Act was issued on 31.03.2021. Thereafter, following the decision

VINEET TIWARI,BANGALORE vs. CIRCLE 12, PUNE, PUNE

In the result, both the appeals filed by the assessee are allowed for statistical purposes

Bench: Shri R. K. Panda & Shri Vinay Bhamore

TDS Form 63,57,095/- 24Q, Section 192) AIR-002 Credit Card bills Paid Rs.2,00,000 or more 8,51,621/- against Credit Card bills Total 72,44,455/- 3. The Assessing Officer, therefore, after recording reasons reopened the assessment and accordingly a notice u/s 148 of the Act was issued on 31.03.2021. Thereafter, following the decision

OMKAR RAMCHANDRA VELHAL,KOLHAPUR vs. INCOME TAX OFFICER, WARD 1(1), KOLHAPUR, KOLHAPUR

In the result, appeal of the assessee is Partly Allowed

144B of\nthe Income Tax Act, 1961, dated 31.01.2023. The Assessee has\nraised following grounds of appeal :\nITA No.672/PUN/2025 [A]\n\"1. Reopening of the Assessment under Section 147 On the facts and in\nthe circumstances of the case and in law, the Assessing Officer has\nerred in initiating sec. 148A/148 proceedings vide corresponding notice\ndated 22.03.2023; it emerges

DREAMS BELLE VUE,PUNE vs. ITO WARD-2(3), PUNE, PUNE

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

TDS amounting to Rs.3,42,744\nought to be granted either to the Appellant AOP or, in the alternative,\nto the respective members who have duly offered the corresponding\nincome in their individual returns of income.\n4.\nThe Appellant craves to add/modify/amend/delete_all / any of\ngrounds of appeal.\"\n4.\nBriefly stated the facts are that the assessee is an Association

DREAMS BELLE VUE,PUNE vs. ITO WARD 2 (1), PUNE

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

TDS amounting to Rs.3,42,744\nought to be granted either to the Appellant AOP or, in the alternative,\nto the respective members who have duly offered the corresponding\nincome in their individual returns of income.\n4.\nThe Appellant craves to add/modify/amend/delete all / any of\ngrounds of appeal.\"\n4.\nBriefly stated the facts are that the assessee is an Association

CUMMINS INDIA LIMITED,,PUNE vs. DEPUTY COMMISSIONER OF INCOME-TAX, CIRCLE - 1(1),, PUNE

In the result, the appeal is allowed for statistical purposes

Bench: Shri R.S. Syal & Shri S.S.Viswanethra Raviआयकर अपील सं. / Ita Nos.338/Pun/2021 & 236/Pun/2022 "नधा"रण वष" / Assessment Years : 2016-17 & 2017-18

section 144B of the Act. The ld. AR fairly admitted that statutory amendment has been carried out by the Finance Act, 2022 with retrospective effect and the assessee’s ground has, therefore, become infructuous. This ground is thus dismissed. 16. Ground nos. 2 to 5 are against the transfer pricing adjustment of Rs.11,95,85,010/- in the international transaction