PARVATI STEEL RE ROLLING MILLS PRIVATE LIMITED,MUMBAI vs. ACIT, CC-2, AURANGABAD, AURANGABAD

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

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

149 of the Income Tax Act only to the extent of relaxing the time limit for issuance of a reassessment notice under Section 148; d. TOLA will extend the time limit for the grant of sanction by the authority specified under Section 151. The test to determine whether TOLA will apply to Section 151 of the new regime is this

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

TDS Statement Interest other than interest on 11125 securities (Section 1944)\nTotal\nRs.36011125/-\n03. Inquiry by the AO:\nOn verification with the departmental websites of e-filing portal, ITBA and Insight, it is noted that the assessee has not filed any return of\n11\nITA No.540/PUN/2025 [A]\nincome for AY 2015-16 but has sold immovable property of Rs.36000000

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

In the result, appeal of the assessee is Partly Allowed

149(1)(b) is read with Taxation\nand other Laws (Relaxation and Amendment of Certain Provisions) Act,\n2020, then all the notices issued between April 1, 2021 and June 30,\n2021 pertaining to the assessment years 2013-2014. 2014-2015, 2015-\n2016, 2016-2017, and 2017-2018 will be within the period of limitation\nas explained in the tabulation below

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

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

TDS and SRO. Further, she has submitted that the property was purchased jointly with her husband and she has taken loan for purchasing the property. However, no any evidence regarding her claim of co-owner and housing loan along with supporting documents is submitted by the assessee in support of her claim. In absence of the explanation along with supporting

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.

TDS thereupon. The Revenue’s case in light of the departmental authorities stand throughout is that the same represents “Royalty” for use of copyright than purchase of copyrighted article claim on behalf of the assessee’s which attracts Section 40(a)(i) disallowance. We find that instant second issue also stands adjudicated in tribunal’s earlier order (supra) in assessee

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.

TDS thereupon. The Revenue’s case in light of the departmental authorities stand throughout is that the same represents “Royalty” for use of copyright than purchase of copyrighted article claim on behalf of the assessee’s which attracts Section 40(a)(i) disallowance. We find that instant second issue also stands adjudicated in tribunal’s earlier order (supra) in assessee

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

TDS thereupon. The Revenue’s case in light of the departmental authorities stand throughout is that the same represents “Royalty” for use of copyright than purchase of copyrighted article claim on behalf of the assessee’s which attracts Section 40(a)(i) disallowance. We find that instant second issue also stands adjudicated in tribunal’s earlier order (supra) in assessee

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

TDS thereupon. The Revenue’s case in light of the departmental authorities stand throughout is that the same represents “Royalty” for use of copyright than purchase of copyrighted article claim on behalf of the assessee’s which attracts Section 40(a)(i) disallowance. We find that instant second issue also stands adjudicated in tribunal’s earlier order (supra) in assessee

MRS. SNEHAL SAMEER BHUJBAL,PUNE vs. ITO, WARD 13(2), PUNE, PUNE

Accordingly, Ground No.1 of the Assessee is allowed

Bench: Dr.Dipak P. Ripote & Shri Vinay Bhamoreआयकर अपील सं. / Ita No.1549/Pun/2025 िनधा"रण वष" / Assessment Year: 2018-19 Mrs. Snehal Sameer Bhujbal, V The Income Tax Officer, Sanswadi, Nagar Road, S Ward-13(2), Pune. Pune – 412208. Maharashtra. Pan: Blcpb5495C Appellant/ Assessee Respondent / Revenue Assessee By Shri Bhuvanesh Kankani – Ar Revenue By Shri Sandeep P Sathe – Jcit(Dr) Date Of Hearing 17/07/2025 Date Of Pronouncement 21/07/2025 आदेश/ Order Per Dr. Dipak P. Ripote, Am: This Is An Appeal Filed By Assessee Against The Order Of Ld.Commissioner Of Income Tax(Appeal)[Nfac],Passed Under Section 250 Of The Income Tax Act, 1961 For The A.Y.2018-19 Dated 16.05.2025, Emanating From Order U/S.147 R.W.S 144 Of The Income Tax Act, 1961, Dated 19.01.2024. The Assessee Has Raised Following Grounds Of Appeal : “1. On The Facts & Circumstances Prevailing In The Case & As Per Provisions & Scheme Of The Income-Tax Act, 1961 ('The Act') It Be Held

section 149(1)(b) of the Act since the income alleged to have been escaped from assessment is below Rs.50,00,000/-. Accordingly, the assessment proceedings so initiated and completed be kindly quashed and Appellant be granted just and proper relief in this respect. 3. Without prejudice to other grounds and on the facts and circumstances prevailing in the case

APPASO SAMPATRAO MANE,PUNE vs. ITO WARD 7(1), PUNE

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

TDS under section 1941A were duly met, proving that\nthere was no escapement of income.\n3.2 On the facts and circumstances of the case, the learned CIT(A) erred in not\nappreciating that submission made before him whereby the underlying\ntransaction related to payment through credit card of 3,08,995/-, was fully\nexplained through banking records.\n3.3

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

TDS provisions. As regards, the claim for allowance as revenue expenditure on product development expenditure of Rs.4,19,75,171/-, the ld. CIT(A) allowed the same following the Tribunal’s order in assessee’s own case for the assessment year 2008-09. Being aggrieved by the decision of the ld. CIT(A), the Revenue is in appeal before

DILIP HIRALAL CHAUDHARI,NANDURBAR vs. ITO, WARD, DHULE

In the result, the appeal of the assessee stands allowed for statistical purposes

Bench: SHRI INTURI RAMA RAO (Accountant Member), SHRI VINAY BHAMORE (Judicial Member)

section 209(1)(d) the computation of advance tax payment was required to be made after considering TDS / TCS if any. In the instant case an amount of Rs.61,149

KIMBERLY CLARK LEVER P.LTD.,PUNE vs. ACIT, PUNE

In the result, the appeal of the assessee stands allowed

Bench: Shri Inturi Rama Rao, Am & Shri Partha Sarathi Chaudhury, Jm आयकर अपील सं. / Ita No.2481/Pun/2012 िनधा"रण वष" / Assessment Year : 2008-09 Kimberly Clark Lever P. Ltd., Gat No.934 To 937, Village Sanaswadi Off Nagar Road, Ta- Shirur, Pune-412208. .......अपीलाथ" / Appellant Pan : Aaack4647E बनाम / V/S. Acit, Circle-Xi(I), ……""यथ" / Respondent Pune. Assessee By : Shri Percy Pardiwalla Revenue By : Shri Sandeep Garg सुनवाई क" तारीख / Date Of Hearing : 08.02.2021 घोषणा क" तारीख / Date Of Pronouncement : 22.02.2021 आदेश / Order Per Inturi Rama Rao, Am: This Is An Appeal Filed By The Assessee Directed Against The Final Assessment Order U/S 143(3) R.W.S. 144C Of The Income Tax Act, 1961 (‘The Act’ For Short) Of The Asstt. Commissioner Of Income Tax, Circle-11(1), Pune (‘The Assessing Officer’ For Short) Dated 29.10.2012 For The Assessment Year 2008-09. 2. The Appellant Raised The Following Grounds Of Appeal :- “The Appellant Objects To The Order Dated 29 October 2012 Passed Under Section 143(3) R.W.S. 144(C) Of The Income-Tax Act, 1961 (‘The Act’) By The Assistant Commissioner Of Income Tax, Circle 11(1), Pune [‘Acit’ Or ‘Ao’] Following The Directions Issued By The Dispute Resolution Panel (‘Drp’) In Respect Of The Aforesaid Assessment Year On The Following Among Other Grounds:

149 ITD 363; (iii) CIT vs. S.M. Anand, 422 ITR 209; (iv) PCIT vs. Perfect Circle India Pvt. Ltd., 104 CCH 8; (v) Calcutta Export Company, 93 taxman 51; (vi) G. Shankar vs. ACIT, 41 CCH 309; and, (vii) Vardhvinayak Township Development, 168 ITD 456. 15. On the other hand, the ld. CIT-DR submitted that the details

SHRI MANOJ MADANLAL CHHAJED,PUNE vs. ASSISTANT COMMISSIONER OF INCOME TAX, CIRCLE -1(1)PUNE, PUNE

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

Bench: Shri Inturi Rama Rao & Shri S. S. Viswanethra Raviआयकर अपील सं. / It(Ss)A Nos.91 To 96/Pun/2022 िनधा"रण वष" / Assessment Years : 2012-13 To 2017-18 Shri Manoj Madanlal Vs. Acit, Central Circle- Chhajed, 1(1), Pune. 601, A-8 Building, Karishma Housing Society, Near Sangam Press, Kothrud, Pune- 411029. Pan : Aalpc4991M Appellant Respondent आयकर अपील सं. / It(Ss)A Nos.97 & 98/Pun/2022 िनधा"रण वष" / Assessment Years : 2012-13 & 2015-16 Acit, Circle-1(1), Pune. Vs. Shri Manoj Madanlal Chhajed, 601, A-8 Building, Karishma Housing Society, Near Sangam Press, Kothrud, Pune- 411029. Pan : Aalpc4991M Appellant Respondent आयकर अपील सं. / Ita No.725/Pun/2022 िनधा"रण वष" / Assessment Year: 2018-19 Shri Manoj Madanlal Vs. Acit, Circle-1(1), Pune. Chhajed, 601, A-8 Building, Karishma Housing Society, Near Sangam Press, Kothrud, Pune- 411029. Pan : Aalpc4991M Appellant Respondent

TDS. Thus, he submits that the appellant had discharged the onus lying upon it in terms of provisions of section 19 IT(SS)A Nos.91 to 96/PUN/2022 IT(SS)A Nos.97 & 98/PUN/2022 68 of the Act. In the circumstances, the AO was not justified in making the addition of unsecured loans. E. As regards, the addition made on account

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

TDS thereupon. The Revenue’s case in light of the departmental authorities stand throughout is that the same represents “Royalty” for use of copyright than purchase of copyrighted article claim on behalf of the assessee’s which attracts Section 40(a)(i) disallowance. We find that instant second issue also stands adjudicated in tribunal’s earlier order (supra) in assessee

KOTHARI AGRITECH PRIVATE LIMITED,SOLAPUR vs. DCIT CIRCLE 1, SOLAPUR, SOLAPUR

In the result, appeal of the Assessee is Partly Allowed

Bench: Dr.Dipak P. Ripote & Shri Vinay Bhamoreआयकर अपील सं. / Ita No.2354/Pun/2024 िनधा"रण वष" / Assessment Year: 2015-16 Kothari Agritech Private V The Dcit, Limited, S Circle-1, Solapur. 3Rd Floor, Sunplaza, 8516/11, Subhash Chowk, Murarji Peth, Solapur North, Jawaharlal Nehru Vastigrah S.O., Solapur – 413001. Maharashtra Pan: Aadck8017H Appellant/ Assessee Respondent / Revenue Assessee By Mr.Piyush Bafna – Ar Revenue By Shri Ramnath P Murkunde – Dr Date Of Hearing 24/04/2025 Date Of Pronouncement 20/05/2025 आदेश/ Order Per Dr. Dipak P. Ripote, Am: This Appeal Filed By The Assessee Is Against The Order Of Ld.Commissioner Of Income Tax(Appeals)[Nfac], Passed Under Section 250 Of The Income Tax Act, 1961; Dated 19.09.2024 For Assessment Year 2015-16. The Assessee Has Raised The Following Grounds Of Appeal :

section 250 of the Income Tax Act, 1961; dated 19.09.2024 for Assessment Year 2015-16. The assessee has raised the following grounds of appeal : ITA No.2354/PUN/2024 [A] “1. On the facts and in the circumstances of the case, Ld. CIT-Appeal has erred in upholding the disallowance of commission expenses to the extent of Rs 45,24,707, which

DCIT, SWARGATE PUNE vs. CUMMINS INDIA LTD , PUNE

In the result, appeal of the assessee bearing ITA No

TDS)/tax collected at source (TCS) of Rs.14,59,293/- and\nshort credit of dividend distribution tax (DDT) at Rs.\n50,78,82,579/- respectively. Considering the contention of\nlearned counsel for the assessee and also observing that the\nrectification application filed by the assessee on 13/07/2022\nis not yet disposed of, we remit the issues raised in ground\nNos.3

ASSISTANT COMMISSIONER OF INCOME TAX CENTRAL CIRCLE 2(1), PUNE, PUNE vs. PATIL CONSTRUCTION AND INFRASTRUCTURE LIMITED, MUMBAI

In the result, all the three appeals filed by the Revenue are allowed for statistical purposes

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

TDS was deducted shows that the relationship between the assessee, purportedly the developer and the government is that of contractor and contractee. ii) The assessee company has acted as a contractor only on a specific contract allotted by its principals, cost of which has been reimbursed from the principals who is the actual owner/developer. iii) The assessee's profits