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

section 263 of the Act. The notice so issued by the PCIT reads as under : “NOTICE FOR THE HEARING M/s/Mr/Ms Subject: Notice for Hearing in respect of Revision proceedings u/s 263 of the THE INCOME TAX ACT, 1961-Assessment Year 2017- 18. In this regard, a hearing in the matter is fixed on 20/02/2024

PUSPAK STEEL INDUSTRIES PRIVATE LIMITED,PUNE vs. ASSISTANT COMMISSIONER OF INCOME TAX, CIRCLE-10, PUNE, PUNE

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

TDS & Service Tax of Rs.12,715/-. (iv) Disallowance of expenditure u/s 14A r.w. Rule 8D of Rs.21,16,195/-. (v) Disallowance of depreciation on cars of Rs.2,79,725/-. 4. Being aggrieved by the above disallowances/additions, an appeal was filed before the ld. CIT(A), who vide impugned order confirmed the disallowance on account of belated deposit of employees contribution

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

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

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]

14A of the Act. Ground No.10 : 18. The assessee had made additional claim of deduction under section 90 of the Act by filing a letter before the Assessing Officer which was not claimed in the Return of Income. The Assessing Officer rejected the said claim as it was not claimed in the Return of Income. 18.1 It has been submitted

BAJAJ FINANCE LIMITED,PUNE vs. PRINCIPAL COMMISSIONER OF INCOME TAX-3, PUNE, PUNE

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

Bench: Shri R. K. Panda & Shri Vinay Bhamoreassessment Year : 2019-20 Bajaj Finance Limited Pcit-3, Pune 3Rd Floor, Panchshil Tech Park, Vs. Viman Nagar, Pune – 411014 Pan: Aabcb1518L (Appellant) (Respondent) Assessee By : Shri Percy Pardiwalla Department By : Shri Amol Khairnar, Cit-Dr Date Of Hearing : 06-01-2026 Date Of Pronouncement : 29-01-2026

TDS in Revised Return iii. High Creditors/liabilities iv. Reduction of Income in Revised Return & Claim of Refund v. Refund Claim vi. Unsecured Loans vii. Expenses Incurred for Earning Exempt Income viii. Taxability of business liability written off u/s 41 or any other section ix. Foreign Outward Remittance x. Capital Gains/Income on Sale of Property xi. Deduction from Total Income under

M/S SUKHWANI PROMOTORS AND BUILDERS,PUNE vs. PRINCIPAL COMMISSIONER OF INCOME-TAX, (CENTRAL),, PUNE

In the result, appeal of the Assessee is Partly Allowed

Bench: Shri S.S.Godara & Dr. Dipak P. Ripoteआयकर अपील सं. / Ita No.301/Pun/2022 िनधा"रण वष" / Assessment Year : 2017-18 M/S.Sukhwani Promoters & The Principal Builders, Vs Commissioner Of Income 208/2A, Near Swaminathan Tax, (Central), Pune. Clinic, Station Road, Pimpri, Pune – 411018. Pan: Abrfs 1253 P Assessee/ Appellant Respondent /Revenue Assessee By Shri Jitendra Jain – Ar Revenue By Shri Sardar Singh Meena – Dr Date Of Hearing 16/05/2023 Date Of Pronouncement 27/06/2023 आदेश/ Order Per Dr. Dipak P. Ripote, Am: This Appeal Is Filed By The Assessee Against The Order Of Ld.Principal Commissioner Of Income Tax(Central), Pune Dated 24.03.2022 Under Section 263 Of The Act For A.Y.2017-18. The Grounds Of Appeal Raised By The Assessee Are As Under : “1 & 2. Pcit Erred In Passing The Order U/S 263 Of The Act Which Is Bad In Law, Illegal, Ultra-Virus, In Excess Of And/Or In Want Of Jurisdiction & Otherwise Void. M/S.Sukhwani Promoters & Builders [A]

14A. Even if one assumes that he has, after reading of the order expressed his views, but still the position is two views therefore were possible. Therefore, if one of the two possible views was taken by the Assessing Officer, the PCIT could not have exercised his powers under section 263 of the Act. 8. ” Unquote . 5.5 Thus, the principle

DCIT, CIRCLE 8 PUNE, PUNE vs. ALFA LAVAL INDIA PVT LTD, PUNE

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

section 36(1)(va) of the Act.\nSubsequently, the case was selected for scrutiny under CASS for the following\nreasons:\n“1.\nDeemed International Transactions\n2.\nLarge value of international transactions\n3.\nTransactions with Company whose Registration has been Cancelled by\nMCA\n4.\nDuty Drawback\n5.\nLower amount disallowed u/s 40(a)(ia) in ITR (Part A-OI) in comparison

JOHN DEERE INDIA PRIVATE LIMITED,PUNE vs. ASSISTANT COMMISSIONER OF INCOME TAX, PUNE

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

Bench: Shri R. K. Panda & Ms Astha Chandraassessment Year : 2016-17 John Deere India Pvt. Ltd., Acit , Pune Tower.No.14, Magarpatta City, Cyber City, Vs. Hadapsar,I.E.S.O., Pune – 411013 Pan: Aaacj4233B (Appellant) (Respondent) Assessee By : Shri Nikhil Pathak Department By : Shri Ramnath P. Murkunde Date Of Hearing : 16-07-2024 Date Of Pronouncement : 22-07-2024 O R D E R Per R.K. Panda, Vp :

14A of the Act. 4. Before the CIT(A) the assessee through an additional ground challenged the order of the Assessing Officer in not granting the credit of the excess Dividend Distribution Tax of Rs.2,88,31,272/- paid by the assessee. It was submitted that in respect of the dividend declared by it, the dividend distribution tax has been

SHARADA ELECTORS PRIVATE LIMITED,PUNE vs. PCIT, PUNE-3, PUNE

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

Bench: Dr.Manish Borad & Shri Vinay Bhamore

14A shall apply and deemed to have always been applied even in a case where the income, not forming part of the total income, has not accrued or arisen or has not been received during the previous year relevant to an assessment year and the expenditure has been incurred during the said previous year. However, the above aspects were

DCIT, SWARGATE PUNE vs. CUMMINS INDIA LTD , PUNE

In the result, appeal of the assessee bearing ITA No

14A of the Act r.w.r. BD of the Income-\ntax Rules, 1962.\n9.2 The Appellant submits that considering the facts and\ncircumstances of its case and the law prevailing on the subject nо\nfurther disallowance u/s.14A of the Act is called for in addition to\nthe amount of INR 48,48,551/- suo-moto disallowed by the\nAppellant

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

In the result, appeal of the assessee bearing ITA No

14A of the Act r.w.r. BD of the Income-\ntax Rules, 1962.\n\n9.2 The Appellant submits that considering the facts and\ncircumstances of its case and the law prevailing on the subject nо\nfurther disallowance u/s.14A of the Act is called for in addition to\nthe amount of INR 48,48,551/- suo-moto disallowed by the\nAppellant

INCOME TAX OFFICER, BODHI TOWER vs. KUMAR BUILDERS PROJECT PUNE PRIVATE LIMITED, BUND GARDEN

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

Bench: Shri R. K. Panda & Ms Astha Chandraassessment Year : 2019-20

TDS credit of Rs.4,02,541/- thereby claiming a refund of Rs.4,02,541/-. The return was revised on 06.03.2020 claiming income tax refund of Rs.2541/- and carry forward loss of Rs.3,95,51,713/-. However, the CPC did not allow the claim of carry forward 2 business loss of Rs.3,95,51,713/- as claimed in the return