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32 results for “TDS”+ Section 155clear

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Key Topics

Section 12A36Section 10(20)24Section 1124TDS23Section 143(3)18Section 201(1)18Section 20117Addition to Income14Section 234E13Section 143(1)

PADMAKAR VISHWAS DATE,BHOSARI vs. INCOME TAX E ASSESSMENT , PUNE

In the result, appeal of the assessee is dismissed

ITA 929/PUN/2023[2013-14]Status: DisposedITAT Pune16 Feb 2024AY 2013-14

Bench: Shri S.S.Godara & Dr. Dipak P. Ripoteआयकर अपील सं. / Ita Nos.929, 930 & 931/Pun/2023 िनधा"रण वष" / Assessment Years : 2013-14, 2014-15 & 2015-16 Padmakar Vishwas Date, The Income Tax Officer S.No.218, Near Shri Krishn V –Tds(2), Pune. Mandir, Alandi Road, S Bhosari, Pune – 411038. Pan: Anhpd3804B Appellant/ Assessee Respondent /Revenue Assessee By None Revenue By Shri Sourabh Nayak – Addl.Cit(Dr) Date Of Hearing 15/02/2024 Date Of Pronouncement 16/02/2024 आदेश/ Order Per Dr. Dipak P. Ripote, Am: These Three Appeals Filed By The Assessee Are Against The Separate Orders Of Ld.Commissioner Of Income Tax(Appeals)[Nfac], Passed Under Section 250 Of The Income Tax Act, 1961 All Dated 26.06.2023. Since Issue Involved Is Same, All These Appeals Were Heard Together & Decided By This Consolidated Order. We Treat Appeal In Ita No.929/Pun/2023 For A.Y.2013-14

Section 201Section 234Section 234ESection 246ASection 250

155 having the effect of enhancing the assessment or reducing a refund or an order refusing to allow the claim made by the assessee under either of the said sections except an order referred to in sub-section (12) of section 144BA; (d) an order made under section 163 treating the assessee as the agent of a non-resident

Showing 1–20 of 32 · Page 1 of 2

11
Exemption9
Double Taxation/DTAA9

PADMAKAR VISHWAS DATE,,BHOSARI vs. INCOME TAX E ASSESSMENT, PUNE

In the result, appeal of the assessee is dismissed

ITA 930/PUN/2023[2014-15]Status: DisposedITAT Pune16 Feb 2024AY 2014-15

Bench: Shri S.S.Godara & Dr. Dipak P. Ripoteआयकर अपील सं. / Ita Nos.929, 930 & 931/Pun/2023 िनधा"रण वष" / Assessment Years : 2013-14, 2014-15 & 2015-16 Padmakar Vishwas Date, The Income Tax Officer S.No.218, Near Shri Krishn V –Tds(2), Pune. Mandir, Alandi Road, S Bhosari, Pune – 411038. Pan: Anhpd3804B Appellant/ Assessee Respondent /Revenue Assessee By None Revenue By Shri Sourabh Nayak – Addl.Cit(Dr) Date Of Hearing 15/02/2024 Date Of Pronouncement 16/02/2024 आदेश/ Order Per Dr. Dipak P. Ripote, Am: These Three Appeals Filed By The Assessee Are Against The Separate Orders Of Ld.Commissioner Of Income Tax(Appeals)[Nfac], Passed Under Section 250 Of The Income Tax Act, 1961 All Dated 26.06.2023. Since Issue Involved Is Same, All These Appeals Were Heard Together & Decided By This Consolidated Order. We Treat Appeal In Ita No.929/Pun/2023 For A.Y.2013-14

Section 201Section 234Section 234ESection 246ASection 250

155 having the effect of enhancing the assessment or reducing a refund or an order refusing to allow the claim made by the assessee under either of the said sections except an order referred to in sub-section (12) of section 144BA; (d) an order made under section 163 treating the assessee as the agent of a non-resident

PADMAKAR VISHWAS DATE,BHOSARI vs. INCOME TAX E ASSESSMENT, PUNE

In the result, appeal of the assessee is dismissed

ITA 931/PUN/2023[2015-16]Status: DisposedITAT Pune16 Feb 2024AY 2015-16

Bench: Shri S.S.Godara & Dr. Dipak P. Ripoteआयकर अपील सं. / Ita Nos.929, 930 & 931/Pun/2023 िनधा"रण वष" / Assessment Years : 2013-14, 2014-15 & 2015-16 Padmakar Vishwas Date, The Income Tax Officer S.No.218, Near Shri Krishn V –Tds(2), Pune. Mandir, Alandi Road, S Bhosari, Pune – 411038. Pan: Anhpd3804B Appellant/ Assessee Respondent /Revenue Assessee By None Revenue By Shri Sourabh Nayak – Addl.Cit(Dr) Date Of Hearing 15/02/2024 Date Of Pronouncement 16/02/2024 आदेश/ Order Per Dr. Dipak P. Ripote, Am: These Three Appeals Filed By The Assessee Are Against The Separate Orders Of Ld.Commissioner Of Income Tax(Appeals)[Nfac], Passed Under Section 250 Of The Income Tax Act, 1961 All Dated 26.06.2023. Since Issue Involved Is Same, All These Appeals Were Heard Together & Decided By This Consolidated Order. We Treat Appeal In Ita No.929/Pun/2023 For A.Y.2013-14

Section 201Section 234Section 234ESection 246ASection 250

155 having the effect of enhancing the assessment or reducing a refund or an order refusing to allow the claim made by the assessee under either of the said sections except an order referred to in sub-section (12) of section 144BA; (d) an order made under section 163 treating the assessee as the agent of a non-resident

MAJALGAON ART SCI & COMMERCE COLLEGE BEED,MAJALGAON vs. ITO TDS WARD, AURANGABAD, AURANGABAD

In the result, the appeal of assessee is dismissed

ITA 1109/PUN/2023[A.Y- 2014-15]Status: DisposedITAT Pune30 Nov 2023

Bench: Shri S.S. Viswanethra Ravi & Shri G.D. Padmahshali

For Appellant: Shri Digambar SurwaseFor Respondent: Shri Ramnath P. Murkunde
Section 154Section 154(7)Section 155Section 186Section 200ASection 220(2)Section 234E

TDS have been perused. On perusal of the records it is seen that the order u/s 200A was passed on 08.07.2014 and the appellant has filed rectification application on 16.03.2023. As per section 154(7) the rectification application should be filed within 4 years from the end of the financial year in which the order sought to be amended

SHOBHA RAMKISAN DARGAD,SOLAPUR vs. INCOME TAX OFFICER, WARD-1(1), SOLAPUR, SOLAPUR

In the result, the appeal is partly allowed for statistical purposes

ITA 494/PUN/2023[2003-04]Status: DisposedITAT Pune21 Aug 2023AY 2003-04

Bench: Shri R.S. Syal & Shri Partha Sarathi Chaudhuryassessment Year : 2003-04

For Appellant: None (Written submissions)For Respondent: Shri M.G. Jasnani
Section 139Section 139(1)Section 139(4)Section 139(5)Section 143(1)Section 155(14)Section 203Section 250

section 155(14), which provides that where in the assessment for any previous year or in an intimation u/s.143(1) of the Act, credit for TDS

JOHN DEERE INDIA PVT. LTD.,,PUNE vs. DEPUTY DIRECTOR OF INCOME-TAX,,

In the result, all the appeals of assessee are allowed

ITA 906/PUN/2015[2008-09]Status: DisposedITAT Pune23 Jan 2019AY 2008-09

Bench: Ms. Sushma Chowla, Jm & Shri Anil Chaturvedi, Am आयकर अपीऱ सं. / Ita Nos.905 & 906/Pun/2015 यििाारण वषा / Assessment Years :2007-08 & 2008-09

For Appellant: Shri Nikhil PathakFor Respondent: S/Shri Ajay Modi, Pankaj Garg and Sudhendu Das
Section 195Section 201Section 201(1)Section 9(1)(vi)

section 9(1)(vi) of the Act or Article 12 of the DTAA. Article 12 of DTAA with USA stipulates and defines what is royalty and fees for technical services. The term ‘royalty’ as per clause 3 of Article 12 means payment of any kind received as consideration for the use of, or the right to use, any copyright

JOHN DEERE EQIPMENT P. LTD.,,PUNE vs. DEPUTY DIRECTOR OF INCOME-TAX,,

In the result, all the appeals of assessee are allowed

ITA 907/PUN/2015[2008-09]Status: DisposedITAT Pune23 Jan 2019AY 2008-09

Bench: Ms. Sushma Chowla, Jm & Shri Anil Chaturvedi, Am आयकर अपीऱ सं. / Ita Nos.905 & 906/Pun/2015 यििाारण वषा / Assessment Years :2007-08 & 2008-09

For Appellant: Shri Nikhil PathakFor Respondent: S/Shri Ajay Modi, Pankaj Garg and Sudhendu Das
Section 195Section 201Section 201(1)Section 9(1)(vi)

section 9(1)(vi) of the Act or Article 12 of the DTAA. Article 12 of DTAA with USA stipulates and defines what is royalty and fees for technical services. The term ‘royalty’ as per clause 3 of Article 12 means payment of any kind received as consideration for the use of, or the right to use, any copyright

JOHN DEERE INDIA PVT. LTD.,,PUNE vs. DEPUTY DIRECTOR OF INCOME-TAX,,

In the result, all the appeals of assessee are allowed

ITA 905/PUN/2015[2007-08]Status: DisposedITAT Pune23 Jan 2019AY 2007-08

Bench: Ms. Sushma Chowla, Jm & Shri Anil Chaturvedi, Am आयकर अपीऱ सं. / Ita Nos.905 & 906/Pun/2015 यििाारण वषा / Assessment Years :2007-08 & 2008-09

For Appellant: Shri Nikhil PathakFor Respondent: S/Shri Ajay Modi, Pankaj Garg and Sudhendu Das
Section 195Section 201Section 201(1)Section 9(1)(vi)

section 9(1)(vi) of the Act or Article 12 of the DTAA. Article 12 of DTAA with USA stipulates and defines what is royalty and fees for technical services. The term ‘royalty’ as per clause 3 of Article 12 means payment of any kind received as consideration for the use of, or the right to use, any copyright

JOHN DEERE EQIPMENT P. LTD.,,PUNE vs. DEPUTY DIRECTOR OF INCOME-TAX,,

In the result, all the appeals of assessee are allowed

ITA 908/PUN/2015[2008-09]Status: DisposedITAT Pune23 Jan 2019AY 2008-09

Bench: Ms. Sushma Chowla, Jm & Shri Anil Chaturvedi, Am आयकर अपीऱ सं. / Ita Nos.905 & 906/Pun/2015 यििाारण वषा / Assessment Years :2007-08 & 2008-09

For Appellant: Shri Nikhil PathakFor Respondent: S/Shri Ajay Modi, Pankaj Garg and Sudhendu Das
Section 195Section 201Section 201(1)Section 9(1)(vi)

section 9(1)(vi) of the Act or Article 12 of the DTAA. Article 12 of DTAA with USA stipulates and defines what is royalty and fees for technical services. The term ‘royalty’ as per clause 3 of Article 12 means payment of any kind received as consideration for the use of, or the right to use, any copyright

NEW ERA HIGH SCHOOL COMMITTEE,SATARA vs. ASSISTANT COMMISSIONER OF INCOME-TAX, EXEMPTION CIRCLE,, PUNE

The appeal of the appellant is ALLOWED in above terms

ITA 622/PUN/2022[2018-19]Status: DisposedITAT Pune30 Dec 2022AY 2018-19

Bench: Hon’Ble Shri S.S. Godara & Shri G. D. Padmahshaliआयकर अपीलसं. / Ita No. 622/Pun/2022 कर धििाारण वर्ा / Assessment Year :2018-19 New Era High School Committee Chesson Rd., Panchgani, Satara - 412805 Pan : Aaatn2455L . . . . . . . अपीलाथी / Appellant बिाम / V/S. Asstt. Commissioner Of Income Tax Exemption Circle-8, Pune. . . . . . . .प्रत्यथी / Respondent द्वारा / Appearances Assessee By : Shri Rohit Tapadiya Revenue By : Shri Suhas Kulkarni सुनवाई की तारीख / Date Of Conclusive Hearing : 28/12/2022 घोषणा की तारीख / Date Of Pronouncement : 30/12/2022 आदेश / Order Per G. D. Padmahshali, Am; By The Present Appeal, The Assessee Challenges The Order Of National Faceless Appeal Centre, Delhi [For Short “Nfac”] Dt. 13/06/2022 Passed U/S 250 Of The Income Tax Act, 1961 [For Short “The Act”] Confirming Order Of Rectification Passed U/S 154 Which Denied To Interfere With Computation Of Income Carried Out U/S 143(3) Passed By National E-Asstt. Centre [For Short “Neas”] For Assessment Year [For Short “Ay”] 2018-19. Itat-Pune Page 1 Of 7

For Appellant: Shri Rohit TapadiyaFor Respondent: Shri Suhas Kulkarni
Section 1Section 119Section 139(1)Section 143(1)Section 143(2)Section 143(3)Section 154Section 199Section 206CSection 234A

155/-. ITAT-Pune Page 2 of 7 New Era High School Committee ITA No.622/PUN/2022 PAN: AAATN2455L 4.2 The case of the appellant was then selected for complete scrutiny u/s 143(2) of the Act under e-Asstt. Scheme and accepting the submission of the appellant, the assessment was culminated without variance u/s 143(3) of the Act, however computation

GRI RENEWABLE INDUSTRIES S L (FORMERLY KNOWN AS GONVARRI EOLICA S L),MADRID vs. ASSISTANT COMMISSIONER OF INCOME-TAX (INTERNATIONAL TAXATION) CIRCLE -1, PUNE

In the result, the appeal is partly allowed

ITA 202/PUN/2021[2016-17]Status: DisposedITAT Pune15 Feb 2022AY 2016-17

Bench: Shri R.S. Syal & Shri Partha Sarathi Chaudhuryआयकर अपील सं. / Ita No.202/Pun/2021 "नधा"रण वष" / Assessment Year : 2016-17

Section 115ASection 143(3)Section 90Section 90(1)

section 90(1) of the Act leaving no room for any separate notification for the importation. The sequitur is that that the authorities below were not justified in denying the benefit of the straight rate of tax at 10% as per the DTAA read with Portuguese DTAA and also additionally charging Surcharge and Education cess. 14 GRI Renewable Industries

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

Accordingly, Ground No.1 of the Assessee is allowed

ITA 1549/PUN/2025[2018-19]Status: DisposedITAT Pune21 Jul 2025AY 2018-19

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 147Section 148ASection 149(1)(b)Section 151Section 250

Section 194IA) SFT-012(B) Purchase by any person of immovable 7015050 property 21045150/- 4. It can be apparently observed that, the information shared with the AO is from SFT data and another from TDS data. And since Appellant is co-owner, SFT information has provided 50% part of Appellants ownership. That is to say, both the information lines

M/S. TATA TECHNOLOGIES LTD.,,PUNE vs. DEPUTY DIRECTOR OF INCOME-TAX,,

In the result, appeal of assessee is partly allowed

ITA 1433/PUN/2014[2007-08]Status: DisposedITAT Pune05 Apr 2018AY 2007-08

Bench: Ms. Sushma Chowla, Jm & Shri Anil Chaturvedi, Am आयकर अपीऱ सं. / Ita No.1433/Pun/2014 यििाारण वषा / Assessment Year : 2007-08 M/S. Tata Technologies Limited, Plot No.25, Rajiv Gandhi Infotech Park, अऩीऱाथी/Appellant Hingewadi, Pune – 411057 …. Pan: Aaact3092N Vs. The Dy. Director Of Income Tax …. प्रत्यथी / Respondent (International Taxation)-Ii, Pune

For Appellant: S/Shri Dhanesh Bafna and Arpitha ChoudaryFor Respondent: S/Shri Vivek Aggarwal and Mukesh Jha
Section 115ASection 195Section 201Section 201(1)Section 9(1)(vi)Section 90(2)

155 CTR 489 (SC) / 239 ITR 587 (SC). Further, the assessee referred to section 90 of the Act and pointed out that where the DTAA has been entered into with a country, then the provisions of the Act or Treaty, whichever is more beneficial shall apply. He referred to the relevant extracts of provisions relating to the royalty as defined

M/S. B. M. CHAPALKAR & SONS,,NASHIK vs. ASSISTANT COMMISSIONER OF INCOME TAX,,

In the result, appeal of the assessee is partly allowed for statistical purposes

ITA 2906/PUN/2016[2010-11]Status: DisposedITAT Pune12 Dec 2019AY 2010-11

Bench: Shri R.S.Syal, Vp & Shri Partha Sarathi Chaudhury, Jm आयकर अपीऱ सं. / Ita No.2906/Pun/2016 नििाारण वषा / Assessment Year : 2010-11 M/S. B.M. Chapalkar & Sons, 26, Dehbanoo Complex, Nashik Pune Road, Nashik Road, Nashik-422 101, Pan: Aadfb5084C .......अऩीऱाथी / Appellant बिाम / V/S.

For Appellant: Shri Pramod ShingteFor Respondent: Shri Ajay Dhoke
Section 139Section 194ASection 201Section 3(1)Section 40

155 TTJ (Co chin) 470 and confirming the addition of Rs.80,88,260 when the provisions of section 40(a)(ia) are not applicable to short deduction in view of the decisions. The addition may please be deleted. 2. On the facts and in the circumstances of the case and in law the Learned Assessing Officer is not justified

TIBCO SOFTWARE BV,,PUNE vs. ASSISTANT COMMISSIONER OF INCOME-TAX, (INTERNATIONAL TAXATION), CIRCLE -2,, PUNE

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

ITA 1554/PUN/2018[2015-16]Status: DisposedITAT Pune17 May 2022AY 2015-16

Bench: Shri Inturi Rama Rao & Shri S.S. Viswanethra Ravisl.

For Appellant: Shri Somil AgarwalFor Respondent: Shri Deepak Garg
Section 144C(13)Section 234BSection 274

TDS had been deducted, the Assessing Officer formed an opinion that income had escaped assessment to tax, then issued notice u/s 148 on 29.03.2018 after recording reasons u/s 147. In response to notice u/s 148, the appellant had filed return of income on 26.04.2018. Against the said return of income, the assessment was completed by the Assistant Commissioner of Income

TIBCO SOFTWARE BV,,PUNE vs. ASSISTANT COMMISSIONER OF INCOME-TAX, (IT), CIRCLE-2,, PUNE

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

ITA 1348/PUN/2019[2011-12]Status: DisposedITAT Pune17 May 2022AY 2011-12

Bench: Shri Inturi Rama Rao & Shri S.S. Viswanethra Ravisl.

For Appellant: Shri Somil AgarwalFor Respondent: Shri Deepak Garg
Section 144C(13)Section 234BSection 274

TDS had been deducted, the Assessing Officer formed an opinion that income had escaped assessment to tax, then issued notice u/s 148 on 29.03.2018 after recording reasons u/s 147. In response to notice u/s 148, the appellant had filed return of income on 26.04.2018. Against the said return of income, the assessment was completed by the Assistant Commissioner of Income

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

ITA 725/PUN/2022[2018-19]Status: DisposedITAT Pune28 Jun 2023AY 2018-19

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

For Appellant: Shri Ratan SamalFor Respondent: Shri Keyur Patel
Section 132(4)Section 139(1)

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

CAPGEMINI TECHNOLOGY SERVICES INDIA LTD,,PUNE vs. DEPUTY COMMISSIONER OF INCOME-TAX, CIRCLE - 11,, PUNE

In the result, both the appeals are partly allowed

ITA 1857/PUN/2017[2013-14]Status: DisposedITAT Pune30 Aug 2022AY 2013-14

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

Section 10ASection 115JSection 391Section 72ASection 74

155 ITR 152 (SC). In that case, a partnership firm took over the business of an earlier firm and all the assets and liabilities of the predecessor firm passed on to the successor firm. The assets included a certain amount of debt due from a certain party to the predecessor firm. Later on, the amount became bad and the successor

ASSISTANT COMMISSIONER OF INCOME-TAX, CIRCLE -11,, PUNE vs. CAPGEMINI TECHNOLOGY SERVICES INDIA LIMITED , (FORMERLY IGATE GLOBAL SOLUTIONS LTD.),, PUNE

In the result, both the appeals are partly allowed

ITA 1935/PUN/2017[2013-14]Status: DisposedITAT Pune30 Aug 2022AY 2013-14

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

Section 10ASection 115JSection 391Section 72ASection 74

155 ITR 152 (SC). In that case, a partnership firm took over the business of an earlier firm and all the assets and liabilities of the predecessor firm passed on to the successor firm. The assets included a certain amount of debt due from a certain party to the predecessor firm. Later on, the amount became bad and the successor

TIBCO SOFTWARE B.V.,,PUNE vs. DEPUTY COMMISSIONER OF INCOME TAX, (IT), CIRCLE - 2,, PUNE

Appeal is allowed for statistical purposes

ITA 2979/PUN/2017[2014-15]Status: DisposedITAT Pune29 Mar 2022AY 2014-15

Bench: Shri R.S.Syal & Sonjoy Sarma,Jm Assessment Year : 2014-15 Tibco Software B.V. ...... Appellant C/O Tibco Software India P.Ltd. 3 Floor, Binnarius,Deepak Complex, National Games Road, Shastri Nagar, Yerwada, Pune – 411 006. Pan : Aaect3252G V/S. Dcit(It),Circle-2, Pune ……Respondent

For Appellant: Shri Somil AgarwalFor Respondent: Shri Rajiv Kumar
Section 144C(13)Section 274

TDS‟) amounting to INR 2,47,666. Ground No.7: On the facts and circumstances of the case and in law, the Ld. AO has erred in initiating penalty proceedings against the Appellant under Section 274 r.w.s 271(1)(c) of the Income-tax Act, 1961.” 3. Briefly, the facts are under : 4. The Appellant TIBCO Software