DEPUTY COMMISSIONER OF INCOME-TAX, CIRCLE - 1(1),, PUNE vs. M/S. IAC INTERNATIONAL AUTOMOTIVE INDIA PVT.LTD,, PUNE

In the result, the appeal of the Revenue is dismissed

Bench: Ms. Astha Chandra & Shree Dr. Dipak P. Ripote

section 92CA(1) of the Act in order to determine the Arm‟s Length Price (“ALP”) in respect of such international transactions. 2.2 The assessee undertook the following international transactions with its AEs during AY 2013-14 and benchmarked each transaction by selecting the Most Appropriate Method (“MAM”) mentioned in the table below: Sr. Nature of International Amount

HARSHAD HIMMATLAL RUPANI,PUNE vs. ITO WARD 5(2), PUNE

In the result the ground number 3 is allowed for Statistical

Bench: Dr.Dipak P. Ripote & Shri Vinay Bhamoreआयकर अपऩल सं. / Ita No.920/Pun/2025 निर्धारण वषा / Assessment Year: 2014-15 Harshad Himmatlal Rupani, V The Income Tax Officer, 101/102, Ashoka Building, S Ward-5(1), Pune. Green Valley Housing Society, Wanwadi, Pune – 411040. Pan: Adopr6163Q Appellant/ Assessee Respondent / Revenue Assessee By Shri Mahavir Jain Revenue By Smt Neha Thakur – (Virtual) Date Of Hearing 21/01/2026 Date Of Pronouncement 28/01/2026 आदेश/ Order Per Dr. Dipak P. Ripote, Am: This Appeal Filed By The Assessee Is Against The Order Of Ld.Commissioner Of Income Tax(Appeal)[Nfac], Passed Under Section 250 Of The Income Tax Act, 1961 For A.Y.2014-15 Dated 26.08.2024 Emanating From The Assessment Order Passed Under Section 143(3) Of The Income Tax Act, 1961, Dated 22.11.2016. The Assessee Has Raised The Following Grounds Of Appeal :

196) 6.2) On a specific query from the Bench, Ld.DR for the Revenue submitted that these Creditors were added u/s.41(1) of the Act as they have been outstanding for long period. 6.3) Section 41(1) of the Act is reproduced here as under : Profits chargeable to tax. 41. (1) Where an allowance or deduction has been made

DCIT, SWARGATE PUNE vs. CUMMINS INDIA LTD , PUNE

In the result, appeal of the assessee bearing ITA No

196,96,24,249/) of the Act.\n7.2 The Appellant submits that considering the facts and\ncircumstances of its case and the law prevailing on the subject, it is\ninter alia eligible for claiming exemption u/s.10AA of the Act and\nthe stand taken by the Ld. AO/Hon'ble DRP in this regard is illegal,\nincorrect, erroneous and misconceived.\n7.3

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

In the result, appeal of the assessee bearing ITA No

196,96,24,249/) of the Act.\n\n7.2 The Appellant submits that considering the facts and\ncircumstances of its case and the law prevailing on the subject, it is\ninter alia eligible for claiming exemption u/s.10AA of the Act and\nthe stand taken by the Ld. AO/Hon'ble DRP in this regard is illegal,\nincorrect, erroneous and misconceived