SHRI BHASKARACHARYA PRATISHTHAN,CHH. SAMBHAJINAGAR vs. LD. DEPUTY COMMISSIONER OF INCOME TAX, CPC-TDS

In the result, both the bunch of appeals filed by the respective assessee’s in ITA Nos

Bench: Dr.Manish Borad & Shri Vinay Bhamoreआयकर अपील सं. / Ita Nos.476 To 480/Pun/2024 Chate Tutorials Pvt. Ltd., Vs. Acit,Tds Circle, Chate House, Plot No.4, Nashik Near N-2 Cricket Stadium, Cidco, Aurangabad – 431 003 Maharashtra Tan : Nskco1565E Appellant Respondent

22. Now taking guidance from the above observations of the Hon’ble Jurisdictional High Court and also going through the provisions of section 200A in totality, we find that so far as sub- section (1) of section 200A of the Act there is no dispute as it provides the mechanism for processing the TDS returns/statements. Sub-section (2

SHREE BHASKARACHARYA PRATISHTHAN,CHH SAMBHAJINAGAR vs. LD. DEPUTY COMMISSIONER OF INCOME TAX, GHAZIABAD

In the result, both the bunch of appeals filed by the respective assessee’s in ITA Nos

Bench: Dr.Manish Borad & Shri Vinay Bhamoreआयकर अपील सं. / Ita Nos.476 To 480/Pun/2024 Chate Tutorials Pvt. Ltd., Vs. Acit,Tds Circle, Chate House, Plot No.4, Nashik Near N-2 Cricket Stadium, Cidco, Aurangabad – 431 003 Maharashtra Tan : Nskco1565E Appellant Respondent

22. Now taking guidance from the above observations of the Hon’ble Jurisdictional High Court and also going through the provisions of section 200A in totality, we find that so far as sub- section (1) of section 200A of the Act there is no dispute as it provides the mechanism for processing the TDS returns/statements. Sub-section (2

SHRI BHASKARACHARYA PRATISHTHAN,CHH. SAMBHAJINAGAR vs. LD. DEPUTY COMMISSIONER OF INCOME TAX, CPC-TDS

In the result, both the bunch of appeals filed by the respective assessee’s in ITA Nos

Bench: Dr.Manish Borad & Shri Vinay Bhamoreआयकर अपील सं. / Ita Nos.476 To 480/Pun/2024 Chate Tutorials Pvt. Ltd., Vs. Acit,Tds Circle, Chate House, Plot No.4, Nashik Near N-2 Cricket Stadium, Cidco, Aurangabad – 431 003 Maharashtra Tan : Nskco1565E Appellant Respondent

22. Now taking guidance from the above observations of the Hon’ble Jurisdictional High Court and also going through the provisions of section 200A in totality, we find that so far as sub- section (1) of section 200A of the Act there is no dispute as it provides the mechanism for processing the TDS returns/statements. Sub-section (2

CHATE TUTORIALS PVT. LTD.,AURANGABAD vs. LD. ASSISTANT COMMISSIONER OF INCOME TAX, TDS CIRCLE, NASHIK, NASHIK

In the result, both the bunch of appeals filed by the respective assessee’s in ITA Nos

Bench: Dr.Manish Borad & Shri Vinay Bhamoreआयकर अपील सं. / Ita Nos.476 To 480/Pun/2024 Chate Tutorials Pvt. Ltd., Vs. Acit,Tds Circle, Chate House, Plot No.4, Nashik Near N-2 Cricket Stadium, Cidco, Aurangabad – 431 003 Maharashtra Tan : Nskco1565E Appellant Respondent

22. Now taking guidance from the above observations of the Hon’ble Jurisdictional High Court and also going through the provisions of section 200A in totality, we find that so far as sub- section (1) of section 200A of the Act there is no dispute as it provides the mechanism for processing the TDS returns/statements. Sub-section (2

SHREE BHASKARACHARYA PRATISHTHAN,CHH SAMBHAJINAGAR vs. LD. DEPUTY COMMISSIONER OF INCOME TAX CPC TDS, GHAZIABAD

In the result, both the bunch of appeals filed by the respective assessee’s in ITA Nos

Bench: Dr.Manish Borad & Shri Vinay Bhamoreआयकर अपील सं. / Ita Nos.476 To 480/Pun/2024 Chate Tutorials Pvt. Ltd., Vs. Acit,Tds Circle, Chate House, Plot No.4, Nashik Near N-2 Cricket Stadium, Cidco, Aurangabad – 431 003 Maharashtra Tan : Nskco1565E Appellant Respondent

22. Now taking guidance from the above observations of the Hon’ble Jurisdictional High Court and also going through the provisions of section 200A in totality, we find that so far as sub- section (1) of section 200A of the Act there is no dispute as it provides the mechanism for processing the TDS returns/statements. Sub-section (2

CHATE TUTORIALS PVT LTD,AURANGABAD vs. ASSISTANT COMMISSIONER OF INCOME TAX, TDS CIRCLE, NASHIK, NASHIK

In the result, both the bunch of appeals filed by the respective assessee’s in ITA Nos

Bench: Dr.Manish Borad & Shri Vinay Bhamoreआयकर अपील सं. / Ita Nos.476 To 480/Pun/2024 Chate Tutorials Pvt. Ltd., Vs. Acit,Tds Circle, Chate House, Plot No.4, Nashik Near N-2 Cricket Stadium, Cidco, Aurangabad – 431 003 Maharashtra Tan : Nskco1565E Appellant Respondent

22. Now taking guidance from the above observations of the Hon’ble Jurisdictional High Court and also going through the provisions of section 200A in totality, we find that so far as sub- section (1) of section 200A of the Act there is no dispute as it provides the mechanism for processing the TDS returns/statements. Sub-section (2

SHRI BHASKARACHARYA PRATISHTHAN,CHH. SAMBHAJINAGAR vs. LD. DEPUTY COMMISSIONER OF INCOME TAX, CPC-TDS

In the result, both the bunch of appeals filed by the\nrespective assessee's in ITA Nos

22).\n1.5 The assessee Appellant, additionally submitted that the distinction\nbetween tax, interest and fees canalso be made out from the fact that the\ncharging section for tax, i.e. section 4 also mentions only income tax, TDS/TCS.\nFor interest and late fees, there are separate charging sections namely\n201(1A), 220(2) and 234E.\nIt has been also submitted

SHREE BHASKARACHARYA PRATISHTHAN,CHH SAMBHAJINAGAR vs. LD. DEPUTY COMMISSIONER OF INCOME TAX, CPC-TDS

In the result, both the bunch of appeals filed by the\nrespective assessee's in ITA Nos

22).\n1.5 The assessee Appellant, additionally submitted that the distinction\nbetween tax, interest and fees canalso be made out from the fact that the\ncharging section for tax, i.e. section 4 also mentions only income tax, TDS/TCS.\nFor interest and late fees, there are separate charging sections namely\n201(1A), 220(2) and 234E.\nIt has been also submitted

CHATE TUTORIALS PVT. LTD. AURANGABAD , AURANGABAD vs. LD. ASSISTANT COMMISSIONER OF INCOME TAX, TDS CIRCLE, NASHIK , NASHIK

In the result, both the bunch of appeals filed by the\nrespective assessee's in ITA Nos

22).\n1.5 The assessee Appellant, additionally submitted that the distinction\nbetween tax, interest and fees canalso be made out from the fact that the\ncharging section for tax, i.e. section 4 also mentions only income tax, TDS/TCS.\nFor interest and late fees, there are separate charging sections namely\n201(1A), 220(2) and 234E.\nIt has been also submitted

SHREE BHASKARACHARYA PRATISHTHAN,CHH SAMBHAJINAGAR vs. LD. DEPUTY COMMISSIONER OF INCOME TAX, GHAZIABAD

In the result, both the bunch of appeals filed by the\nrespective assessee's in ITA Nos

22).\n1.5 The assessee Appellant, additionally submitted that the distinction\nbetween tax, interest and fees canalso be made out from the fact that the\ncharging section for tax, i.e. section 4 also mentions only income tax, TDS/TCS.\nFor interest and late fees, there are separate charging sections namely\n201(1A), 220(2) and 234E.\n1.6 It has been also submitted

SHRI BHASKARACHARYA PRATISHTHAN,CHH SAMBHAJINAGAR vs. LD. DEPUTY COMMISSIONER OF INCOME TAX, CPC-TDS, CPC TDS

In the result, both the bunch of appeals filed by the\nrespective assessee's in ITA Nos

22).\n1.5 The assessee Appellant, additionally submitted that the distinction\nbetween tax, interest and fees canalso be made out from the fact that the\ncharging section for tax, i.e. section 4 also mentions only income tax, TDS/TCS.\nFor interest and late fees, there are separate charging sections namely\n201(1A), 220(2) and 234E.\n1.6 It has been also submitted

SHREE BHASKARACHARYA PRATISHTHAN,CHH SAMBHAJINAGAR vs. LD. DEPUTY COMMISSIONER OF INCOME TAX, GHAZIABAD

In the result, both the bunch of appeals filed by the\nrespective assessee's in ITA Nos

22).\n1.5 The assessee Appellant, additionally submitted that the distinction\nbetween tax, interest and fees canalso be made out from the fact that the\ncharging section for tax, i.e. section 4 also mentions only income tax, TDS/TCS.\nFor interest and late fees, there are separate charging sections namely\n201(1A), 220(2) and 234E.\nIt has been also submitted

SHREE BHASKARACHARYA PRATISHTHAN,CHH SAMBHAJINAGAR vs. LD. DEPUTY COMMISSIONER OF INCOME TAX, CPC-TDS

In the result, both the bunch of appeals filed by the\nrespective assessee's in ITA Nos

22).\n1.5\nThe assessee Appellant, additionally submitted that the distinction\nbetween tax, interest and fees canalso be made out from the fact that the\ncharging section for tax, i.e. section 4 also mentions only income tax, TDS/TCS.\nFor interest and late fees, there are separate charging sections namely\n201(1A), 220(2) and 234E.\nChate Tutorials Pvt. Ltd.and\nShree Bhaskaracharya

CHATE TUTORIALS PVT. LTD. ,AURANGABAD vs. LD. ASSISTANT COMMISSIONER OF INCOME TAX, TDS CIRCLE, NASHIK , NASHIK

In the result, both the bunch of appeals filed by the\nrespective assessee's in ITA Nos

22).\n1.5 The assessee Appellant, additionally submitted that the distinction\nbetween tax, interest and fees canalso be made out from the fact that the\ncharging section for tax, i.e. section 4 also mentions only income tax, TDS/TCS.\nFor interest and late fees, there are separate charging sections namely\n201(1A), 220(2) and 234E.\nIt has been also submitted

CHATE TUTORIALS PVT. LTD. ,AURANGABAD vs. LD. ASSISTANT COMMISSIONER OF INCOME TAX, TDS CIRCLE, NASHIK , NASHIK

In the result, both the bunch of appeals filed by the\nrespective assessee's in ITA Nos

22).\n1.5 The assessee Appellant, additionally submitted that the distinction\nbetween tax, interest and fees canalso be made out from the fact that the\ncharging section for tax, i.e. section 4 also mentions only income tax, TDS/TCS.\nFor interest and late fees, there are separate charging sections namely\n201(1A), 220(2) and 234E.\n1.6 It has been also submitted

KIRAN BABURAO JADHAV,,PUNE vs. DEPUTY COMMISSIONER OF INCOME TAX,, PUNE

In the result, appeal of assessee is allowed

Bench: Ms. Sushma Chowla, Jm & Shri Anil Chaturvedi, Am आयकर अपीऱ सं. / Ita No.311/Pun/2017 यििाारण वषा / Assessment Year : 2012-13

section 2(22)(e) of the Act. The assessee was 99% shareholder in two concerns AICPL and AESL. The concern AESL was in need of funds and AICPL advanced the funds to sister concern for payment of statutory dues and salaries & wages. The assessee had explained that sum of ₹ 44,029/- was payment against TDS

SHREE GARUDA PLANT PRODUCTS LTD,,NASHIK vs. INCOME-TAX OFFICER, WARD - 1 (2),, NASHIK

Bench: Shri S.S.Godara & Dr. Dipak P. Ripoteआयकर अपील सं. / Ita No.492/Pun/2019 िनधा"रण वष" / Assessment Year : 2015-16 Shree Garuda Plant Products The Income Tax Officer, Ltd., Vs Ward-1(2), Nashik. B-26, Additional Midc Area, Ambad, Nashik. Pan: Aaacg 0563 H Appellant/ Assessee Respondent / Revenue Assessee By Shri Nishint Gandhi – Ar Revenue By Shri M.G.Jasnani – Dr Date Of Hearing 20/07/2022 Date Of Pronouncement 14/10/2022 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)-1, Nashik For The Assessment Year 2015-16, Dated 19.02.2019, Emanating Out Of Order Under Section 143(3) Of The Income Tax Act, 1961 Dated 26.12.2017. The Assessee Has Raised The Following Grounds Of Appeal: “1.In The Facts & Circumstances Of The Case & In Law, The Learned Commissioner Of Income Tax (Appeals) - 1, Nashik ["The Cit (A)" For Short] Erred In Confirming The Order Of The Learned Income Tax Officer - 1 (2), Nashik, ["The Ao" For Short] Which Was Passed In Violation Of Principles Of Natural Justice Without Affording A Proper Opportunity Of Being Heard To The Appellant. 2. In The Facts & Circumstances Of The Case & In Law, The Ld. Cit(A) Erred In Confirming The Action Of The Ao In Invoking Section 14A R.W.R. 8D Of The Act, Whereby A Disallowance Of Rs.12,81,831/- Was Made In The Hands Of The Appellant.

Section 2(22)(e) are attracted for the loan of Rs.Rs.11,12,387/- from Kimplas Piping System Ltd to the assessee. Therefore, respectfully following the ITAT Mumbai bench decision , we hold that the AO has rightly treated loan of Rs.11,12,387/- received from Kimplas Piping System Ltd as deemed dividend. Accordingly, impugned addition is upheld. Therefore, the Ground

DIRECTOR, VJNT OBC & SBC WELFARE, MS, PUNE,,PUNE vs. ADDITIONAL COMMISSIONER OF INCOME-TAX,,

In the result, appeal of assessee is allowed

Bench: Ms. Sushma Chowla, Jm & Shri Anil Chaturvedi, Am आयकर अपीऱ सं. / Ita No.906/Pun/2016 यििाारण वषा / Assessment Year : 2011-12

TDS returns under section 272A(2)(k) of the Act. Since section 273B of the Act covers the cases of levy of penalty under section 272A(2) of the Act, then in line with the provisions of said section in case a person establishes its case of reasonable cause for not complying with the provisions of said section, then