SIDHESH MOHAN RAIKAR,NASHIK vs. DEPUTY DIRECTOR OF INCOME TAX, CENTRALIZED PROCESSING CENTRE, BANGLORE

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

Bench: Dr.Manish Borad & Shri Vinay Bhamoreआयकर अपील सं. / Ita No.294/Pun/2025 Assessment Year : 2023-24

TDS credit corresponding to the income offered by the Appellant. The AO shall give an opportunity of being heard to the Appellant and call for requisite details. The appeal filed on Ground No 1 is Partly allowed for statistical purposes. 5.2 Ground No. 2: Levy of Interest u/s 234B & 234C: The Appellant has contested the levy of interest under section

CARRORO INDIA PRIVATE LTD.,,PUNE vs. DEPUTY COMMISSIONER OF INCOME-TAX,,

In the result, appeal of the Revenue in ITA No

Bench: Shri Inturi Rama Rao & Shri Partha Sarathi Chaudhury

section 234B of the Act. The Appellant craves leave to add, alter, vary, omit, substitute, amend or delete one or more of the above grounds of appeal on or before or at the time of hearing of the appeal, so as to enable the Hon'ble Income Tax Appellate Tribunal to dispose off the appeal according

DEPUTY COMMISSIONER OF INCOME-TAX vs. CARRARO INDIA PVT. LTD.,, PUNE

In the result, appeal of the Revenue in ITA No

Bench: Shri Inturi Rama Rao & Shri Partha Sarathi Chaudhury

section 234B of the Act. The Appellant craves leave to add, alter, vary, omit, substitute, amend or delete one or more of the above grounds of appeal on or before or at the time of hearing of the appeal, so as to enable the Hon'ble Income Tax Appellate Tribunal to dispose off the appeal according

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

234B and 234C of the Act. Each and above grounds is independent and without prejudice to the other grounds of appeal preferred by the Appellant.” 3. It emerges during the course of hearing that this tribunal’s recent common order in Revenue’s appeals ITA Nos. 42 and 43/PUN/2021 for A.Yrs. 2015-16 and 2016-17 dated

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

234B and 234C of the Act. Each and above grounds is independent and without prejudice to the other grounds of appeal preferred by the Appellant.” 3. It emerges during the course of hearing that this tribunal’s recent common order in Revenue’s appeals ITA Nos. 42 and 43/PUN/2021 for A.Yrs. 2015-16 and 2016-17 dated

NANASAHEB BHAGAWAN SASAR,PUNE vs. ITO, WARD 2(2), PUNE, PUNE

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

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

TDS credit of Rs.6,50,000/- and accordingly calculated interest u/s 234A, 234B and 234C of the Act. In response section

SUNGARD SOLUTIONS (INDIA) P. LTD.,,PUNE vs. DEPUTY COMMISSIONER OF INCOME-TAX,,

In the result, the appeal of Revenue in ITA

Bench: Shri Anil Chaturvedi, Am & Shri S.S. Viswanethra Ravi, Jm

234B and Section 234C of the Act; 4.2. On the facts and in the circumstances of the case, the Learned AO erred in initiating penalty proceedings under section 271(1)(c) of the Act on the premise that the Appellant has concealed / furnished inaccurate particulars of income, without appreciating the fact that the disallowances made by the Learned

DEPUTY COMMISSIONER OF INCOME-TAX vs. M/S. SUNGARD SOLUTIONS (I) PVT. LTD.,, PUNE

In the result, the appeal of Revenue in ITA

Bench: Shri Anil Chaturvedi, Am & Shri S.S. Viswanethra Ravi, Jm

234B and Section 234C of the Act; 4.2. On the facts and in the circumstances of the case, the Learned AO erred in initiating penalty proceedings under section 271(1)(c) of the Act on the premise that the Appellant has concealed / furnished inaccurate particulars of income, without appreciating the fact that the disallowances made by the Learned

DCIT, BANGALORE vs. M/S SUNGARD SOLUTIONS INDIA PVT. LTD.,, BANGALORE

In the result, the appeal of Revenue in ITA

Bench: Shri Anil Chaturvedi, Am & Shri S.S. Viswanethra Ravi, Jm

234B and Section 234C of the Act; 4.2. On the facts and in the circumstances of the case, the Learned AO erred in initiating penalty proceedings under section 271(1)(c) of the Act on the premise that the Appellant has concealed / furnished inaccurate particulars of income, without appreciating the fact that the disallowances made by the Learned

M/S SUNGARD SOLUTIONS (INDIA) PRIVATE LIMITED,PUNE vs. DCIT, BANGALORE

In the result, the appeal of Revenue in ITA

Bench: Shri Anil Chaturvedi, Am & Shri S.S. Viswanethra Ravi, Jm

234B and Section 234C of the Act; 4.2. On the facts and in the circumstances of the case, the Learned AO erred in initiating penalty proceedings under section 271(1)(c) of the Act on the premise that the Appellant has concealed / furnished inaccurate particulars of income, without appreciating the fact that the disallowances made by the Learned

SAMEER SHRIKANT PISE,PUNE vs. DCIT CIRCLE 12, PUNE

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

Bench: Dr. Manish Borad & Shri Vinay Bhamore

TDS credit allowed to the appellant by the CPC. Accordingly, this ground of appeal is partly allowed. Regarding the issue of charging of interest u/s 234 of the Act, it is held that charging interest under sections 234 is consequential in nature and mandatory. This has been held by the Hon'ble Supreme Court in the case of Anjum M.H.Ghaswala

SACHIN GOVIND KELKAR,PUNE vs. CIT (A), PUNE

Appeal is allowed for statistical

Bench: Shri Satbeer Singh Godara & Dr. Dipak P. Ripote

TDS unmatched and hence the same is bad in law and devoid of any merits. 6. The Assessing Officer erred in levy of interest under section 234A, 234B

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

234B and 234C of the Act.\n7.\nYour appellant craves leave to add, amend, modify alter and / or delete any of the above grounds of appeal on or before the date of hearing.\nDelay condonation :\n1.1 There is a delay of 16 days in filing appeal before this Tribunal. We have perused the submission and found that there is sufficient

M/S. VISHAY COMPONENTS INDIA PRIVATE LIMITED,,PUNE vs. ASSISTANT COMMISSIONER OF INCOME-TAX, CIRCLE - 12, PUNE

The appeal of the assessee is partly allowed for statistical purposes

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

TDS amount of INR 90,000 while computing the tax liability of the Appellant and consequential1y error in computation of interest liability under section 234C of the Act. 17. Erroneous levy of interest under section 2348 of the Act Erred in levying additional interest under section 234B

M/S. AQUATECH SYSTEMS (ASIA) PRIAVATE LTD.,,PUNE vs. DEPUTY COMMISSIONER OF INCOME-TAX,,

In the result, the appeal of assessee is partly allowed

Bench: Ms. Sushma Chowla, Jm & Shri Anil Chaturvedi, Am आयकर अपीऱ सं. / Ita No.610/Pun/2016 यििाारण वषा / Assessment Year : 2011-12

234B and 234C of the Act. 3. The issue raised in the present appeal is against transfer pricing adjustment in respect of international transactions undertaken by the assessee. 4. Briefly, in the facts of the case, the assessee was engaged in the business of providing engineering, software and technical design services with use of Computer Aided Design (CAD), Computer Aided

KAPIL ALCOTECH LLP,AURANGABAD vs. DEPUTY COMMISSIONER OF INCOME TAX CIRCLE - 1, AURANGABAD

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

Bench: Shri R. K. Panda & Ms Astha Chandraassessment Year : 2020-21

234B and 234C of the Act being mandatory and consequential in nature, is dismissed. 6. So far as the ground No.4 is concerned, the same relates to the order of the CIT(A) / NFAC in confirming the disallowance of Rs.5,90,000/- being remuneration to working partners. 7. Facts of the case in brief are that the Assessing Officer during

DCIT, SWARGATE PUNE vs. CUMMINS INDIA LTD , PUNE

In the result, appeal of the assessee bearing ITA No

234B, 234C\n& 234D if applicable. Issue demand noticed and challan accordingly. Issue Penalty\nnotice under section 274 r.w.s.270A of the Income Tax Act 1961, separately for mis-\nreporting and under-reporting of income.\nAggrieved by the assessment order, assessee now is in\nappeal ITA No.632/PUN/2022 before this Tribunal raising the\nfollowing grounds of appeal:-\n“Based on the facts

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

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

TDS. Ground No.7: On the facts and circumstances of the case and in law, the Ld. AO erred in levying interest under section 234B