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10 results for “TDS”+ Section 269clear

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Key Topics

Addition to Income8Section 143(1)(a)6TDS6Section 143(3)5Section 2745Section 143(1)4Section 404Section 92C4Section 14A4Deduction

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

ITA 294/PUN/2025[2023-24]Status: DisposedITAT Pune11 Dec 2025AY 2023-24

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

For Appellant: Shri Devendra JainFor Respondent: Shri Pramod Shahkar
Section 143(1)Section 154Section 199Section 5A

Section 5A of the Act. He further states that even assuming for convenience that TDS must be apportioned, the TDS corresponding to the apportioned income should be considered for calculating proportionate credit. Since, the income is to be apportioned equally, therefore, TDS of Rs. 10,36,269

4
Section 143(2)3
Transfer Pricing3

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

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

ITA 2270/PUN/2024[2018-19]Status: DisposedITAT Pune10 Oct 2025AY 2018-19
Section 143(1)Section 143(2)Section 143(3)Section 14ASection 36(1)(va)Section 40Section 92C

section 40(a)(ia). He\nfurther submitted that from the books of account of the asssessee it was established\nthat these were actual expenses incurred during AY 2017-18 and not the\n\"provisions for expenses” on which TDS was not deducted. He submitted that the\nassessee failed to furnish any documentary evidence that TDS was deducted during\nthe assessment

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

APAASSO MALI,PUNE vs. ITO 11(1), SWARGATE

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

ITA 1110/PUN/2025[2018-19]Status: DisposedITAT Pune28 Nov 2025AY 2018-19

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

For Appellant: Shri Suhas KulkarniFor Respondent: Shri A D Kulkarni
Section 142(1)Section 144Section 147Section 147rSection 148Section 249Section 249(2)

269, "s. 5 gives the Court a discretion which in respect of jurisdiction is to be exercised in the way in which judicial power and discretion ought to be exercised upon principles which are well understood, the words sufficient 5 ITA No.1110/PUN/2025, AY 2018-19 cause' receiving a liberal construction so as to advance substantial justice when no negligence

AGASTI SHAKARI SAKHAR KARKHANA LTD,,AHMEDNAGAR vs. ASSISTANT COMMISSIONER OF INCOME-TAX, AHMEDNAGAR CIRCLE,, AHMEDNAGAR

In the result, the appeal of assessee is allowed for statistical purpose

ITA 5/PUN/2019[2015-16]Status: DisposedITAT Pune17 Nov 2022AY 2015-16

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

For Appellant: N O N EFor Respondent: Shri Ramnath P. Murkunde
Section 40

TDS. He prayed to remand the issue to the file of AO for verification, as to whether the payee recognized the receipt from assessee as income in its income or not and placed reliance on the decision of Hon’ble High Court of Delhi in the case of Ansal Land Mark Township P. Ltd. reported in 377 ITR 635 (Delhi

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

BAPURAO RAMKISHAN KAGNE,,AURANGABAD vs. COMMISSIONER OF INCOME-TAX, AURANGABAD, AURANGABAD

In the result, appeal of the assessee is dismissed

ITA 739/PUN/2019[2008-09]Status: DisposedITAT Pune17 Oct 2022AY 2008-09

Bench: Shri S.S.Godara & Dr. Dipak P. Ripote. आयकर अपीलसं. / Ita No.739/Pun/2019 िनधा"रण वष" / Assessment Year : 2008-09 Shri Bapural Ramkishan Kagne, The Commissioner Of Prop. M/S.Sai Electricals & Vs Income Tax, Electronics, Plot No.3, Om Sai Aurangabad. Avenue, Thakre Nagar, N-2, Cidco, Aurangabad. Pan: Akwpk 3467 F Appellant/ Assessee Respondent /Revenue Assessee By None. Revenue By Shri Sardar Singh Meena - Cit Date Of Hearing 26/07/2022 Date Of Pronouncement 17/10/2022 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, Aurangabad, Dated 26.02.2014 For The A.Y. 2008-09 Under Section 263 Of The Act. The Assessee Has Raised The Following Grounds Of Appeal: “1. On The Facts & Circumstances Of The Case, The Learned Cit Was Not Justified By Giving Direction To The Ao To Give Consequential Effect To The Order By Adding Back Contract Receipts Of Rs.17,93,686/- To The Total Income Of The Assessees. 2. The Learned Cit Erred In Making Giving Direction To The Ao For Further Enquiry In Respect Of Tds To Be Deducted On Dg Rent Payment, Rather The Dg Rent Payment To Single Person Does Not Exceed Rs.1,20,000/- 3. On The Facts & Circumstances Of The Case The Learned Cit Was Not Justified In Disallowing Rs.23,269/- (Ground Is Not Forced).

Section 263

section 263 of the Act. The assessee has raised the following grounds of appeal: “1. On the facts and circumstances of the case, the learned CIT was not justified by giving direction to the AO to give consequential effect to the order by adding back contract receipts of Rs.17,93,686/- to the total income of the assessees

DCIT, SWARGATE PUNE vs. CUMMINS INDIA LTD , PUNE

In the result, appeal of the assessee bearing ITA No

ITA 1256/PUN/2023[2018-19]Status: DisposedITAT Pune04 Dec 2025AY 2018-19
Section 115JSection 143(1)Section 143(1)(a)Section 143(2)Section 143(3)Section 144C(5)Section 14ASection 250Section 80JSection 92C

TDS) reported in [2018] 100 taxmann.com 78\n(Pune - Trib.).\nA copy of the said decisions is forwarded herewith as\n\"Appendix - B\" - refer Page Nos.37 to 54 of the compilation.\nTimely filing of return of income is not a pre-requisite\nfor allowability of deduction u/s.10AA of the Act:\n9. In the instant case, the eligibility to claim

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

In the result, appeal of the assessee bearing ITA No

ITA 632/PUN/2022[2018-19]Status: DisposedITAT Pune04 Dec 2025AY 2018-19
Section 115JSection 143(1)Section 143(1)(a)Section 143(2)Section 143(3)Section 144C(5)Section 14ASection 250Section 80JSection 92C

TDS) reported in [2018] 100 taxmann.com 78\n(Pune - Trib.).\n\nA copy of the said decisions is forwarded herewith as\n\"Appendix - B\" - refer Page Nos.37 to 54 of the compilation.\n\nTimely filing of return of income is not a pre-requisite\nfor allowability of deduction u/s.10AA of the Act:\n\n9. In the instant case, the eligibility