DEPUTY COMMISSIONER OF INCOME-TAX CIRCLE -5, PUNE vs. SERUM INSTITUTE OF INDIA PVT LTD.,, PUNE

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

36,450/-. 5 Disallowance of sales and promotion expenditure of Rs.2,90,94,637/-. (j) Disallowance of Corporate Guarantee Commission of Rs.1,20,29,793/-. (k) Disallowance of deduction u/s 10AA of Rs.47,46,67,962/-. 4. Being aggrieved by the above disallowances, an appeal was filed before the ld. CIT(A), who vide impugned order held that

ANNASAHEB PATIL PRASHALA,,SOLAPUR vs. ASSISTANT COMMISSIONER OF INCOME-TAX, CPC-TDS,, GHAZIABAD

Appeals are allowed in above terms

Bench: Shri S.S.Godara, Jm & Shri Dr. Dipak P. Ripote, Am आयकर अपीऱ सं. / Ita No.1584 To 1586/Pun/2019 ननधधारण वषा / Assessment Year : 2013-14

iii) deemed as notice of payment under section 156 of the Act. The Finance Bill further provided that intimation generated after the proposed processing of TCS statement shall be at par with the intimation generated after processing of TDS statement and also provided that failure to pay tax specified in the intimation shall attract levy of interest as per provisions

ANNASAHEB PATIL PRASHALA,,SOLAPUR vs. ASSISTANT COMMISSIONER OF INCOME-TAX, CPC-TDS,, GHAZIABAD

Appeals are allowed in above terms

Bench: Shri S.S.Godara, Jm & Shri Dr. Dipak P. Ripote, Am आयकर अपीऱ सं. / Ita No.1584 To 1586/Pun/2019 ननधधारण वषा / Assessment Year : 2013-14

iii) deemed as notice of payment under section 156 of the Act. The Finance Bill further provided that intimation generated after the proposed processing of TCS statement shall be at par with the intimation generated after processing of TDS statement and also provided that failure to pay tax specified in the intimation shall attract levy of interest as per provisions

ANNASAHEB PATIL PRASHALA,,SOLAPUR vs. ASSISTANT COMMISSIONER OF INCOME-TAX, CPC-TDS,, GHAZIABAD

Appeals are allowed in above terms

Bench: Shri S.S.Godara, Jm & Shri Dr. Dipak P. Ripote, Am आयकर अपीऱ सं. / Ita No.1584 To 1586/Pun/2019 ननधधारण वषा / Assessment Year : 2013-14

iii) deemed as notice of payment under section 156 of the Act. The Finance Bill further provided that intimation generated after the proposed processing of TCS statement shall be at par with the intimation generated after processing of TDS statement and also provided that failure to pay tax specified in the intimation shall attract levy of interest as per provisions

B.C. BIYANI PROJECTS PVT.LTD,,BHUSAWAL vs. ASSISTANT COMMISSIONER OF INCOME-TAX, CPC- (TDS),, GHAZIABAD

Bench: Shri S.S.Godara, Jm & Shri Dr. Dipak P. Ripote, Am आयकर अपीऱ सं. / Ita No.1655 To 1665/Pun/2019 ननधधारण वषा / Assessment Year : 2013-14 To 2016-17

iii) deemed as notice of payment under section 156 of the Act. The Finance Bill further provided that intimation generated after the proposed processing of TCS statement shall be at par with the intimation generated after processing of TDS statement and also provided that failure to pay tax specified in the intimation shall attract levy of interest as per provisions

B. C. BIYANI PROJECTS PVT.LTD,,BHUSAWAL vs. ASSISTANT COMMISSIONER OF INCOME-TAX, CPC (TDS), , GHAZIABAD

Bench: Shri S.S.Godara, Jm & Shri Dr. Dipak P. Ripote, Am आयकर अपीऱ सं. / Ita No.1655 To 1665/Pun/2019 ननधधारण वषा / Assessment Year : 2013-14 To 2016-17

iii) deemed as notice of payment under section 156 of the Act. The Finance Bill further provided that intimation generated after the proposed processing of TCS statement shall be at par with the intimation generated after processing of TDS statement and also provided that failure to pay tax specified in the intimation shall attract levy of interest as per provisions

B.C. BIYANI PROJECTS PRIVATE LIMITED,,BHUSAWAL vs. ASSISTANT COMMISSIONER OF INCOME-TAX, CPC- (TDS),, GHAZIABAD

Bench: Shri S.S.Godara, Jm & Shri Dr. Dipak P. Ripote, Am आयकर अपीऱ सं. / Ita No.1655 To 1665/Pun/2019 ननधधारण वषा / Assessment Year : 2013-14 To 2016-17

iii) deemed as notice of payment under section 156 of the Act. The Finance Bill further provided that intimation generated after the proposed processing of TCS statement shall be at par with the intimation generated after processing of TDS statement and also provided that failure to pay tax specified in the intimation shall attract levy of interest as per provisions

B. C. BIYANI PROJECTS PRIVATE LIMITED,,BHUSAWAL vs. ASSISTANT COMMISSIONER OF INCOME-TAX, CPC (TDS),, GHAZIABAD

Bench: Shri S.S.Godara, Jm & Shri Dr. Dipak P. Ripote, Am आयकर अपीऱ सं. / Ita No.1655 To 1665/Pun/2019 ननधधारण वषा / Assessment Year : 2013-14 To 2016-17

iii) deemed as notice of payment under section 156 of the Act. The Finance Bill further provided that intimation generated after the proposed processing of TCS statement shall be at par with the intimation generated after processing of TDS statement and also provided that failure to pay tax specified in the intimation shall attract levy of interest as per provisions

B.C. BIYANI PROJECTS PVT.LTD,,BHUSAWAL vs. ASSISTANT COMMISSIONER OF INCOME-TAX, CPC-(TDS),- , GHAZIABAD

Bench: Shri S.S.Godara, Jm & Shri Dr. Dipak P. Ripote, Am आयकर अपीऱ सं. / Ita No.1655 To 1665/Pun/2019 ननधधारण वषा / Assessment Year : 2013-14 To 2016-17

iii) deemed as notice of payment under section 156 of the Act. The Finance Bill further provided that intimation generated after the proposed processing of TCS statement shall be at par with the intimation generated after processing of TDS statement and also provided that failure to pay tax specified in the intimation shall attract levy of interest as per provisions

B.C. BIYANI PROJECTS PVT.LTD,,BHUSAWAL vs. ASSISTANT COMMISSIONER OF INCOME-TAX, CPC (TDS),, GHAZIABAD

Bench: Shri S.S.Godara, Jm & Shri Dr. Dipak P. Ripote, Am आयकर अपीऱ सं. / Ita No.1655 To 1665/Pun/2019 ननधधारण वषा / Assessment Year : 2013-14 To 2016-17

iii) deemed as notice of payment under section 156 of the Act. The Finance Bill further provided that intimation generated after the proposed processing of TCS statement shall be at par with the intimation generated after processing of TDS statement and also provided that failure to pay tax specified in the intimation shall attract levy of interest as per provisions

B. C. BIYANI PROJECTS PVT.LTD,,BHUSAWAL vs. ASSISTANT COMMISSIONER OF INCOME-TAX, CPC- (TDS), , GHAZIABAD

Bench: Shri S.S.Godara, Jm & Shri Dr. Dipak P. Ripote, Am आयकर अपीऱ सं. / Ita No.1655 To 1665/Pun/2019 ननधधारण वषा / Assessment Year : 2013-14 To 2016-17

iii) deemed as notice of payment under section 156 of the Act. The Finance Bill further provided that intimation generated after the proposed processing of TCS statement shall be at par with the intimation generated after processing of TDS statement and also provided that failure to pay tax specified in the intimation shall attract levy of interest as per provisions

B.C. BIYANI PROJECTS PRIVATE LIMITED,,BHUSAWAL vs. ASSISTANT COMMISSIONER OF INCOME-TAX, CPC (TDS), , GHAZIABAD

Bench: Shri S.S.Godara, Jm & Shri Dr. Dipak P. Ripote, Am आयकर अपीऱ सं. / Ita No.1655 To 1665/Pun/2019 ननधधारण वषा / Assessment Year : 2013-14 To 2016-17

iii) deemed as notice of payment under section 156 of the Act. The Finance Bill further provided that intimation generated after the proposed processing of TCS statement shall be at par with the intimation generated after processing of TDS statement and also provided that failure to pay tax specified in the intimation shall attract levy of interest as per provisions

B.C. BIYANI PROJECTS PVT.LTD,,BHUSAWAL vs. ASSISTANT COMMISSIONER OF INCOME-TAX, CPC- (TDS),, GHAZIABAD

Bench: Shri S.S.Godara, Jm & Shri Dr. Dipak P. Ripote, Am आयकर अपीऱ सं. / Ita No.1655 To 1665/Pun/2019 ननधधारण वषा / Assessment Year : 2013-14 To 2016-17

iii) deemed as notice of payment under section 156 of the Act. The Finance Bill further provided that intimation generated after the proposed processing of TCS statement shall be at par with the intimation generated after processing of TDS statement and also provided that failure to pay tax specified in the intimation shall attract levy of interest as per provisions

B.C. BIYANI PROJECTS PRIVATE LIMITED,,BHUSAWAL vs. ASSISTANT COMMISSIONER OF INCOME-TAX,CPC- (TDS),, GHAZIABAD

Bench: Shri S.S.Godara, Jm & Shri Dr. Dipak P. Ripote, Am आयकर अपीऱ सं. / Ita No.1655 To 1665/Pun/2019 ननधधारण वषा / Assessment Year : 2013-14 To 2016-17

iii) deemed as notice of payment under section 156 of the Act. The Finance Bill further provided that intimation generated after the proposed processing of TCS statement shall be at par with the intimation generated after processing of TDS statement and also provided that failure to pay tax specified in the intimation shall attract levy of interest as per provisions

B.C. BIYANI PROJECTS PVT.LTD,,BHUSAWAL vs. ASSISTANT COMMISSIONER OF INCOME-TAX, CPC (TDS), , GHAZIABAD

Bench: Shri S.S.Godara, Jm & Shri Dr. Dipak P. Ripote, Am आयकर अपीऱ सं. / Ita No.1655 To 1665/Pun/2019 ननधधारण वषा / Assessment Year : 2013-14 To 2016-17

iii) deemed as notice of payment under section 156 of the Act. The Finance Bill further provided that intimation generated after the proposed processing of TCS statement shall be at par with the intimation generated after processing of TDS statement and also provided that failure to pay tax specified in the intimation shall attract levy of interest as per provisions

ARMEKA FINANCIAL CONSULTANTS PRIVATE LIMITED,PUNE vs. ACIT, CPC- TDS,, GHAZIABAD

Appeals are allowed in above terms

Bench: Shri S.S.Godara, Jm & Shri Dr. Dipak P. Ripote, Am

iii) deemed as notice of payment under section 156 of the Act. The Finance Bill further provided that intimation generated after the proposed processing of TCS statement shall be at par with the intimation generated after processing of TDS statement and also provided that failure to pay tax specified in the intimation shall attract levy of interest as per provisions

ARMEKA FINANCIAL CONSULTANTS PRIVATE LIMITED,PUNE vs. ACIT, CPC- TDS,, GHAZIABAD

Appeals are allowed in above terms

Bench: Shri S.S.Godara, Jm & Shri Dr. Dipak P. Ripote, Am

iii) deemed as notice of payment under section 156 of the Act. The Finance Bill further provided that intimation generated after the proposed processing of TCS statement shall be at par with the intimation generated after processing of TDS statement and also provided that failure to pay tax specified in the intimation shall attract levy of interest as per provisions

ARMEKA FINANCIAL CONSULTANTS PRIVATE LIMITED,PUNE vs. ACIT, CPC- TDS,, GHAZIABAD

Appeals are allowed in above terms

Bench: Shri S.S.Godara, Jm & Shri Dr. Dipak P. Ripote, Am

iii) deemed as notice of payment under section 156 of the Act. The Finance Bill further provided that intimation generated after the proposed processing of TCS statement shall be at par with the intimation generated after processing of TDS statement and also provided that failure to pay tax specified in the intimation shall attract levy of interest as per provisions

BAJAJ FINANCE LIMITED,PUNE vs. PRINCIPAL COMMISSIONER OF INCOME TAX-3, PUNE, PUNE

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

Bench: Shri R. K. Panda & Shri Vinay Bhamoreassessment Year : 2019-20 Bajaj Finance Limited Pcit-3, Pune 3Rd Floor, Panchshil Tech Park, Vs. Viman Nagar, Pune – 411014 Pan: Aabcb1518L (Appellant) (Respondent) Assessee By : Shri Percy Pardiwalla Department By : Shri Amol Khairnar, Cit-Dr Date Of Hearing : 06-01-2026 Date Of Pronouncement : 29-01-2026

TDS in Revised Return iii. High Creditors/liabilities iv. Reduction of Income in Revised Return & Claim of Refund v. Refund Claim vi. Unsecured Loans vii. Expenses Incurred for Earning Exempt Income viii. Taxability of business liability written off u/s 41 or any other section ix. Foreign Outward Remittance x. Capital Gains/Income on Sale of Property xi. Deduction from Total Income under