SALASAR WAREHOUSING PRIVATE LIMITED,PUNE vs. INOCME TAX OFFICER, WARD-6(1), PUNE, PUNE

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

Bench: Shri Partha Sarathi Chaudhuryand Dr. Dipak P. Ripoteआयकर अपील सं. / Ita No.59/Pun/2023 िनधा"रण वष" / Assessment Year : 2020-21 Salasar Warehousing Private The Income Tax Officer, Limited, V Ward-6(1), Pune. F-2,Warehouse, Sr.No.20/2A, S Near Mundhwa Bridge, Kharadi, Pune – 411014. Pan: Aamcs4834C Appellant/ Assessee Respondent /Revenue Assessee By Shri Sarvesh Kandelwal – Ar Revenue By Shri M.G.Jasnani – Dr Date Of Hearing 27/09/2023 Date Of Pronouncement 30/11/2023

87,860/- under section 43B, which includes GST payment of Rs.12,34,655/-, TDS payment of Rs.15,21,817/-, Employers

M/S PERSISTENT SYSTEMS LIMITED,PUNE vs. ASSESSMENT UNIT, INCOME-TAX DEPARTMENT, PUNE

In the result, appeal of the Assessee is Partly Allowed

Bench: Shri S.S.Godara & Dr. Dipak P. Ripoteआयकरअपीलसं. / Ita No.692/Pun/2022 िनधा"रणवष" / Assessment Year : 2018-19 M/S.Persistent Systems Assessment Unit, Income Limited, V Tax Department. “Bhageerath” 402, Senapati S Bapat Road, Pune – 411016. Pan: Aabcp 1209 Q Appellant/ Assessee Respondent /Revenue Assessee By Shri Dhanesh Bafna& Shriaditya Vaidya– Ar’S Revenue By Shri Suhas Kulkarni - Irs Addl Commissioner Of Income Tax Date Of Hearing 26/09/2023 Date Of Pronouncement 02/11/2023 आदेश/ Order Per Dr. Dipak P. Ripote, Am: This Appeal Filed By The Assessee Is Directed Against The Assessment Order, Dated 20.07.2022 Under Section 143(3) R.W.S. 144C(13) Read With Section 144B Of The Income Tax Act, 1961 For A.Y.2018-19. The Assessee Has Raised The Following Grounds Of Appeal: “Ground 1: Order Is Invalid / Non Est  On The Facts & In The Circumstances Of The Case & In Law, The Assessment Unit (‘Au’) Has Erred In Passing The Draft Assessment M/S.Persistent Systems Limited [A]

section 90 of the Act for an amount of INR 3,99,87,795 based on the TDS certificates received

SHAMKANT KESHAV KOTKAR (PROP. NANDAN BUILDERS),PUNE vs. PR. COMMISSIONER OF INCOME TAX (CENTRAL), PUNE

In the result, appeal of the assessee is allowed

Bench: SHRI VINAY BHAMORE (Judicial Member)

section 40(a)(i) of the Act. The Assessing Officer disallowed interest on TDS of Rs.1,189/- and added Rs.1,189/- to the returned income. Ld.AR submitted that A.Y.2017-18 was unabated assessment. Therefore, addition could have been made only based on incriminating documents. Since there were no incriminating documents for A.Y.2017-18, Assessing Officer has not made any addition. Pr.CIT issued

MAHARASHTRA GRAMIN BANK,AURANGABAD vs. COMMISSIONER OF INCOME TAX (APPEALS), DELHI

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

Bench: Shri R. K. Panda & Shri Vinay Bhamoreआयकर अपील सं. / Ita No.1485/Pun/2024 िनधा"रण वष" / Assessment Year : 2020-21 Maharashtra Gramin Bank, Vs. Cit(A), Delhi. Plot No.42, Gut No.33 (Part) Village- Golwadi, Growth Centre, Waluj Mahanagar Iv, Cidco, Aurangabad- 431010. Pan : Aacam8494M Appellant Respondent Assessee By : Shri Ramesh Magar Revenue By : Shri Uma Shankar Prasad Date Of Hearing : 21.11.2024 Date Of Pronouncement : 20.12.2024 आदेश / Order Per Vinay Bhamore, Jm: This Appeal Filed By The Assessee Is Directed Against The Order Dated 14.05.2024 Passed By Ld. Cit(A)/Nfac For The Assessment Year 2020-21. 2. The Appellant Has Raised The Following Grounds Of Appeal :- “1 Erroneous Addition Of Rs. 87,73,904/- I. The Ld. Assessing Officer & The Commissioner (Appeals) Erred In Making & Upholding The Addition Of Rs. 87,73,904/- Without Considering The Appellant'S Explanation That This Amount Is Already Included Under The Head Income From Business Or Profession. The Addition Is Based Solely On The Tds Schedule Without Verifying The Classification Of Income In The Itr, Which Was Incorrectly Classified Due To A Software Error. In The Complex Labyrinth Of Income Tax Law, The Principle Of Finality Serves As A Cornerstone

87,73,904/- made in the assessment order under section 143(3) read with section 144B of the Income Tax Act, 1961. 5 5. The appellant reserves the right to add. amend or alter any of the grounds of appeal before or at the time of hearing. 6. 6. In the light of the facts and circumstances mentioned above

INCOME TAX OFFICER, WARD-9(3), PUNE, PUNE vs. LALIT RAGHUNATHRAO SHINDE , PUNE

87,08,845) actually pertained to\nDMSPL due to merger/take over/joint venture of the appellant's business by DMSPL\nw.e.f. 01.03.2008 though TDS was continued to be deducted by the parties\nconcerned in the appellant's PAN as per the past practice. The appellant has\ncontended that these receipts were transferred by the appellant to DMSPL by\npassing journal entries

REKHA KISHORE BARI,DHULE vs. ASSESSING OFFICER-NFAC, DELHI

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

Bench: Dr.Dipak P. Ripote & Shri Vinay Bhamoreआयकर अपील सं. / Ita No.1667/Pun/2024 िनधा"रण वष" / Assessment Year: 2020-21 Rekha Kishore Bari, V The Assessing Officer- Datta Bari Bhavan, S Nfac. Opp.Rana Pratap Statute, Dhule – 424001. Pan: Abepb3597J Appellant/ Assessee Respondent / Revenue Assessee By Shri Bhuvanesh Kankani – Ar Revenue By Shri Sandeep P Sathe – Jcit(Dr) Date Of Hearing 09/12/2024 Date Of Pronouncement 27/01/2025 आदेश/ Order Per Dr. Dipak P. Ripote, Am: This Is An Appeal Filed By The Assessee Against The Order Of Ld.Commissioner Of Income Tax(Appeals)[Nfac] For Assessment Year 2020-21 Dated 19.07.2024 Passed U/Sec.250 Of The Income Tax Act, 1961, Emanating From The Assessment Order U/S 143(3) R.W.S. 144B Of The Act, Dated 31/08/2022. The Assessee Has Raised The Following Grounds Of Appeal :

87,800/- and agricultural income of Rs.20,000/-. The said return was processed under section 143(1) of the Act. Then, assessee filed Revised return on 21/05/2021 declaring Total Income at Rs.11,19,950/-. The assessee’s case was selected for scrutiny, accordingly various notices were issued. Assessee partially complied the notices. 4.2 The main issue in this case

LATA MANGESHKAR MEDICAL FOUNDATION,ERANDWANE,PUNE vs. DCIT-EXEMPTIONS-PUNE, SWARGATE,PUNE

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

Bench: Shri Partha Sarathi Chaudhury & Dr. Dipak P. Ripotelata Mangeshkar Medical Vs Dcit (Exemptions), Foundation, Deenanath Pune. Mangeshkar Hospital, D.No. 8,13, Erandwane, Pune (Mh) Pan: Aaatl 1944 N Appellant Respondent Assessee By : Shri Nikhil S. Pathak, Adv. Revenue By : Shri Ramnath P. Murkunde,Dr Date Of Hearing : 01/04/2024 Date Of Pronouncement : 03/04/2024 Order Per Partha Sarathi Chaudhury, Jm: This Appeal Preferred By The Assessee Emanates From The Order Of National Faceless Appeal Centre [Nfac], Delhi, Dated 11.08.2023 For A.Y.2018-19 As Per The Following Grounds Of Appeal:-

87,117/-” and “as computed u/sec. 143(1) Rs. 8,86,77,134/-”. Further, in column No.55, there is interest u/sec. 244A on refund given at Rs.88,67,710/- in the said intimation and similarly in the assessment order u/sec. 143(3) dated 28/01/2021 there is TDS amount of Rs.8,86,78,873/- and the interest u/sec. 244A

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 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

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

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

SHRI MANOJ MADANLAL CHHAJED,PUNE vs. ASSISTANT COMMISSIONER OF INCOME TAX, CIRCLE -1(1)PUNE, PUNE

In the result, the appeal filed by the assessee in ITA

Bench: Shri Inturi Rama Rao & Shri S. S. Viswanethra Raviआयकर अपील सं. / It(Ss)A Nos.91 To 96/Pun/2022 िनधा"रण वष" / Assessment Years : 2012-13 To 2017-18 Shri Manoj Madanlal Vs. Acit, Central Circle- Chhajed, 1(1), Pune. 601, A-8 Building, Karishma Housing Society, Near Sangam Press, Kothrud, Pune- 411029. Pan : Aalpc4991M Appellant Respondent आयकर अपील सं. / It(Ss)A Nos.97 & 98/Pun/2022 िनधा"रण वष" / Assessment Years : 2012-13 & 2015-16 Acit, Circle-1(1), Pune. Vs. Shri Manoj Madanlal Chhajed, 601, A-8 Building, Karishma Housing Society, Near Sangam Press, Kothrud, Pune- 411029. Pan : Aalpc4991M Appellant Respondent आयकर अपील सं. / Ita No.725/Pun/2022 िनधा"रण वष" / Assessment Year: 2018-19 Shri Manoj Madanlal Vs. Acit, Circle-1(1), Pune. Chhajed, 601, A-8 Building, Karishma Housing Society, Near Sangam Press, Kothrud, Pune- 411029. Pan : Aalpc4991M Appellant Respondent

TDS. Thus, he submits that the appellant had discharged the onus lying upon it in terms of provisions of section 19 IT(SS)A Nos.91 to 96/PUN/2022 IT(SS)A Nos.97 & 98/PUN/2022 68 of the Act. In the circumstances, the AO was not justified in making the addition of unsecured loans. E. As regards, the addition made on account

DY. COMMISSIONER OF INCOME TAX, PUNE vs. DILIP MOTILALJI CHORDIA, PUNE

In the result, the appeal filed by the Revenue as well as\nthe Cross Objection filed by the assessee are allowed for\nstatistical purposes

TDS) v. Tushira Industries [2025] 168\ntaxmann.com 169 (Karnataka), wherein it was held that the income-\ntax exemption provided under Section 96 of the RFCTLARR Act is\nrestricted only to the compensation or awards made under the\nprovisions of the said Act itself. The Hon'ble Court observed that the\nwording of Section 96 \"made under this Act\" is explicit

DY. COMMISSIONER OF INCOME TAX, CIRCLE-1(1), PUNE, PUNE vs. MUKUND MANOHAR SANGAMNERKAR, PUNE

In the result, the cross objection filed by the assessee in C

Bench: Shri R. K. Panda & Shri Vinay Bhamoreआयकर अपील सं. / Ita No.1092/Pun/2023 िनधा"रण वष" / Assessment Year: 2017-18 Dcit, Circle-1(1), Pune. Vs. Mukund Manohar Sangamnerkar, 210/B, Amogh, Opp. Ganjave Chowk, Navi Peth, Near Lokmanya Wachanalay, Pune- 411030. Pan : Adxps4789A Appellant Respondent C.O. No.09/Pun/2024 (Arising Out Of Ita No.1092/Pun/2023) िनधा"रण वष" / Assessment Year: 2017-18 Mukund Manohar Vs. Dcit, Circle-1(1), Pune. Sangamnerkar, 210/B, Amogh, Opp. Ganjave Chowk, Navi Peth, Near Lokmanya Wachanalay, Pune- 411030. Pan : Adxps4789A Appellant Respondent Revenue By : Shri Ramnath P. Murkunde Assessee By : Shri Abhay A. Avchat Date Of Hearing : 06.08.2024 Date Of Pronouncement : 16.10.2024 आदेश / Order Per Vinay Bhamore, Jm: This Appeal Filed By The Revenue Is Directed Against The Order Dated 24.08.2023 Passed By Ld. Cit(A)/Nfac For The Assessment

section 68 gets invoked? 2) Whether on the facts and the circumstances of the case and in law, the Ld. CIT(A) erred in deleting the addition made by the AO u/s 69 of the Act (inadvertently mentioned as u/s 68 in assessment order) on account of the FD/investments not recorded in the books of account, without considering the fact

VEENA INDUSTRIES PVT LTD,PUNE vs. DCIT CENTRAL CIRCLE2(1, PUNE

In the result, the assessee's appeal is allowed

Bench: Shri R. K. Panda & Shri Vinay Bhamore

87,80,162/- were made, subsequently Ld. CIT(A) vide order dated 28.10.2019 deleted the addition of Rs.14,44,27,434/- accordingly quantum addition of only Rs.1,43,52,728/- was sustained. However, we find that the penalty u/s 271(1)(c) of the IT Act was calculated on quantum addition of Rs.1

VEENA INDUSTRIES PVT LTD,PUNE vs. DCIT CENTRAL CIRCLE2(1), PUNE

In the result, the assessee's appeal is allowed

Bench: Shri R. K. Panda & Shri Vinay Bhamore

87,80,162/- were made, subsequently Ld. CIT(A) vide order dated 28.10.2019 deleted the addition of Rs.14,44,27,434/- accordingly quantum addition of only Rs.1,43,52,728/- was sustained. However, we find that the penalty u/s 271(1)(c) of the IT Act was calculated on quantum addition of Rs.1

VEENA INDUSTRIES PVT LTD,PUNE vs. DCIT CENTRAL CIRCLE2(1), PUNE

In the result, the assessee's appeal is allowed

Bench: Shri R. K. Panda & Shri Vinay Bhamore

87,80,162/- were made, subsequently Ld. CIT(A) vide order dated 28.10.2019 deleted the addition of Rs.14,44,27,434/- accordingly quantum addition of only Rs.1,43,52,728/- was sustained. However, we find that the penalty u/s 271(1)(c) of the IT Act was calculated on quantum addition of Rs.1

VEENA INDUSTRIES PVT LTD,PUNE vs. DCIT CENTRAL CIRCLE2(1), PUNE

In the result, the assessee's appeal is allowed

Bench: Shri R. K. Panda & Shri Vinay Bhamore

87,80,162/- were made, subsequently Ld. CIT(A) vide order dated 28.10.2019 deleted the addition of Rs.14,44,27,434/- accordingly quantum addition of only Rs.1,43,52,728/- was sustained. However, we find that the penalty u/s 271(1)(c) of the IT Act was calculated on quantum addition of Rs.1

DCIT, SWARGATE PUNE vs. CUMMINS INDIA LTD , PUNE

In the result, appeal of the assessee bearing ITA No

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

WATERSHED ORGANISATION TRUST,AHMEDNAGAR vs. ACIT EXEMPTION CIRCLE, AURANGABAD

In the result, the appeal of the assessee is allowed for statistical\npurposes

TDS\nwhich clearly indicated that the assessee was involved in business\nactivity and that the assessee had not maintained separate books of\naccounts for business income, thereby violating section 11(4A) of the\nAct.\niii.\nadding to declared income Rs.8.53,50,000/- claimed by the assessee\nas deduction u/s 11(2) on account of accumulation of income out of\nthe