DINESH DATTATRAY SHINDE,RATNAGIRI vs. INCOME-TAX OFFICER,CIRCLE-1, KOLHAPUR

In the result, appeal of the Assessee is allowed

Bench: Dr.Dipak P. Ripote & Shri Vinay Bhamoreआयकर अपऩल सं. / Ita Nos.2285, 2286 & 2287/Pun/2025 निर्धारण वषा / Assessment Year: 2014-15(Q3, Q2 & Q4) Dinesh Dattatray Shinde, Vs The Income Tax Officer, 1756, Jutica, Teli Ali, Circle-1, Kolhapur. Ratnagiri – 415612. Pan: Klpdo1360C Appellant/ Assessee Respondent / Revenue Assessee By Shri Anup Bipin Shaha(Virtual) & Shri Rohit Rajeev Shah Revenue By Smt Neha Thakkar (Virtual) Date Of Hearing 21/01/2026 Date Of Pronouncement 23/01/2026 आदेश/ Order Per Bench : These Threeappeals Filed By The Assessee Against The Separate Orders Of Ld.Commissioner Of Income Tax(Appeal)[Nfac], Passed Under Section 250 Of The Income Tax Act, 1961 For A.Y.2014-15- Q3, Q2 & Q4 Respectively, All Dated 28.07.2025. For The Sake Of Convenience, These Three Appeals Were Heard Together & Are Being Disposed Of By This Common Order. We Treat Appeal For A.Y.2014-

88 ITR 192 (SC). The decision of Hon’ble Karnataka High Court(supra) was followed by ITAT Pune Bench in the case of Medical Superintendent Rural Hospital, vs. DCIT, CPC(TDS) [2018] 100 taxmann.com 78. 6. In this case, Late Fee under section

DINESH DATTATRAY SHINDE,RATNAGIRI vs. INCOME-TAX OFFICER, CIRCLE-1, KOLHAUR

In the result, appeal of the Assessee is allowed

Bench: Dr.Dipak P. Ripote & Shri Vinay Bhamoreआयकर अपऩल सं. / Ita Nos.2285, 2286 & 2287/Pun/2025 निर्धारण वषा / Assessment Year: 2014-15(Q3, Q2 & Q4) Dinesh Dattatray Shinde, Vs The Income Tax Officer, 1756, Jutica, Teli Ali, Circle-1, Kolhapur. Ratnagiri – 415612. Pan: Klpdo1360C Appellant/ Assessee Respondent / Revenue Assessee By Shri Anup Bipin Shaha(Virtual) & Shri Rohit Rajeev Shah Revenue By Smt Neha Thakkar (Virtual) Date Of Hearing 21/01/2026 Date Of Pronouncement 23/01/2026 आदेश/ Order Per Bench : These Threeappeals Filed By The Assessee Against The Separate Orders Of Ld.Commissioner Of Income Tax(Appeal)[Nfac], Passed Under Section 250 Of The Income Tax Act, 1961 For A.Y.2014-15- Q3, Q2 & Q4 Respectively, All Dated 28.07.2025. For The Sake Of Convenience, These Three Appeals Were Heard Together & Are Being Disposed Of By This Common Order. We Treat Appeal For A.Y.2014-

88 ITR 192 (SC). The decision of Hon’ble Karnataka High Court(supra) was followed by ITAT Pune Bench in the case of Medical Superintendent Rural Hospital, vs. DCIT, CPC(TDS) [2018] 100 taxmann.com 78. 6. In this case, Late Fee under section

GURUNATH SHAMBHU VERNEKAR,PUNE vs. ITO, TDS-1, PUNE, PUNE

In the result, appeals of the assessee are allowed

Bench: Dr.Dipak P. Ripote & Shri Vinay Bhamoreआयकर अपील सं. / Ita Nos.136 To 141/Pun/2025 िनधा"रण वष" / Assessment Years: 2013-14 Gurunath Shambhi Vernekar, V The Income Tax Officer, Office No.113, Gagan Enclave, S Tds-1, Pune. Gangadham Road, Bibwewadi, Pune – 411037. Maharashtra. Pan: Pnego6309C Appellant/ Assessee Respondent / Revenue Assessee By Shri Sarang Gudhate & Advocate-M.Ashvini – Ar’S Revenue By Shri Ramnath P Murkunde - Dr Date Of Hearing 23/04/2025 Date Of Pronouncement 29/04/2025 आदेश/ Order Per Dr. Dipak P. Ripote, Am: These Six Appeals Filed By The Assessee Are Against The Separate Orders Of Ld.Commissioner Of Income Tax(Appeals)[Nfac], Passed Under Section 250 Of The Income Tax Act, 1961, All Dated 13.12.2024. Assessee Has Filed Identical Grounds For All These Years. Since The Issue Involved Is Common, All These Appeals Were Heard

88 ITR 192 (SC). The decision of Hon’ble Karnataka High Court(supra) was followed by ITAT Pune Bench in the case of Medical Superintendent Rural Hospital, vs. DCIT, CPC(TDS) [2018] 100 taxmann.com 78. 6. In this case, Late Fee under section

GURUNATH SHAMBHU VERNEKAR,PUNE vs. ITO, TDS-1, PUNE, PUNE

In the result, appeals of the assessee are allowed

Bench: Dr.Dipak P. Ripote & Shri Vinay Bhamoreआयकर अपील सं. / Ita Nos.136 To 141/Pun/2025 िनधा"रण वष" / Assessment Years: 2013-14 Gurunath Shambhi Vernekar, V The Income Tax Officer, Office No.113, Gagan Enclave, S Tds-1, Pune. Gangadham Road, Bibwewadi, Pune – 411037. Maharashtra. Pan: Pnego6309C Appellant/ Assessee Respondent / Revenue Assessee By Shri Sarang Gudhate & Advocate-M.Ashvini – Ar’S Revenue By Shri Ramnath P Murkunde - Dr Date Of Hearing 23/04/2025 Date Of Pronouncement 29/04/2025 आदेश/ Order Per Dr. Dipak P. Ripote, Am: These Six Appeals Filed By The Assessee Are Against The Separate Orders Of Ld.Commissioner Of Income Tax(Appeals)[Nfac], Passed Under Section 250 Of The Income Tax Act, 1961, All Dated 13.12.2024. Assessee Has Filed Identical Grounds For All These Years. Since The Issue Involved Is Common, All These Appeals Were Heard

88 ITR 192 (SC). The decision of Hon’ble Karnataka High Court(supra) was followed by ITAT Pune Bench in the case of Medical Superintendent Rural Hospital, vs. DCIT, CPC(TDS) [2018] 100 taxmann.com 78. 6. In this case, Late Fee under section

GURUNATH SHAMBHU VERNEKAR,PUNE vs. ITO, TDS-1, PUNE, PUNE

In the result, appeals of the assessee are allowed

Bench: Dr.Dipak P. Ripote & Shri Vinay Bhamoreआयकर अपील सं. / Ita Nos.136 To 141/Pun/2025 िनधा"रण वष" / Assessment Years: 2013-14 Gurunath Shambhi Vernekar, V The Income Tax Officer, Office No.113, Gagan Enclave, S Tds-1, Pune. Gangadham Road, Bibwewadi, Pune – 411037. Maharashtra. Pan: Pnego6309C Appellant/ Assessee Respondent / Revenue Assessee By Shri Sarang Gudhate & Advocate-M.Ashvini – Ar’S Revenue By Shri Ramnath P Murkunde - Dr Date Of Hearing 23/04/2025 Date Of Pronouncement 29/04/2025 आदेश/ Order Per Dr. Dipak P. Ripote, Am: These Six Appeals Filed By The Assessee Are Against The Separate Orders Of Ld.Commissioner Of Income Tax(Appeals)[Nfac], Passed Under Section 250 Of The Income Tax Act, 1961, All Dated 13.12.2024. Assessee Has Filed Identical Grounds For All These Years. Since The Issue Involved Is Common, All These Appeals Were Heard

88 ITR 192 (SC). The decision of Hon’ble Karnataka High Court(supra) was followed by ITAT Pune Bench in the case of Medical Superintendent Rural Hospital, vs. DCIT, CPC(TDS) [2018] 100 taxmann.com 78. 6. In this case, Late Fee under section

GURUNATH SHAMBHU VERNEKAR,PUNE vs. ITO, TDS-1, PUNE, PUNE

In the result, appeals of the assessee are allowed

Bench: Dr.Dipak P. Ripote & Shri Vinay Bhamoreआयकर अपील सं. / Ita Nos.136 To 141/Pun/2025 िनधा"रण वष" / Assessment Years: 2013-14 Gurunath Shambhi Vernekar, V The Income Tax Officer, Office No.113, Gagan Enclave, S Tds-1, Pune. Gangadham Road, Bibwewadi, Pune – 411037. Maharashtra. Pan: Pnego6309C Appellant/ Assessee Respondent / Revenue Assessee By Shri Sarang Gudhate & Advocate-M.Ashvini – Ar’S Revenue By Shri Ramnath P Murkunde - Dr Date Of Hearing 23/04/2025 Date Of Pronouncement 29/04/2025 आदेश/ Order Per Dr. Dipak P. Ripote, Am: These Six Appeals Filed By The Assessee Are Against The Separate Orders Of Ld.Commissioner Of Income Tax(Appeals)[Nfac], Passed Under Section 250 Of The Income Tax Act, 1961, All Dated 13.12.2024. Assessee Has Filed Identical Grounds For All These Years. Since The Issue Involved Is Common, All These Appeals Were Heard

88 ITR 192 (SC). The decision of Hon’ble Karnataka High Court(supra) was followed by ITAT Pune Bench in the case of Medical Superintendent Rural Hospital, vs. DCIT, CPC(TDS) [2018] 100 taxmann.com 78. 6. In this case, Late Fee under section

GURUNATH SHAMBHU VERNEKAR,PUNE vs. ITO, TDS-1, PUNE, PUNE

In the result, appeals of the assessee are allowed

Bench: Dr.Dipak P. Ripote & Shri Vinay Bhamoreआयकर अपील सं. / Ita Nos.136 To 141/Pun/2025 िनधा"रण वष" / Assessment Years: 2013-14 Gurunath Shambhi Vernekar, V The Income Tax Officer, Office No.113, Gagan Enclave, S Tds-1, Pune. Gangadham Road, Bibwewadi, Pune – 411037. Maharashtra. Pan: Pnego6309C Appellant/ Assessee Respondent / Revenue Assessee By Shri Sarang Gudhate & Advocate-M.Ashvini – Ar’S Revenue By Shri Ramnath P Murkunde - Dr Date Of Hearing 23/04/2025 Date Of Pronouncement 29/04/2025 आदेश/ Order Per Dr. Dipak P. Ripote, Am: These Six Appeals Filed By The Assessee Are Against The Separate Orders Of Ld.Commissioner Of Income Tax(Appeals)[Nfac], Passed Under Section 250 Of The Income Tax Act, 1961, All Dated 13.12.2024. Assessee Has Filed Identical Grounds For All These Years. Since The Issue Involved Is Common, All These Appeals Were Heard

88 ITR 192 (SC). The decision of Hon’ble Karnataka High Court(supra) was followed by ITAT Pune Bench in the case of Medical Superintendent Rural Hospital, vs. DCIT, CPC(TDS) [2018] 100 taxmann.com 78. 6. In this case, Late Fee under section

GURUNATH SHAMBHU VERNEKAR,PUNE vs. ITO, TDS-1, PUNE, PUNE

In the result, appeals of the assessee are allowed

Bench: Dr.Dipak P. Ripote & Shri Vinay Bhamoreआयकर अपील सं. / Ita Nos.136 To 141/Pun/2025 िनधा"रण वष" / Assessment Years: 2013-14 Gurunath Shambhi Vernekar, V The Income Tax Officer, Office No.113, Gagan Enclave, S Tds-1, Pune. Gangadham Road, Bibwewadi, Pune – 411037. Maharashtra. Pan: Pnego6309C Appellant/ Assessee Respondent / Revenue Assessee By Shri Sarang Gudhate & Advocate-M.Ashvini – Ar’S Revenue By Shri Ramnath P Murkunde - Dr Date Of Hearing 23/04/2025 Date Of Pronouncement 29/04/2025 आदेश/ Order Per Dr. Dipak P. Ripote, Am: These Six Appeals Filed By The Assessee Are Against The Separate Orders Of Ld.Commissioner Of Income Tax(Appeals)[Nfac], Passed Under Section 250 Of The Income Tax Act, 1961, All Dated 13.12.2024. Assessee Has Filed Identical Grounds For All These Years. Since The Issue Involved Is Common, All These Appeals Were Heard

88 ITR 192 (SC). The decision of Hon’ble Karnataka High Court(supra) was followed by ITAT Pune Bench in the case of Medical Superintendent Rural Hospital, vs. DCIT, CPC(TDS) [2018] 100 taxmann.com 78. 6. In this case, Late Fee under section

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

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

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

REXEL INDIA PRIVATE LIMITED,PUNE vs. DEPUTY COMMISSIONER OF INCOME TAX, PUNE

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

TDS credit of YAPL and ADEPL amounting to\nINR 18,88,630 and INR 7,74,946 respectively to the Appellant.\n3. Briefly stated the facts are that the assessee is a company\nincorporated under the Companies Act, 1956 on 24.01.2012. It is a\nsubsidiary of Relex Holdings Netherlands B.V. and is primarily engaged in\nthe business of automation products

DR KHANADE HOSPITAL,PUNE vs. PUNE.ITO 1, PUNE

In the result, appeal of the assessee is allowed

Bench: Shri S.S.Godara & Dr. Dipak P. Ripoteआयकर अपील सं. / Ita No.452/Pun/2024 िनधा"रण वष" / Assessment Year : 2013-14(Q3) Dr.Khande Hospital, V The Pune Ito-1, 732, A Leela Chambers, Pune- S Pune. Satara Road, Bibvewadi, Pune – 411037. Pan: Aadfd9569Q Appellant / Assessee Respondent / Revenue Assessee By None Revenue By Shri Arvind Desai – Dr Date Of Hearing 11/06/2024 Date Of Pronouncement 12/06/2024 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] Dated 29.02.2024 For The A.Y.2013-14(Q3.) The Assessee Has Raised Following Grounds Of Appeal : “1. As The Tds Return Was Filed On 06-Mar-2013 & The Fy Is 2012/13, The Provisions Of Section 234E Were Not Applicable To The Said Tds Return. The Provisions Of Sec 234E Cannot Be Applied For A Period Before 1 June 2015. Ita No.452/Pun/2024 For A.Y.2013-14(Q3) Dr.Khanade Hospital [A]

88 ITR 192 (SC). The decision of Hon’ble Karnataka High Court(supra) was followed by ITAT Pune Bench in the case of Medical Superintendent Rural Hospital, vs. DCIT, CPC(TDS) [2018] 100 taxmann.com 78. 2.5 In this case, Late Fee under section

DEPUTY COMMISSIONER OF INCOME TAX CIR 1(1), PUNE vs. EATON TECHNOLOGIES PVT. LTD.,, PUNE

Appeals are partly allowed for statistical purpose in above terms

Bench: Shri S.S.Godara & Dr. Dipak P. Ripoteआयकरअपीलसं. / Ita Nos.42 & 43/Pun/2021 िनधा"रणवष" / Assessment Years : 2015-16 & 16-17 Dcit, Circle-1(1), Pune. M/S.Eaton Technologies Pvt. Ltd., Vs Cluster C Wing-1, Eon Zone, Midc Kharadi, Knowledge Park, Plot No.1, Survey No.77, Kharadi, Pune – 411014. Pan: Aabce 4323 Q Appellant/ Assessee Respondent /Revenue Assessee By Shri Vishal Kalra & Shri Ss Tomar -Ar Revenue By Shri Sunil Kumar – Cit(Dr) Date Of Hearing 24/06/2022 Date Of Pronouncement 07/07/2022 आदेश/ Order Per S.S.Godara, Jm: These Revenue’S Twin Appeals For The Assessment Years 2015- 16 & 2016-17 Arise Against The Cit(A)-13, Pune’S Separate Orders; Both Dated 29.05.2020, Passed In Case No.Pn/Cit(A)-13/Dcit, Circle-1(2), Pune/10142/2019-20/02, Pn/Cit(A)-13/Dcit, Circle- 1(2), Pune/10142/2019-20/03 Respectively, Involving Proceedings Under Section 143(3) Of The Income Tax Act, 1961. Heard Both The Parties. Case Files Perused.

TDS thereupon. The Revenue’s case in light of the departmental authorities stand throughout is that the same represents “Royalty” for use of copyright than purchase of copyrighted article claim on behalf of the assessee’s which attracts Section 40(a)(i) disallowance. We find that instant second issue also stands adjudicated in tribunal’s earlier order (supra) in assessee

DEPUTY COMMISSIONER OF INCOME TAX CIR 1(1), PUNE vs. EATON TECHNOLOGIES PVT. LTD.,, PUNE

Appeals are partly allowed for statistical purpose in above terms

Bench: Shri S.S.Godara & Dr. Dipak P. Ripoteआयकरअपीलसं. / Ita Nos.42 & 43/Pun/2021 िनधा"रणवष" / Assessment Years : 2015-16 & 16-17 Dcit, Circle-1(1), Pune. M/S.Eaton Technologies Pvt. Ltd., Vs Cluster C Wing-1, Eon Zone, Midc Kharadi, Knowledge Park, Plot No.1, Survey No.77, Kharadi, Pune – 411014. Pan: Aabce 4323 Q Appellant/ Assessee Respondent /Revenue Assessee By Shri Vishal Kalra & Shri Ss Tomar -Ar Revenue By Shri Sunil Kumar – Cit(Dr) Date Of Hearing 24/06/2022 Date Of Pronouncement 07/07/2022 आदेश/ Order Per S.S.Godara, Jm: These Revenue’S Twin Appeals For The Assessment Years 2015- 16 & 2016-17 Arise Against The Cit(A)-13, Pune’S Separate Orders; Both Dated 29.05.2020, Passed In Case No.Pn/Cit(A)-13/Dcit, Circle-1(2), Pune/10142/2019-20/02, Pn/Cit(A)-13/Dcit, Circle- 1(2), Pune/10142/2019-20/03 Respectively, Involving Proceedings Under Section 143(3) Of The Income Tax Act, 1961. Heard Both The Parties. Case Files Perused.

TDS thereupon. The Revenue’s case in light of the departmental authorities stand throughout is that the same represents “Royalty” for use of copyright than purchase of copyrighted article claim on behalf of the assessee’s which attracts Section 40(a)(i) disallowance. We find that instant second issue also stands adjudicated in tribunal’s earlier order (supra) in assessee

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

TDS thereupon. The Revenue’s case in light of the departmental authorities stand throughout is that the same represents “Royalty” for use of copyright than purchase of copyrighted article claim on behalf of the assessee’s which attracts Section 40(a)(i) disallowance. We find that instant second issue also stands adjudicated in tribunal’s earlier order (supra) in assessee

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

TDS thereupon. The Revenue’s case in light of the departmental authorities stand throughout is that the same represents “Royalty” for use of copyright than purchase of copyrighted article claim on behalf of the assessee’s which attracts Section 40(a)(i) disallowance. We find that instant second issue also stands adjudicated in tribunal’s earlier order (supra) in assessee

DR KHANADE HOSPITAL,PUNE vs. PUNE.ITO 1, PUNE

In the result, appeal of the assessee is allowed

Bench: Shri S.S.Godara & Dr. Dipak P. Ripoteआयकर अपील सं. / Ita No.457/Pun/2024 िनधा"रण वष" / Assessment Year : 2013-14(Q4) Dr.Khande Hospital, V The Pune Ito-1, 732, A Leela Chambers, Pune- S Pune. Satara Road, Bibvewadi, Pune – 411037. Pan: Aadfd9569Q Appellant / Assessee Respondent / Revenue Assessee By None Revenue By Shri Arvind Desai – Dr Date Of Hearing 11/06/2024 Date Of Pronouncement 12/06/2024 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] Dated 29.02.2024 For The A.Y.2013-14(Q4). The Assessee Has Raised Following Grounds Of Appeal : “1. The Tds Return Was Filed On 26-Sep-2013 & The Intimation Under Sec 200 A Was Passed On 16-Oct-2016 . An Intimation Under Section 200A Raising The Demand Or Directing A Refund To The Tax Deductor Could Be Passed Within One Year. So The Intimation U/S 200 A Is Time Barred.

88 ITR 192 (SC). The decision of ITA No.457/PUN/2024 for A.Y.2013-14(Q4) Dr.Khanade Hospital [A] Hon’ble Karnataka High Court(supra) was followed by ITAT Pune Bench in the case of Medical Superintendent Rural Hospital, vs. DCIT, CPC(TDS) [2018] 100 taxmann.com 78. 2.5 In this case, Late Fee under section

VIDYA SUNIL MANE ,KOLHAPUR vs. INCOME TAX OFFICER TDS, KOLHAPUR , KOLHAPUR

In the result, appeal of the assessee is Partly Allowed

Bench: Shri S.S.Godara & Dr. Dipak P. Ripoteआयकर अपील सं. / Ita Nos.128, 129, 130 & 131/Pun/2024 िनधा"रणवष" / Assessment Years : 2013-14 & 2014-15 Vidya Sunil Mane, The Income Tax Officer, F1 Midc, Gokulshirgaon V Tds, Kolhapur. Kolhpur, Kolhapur – 416234. S Pan: Acbpm1640F Appellant/ Assessee Respondent /Revenue Assessee By Shri Mayuresh Doshi – Ar Revenue By Shri Sourabh Nayak – Addl.Cit(Dr) Date Of Hearing 19/03/2024 Date Of Pronouncement 26/03/2024 आदेश/ Order Per Dr. Dipak P. Ripote, Am: These Four Appeals Filed By The Assessee Are Against The Common Order Of Ld.Commissioner Of Income Tax(Appeals) [Nfac], Passed Under Section 250 Of The Income Tax Act, 1961 All Dated 21.11.2023. Since Issue Involved Is Same, All These Appeals Were Heard Together & Decided By This Consolidated Order. We Treat Appeal In Ita No.128/Pun/2024 For A.Y.2013-14, As A Lead Case. The Assessee For A.Y.2013-14 Has Raised The Following Grounds Of Appeal :

88 ITR 192 (SC). The decision of Hon’ble Karnataka High Court(supra) was followed by ITAT Pune Bench in the case of Medical Superintendent Rural Hospital, vs. DCIT, CPC(TDS) [2018] 100 taxmann.com 78. 2.5 In this case, Late Fee under section

VIDYA SUNIL MANE,KOLHAPUR vs. INCOME TAX OFFICER TDS, KOLHAPUR, KOLHAPUR

In the result, appeal of the assessee is Partly Allowed

Bench: Shri S.S.Godara & Dr. Dipak P. Ripoteआयकर अपील सं. / Ita Nos.128, 129, 130 & 131/Pun/2024 िनधा"रणवष" / Assessment Years : 2013-14 & 2014-15 Vidya Sunil Mane, The Income Tax Officer, F1 Midc, Gokulshirgaon V Tds, Kolhapur. Kolhpur, Kolhapur – 416234. S Pan: Acbpm1640F Appellant/ Assessee Respondent /Revenue Assessee By Shri Mayuresh Doshi – Ar Revenue By Shri Sourabh Nayak – Addl.Cit(Dr) Date Of Hearing 19/03/2024 Date Of Pronouncement 26/03/2024 आदेश/ Order Per Dr. Dipak P. Ripote, Am: These Four Appeals Filed By The Assessee Are Against The Common Order Of Ld.Commissioner Of Income Tax(Appeals) [Nfac], Passed Under Section 250 Of The Income Tax Act, 1961 All Dated 21.11.2023. Since Issue Involved Is Same, All These Appeals Were Heard Together & Decided By This Consolidated Order. We Treat Appeal In Ita No.128/Pun/2024 For A.Y.2013-14, As A Lead Case. The Assessee For A.Y.2013-14 Has Raised The Following Grounds Of Appeal :

88 ITR 192 (SC). The decision of Hon’ble Karnataka High Court(supra) was followed by ITAT Pune Bench in the case of Medical Superintendent Rural Hospital, vs. DCIT, CPC(TDS) [2018] 100 taxmann.com 78. 2.5 In this case, Late Fee under section