MR POPATRAO DASHRATHRAO SURYAWANSHI,PUNE vs. INCOME TAX OFFICER, WARD-7(4), PUNE, PUNE

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

Bench: Shri R. K. Panda & Ms. Astha Chandraassessment Year : 2017-18 Mr. Popatrao Dashrathrao Suryawanshi Ito, Ward 7(4), Pune S.No.38, Tingre Nagar, Havaldar Mala, Vs. Vishrantwadi, Pune – 411015 Pan: Adhps2643F (Appellant) (Respondent) Assessee By : Shri Suhas Bora Department By : Shri Manish Mehta, Addl.Cit Date Of Hearing : 19-01-2026 Date Of Pronouncement : 21-01-2026 O R D E R

section 54B of the Income Tax Act 1961 against the capital gain on transfer of land. 3. On facts and circumstances of the case and in law, the learned AO and the CIT (Appeals) have erred in considering year of transfer of capital asset and charging it to tax in the Assessment Year 2017-18. 4. The learned CIT (Appeals

DINESHKUMAR RAMCHANDRA TULSYAN (HUF),,NASHIK vs. INCOME-TAX OFFICER, WARD - 1(5),, NASHIK

In the result, both the appeals filed by the assessee are partly allowed

Bench: Shri R. K. Panda & Ms. Astha Chandraassessment Year : 2014-15 Dineshkumar Ramchandra Tulsyan (Huf) Ito, Ward 1(5), 214B, Laxmi Niwas, Mahatma Nagar, Vs. Nashik Nashik – 422007 Pan: Aachd5953R (Appellant) (Respondent) Assessment Year : 2014-15 Smt. Sumandevi Dineshkumar Tulsyan Ito, Ward 1(5), 214B, Laxmi Niwas, Mahatma Nagar, Vs. Nashik Nashik – 422007 Pan: Ackpt1322Q (Appellant) (Respondent)

260/- after claiming an amount of Rs.1,00,97,902/- as exempt income u/s 10(38) of the Income Tax Act, 1961 (hereinafter referred to as ‘the Act’) being the long term capital gain on sale of listed shares on which STT was paid. The case was selected for scrutiny through CASS. Accordingly, statutory notice

SMT. SUMANDEVI DINESHKUMAR TULSYAN,,NASHIK vs. INCOME-TAX OFFICER, WARD - 1(5),, NASHIK

260/- after\nclaiming an amount of Rs.1,00,97,902/- as exempt income u/s 10(38) of the\nIncome Tax Act, 1961 (hereinafter referred to as 'the Act') being the long term\ncapital gain on sale of listed shares on which STT was paid. The case was selected\nfor scrutiny through CASS. Accordingly, statutory notice

AVINASH DATTATRAY MULEY,PUNE vs. PCIT, PUNE, PUNE

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

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

Gains required thorough examination by the AO. However, prima facie it is seen that the AO erroneously allowed the "Cost of Improvement" of Rs.1.88 crore (indexed) without conducting proper verification. The assessee claimed "Cost of Improvement" on the Capital Asset i.e. Land over a span of ten years (FY 2009-10 to FY 2019-20), although no substantial documentary evidence

DINAR UMESHKUMAR MORE,MALEGAON vs. ITO WARD 1, MALEGAON

In the result, appeal of the assessee is allowed

Bench: Dr.Manish Borad & Shri Vinay Bhamore

260 ITR 491 (Bom) submitted that the transaction on the basis of which addition for long term capital gain has been made and accepted by the assessee for A.Y.2011-12 basically pertains to 3 Dinar Umeshkumar More A.Y.2003-04 and if the calculation is made then there was no taxable income for A.Y.2003-04 from the said transaction and therefore no penalty should

NATHA PANDIT RAUT,PUNE vs. DCIT, CIRCLE 2, PUNE

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

Bench: Shri R. K. Panda & Ms. Astha Chandraassessment Year : 2018-19 Natha Pandit Raut Dcit, Circle 2, Pune Office No.101, Global Port Pashankar Auto Complex, Off Mumbai Vs. Bangalore Highway, Baner, Pune - 411045 Pan: Aatpr6854L (Appellant) (Respondent)

section 14A of the Income-tax Act, 1961. He further noted that the assessee has declared Rs.4,01,10,000/- towards sale consideration received under LTCG and claimed indexation benefit totalling Rs.3,50,96,000/- and declared long term capital gain of Rs.59,14,000/- u/s 54. Since there was no response from the side of the assessee and this

PUNE MATHADI HAMAL AND OTHER MANUAL WORKERS BOARD,PUNE vs. INCOME TAX OFFICER, WARD-5(1), PUNE, PUNE

In the result, appeal of the assessee is partly allowed

Bench: Shri S.S.Godara & Dr. Dipak P. Ripoteआयकर अपील सं. / Ita No.1012/Pun/2023 िनधा"रण वष" / Assessment Year : 2018-19 Pune Mathadihamal & Other The Income Tax Manual Workers Board, V Officer, Shramashakti Bhavan, S Ward-5(1), Pune. Coomercial Plot No.1, Market Yard, Pune – 411037. Pan: Aaalp0097L Appellant/ Assessee Respondent /Revenue Assessee By Shri Vipul Joshi – Ar Revenue By Shri Ajay Kumar Keshari & Shri Rajesh Gawali– Dr’S Date Of Hearing 17/04/2024 Date Of Pronouncement 27/06/2024 आदेश/ Order Per Dr. Dipak P. Ripote, Am: This Appeal Filed By The Assessee Is Against The Orders Of Ld.Commissionerof Income Tax(Appeals)[Nfac], Under Section 250 Of The Act Dated 14.07.2023 :

capital gains. Once this principle was accepted and consistently applied and followed, the Revenue was bound by it. Unless of course it wanted to change the practice without any change in law or change in facts therein, the basis for the change in practice should have been mentioned either in the assessment order or atleast pointed out to the Tribunal

LALCHAND NARAYAN BHAKT,JALNA vs. ITO WARD 2, JALNA

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

Bench: Justice (Retd.) C V Bhadang & Shri R. K. Pandaassessment Year : 2011-12

gains and taxing the same on a protective basis. 8 2. The addition made by the learned AO and partly confirmed by the CIT(A) NFAC Delhi to the tune of Rs.25,00,000/- being the 50% share of the amount of Rs.50,00,000/- received by the appellant during the year under consideration towards advance against the agreement

DEPUTY COMMISSIONER OF INCOME TAX CIRCLE 7 PUNE, PUNE vs. KOLTE PATIL INTEGRATED TOWNSHIPS LIMITED, PUNE

In the result, both the appeals filed by the Revenue are dismissed

260 ITR\n579 held as under:\n\"in the instant case, it was dear that the assessee undertook two-fold\nactivities. It bought and sold flats. Secondly, the assessee was also\nengaged in the business of construction of buildings. The profits\nfrom both the activities were assessed under section 28. The assessee\nhad undertaken the project of construction of flats

LIQUIDHUB ANALYTICS PVT. LTD. (NOW MERGED WITH CAPGEMINI TECHNOLOGY SERVICES INDIA LTD),PUNE vs. NFAC, PUNE

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

Bench: Shri R. K. Panda & Shri Vinay Bhamoreassessment Year : 2020-21

capital gains amounting to INR 3,26,81,816 at an incorrect rate of 25% instead of 20% under section 112 of the Act and has consequently computed incorrect tax liability 7. The Lid AO has erred in computing the tax liability on income earned by the Appellant from business operations and other sources by applying at an incorrect base

MRS. SUREKHA HANUMANTRAO PAWAR,PUNE vs. ITO, WARD 14(1), PUNE, PUNE

In the result, grounds of appeal raised by the Assessee are allowed for statistical purpose

Bench: Ms.Astha Chandra & Dr.Dipak P. Ripoteआयकर अपील सं. / Ita No.225/Pun/2025 िनधा"रण वष" / Assessment Year: 2012-13 Mrs.Surekha Hanumantrao V The Income Tax Officer, Pawar, S. Ward-14(1), Pune. Sr.No.47, Sunita Nagar, Vadgaon Sheri, Pune - 411014. Maharashtra. Pan: Bhepp5383D Appellant/ Assessee Respondent / Revenue Assessee By Shri Digambar Surwase – Ar Revenue By Shri Ajitesh Kumar Meena – Addl.Cit(Dr) Date Of Hearing 10/06/2025 Date Of Pronouncement 11/06/2025 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(Appeal)[Nfac], Passed Under Section 250 Of The Income Tax Act, 1961, For The A.Y.2012-13 Dated 02.07.2024. 2. The Assessee Has Raised The Following Grounds Of Appeal :

section 250 of the Income Tax Act, 1961, for the A.Y.2012-13 dated 02.07.2024. 2. The Assessee has raised the following grounds of appeal : ITA No.225/PUN/2025 [A] “1. On facts and circumstances of case and in law, the learned CIT(A) (NFAC) erred in dismissing the appeal of appellant for non- prosecution. The appellant prays for just, proper and appropriate relief

PRIDE PURPLE BUILDERS PRIVATE LTD.,,PUNE vs. DEPUTY COMMISSIONER OF INCOME-TAX, CENTRAL CIRCLE - 1 (1),, PUNE

In the result, the appeal of the Assessee is allowed

Bench: Shri S.S.Godara & Dr. Dipak P. Ripoteआयकर अपील सं. / Ita No.699/Pun/2022 िनधा"रण वष" / Assessment Year : 2015-16 Pride Purple Builders Private The Deputy Limited, V Commissioner Income Pride House, 5Th Floor, S Tax, Circle-1(1), Pune. S.No.108/7, Shivajinagar, Near Pune University Circle, Pune – 411016. Pan: Aadcp 4286 H Appellant / Assessee Respondent / Revenue Assessee By Shri Suhas Bora – Ar Revenue By Shri M G Jasnani, Irs - Dr Date Of Hearing 03/10/2023 Date Of Pronouncement 04/10/2023 आदेश/ Order Per Dr. Dipak P. Ripote, Am: This Appeal Filed By Assessee Is Directed Against The Order Of Ld. Commissioner Of Income Tax(Appeal), Pune-11 Dated 18.08.2022For A.Y.2015-16 Emanating From The Assessment Order Under Section 143(3) Of The Income Tax Act, 1961 Dated 30.11.2017. The Assessee Has Raised The Following Grounds Of Appeal: Pride Purple Builders Private Limited [A]

260 ITR 579 (BOM). 5.1 Ld.AR submitted that the Decision of the Hon’ble SC in the case of Tuticorin Alkali Chemicals and Fertilizers Ltd Vs. CIT is distinguishable on facts and hence not applicable to the 6 Pride Purple Builders Private Limited [A] case of the assessee. Ld.AR submitted that in the case of Tuticorin Alkali Chemicals And Fertilizers

PIAGGIO VEHICLES PVT LTD ,PUNE vs. ACIT, CIRCLE 4, PUNE, PUNE

In the result, the appeal of the assessee is dismissed

Bench: Ms. Astha Chandra & Shree Dr. Dipak P. Ripote

capital of the Indian company is held by such Italian company). 5.3. Given that P&C holds more than 10% of shares of the Appellant, the tax on dividend (i.e., DOT) leviable on the Appellant cannot exceed 15 percent as per Article 11 of the Tax Treaty. 5.4. Thus, since DOT represents tax on dividend income, the Appellant should

SHIVAJI VISHNU CHAVAN,PUNE vs. UITO WARD-5(4), PUNE, PUNE

In the result, appeal of the assessee is allowed

Bench: Dr.Dipak P. Ripote & Shri Vinay Bhamoreआयकर अपील सं. / Ita No.1143/Pun/2025 िनधा"रण वष" / Assessment Year: 2011-12 Shivaji Vishnu Chavan, V The Income Tax Officer, Gomukh, 92/2, Gangtok, S Ward-5(4), Pune. Narsapur, Pune – 411004. Maharashtra. Pan: Aaspc1061B Appellant/ Assessee Respondent / Revenue Assessee By Shri Pramod S Shingte – Ar Revenue By Shri Arvind Renge – Addl.Cit(Dr) Date Of Hearing 31/07/2025 Date Of Pronouncement 13/08/2025 आदेश/ Order Per Dr. Dipak P. Ripote, Am: This Is An Appeal Filed By The Assessee Shivaji Vishnu Chavan In Form No.36 Against The Order Of Ld.Commissioner Of Income Tax(Appeal)[Nfac] Passed Under Section 250 Of The Act, Dated 31.05.2024 For The A.Y.2011-12 Emanating From Assessment Order U/S.147 R.W.S 144 Of The Income Tax Act, 1961 For A.Y.2011-12, Dated 12.12.2018. The Assessee Has Raised The Following Grounds Of Appeal :

section 50C of the Income tax Act, 1961. Hence, assessee’s share of Rs.5,42,000 is treated as his income of the year under the head Income from capital gain and unexplained money u/s. 68 of the Act and brought to tax . Penalty proceedings u/s. 274 r.w.s. 271(l)(c ) of the Act has been initiated separately by issuing

TATYASAHEB NARAYAN LAGAD,PUNE vs. ITO WARD 6(2), PUNE

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

Bench: Shri R. K. Panda & Ms. Astha Chandraassessment Year : 2017-18 Tatyasaheb Narayan Lagad Ito, Ward 6(2), Pune B-504, Crossover Country, Sinhagad Vs. Road, Wadgaon Khurd, Pune – 411041 Pan: Acypl2714L (Appellant) (Respondent) Assessee By : Shri Suhas Bora Department By : Shri Vishwas Mundhe Date Of Hearing : 20-02-2025 Date Of Pronouncement : 09-04-2025 O R D E R

260/- Revised - 18,39,236/- 2016-17 29/03/2017 11,14,780/- Original 0/- 22,80,776/- 2017-18 09/03/2018 8,07,740/- Original - 6,38,495/- 5. The Assessing Officer further noted that initially the assessee filed ITR for assessment year 2015-16 declaring income of Rs.3,20,970/- which was revised on 29.03.2017 i.e. after demonetization period. Further

VOLKSWAGEN GROUP TECHNOLOGY SOLUTIONS INDIA PVT. LTD.,PUNE vs. NATIONAL FACELESS ASSESSMENT CENTER, ASSESSMENT UNIT DELHI, DELHI

In the result, appeal of the assessee is partly allowed

Bench: Dr.Dipak P. Ripote & Shri Vinay Bhamoreआयकर अपील सं. / Ita No.1950/Pun/2024 िनधा"रण वष" / Assessment Year: 2020-21 Volkswagen Group Technology V National Faceless Solutions India Pvt. Ltd., S Assessment Center, Embassy Techzone, 9Th Floor, Assessment Unit, Delhi. 1.3 Congo Building, Rajiv Gandhi, Infotech Park, Infotech Park Hinjavadi, Pune – 411057. Maharashtra. Pan: Aafcv1368L Appellant/ Assessee Respondent / Revenue Assessee By Shri Nikhil Pathak – Ar Revenue By Shri Prakash L Pathade – Cit(Dr) Date Of Hearing 15/05/2025 Date Of Pronouncement 28/05/2025

Section 92C(1) and 92C(2) of the Act and the Ld. TPO has erred in disregarding the transfer pricing analysis carried out by the Appellant with respect to the international transaction of provision of IT services. 3. On the facts and in the circumstances of the case, and in law, the Ld. AO / Ld. TPO has erred passing