RAJARSHI SHAHU SHIKSHAN SANSTHA INAM DHAMANI,SANGLI vs. ITO EXEMPTION, KOLHAPUR, KOLHAPUR

In the result, all the appeals filed by the assessee are partly allowed as per terms indicated hereinabove

Bench: Dr.Manish Borad & Shri Vinay Bhamoreआयकर अपील सं. / Ita Nos.1121 To 1126/Pun/2024 Assessment Years : 2012-13 To 2017-18

capital gain income under section 54E of the Act. For Rs.37,00,000/- invested in State Bank of India term deposit for 40 days up to 366

RAJARSHI SHAHU SHIKSHAN SANSTHA INAM DHAMANI,SANGLI vs. ITO EXEMPTION, KOLHAPUR

In the result, all the appeals filed by the assessee are partly allowed as per terms indicated hereinabove

Bench: Dr.Manish Borad & Shri Vinay Bhamoreआयकर अपील सं. / Ita Nos.1121 To 1126/Pun/2024 Assessment Years : 2012-13 To 2017-18

capital gain income under section 54E of the Act. For Rs.37,00,000/- invested in State Bank of India term deposit for 40 days up to 366

RAJARSHI SHAHU SHIKSHAN SANSTHA INAM DHAMANI,SANGLI vs. ITO EXEMPTION, KOLHAPUR, KOLHAPUR

In the result, all the appeals filed by the assessee are\npartly allowed as per terms indicated hereinabove

capital gain income under section 54E of\nthe Act. For Rs.37,00,000/- invested in State Bank of India term\ndeposit for 40 days up to 366

RAJARSHI SHAHU SHIKSHAN SANSTHA INAM DHAMANI,SANGLI vs. ITO EXEMPTION , KOLHAPUR, KOLHAPUR

In the result, all the appeals filed by the assessee are\npartly allowed as per terms indicated hereinabove

capital gain income under section 54E of\nthe Act. For Rs.37,00,000/- invested in State Bank of India term\ndeposit for 40 days up to 366

RAJARSHI SHAHU SHIKSHAN SANSTHA INAM DHAMANI,SANGLI vs. ITO EXEMPTION, KOLHAPUR

In the result, all the appeals filed by the assessee are\npartly allowed as per terms indicated hereinabove

capital gain income under section 54E of\nthe Act. For Rs.37,00,000/- invested in State Bank of India term\ndeposit for 40 days up to 366

ABHIJIT ASHOK BHALERAO,,PUNE vs. ASSISTANT COMMISSIONER OF INCOME-TAX,,

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

Bench: Shri D. Karunakara Rao, Am & Shri Vikas Awasthy, Jm

Capital Gains on transfer of 1/4th share of the appellant in the property situated at Final Plot No.187, C.T.S. No.851/1 Bhamburda Shivainagar Pune 411004. 5 ITA Nos. 146, 147 & 148/PUN/2015, A.Y. 2010-11 4. The appellant craves the permission to add, amend, modify, alter, revise, substitute, delete any or all grounds of appeal, if deemed necessary at the time

ASHOK DATTATRAYA BHALERAO,,PUNE vs. INCOME-TAX OFFICER,,

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

Bench: Shri D. Karunakara Rao, Am & Shri Vikas Awasthy, Jm

Capital Gains on transfer of 1/4th share of the appellant in the property situated at Final Plot No.187, C.T.S. No.851/1 Bhamburda Shivainagar Pune 411004. 5 ITA Nos. 146, 147 & 148/PUN/2015, A.Y. 2010-11 4. The appellant craves the permission to add, amend, modify, alter, revise, substitute, delete any or all grounds of appeal, if deemed necessary at the time

JAYANT DATTATRAYA BHALERAO,,PUNE vs. INCOME-TAX OFFICER,,

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

Bench: Shri D. Karunakara Rao, Am & Shri Vikas Awasthy, Jm

Capital Gains on transfer of 1/4th share of the appellant in the property situated at Final Plot No.187, C.T.S. No.851/1 Bhamburda Shivainagar Pune 411004. 5 ITA Nos. 146, 147 & 148/PUN/2015, A.Y. 2010-11 4. The appellant craves the permission to add, amend, modify, alter, revise, substitute, delete any or all grounds of appeal, if deemed necessary at the time

VINAYA ABHIJIT GAJENDRAGADKAR,PUNE vs. ITO WARD 2(3), PUNE

In the result, the appeal of the assessee for A

Bench: Dr.Manish Borad & Ms. Astha Chandraआयकर अपील सं. / Ita Nos.586 & 585/Pun/2025 Assessment Years : 2012-13 & 2014-15

366/- for A.Yrs. 2012-13 and 2014-15. Both these additions have been made by way of calculating the long term capital gain from the very same transaction wherein the assessee along with other 16 co-owners entered into Development Agreement with Om Ved Turnkey Project Developers on 29.05.2007 for the sale of immovable property situated at Village Mouje Charholi

VINAYA ABHIJIT GAJENDRAGADKAR,PUNE vs. ITO WARD 2(3), PUNE

In the result, the appeal of the assessee for A

Bench: Dr.Manish Borad & Ms. Astha Chandraआयकर अपील सं. / Ita Nos.586 & 585/Pun/2025 Assessment Years : 2012-13 & 2014-15

366/- for A.Yrs. 2012-13 and 2014-15. Both these additions have been made by way of calculating the long term capital gain from the very same transaction wherein the assessee along with other 16 co-owners entered into Development Agreement with Om Ved Turnkey Project Developers on 29.05.2007 for the sale of immovable property situated at Village Mouje Charholi

PARAS JAVERILAL JAIN,,DHULE vs. DEPUTY COMMISSIONER OF INCOME-TAX,,

In the result, the appeal of the assessee is partly allowed

Bench: Shri Anil Chaturvedi, Am

section 106 of the Indian Evidence Act and 68 of the IT Act will be that though apart from establishing the identity of the donor the assessee must establish the genuineness of the transaction as well as the creditworthiness of the donor. In view of this fact, through the appellant is able to establish the identity of the donor

PRAVIN BABANRAO TAMBE,PUNE vs. PRINCIPAL COMMISSIONER OF INCOME TAX-4, PUNE, PUNE

In the result, the appeal filed by the assessee is dismissed as not maintainable

Bench: Shri Manish Borad & Shri Vinay Bhamoreआयकर अपील सं. / Ita No.692/Pun/2023 िनधा"रण वष" / Assessment Year : 2013-14 Pravin Babanrao Tambe, Vs. Pcit, Pune-4. Sr. No.14, Shree Datta Colony, Akashwani, Hadapsar, Pune- 411028. Pan : Aimpt5087G Appellant Respondent Assessee By : Smt. Deepa Khare Revenue By : Shri Ajay Kumar Keshari Date Of Hearing : 12.12.2024 Date Of Pronouncement : 11.03.2025 आदेश / Order Per Vinay Bhamore, Jm: This Appeal Filed By The Assessee Is Directed Against The Order Dated 31.03.2021 Passed By Ld. Pr.Cit, Pune- 4 [‘Ld. Pcit’] U/S 263 Of The It Act For The Assessment Year 2013-14. 2. The Appellant Has Raised The Following Grounds Of Appeal :- “1. Ld Cit Erred In Law & On Facts In Invoking Jurisdiction Under Section 263 & Setting Aside Assessment Order For Fresh Assessment On The Ground That Assessment Has Been Framed

gains shall be computed, by deducting from the full value of the consideration received or accruing 5 as a result of the transfer of the capital asset the following amounts namely:- (i) Expenditure incurred wholly and exclusively in connection with such transfer (ii) The cost of acquisition of the asset and the cost of any improvement thereto. The assessee

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.

Capital Gains,40 ["India- Ireland DTAA"]. Article 12 of the aforesaid treaty defining "royalties" would alone be relevant to determine taxability under the DTAA, as it is more beneficial to the assessee as compared to section 9(1)(vi) of the Income-tax Act, as construed by the High Court. Here again, section 90(2) of the 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.

Capital Gains,40 ["India- Ireland DTAA"]. Article 12 of the aforesaid treaty defining "royalties" would alone be relevant to determine taxability under the DTAA, as it is more beneficial to the assessee as compared to section 9(1)(vi) of the Income-tax Act, as construed by the High Court. Here again, section 90(2) of the Income

TIBCO SOFTWARE B.V.,,PUNE vs. DEPUTY COMMISSIONER OF INCOME TAX, (IT), CIRCLE - 2,, PUNE

Appeal is allowed for statistical purposes

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

Capital Gains,40 ["IndiaIreland DTAA"]. Article 12 of the aforesaid treaty defining "royalties" would alone 7 Tibco Software B.V. A.Y. 2014-15 be relevant to determine taxability under the DTAA, as it is more beneficial to the assessee as compared to section 9(1)(vi) of the Income-tax Act, as construed by the High Court. Here again, section

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

Capital Gains, and income from other sources and deposited cash of Rs.21,40,780/- in Sant Sopan Sahakari Bank Limited during the demonetization period. Entire addition has been made by the AO on account of disbelieving the cash in hand recorded in books of accounts u/s 69A. The deeming fiction u/s 69A can be invoked, where in any financial year

DEPUTY COMMSSIONER OF INCOME-TAX,, PUNE vs. IGATE GLOBAL SOLUTIONS LTD.,, PUNE

In the result, both the appeals are partly allowed

Bench: Shri R.S. Syal & Shri Partha Sarathi Chaudhuryआयकर अपील सं. / Ita. No.342/Pun/2014 िनधा"रण वष" / Assessment Year : 2009-10

366 ITR 515 (Bom). It is further observed that this issue is now no more res integra in view of the judgment delivered by the Hon'ble Supreme Court in Godrej & Boyce Manufacturing Company Ltd. vs. DCIT (2017) 394 ITR 449 (SC), upholding the view of the lower authorities that when interest free funds in the form of share capital

ASSISTANT COMMISSIONER OF INCOME-TAX,CENTRAL CIRCLE - 2(2),, PUNE vs. M/S SINHGAD TECHNICAL EDUCATION SOCIETY (TRUST), PUNE

In the result, the appeal of the Revenue in ITA

Bench: Shri Inturi Rama Rao & Shri S. S. Viswanethra Ravisl. It(Ss)A No./ Name Of Appellant Name Of Respondent Asst. No.

366 (Madras) wherein, the Hon’ble High Court held that loose sheets picked up during search and seizure operations u/s 132 also falls within the definition of documents and it has got evidentiary value. IX. Rebutting the argument of the ld. AR that the loose sheets are simple dumb, ld. CIT-DR submits that the notings on the loose sheets