VINEET PRAKASH POL,NASHIK vs. ACIT CIRCLE-1, NASHIK

In the result, appeal of the assessee is partly allowed

Bench: Dr.Dipak P. Ripote & Shri Vinay Bhamoreआयकर अपील सं. / Ita No.302/Pun/2025 िनधा"रण वष" / Assessment Year: 2015-16 Vineet Prakash Pol, V The Acit, F-16, Midc, Ambad, S. Circle-1, Nashik. Nashik – 422010. Maharashtra. Pan: Abkpp4357J Appellant/ Assessee Respondent / Revenue Assessee By Shri Sanket Joshi – Ar Revenue By Shri Vinod Pawar – Addl.Cit(Dr) Date Of Hearing 08/05/2025 Date Of Pronouncement 26/05/2025 आदेश/ Order Per Dr. Dipak P. Ripote, Am: This Is An Appeal Filed By The Assessee Against The Order Of Ld.Commssioner Of Income Tax(Appeal)[Nfac] Passed Under Section 250 Of The Act, Dated31.01.2024For The A.Y.2015-16. The Assessee Has Raised The Following Grounds Of Appeal : “1. The Learned Cit(A) Erred In Confirming The Disallowance Of Rs.13,81,195 Out Of The Total Disallowance Of Rs.30,74,834 Made By The A.O In Respect Of Interest Paid To Partnership Firms On Loans Obtained From Them Without Appreciating That The Said Disallowance Was Not Justified On Facts & In Law. 2. The Learned Cit(A) Ought To Have Appreciated That While

carry forward loss. 5.4 Accordingly, Ground No.2 is partly allowed. 6. Ground No.1 : The Assessing Officer held that Interest paid of Rs.30,74,834/- is not allowable under section 37(1) of the Act, as it is personal expenditure. The ld.AR has made written submission that he is not challenging the validity of the disallowance of interest on merits. Accordingly

DEPUTY COMMISSIONER OF INCOME TAX CENTRAL CIRCLE-2(2), PUNE vs. M/S. BILCARE LIMITED, PUNE

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

Bench: Shri Inturi Rama Rao & Shri S. S. Viswanethra Raviआयकर अपीऱ सं. / Ita No.273/Pun/2021 निर्धारण वर्ा / Assessment Year: 2016-17 Dcit, Central Circle-2(2), Vs. M/S. Bilcare Limited, Pune. 601, Icc Trade Tower, Pune- 411016. Pan : Aabcb2242F Appellant Respondent आयकर अपीऱ सं. / Ita No.334/Pun/2021 निर्धारण वर्ा / Assessment Year: 2016-17 M/S. Bilcare Limited, Vs. Dcit, Central Circle- 6Th Floor, B Wing, Icc 2(2), Pune. Trade Tower, Senapati Bapat Road, Pune- 411006. Pan : Aabcb2242F Appellant Respondent

condone the delay of 79 days. 29. The issue raised by the assessee company in the present appeal is regarding the quantum of TP adjustments made in respect of corporate guarantee. The assessee company took a plea that the transactions of providing guarantees by the assessee company to its C.O. No.14/PUN/2021 subsidiary is in the nature of shareholders activity

M/S. BILCARE LIMITED,PUNE vs. DEPUTY COMMISSIONER OF INCOME TAX CENTRAL CIRCLE-2(2), PUNE

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

Bench: Shri Inturi Rama Rao & Shri S. S. Viswanethra Raviआयकर अपीऱ सं. / Ita No.273/Pun/2021 निर्धारण वर्ा / Assessment Year: 2016-17 Dcit, Central Circle-2(2), Vs. M/S. Bilcare Limited, Pune. 601, Icc Trade Tower, Pune- 411016. Pan : Aabcb2242F Appellant Respondent आयकर अपीऱ सं. / Ita No.334/Pun/2021 निर्धारण वर्ा / Assessment Year: 2016-17 M/S. Bilcare Limited, Vs. Dcit, Central Circle- 6Th Floor, B Wing, Icc 2(2), Pune. Trade Tower, Senapati Bapat Road, Pune- 411006. Pan : Aabcb2242F Appellant Respondent

condone the delay of 79 days. 29. The issue raised by the assessee company in the present appeal is regarding the quantum of TP adjustments made in respect of corporate guarantee. The assessee company took a plea that the transactions of providing guarantees by the assessee company to its C.O. No.14/PUN/2021 subsidiary is in the nature of shareholders activity

LEARNING UNIVERSE LLP,NEW DELHI vs. DDIT , DDIT CPC BANGALURU

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

Bench: Shri R. K. Panda & Ms. Astha Chandraassessment Year : 2023-24

delay in filing of the appeal is condoned and the appeal is admitted for adjudication. 2 3. Facts of the case, in brief, are that the assessee is a Limited Liability Partnership firm and filed its return of income on 23.10.2023 declaring total income at ‘Nil’. The CP vide intimation passed u/s 143(1) of the Income

SOPAN GAHINAJI LANKE,,PUNE vs. DEPUTY COMMISSIONER OF INCOME-TAX, CPC-GHAZIABAD, GHAZIABAD

The appeals of the assessee are dismissed

carried out by the assessee over the years and we agree with the ld. CIT(A) that when the assessee was able to perform all regular activities of doing business, filing of TDS returns, then, there is no sufficient and genuine cause why he delayed in filing of these appeals for more than 6 ½ years. In the submission

SOPAN GAHINAJI LANKE,,PUNE vs. DEPUTY COMMISSIONER OF INCOME-TAX, CPC-GHAZIABAD, GHAZIABAD

The appeals of the assessee are dismissed

carried out by the assessee over the years and we agree with the ld. CIT(A) that when the assessee was able to perform all regular activities of doing business, filing of TDS returns, then, there is no sufficient and genuine cause why he delayed in filing of these appeals for more than 6 ½ years. In the submission

SOPAN GAHINAJI LANKE,,PUNE vs. DEPUTY COMMISSIONER OF INCOME-TAX, CPC-GHAZIABAD, GHAZIABAD

The appeals of the assessee are dismissed

carried out by the assessee over the years and we agree with the ld. CIT(A) that when the assessee was able to perform all regular activities of doing business, filing of TDS returns, then, there is no sufficient and genuine cause why he delayed in filing of these appeals for more than 6 ½ years. In the submission

SOPAN GAHINAJI LANKE,,PUNE vs. DEPUTY COMMISSIONER OF INCOME-TAX, CPC-GHAZIABAD, GHAZIABAD

The appeals of the assessee are dismissed

carried out by the assessee over the years and we agree with the ld. CIT(A) that when the assessee was able to perform all regular activities of doing business, filing of TDS returns, then, there is no sufficient and genuine cause why he delayed in filing of these appeals for more than 6 ½ years. In the submission

SOPAN GAHINAJI LANKE,,PUNE vs. DEPUTY COMMISSIONER OF INCOME-TAX, CPC-GHAZIABAD, GHAZIABAD

The appeals of the assessee are dismissed

carried out by the assessee over the years and we agree with the ld. CIT(A) that when the assessee was able to perform all regular activities of doing business, filing of TDS returns, then, there is no sufficient and genuine cause why he delayed in filing of these appeals for more than 6 ½ years. In the submission

SOPAN GAHINAJI LANKE,,PUNE vs. DEPUTY COMMISSIONER OF INCOME-TAX, CPC-GHAZIABAD, GHAZIABAD

The appeals of the assessee are dismissed

carried out by the assessee over the years and we agree with the ld. CIT(A) that when the assessee was able to perform all regular activities of doing business, filing of TDS returns, then, there is no sufficient and genuine cause why he delayed in filing of these appeals for more than 6 ½ years. In the submission

SOPAN GAHINAJI LANKE,,PUNE vs. DEPUTY COMMISSIONER OF INCOME-TAX, CPC-GHAZIABAD, GHAZIABAD

The appeals of the assessee are dismissed

carried out by the assessee over the years and we agree with the ld. CIT(A) that when the assessee was able to perform all regular activities of doing business, filing of TDS returns, then, there is no sufficient and genuine cause why he delayed in filing of these appeals for more than 6 ½ years. In the submission

SOPAN GAHINAJI LANKE,,PUNE vs. DEPUTY COMMISSIONER OF INCOME-TAX, CPC-GHAZIABAD, GHAZIABAD

The appeals of the assessee are dismissed

carried out by the assessee over the years and we agree with the ld. CIT(A) that when the assessee was able to perform all regular activities of doing business, filing of TDS returns, then, there is no sufficient and genuine cause why he delayed in filing of these appeals for more than 6 ½ years. In the submission

SOPAN GAHINAJI LANKE,,PUNE vs. DEPUTY COMMISSIONER OF INCOME-TAX, CPC-GHAZIABAD, GHAZIABAD

The appeals of the assessee are dismissed

carried out by the assessee over the years and we agree with the ld. CIT(A) that when the assessee was able to perform all regular activities of doing business, filing of TDS returns, then, there is no sufficient and genuine cause why he delayed in filing of these appeals for more than 6 ½ years. In the submission

SOPAN GAHINAJI LANKE,,PUNE vs. DEPUTY COMMISSIONER OF INCOME-TAX, CPC-GHAZIABAD, GHAZIABAD

The appeals of the assessee are dismissed

carried out by the assessee over the years and we agree with the ld. CIT(A) that when the assessee was able to perform all regular activities of doing business, filing of TDS returns, then, there is no sufficient and genuine cause why he delayed in filing of these appeals for more than 6 ½ years. In the submission

SOPAN GAHINAJI LANKE,,PUNE vs. DEPUTY COMMISSIONER OF INCOME-TAX, CPC-GHAZIABAD, GHAZIABAD

The appeals of the assessee are dismissed

carried out by the assessee over the years and we agree with the ld. CIT(A) that when the assessee was able to perform all regular activities of doing business, filing of TDS returns, then, there is no sufficient and genuine cause why he delayed in filing of these appeals for more than 6 ½ years. In the submission

SOPAN GAHINAJI LANKE,,PUNE vs. DEPUTY COMMISSIONER OF INCOME-TAX, CPC-GHAZIABAD, GHAZIABAD

The appeals of the assessee are dismissed

carried out by the assessee over the years and we agree with the ld. CIT(A) that when the assessee was able to perform all regular activities of doing business, filing of TDS returns, then, there is no sufficient and genuine cause why he delayed in filing of these appeals for more than 6 ½ years. In the submission

SOPAN GAHINAJI LANKE,,PUNE vs. DEPUTY COMMISSIONER OF INCOME-TAX, CPC-GHAZIABAD, GHAZIABAD

The appeals of the assessee are dismissed

carried out by the assessee over the years and we agree with the ld. CIT(A) that when the assessee was able to perform all regular activities of doing business, filing of TDS returns, then, there is no sufficient and genuine cause why he delayed in filing of these appeals for more than 6 ½ years. In the submission

SOPAN GAHINAJI LANKE,,PUNE vs. DEPUTY COMMISSIONER OF INCOME-TAX, CPC-GHAZIABAD, GHAZIABAD

The appeals of the assessee are dismissed

carried out by the assessee over the years and we agree with the ld. CIT(A) that when the assessee was able to perform all regular activities of doing business, filing of TDS returns, then, there is no sufficient and genuine cause why he delayed in filing of these appeals for more than 6 ½ years. In the submission