DEPUTY COMMISSIONER OF INCOME-TAX,, PUNE vs. ATLAS COPCO (INDIA) LTD.,, PUNE

In the result, the Cross objections are partly allowed in so far

Bench: Shri R.S. Syal & Shri Partha Sarathi Chaudhuryआयकर अपील सं. / Ita No.649/Pun/2013 & 1726/Pun/2014 िनधा"रण वष" / Assessment Years : 2008-09 & 2009-10 Dcit, Circle-8, Atlas Copco (India) Limited, Pune Vs. Sveanagar, Dapodi, Pune – 411 012 Pan : Aaaca4074D (Appellant) (Respondent)

2. The Cross objection for the A.Y. 2008-09 is late by 1965 days. Similar cross objection filed by the assessee for the A.Y. 2009-10 is also late by 1018 days. The assessee has moved an application for condonation of delay. The ld. AR submitted that the assessee was not properly advised by its then counsel for espousing

ANANDA GORAKHANATH PAWAR,SATARA vs. ASSESSING OFFICER, WARD 3, SATARA, SATARA

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

Bench: Shri R. K. Panda & Shri Vinay Bhamoreआयकर अपील सं. / Ita No.1796/Pun/2025 िनधा"रण वष" / Assessment Year : 2018-19 Ananda Gorakhanath Pawar, Vs. Ito, Ward-3, Satara. At Post Ambawade, Khatav, Satara- 415506. Pan : Blhpp6081R Appellant Respondent Assessee By Shri R. C. Doshi : Revenue By : Shri Milind Debaje Date Of Hearing : 28.08.2025 Date Of Pronouncement : 28.08.2025 आदेश / Order Per Vinay Bhamore, Jm: This Appeal Filed By The Assessee Is Directed Against The Order Dated 30.06.2025 Passed By Ld. Cit(A)/Nfac For The Assessment Year 2018-19. 2. The Appellant Has Filed The Following Grounds Of Appeal :- “1. The Learned Cit Has Erred Both On Facts & In Law In Dismissing The Appeal Of The Appellant By Refusing To Condone The Delay Of 26 Days On Grounds Of Period Of Limitation, Notwithstanding The Fact That Appellant Has Submitted The Application & Explained The Reasons For Delay.

delay to filing the Appeal should not be condoned especially when he had dealt with all the issues in Appellate Order. 3. The learned CIT has erred both in facts and in law in not dealing with other issues on merits. 4. The Assessment order passed u/s 147 r.w.s

DEPUTY COMMISSIONER OF INCOME-TAX vs. PERSISTENT SYSTEMS PVT. LTD.,, PUNE

In the result, the appeal of Revenue is dismissed and Cross Objections of assessee are allowed

Bench: Ms. Sushma Chowla, Jm & Shri Anil Chaturvedi, Am आयकर अपीऱ सं. / Ita No.1458/Pun/2015 यििाारण वषा / Assessment Year : 2009-10

2. The appeal filed by Revenue and Cross Objections filed by the assessee were heard together and are being disposed of by this consolidated order for the sake of convenience. 3. The Cross Objections filed by assessee are after delay of 148 days. The assessee has moved petition for condonation of delay and has explained the reason for the aforesaid

TIETO I.T. SERVICES INDIA P. LTD., .,,PUNE vs. DEPUTY COMMISSIONER OF INCOME-TAX,, PUNE

In the result, both the appeals are allowed for statistical

Bench: Shri R.S. Syal & Shri S.S. Viswanethra Raviआयकर अपील सं. / Ita No. 340/Pun/2016 िनधा"रण वष" / Assessment Year : 2011-12

144C(13) of the Income-tax Act, 1961 (hereinafter called ‘the Act’) in relation to the assessment year 2011-12. 2. The Revenue’s appeal is time-barred by 13 days. The Revenue has filed an affidavit explaining the reasons which led to the late filing of the appeal. We are satisfied with such reasons. The delay is condoned

DEPUTY COMMISSIONER OF INCOME-TAX,, PUNE vs. TIETO SOFTWARES TECHNOLOGIES LTD.,, PUNE

In the result, both the appeals are allowed for statistical

Bench: Shri R.S. Syal & Shri S.S. Viswanethra Raviआयकर अपील सं. / Ita No. 340/Pun/2016 िनधा"रण वष" / Assessment Year : 2011-12

144C(13) of the Income-tax Act, 1961 (hereinafter called ‘the Act’) in relation to the assessment year 2011-12. 2. The Revenue’s appeal is time-barred by 13 days. The Revenue has filed an affidavit explaining the reasons which led to the late filing of the appeal. We are satisfied with such reasons. The delay is condoned

ASSISTANT COMMISSIONER OF INCOME-TAX vs. M/S. MSC SOFTWARE CORPORATION OF INDIA PVT. LTD.,, PUNE

In the result, appeal of Revenue is dismissed and appeal of assessee is partly allowed

Bench: Ms. Sushma Chowla, Jm & Shri Anil Chaturvedi, Am आयकर अपीऱ सं. / Ita No.577/Pun/2015 यििाारण वषा / Assessment Year : 2010-11

144C(13) of the Income-tax Act, 1961 (in short ‘the Act’). 2. The cross appeals filed by Revenue and assessee were heard together and are being disposed of by this consolidated order for the sake of convenience. 3. The Revenue in ITA No.577/PUN/2015 has raised the following grounds of appeal:- 01. The Hon'ble Dispute Resolution Panel erred

MSC SOFTWARE CORPORATION INDIA P. LTD.,,PUNE vs. DEPUTY COMMISSIONER OF INCOME-TAX,,

In the result, appeal of Revenue is dismissed and appeal of assessee is partly allowed

Bench: Ms. Sushma Chowla, Jm & Shri Anil Chaturvedi, Am आयकर अपीऱ सं. / Ita No.577/Pun/2015 यििाारण वषा / Assessment Year : 2010-11

144C(13) of the Income-tax Act, 1961 (in short ‘the Act’). 2. The cross appeals filed by Revenue and assessee were heard together and are being disposed of by this consolidated order for the sake of convenience. 3. The Revenue in ITA No.577/PUN/2015 has raised the following grounds of appeal:- 01. The Hon'ble Dispute Resolution Panel erred

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

144C(3) dated 30.01.2020 after making the addition on account of TP adjustment of Rs.22,76,78,495/-, addition on account of commission expenditure of Rs.16,03,019/- and addition on account of difference in returned loss as per original C.O. No.14/PUN/2021 return of income filed by the assessee company on 28.11.2016. Accordingly, the Assessing Officer assessed total loss

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

144C(3) dated 30.01.2020 after making the addition on account of TP adjustment of Rs.22,76,78,495/-, addition on account of commission expenditure of Rs.16,03,019/- and addition on account of difference in returned loss as per original C.O. No.14/PUN/2021 return of income filed by the assessee company on 28.11.2016. Accordingly, the Assessing Officer assessed total loss

TASTY BITE EATABLES LTD.,,PUNE vs. DEPUTY COMMSSIONER OF INCOME-TAX,,

In the result, the appeal of the Revenue is dismissed

section 92C(2) of the Income-tax Act, 1961. Corporate Tax Grounds: Ground 5 -Disallowance of provision of Rs. 10,00,000/- and bad debts written off of' Rs. 10,14,691 On the facts and in the circumstances of the case and in law the AO has erred in disallowing: 5.1 A provision

DEPUTY COMMISSIONER OF INCOME-TAX vs. M/S. TASTY BITES EATABLES LTD.,, PUNE

In the result, the appeal of the Revenue is dismissed

section 92C(2) of the Income-tax Act, 1961. Corporate Tax Grounds: Ground 5 -Disallowance of provision of Rs. 10,00,000/- and bad debts written off of' Rs. 10,14,691 On the facts and in the circumstances of the case and in law the AO has erred in disallowing: 5.1 A provision

AHMEDNAGAR ZILHA PARISHAD SERVANT'S CO-OP CREDIT SOCIETY LTD,AHMEDNAGAR vs. INCOME TAX OFFICER, WARD-1, AHMEDNAGAR, AHMEDNAGAR

Appeal is partly allowed in above terms

Bench: Shri Satbeer Singh Godara & Shri Gd Padmahshali

144C of the Income Tax Act, 1961 (in short “the Act”). Heard both the parties. Case file perused. 2. The assessee pleads the following substantive grounds in the instant appeal : 2 ITA.No.1101/PUN./2023 3. It emerges that the assessee’s first and foremost substantive ground seeks to reverse both the learned lower authorities action denying it sec.80P deduction representing

THE INCOME TAX OFFICER, WARD-2, AHMEDNAGAR vs. KRUSHI VIDNYAN PRADHYAPAK SAHAKARI PAT SANSTHA MARYADIT, AHMEDNAGAR

Appeal is dismissed in above terms

Bench: Shri Satbeer Singh Godara & Dr. Dipak P. Ripote

144C of the Income Tax Act, 1961 (in short “the Act”). Heard both the parties. Case file perused. 2. The Revenue raises the following substantive grounds in the instant appeal : 2 I.T.A.No.701/PUN./2023 1. “On the facts and the circumstances of the case and in law, the Ld.CIT(A) erred in holding that the assessee society was eligible

M/S. TRIPLE POINT TECHNOLOGY (INDIA) PRIVATE LIMITED,,PUNE vs. DEPUTY COMMISSIONER OF INCOME-TAX,, PUNE

In the result, appeal of assessee in assessment year 2011-12 is allowed, appeal of Revenue in assessment year 2011-12 is dismissed and the appeal of assessee in assessment year 2012-13 is partly al...

Bench: Ms. Sushma Chowla, Jm & Shri Anil Chaturvedi, Am आयकर अपीऱ सं. / Ita No.581/Pun/2016 यििाारण वषा / Assessment Year : 2011-12 M/S. Triple Point Technology (India) Pvt. Ltd., Building No.3, Commerzone, Survey No.144/145, Samrat Ashok Path, Airport Road, Yerwada, अऩीऱाथी/Appellant Pune – 411006 …. Pan:Aabct8184A Vs. The Dy. Commissioner Of Income Tax, …. प्रत्यथी / Respondent Circle 7, Pune

section 143(3) r.w.s. 144C(13) of the Act. ITA Nos.581 & 628/PUN/2016 3 2. We proceed to decide the present appeals by this consolidated order for the sake of convenience. 3. First, we shall take up cross appeals filed by assessee and Revenue. 4. The assessee in ITA No.581/PUN/2016, relating to assessment year 2011-12 has raised the following grounds

M/S. TRIPLE POOINT TECHNOLOGY (INDIA) P.LTD.,,PUNE vs. DEPUTY COMMISSIONER OF INCOME-TAX,,

In the result, appeal of assessee in assessment year 2011-12 is allowed, appeal of Revenue in assessment year 2011-12 is dismissed and the appeal of assessee in assessment year 2012-13 is partly al...

Bench: Ms. Sushma Chowla, Jm & Shri Anil Chaturvedi, Am आयकर अपीऱ सं. / Ita No.581/Pun/2016 यििाारण वषा / Assessment Year : 2011-12 M/S. Triple Point Technology (India) Pvt. Ltd., Building No.3, Commerzone, Survey No.144/145, Samrat Ashok Path, Airport Road, Yerwada, अऩीऱाथी/Appellant Pune – 411006 …. Pan:Aabct8184A Vs. The Dy. Commissioner Of Income Tax, …. प्रत्यथी / Respondent Circle 7, Pune

section 143(3) r.w.s. 144C(13) of the Act. ITA Nos.581 & 628/PUN/2016 3 2. We proceed to decide the present appeals by this consolidated order for the sake of convenience. 3. First, we shall take up cross appeals filed by assessee and Revenue. 4. The assessee in ITA No.581/PUN/2016, relating to assessment year 2011-12 has raised the following grounds

DEPUTY COMMISSIONER OF INCOME-TAX vs. M/S. TRIPLE POINT TECHNLOGY INDIA PVT. LTD.,, PUNE

In the result, appeal of assessee in assessment year 2011-12 is allowed, appeal of Revenue in assessment year 2011-12 is dismissed and the appeal of assessee in assessment year 2012-13 is partly al...

Bench: Ms. Sushma Chowla, Jm & Shri Anil Chaturvedi, Am आयकर अपीऱ सं. / Ita No.581/Pun/2016 यििाारण वषा / Assessment Year : 2011-12 M/S. Triple Point Technology (India) Pvt. Ltd., Building No.3, Commerzone, Survey No.144/145, Samrat Ashok Path, Airport Road, Yerwada, अऩीऱाथी/Appellant Pune – 411006 …. Pan:Aabct8184A Vs. The Dy. Commissioner Of Income Tax, …. प्रत्यथी / Respondent Circle 7, Pune

section 143(3) r.w.s. 144C(13) of the Act. ITA Nos.581 & 628/PUN/2016 3 2. We proceed to decide the present appeals by this consolidated order for the sake of convenience. 3. First, we shall take up cross appeals filed by assessee and Revenue. 4. The assessee in ITA No.581/PUN/2016, relating to assessment year 2011-12 has raised the following grounds

DEPUTY COMMISSIONER OF INCOME-TAX, CIRCLE- 1(1), PUNE vs. M/S. BHAIRAVNATH SUGAR WORKS LTD., PUNE

In the result, the appeal is dismissed

Bench: Shri R.S. Syal & Shri S.S. Viswanethra Raviनिर्धारण वषा / Assessment Year : 2013-14 Dcit, Circle 1(1), Vs. M/S. Bhairavanath Sugar Works Ltd., Pune S.No. 21/2, Sawant Corner, Pune-Mumbai Bypass Road, Katraj, Pune. Pan: Aadcb0529M Appellant Respondent Assessee By Shri B.C. Malakar Revenue By Smt. Divya Bhajpai Date Of Hearing 10-06-2021 Date Of Pronouncement 11-06-2021 आदेश / Order Per R.S.Syal, Vp : This Appeal By The Revenue Is Directed Against The Order Dated 23.12.2019 Passed By The Ld. Cit(A) U/S.143(3) Read With Section 144C(3) Of The Income-Tax Act, 1961 (Hereinafter Also Called „The Act‟) In Relation To The Assessment Year 2013- 14. 2. This Appeal Was Filed Belatedly By 68 Days. The Ld. Dr Explained The Lockdown Due To Covid-19 As The Reason For The Late Filing Of The Appeal. The Ld. Ar Did Not Object

section 144C(3) of the Income-tax Act, 1961 (hereinafter also called „the Act‟) in relation to the assessment year 2013- 14. 2. This appeal was filed belatedly by 68 days. The ld. DR explained the lockdown due to covid-19 as the reason for the late filing of the appeal. The ld. AR did not object to the condonation

M/S. ANSYS INC,,PUNE vs. DEPUTY COMMISSIONER OF INCOME-TAX, (IT),CIRCLE -1,, PUNE

In the result, appeal of the assessee is allowed

Bench: The Tribunal. He Further Submitted That This Delay Has Been Caused Due To The Bonafide Belief That On The Concerned Day Of Filing Of The Appeal, The Tribunal Was Not Functioning But Later On They Came To Know That It Was A Working Day. Therefore, It Was Prayed By The Ld. Counsel That This One Day‟S Delay May Be Condoned Since It Is Neither Deliberate Nor Intentional & Has Been Caused Because Of Mistake Of Information & Knowledge. The Ld. D.R Did Not Raise Objection.

144C(5) of the Income-tax Act, 1961 (hereinafter referred to as “the Act”) as per the grounds of appeal on record. 2. At the very outset, the ld. Counsel for the assessee submitted that there is one day‟s delay in filing of this appeal before the Tribunal. He further submitted that this delay has been caused