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

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, 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

NALCO WATER INDIA LTD., ,PUNE vs. ASSISTANT COMMISSIONER OF INCOME-TAX, CIRCLE - 2, PUNE

Bench: Shri S.S.Godara & Shri G.D.Padmahshaliआयकर अपील सं. / Ita No.150 /Pun/2022 िनधा"रण वष" / Assessment Year : 2013-14 Nalco Water India Private Vs The Assistant Commissioner Limited, (Formerly Known As . Of Income Tax, Circle-2, Naclo Water India Limited) Pune. S.No.238/239, 3Rd Floor, Quadra 1, Panchshil, Magarpatta Road, Sade Satra Nali, Pune – 411028. Pan: Aaaco 4994 N Appellant / Assessee Respondent /Revenue आयकर अपील सं. / Ita No. 151/Pun/2022 िनधा"रण वष" / Assessment Year : 2013-14 The Assistant Commissioner Of Vs Nalco Water India Private Income Tax, Circle-2, Pune. . Limited, S.No.238/239, 3Rd Floor, Quadra 1, Hadapsar, Magarpatta Road, Sade Satra Nali, Pune – 411028. Pan: Aaaco 4994 N Appellant / Revenue Respondent / Assessee Assessee By Shri Ketan Ved – Ar Revenue By Shri Prashant Gadekar & Shri Piyush Kumar Singh Yadav – Dr Date Of Hearing 26/08/2022 Date Of Pronouncement 07/10/2022 आदेश/ Order Per S.S.Godara, Jm: These Assessee’S & Revenue’S Cross Appeals Ita No.150 & 151/Pun/2022 For A.Y. 2013-14, Arise Against The Cit(A)-13

section 143(3) r.w.s 144C(3) of the Income Tax Act, 1961(in short “the Act”). Heard both the parties. Case files perused. 2. Delay of two days in filing of the assessee’s appeal ITA No.150/PUN/2022 stands condoned

ASSISTANT COMMISSIONER OF INCOME-TAX, CIRCLE - 2, PUNE vs. NALCO WATER INDIA LTD., , PUNE

Bench: Shri S.S.Godara & Shri G.D.Padmahshaliआयकर अपील सं. / Ita No.150 /Pun/2022 िनधा"रण वष" / Assessment Year : 2013-14 Nalco Water India Private Vs The Assistant Commissioner Limited, (Formerly Known As . Of Income Tax, Circle-2, Naclo Water India Limited) Pune. S.No.238/239, 3Rd Floor, Quadra 1, Panchshil, Magarpatta Road, Sade Satra Nali, Pune – 411028. Pan: Aaaco 4994 N Appellant / Assessee Respondent /Revenue आयकर अपील सं. / Ita No. 151/Pun/2022 िनधा"रण वष" / Assessment Year : 2013-14 The Assistant Commissioner Of Vs Nalco Water India Private Income Tax, Circle-2, Pune. . Limited, S.No.238/239, 3Rd Floor, Quadra 1, Hadapsar, Magarpatta Road, Sade Satra Nali, Pune – 411028. Pan: Aaaco 4994 N Appellant / Revenue Respondent / Assessee Assessee By Shri Ketan Ved – Ar Revenue By Shri Prashant Gadekar & Shri Piyush Kumar Singh Yadav – Dr Date Of Hearing 26/08/2022 Date Of Pronouncement 07/10/2022 आदेश/ Order Per S.S.Godara, Jm: These Assessee’S & Revenue’S Cross Appeals Ita No.150 & 151/Pun/2022 For A.Y. 2013-14, Arise Against The Cit(A)-13

section 143(3) r.w.s 144C(3) of the Income Tax Act, 1961(in short “the Act”). Heard both the parties. Case files perused. 2. Delay of two days in filing of the assessee’s appeal ITA No.150/PUN/2022 stands condoned

SANDVIK AB,PUNE vs. ACIT (INTL TAXATION), CIR-2, , PUNE

In the result, the appeal is partly allowed

Bench: Shri R.S. Syal & Shri S.S.Viswanethra Raviआयकर अपील सं. / Ita No.18/Pun/2021 "नधा"रण वष" / Assessment Year : 2017-18

3) read with sections 144C(13) of the Income-tax Act, 1961 (hereinafter also called ‘the Act’) in relation to the assessment year 2017-18. 2. The appeal is time barred by 166 days. The ld. AR stated that the delay pertains to Covid-19 Pandemic and hence, covered by the judgment of Hon’ble Supreme Court in Cognizance

TDK ELECTRONICS AG (FORMERLY KNOWN AS EPCOS AG),,NASHIK vs. ASSISTANT COMMISSIONER OF INCOME-TAX, (INTL. TAXATION), CIRCLE - 2,, PUNE

In the result, both the appeals are partly allowed

Bench: Shri R.S. Syal & Shri S.S.Viswanethra Raviआयकर अपीऱ सं. / Ita No.160/Pun/2021 निर्धारण वषा / Assessment Year : 2016-17 Tdk Electronics Ag Vs. Acit, (Formerly Known As Epcos Ag) (International C/O Epcos India Pvt. Ltd., Taxation), Plot No.E 22-25, Midc, Satpur, Circle-2, Pune Nashik – 422007 Pan: Aaace9787H Appellant Respondent आयकर अपीऱ सं. / Ita No.172/Pun/2022 निर्धारण वषा / Assessment Year : 2017-18 Tdk Electronics Ag Vs. Acit, (Formerly Known As Epcos Ag) (International C/O Epcos India Pvt. Ltd., Taxation), Plot No.E 22-25, Midc, Satpur, Circle-2, Pune Nashik – 422007 Pan: Aaace9787H Appellant Respondent

section 144C(13) of the Income-tax Act, 1961 (hereinafter also called `the Act’) in relation to the assessment years 2016-17 and 2017-18. Since both the appeals are based on similar facts and identical grounds, we are, therefore, proceeding to dispose them off by this consolidated order for the sake of convenience. A.Y. 2016-17 2. Tersely stated

TDK ELECTRONICS AG (FORMERLY KNOWN AS EPCOS AG),,NASHIK vs. ASSISTANT COMMISSIONER OF INCOME-TAX, (INTL. TAXATION), CIRCLE - 2,, PUNE

In the result, both the appeals are partly allowed

Bench: Shri R.S. Syal & Shri S.S.Viswanethra Raviआयकर अपीऱ सं. / Ita No.160/Pun/2021 निर्धारण वषा / Assessment Year : 2016-17 Tdk Electronics Ag Vs. Acit, (Formerly Known As Epcos Ag) (International C/O Epcos India Pvt. Ltd., Taxation), Plot No.E 22-25, Midc, Satpur, Circle-2, Pune Nashik – 422007 Pan: Aaace9787H Appellant Respondent आयकर अपीऱ सं. / Ita No.172/Pun/2022 निर्धारण वषा / Assessment Year : 2017-18 Tdk Electronics Ag Vs. Acit, (Formerly Known As Epcos Ag) (International C/O Epcos India Pvt. Ltd., Taxation), Plot No.E 22-25, Midc, Satpur, Circle-2, Pune Nashik – 422007 Pan: Aaace9787H Appellant Respondent

section 144C(13) of the Income-tax Act, 1961 (hereinafter also called `the Act’) in relation to the assessment years 2016-17 and 2017-18. Since both the appeals are based on similar facts and identical grounds, we are, therefore, proceeding to dispose them off by this consolidated order for the sake of convenience. A.Y. 2016-17 2. Tersely stated

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

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