MATSYODARI SHIKSHAN SANSTHAS ANKUSHRAO TOPE JUNIOR COLLEGE, JALNA,JALNA vs. INCOME TAX OFFICER TDS, AURANGABAD

Bench: Shri R. K. Panda & Ms. Astha Chandra

9. Section 3 of the Limitation Act in no uncertain terms lays down that no suit, appeal or application instituted, preferred or made after the period prescribed shall be entertained rather dismissed even though limitation has not been set up as a defence subject to the exceptions contained in Sections 4 to 24 (inclusive) of the Limitation Act. 10. Section

MATSYODARI SHIKSHAN SANSTHAS ANKUSHRAO TOPE JUNIOR COLLEGE, JALNA,JALNA vs. INCOME TAX OFFICER TDS, AURANGABAD

Bench: Shri R. K. Panda & Ms. Astha Chandra

9. Section 3 of the Limitation Act in no uncertain terms lays down that no suit, appeal or application instituted, preferred or made after the period prescribed shall be entertained rather dismissed even though limitation has not been set up as a defence subject to the exceptions contained in Sections 4 to 24 (inclusive) of the Limitation Act. 10. Section

MATSYODARI SHIKSHAN SANSTHAS ANKUSHRAO TOPE COLLEGE, JALNA,JALNA vs. INCOME TAX OFFICER TDS, AURANGABAD

Bench: Shri R. K. Panda & Ms. Astha Chandra

9. Section 3 of the Limitation Act in no uncertain terms lays down that no suit, appeal or application instituted, preferred or made after the period prescribed shall be entertained rather dismissed even though limitation has not been set up as a defence subject to the exceptions contained in Sections 4 to 24 (inclusive) of the Limitation Act. 10. Section

DEPUTY COMMISSIONER OF INCOME TAX CIR 1(1), PUNE vs. EATON TECHNOLOGIES PVT. LTD.,, PUNE

Appeals are partly allowed for statistical purpose in above terms

Bench: Shri S.S.Godara & Dr. Dipak P. Ripoteआयकरअपीलसं. / Ita Nos.42 & 43/Pun/2021 िनधा"रणवष" / Assessment Years : 2015-16 & 16-17 Dcit, Circle-1(1), Pune. M/S.Eaton Technologies Pvt. Ltd., Vs Cluster C Wing-1, Eon Zone, Midc Kharadi, Knowledge Park, Plot No.1, Survey No.77, Kharadi, Pune – 411014. Pan: Aabce 4323 Q Appellant/ Assessee Respondent /Revenue Assessee By Shri Vishal Kalra & Shri Ss Tomar -Ar Revenue By Shri Sunil Kumar – Cit(Dr) Date Of Hearing 24/06/2022 Date Of Pronouncement 07/07/2022 आदेश/ Order Per S.S.Godara, Jm: These Revenue’S Twin Appeals For The Assessment Years 2015- 16 & 2016-17 Arise Against The Cit(A)-13, Pune’S Separate Orders; Both Dated 29.05.2020, Passed In Case No.Pn/Cit(A)-13/Dcit, Circle-1(2), Pune/10142/2019-20/02, Pn/Cit(A)-13/Dcit, Circle- 1(2), Pune/10142/2019-20/03 Respectively, Involving Proceedings Under Section 143(3) Of The Income Tax Act, 1961. Heard Both The Parties. Case Files Perused.

Delay of 32 days in filing of these appeals stands condoned since falling under Covid-19 pandemic outbreak period. ITA Nos.42 & 43/PUN/2021 for A.Y’s: 2015-16 & 16-17 DCIT Vs. M/s.Eaton Technologies Pvt. Ltd., (R) 3. The Revenue’s former appeal ITA No.42/PUN/2021 for the A.Y. 2015-16 raises the following substantive grounds: “1. The order

DEPUTY COMMISSIONER OF INCOME TAX CIR 1(1), PUNE vs. EATON TECHNOLOGIES PVT. LTD.,, PUNE

Appeals are partly allowed for statistical purpose in above terms

Bench: Shri S.S.Godara & Dr. Dipak P. Ripoteआयकरअपीलसं. / Ita Nos.42 & 43/Pun/2021 िनधा"रणवष" / Assessment Years : 2015-16 & 16-17 Dcit, Circle-1(1), Pune. M/S.Eaton Technologies Pvt. Ltd., Vs Cluster C Wing-1, Eon Zone, Midc Kharadi, Knowledge Park, Plot No.1, Survey No.77, Kharadi, Pune – 411014. Pan: Aabce 4323 Q Appellant/ Assessee Respondent /Revenue Assessee By Shri Vishal Kalra & Shri Ss Tomar -Ar Revenue By Shri Sunil Kumar – Cit(Dr) Date Of Hearing 24/06/2022 Date Of Pronouncement 07/07/2022 आदेश/ Order Per S.S.Godara, Jm: These Revenue’S Twin Appeals For The Assessment Years 2015- 16 & 2016-17 Arise Against The Cit(A)-13, Pune’S Separate Orders; Both Dated 29.05.2020, Passed In Case No.Pn/Cit(A)-13/Dcit, Circle-1(2), Pune/10142/2019-20/02, Pn/Cit(A)-13/Dcit, Circle- 1(2), Pune/10142/2019-20/03 Respectively, Involving Proceedings Under Section 143(3) Of The Income Tax Act, 1961. Heard Both The Parties. Case Files Perused.

Delay of 32 days in filing of these appeals stands condoned since falling under Covid-19 pandemic outbreak period. ITA Nos.42 & 43/PUN/2021 for A.Y’s: 2015-16 & 16-17 DCIT Vs. M/s.Eaton Technologies Pvt. Ltd., (R) 3. The Revenue’s former appeal ITA No.42/PUN/2021 for the A.Y. 2015-16 raises the following substantive grounds: “1. The order

APAASSO MALI,PUNE vs. ITO 11(1), SWARGATE

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

Bench: Shri R.K. Panda & Ms. Astha Chandra

VI. The appellant has not provided credible evidence of extraordinary circumstances that prevented them from filing the appeal within the prescribed timeline. Delay of 248 days is substantial and cannot be brushed aside as a minor lapse. For such an inordinate delay, the appellant must demonstrate unavoidable hindrances, which they have failed to establish. VII. The principle of limitation serves

SHRI GANADHIPATI GANDHARACHARYA KUNTIUSAGAR VIDYA SODH SONSTHA,PUNE vs. ITO, EXEMPTION, PUNE, PUNE

Bench: Shri Manish Borad & Ms. Astha Chandra

delay which was condoned by the Ld. Addl./JCIT(A). The Ld. Addl./JCIT(A) upheld the decision of the Ld. AO and dismissed the assessee’s appeal for the reason that the assessee filed the income tax return beyond the due date of filing of the return, by observing as under : “6.3 In this context, it's important

SHRI GANADHIPATI GANDHARACHARYA KUNTIUSAGAR VIDYA SODH SONSTHA,KOLHAPUR vs. ITO, EXEMPTION, PUNE, KOLHAPUR

Bench: Shri Manish Borad & Ms. Astha Chandra

delay which was condoned by the Ld. Addl./JCIT(A). The Ld. Addl./JCIT(A) upheld the decision of the Ld. AO and dismissed the assessee’s appeal for the reason that the assessee filed the income tax return beyond the due date of filing of the return, by observing as under : “6.3 In this context, it's important

SHRI GANADHIPATI GANDHARACHARYA KUNTIUSAGAR VIDYA SODH SONSTHA,KOLHAPUR vs. ITO, EXEMPTION, PUNE, KOLHAPUR

Bench: Shri Manish Borad & Ms. Astha Chandra

delay which was condoned by the Ld. Addl./JCIT(A). The Ld. Addl./JCIT(A) upheld the decision of the Ld. AO and dismissed the assessee’s appeal for the reason that the assessee filed the income tax return beyond the due date of filing of the return, by observing as under : “6.3 In this context, it's important

SHRI GANADHIPATI GANDHARACHARYA KUNTIUSAGAR VIDYA SODH SONSTHA,KOLHAPUR vs. ITO, EXEMPTION, PUNE, KOLHAPUR

Bench: Shri Manish Borad & Ms. Astha Chandra

delay which was condoned by the Ld. Addl./JCIT(A). The Ld. Addl./JCIT(A) upheld the decision of the Ld. AO and dismissed the assessee’s appeal for the reason that the assessee filed the income tax return beyond the due date of filing of the return, by observing as under : “6.3 In this context, it's important

DECCAN GYMKHANA,PUNE vs. CIT(EXEMPTION), PUNE

In the result, both the appeals filed by the assessee are allowed for statistical purposes

Bench: Shri R. K. Panda & Ms. Astha Chandra

condoning the delay, if such provision is provided in the Act while considering any issue for adjudication. Therefore, considering the above proposition, we are of the view that Id. CIT (Exemption) has rightly rejected the application of the assessee for grant of approval under section 10(23C) (vi) of the Income-tax Act. All these three appeals are rejected

DECCAN GYMKHANA,DECCAN vs. CIT(EXEMPTION), PUNE, PUNE

In the result, both the appeals filed by the assessee are allowed for statistical purposes

Bench: Shri R. K. Panda & Ms. Astha Chandra

condoning the delay, if such provision is provided in the Act while considering any issue for adjudication. Therefore, considering the above proposition, we are of the view that Id. CIT (Exemption) has rightly rejected the application of the assessee for grant of approval under section 10(23C) (vi) of the Income-tax Act. All these three appeals are rejected

SHREE CHAITANYA-RAM FOUNDATION,BAVDHAN vs. CIT EXEMPTION, PUNE

In the result, both the appeals filed by the assessee are allowed for statistical purposes

Bench: Shri R. K. Panda & Ms. Astha Chandra

vi) empowers the Principal Commissioner or Commissioner to condone delay if they find that there was reasonable cause in not filing application within prescribed time limit. 8. So far as the wrong code is concerned, he submitted that the Pune Bench of the Tribunal in the case of PSR Sustainability Foundation vs. CIT (Exemption) reported in (2025) 179 taxmann.com

SHREE CHAITANYA-RAM FOUNDATION,BAVDHAN PUNE vs. CIT EXEMPTION, PUNE

In the result, both the appeals filed by the assessee are allowed for statistical purposes

Bench: Shri R. K. Panda & Ms. Astha Chandra

vi) empowers the Principal Commissioner or Commissioner to condone delay if they find that there was reasonable cause in not filing application within prescribed time limit. 8. So far as the wrong code is concerned, he submitted that the Pune Bench of the Tribunal in the case of PSR Sustainability Foundation vs. CIT (Exemption) reported in (2025) 179 taxmann.com

STARS FORUM,PUNE vs. CIT EXEMPTION , PUNE

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

Bench: SHRI R. K. PANDA (Vice President), SHRI VINAY BHAMORE (Judicial Member)

condone the delay of 129 days and proceed to adjudicate the appeal. 3. Facts of the case, in brief, are that the assessee is a charitable trust registered under the Bombay Public Trust Act, 1950 w.e.f. 23.12.2014 and is actively engaged in range of charitable activities centred around skilled training for advancement and rural societies reform. The assessee trust

STARS FORUM,PUNE vs. CIT EXEMPTION, PUNE

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

Bench: SHRI R. K. PANDA (Vice President), SHRI VINAY BHAMORE (Judicial Member)

condone the delay of 129 days and proceed to adjudicate the appeal. 3. Facts of the case, in brief, are that the assessee is a charitable trust registered under the Bombay Public Trust Act, 1950 w.e.f. 23.12.2014 and is actively engaged in range of charitable activities centred around skilled training for advancement and rural societies reform. The assessee trust

TEJAS SHIVAJI ADSUL,KOLHAPUR vs. INCOME TAX OFFICER WARD 1(1), KOLHAPUR, KOLHAPUR

In the result, appeal of the assessee is allowed

Bench: Shri R.K. Panda & Ms. Astha Chandra

condone the said delay and proceed to decide the appeal. 2 ITA No.59/PUN/2025, AY 2018-19 3. Briefly stated, the facts of the case are that the assessee is an individual and engaged in family business of agriculture. For A.Y. 2018- 19, the assessee did not file his return of income. The case of the assessee was reopened

SOLO RESEARCH FOUNDATION,PUNE vs. CIT EXEMPTION, PUNE

In the result, appeal of the Assessee in ITA No

Bench: Ms.Astha Chandra & Dr.Dipak P. Ripoteआयकर अपऩल सं. / Ita No.216 & 217/Pun/2025 निर्धारण वषा / Assessment Year:- Solo Research Foundation, V The Commissioner Of Office No.50/51, B12 S Income Tax(Exemption), Shardaram Park, Sasoon Road, Pune. Pune – 411001. Pan: Aaxcs3760K Appellant/ Assessee Respondent / Revenue Assessee By Shri Rahul Kaul – Ar Revenue By Shri Amit Bobde – Dr Date Of Hearing 25/09/2025 Date Of Pronouncement 30/09/2025 आदेश/ Order Per Dr. Dipak P. Ripote, Am: These Two Appeals Filed By The Assessee Are Directed Against The Separate Orders Of Ld.Commissioner Of Income Tax(Exemption), Pune Rejecting The Application For Grant Of Registration U/S.12Ar.W.S 12Ab & 80G(5) Of The Income Tax Act, 1961(Hereinafter Referred To As „The Act‟) Both Dated 28.11.2024 Respectively. For The Sake Of Convenience, These Two Appeals Were Heard Together & Are Being

vi), the Principal Commissioner or Commissioner may, if he considers that there is a reasonable cause for delay in filing the application, condone such delay and such application shall be deemed to have been filed within time;] 5. Since the Assessee was already having registration u/s.12AA of the Act, as per Amended Section 12A(1