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59 results for “condonation of delay”+ Transfer Pricingclear

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Key Topics

Section 12A65Section 143(3)48Addition to Income40Section 1138Section 10(20)24Section 80G22Section 80G(5)20Exemption19Transfer Pricing16

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

ITA 43/PUN/2021[2016-17]Status: DisposedITAT Pune07 Jul 2022AY 2016-17

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.

Section 10Section 10ASection 143(3)Section 14ASection 40Section 80ISection 9(1)(vi)

Showing 1–20 of 59 · Page 1 of 3

Limitation/Time-bar15
Comparables/TP14
Section 2(15)12

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

ITA 42/PUN/2021[2015-16]Status: DisposedITAT Pune07 Jul 2022AY 2015-16

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.

Section 10Section 10ASection 143(3)Section 14ASection 40Section 80ISection 9(1)(vi)

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

DANA INDIA PVT.LTD,,PUNE vs. DEPUTY COMMISSIONER OF INCOME-TAX, CIRCLE - 1(2),, PUNE

In the result, the appeal is partly allowed

ITA 473/PUN/2018[2013-14]Status: DisposedITAT Pune25 Feb 2021AY 2013-14

Bench: Shri R.S. Syal & Shri Partha Sarathi Chaudhuryआयकर अपील सं. / Ita No.473/Pun/2018 िनधा"रण वष" / Assessment Year : 2013-14

Section 143(3)Section 92C

delay is condoned and the appeal is admitted for hearing. 2 Dana India Private Limited A. TRANSFER PRICING ADDITION IN `MANUFACTURING

DEPUTY COMMISSIONER OF INCOME-TAX vs. THE JAWAHARLAL NEHRU PORT TRUST,, RAIGAD

In the result, all the three appeals filed by the Revenue are dismissed and all the three appeals filed by the assessee are partly allowed

ITA 545/PUN/2016[2005-06]Status: DisposedITAT Pune30 Sept 2025AY 2005-06

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

For Appellant: S/Shri Madhur Agrawal, AdvocateFor Respondent: S/Shri Sham Walve, Special Counsel along with Tanzil Padvekar and Bhavik Chheda
Section 10(20)Section 11Section 12ASection 142Section 143(1)Section 143(3)Section 263

condone the delay for accepting the auditor’s report at a later date has only been given to the ITO and not thereafter, i.e., at the appellate stage. We find no merit in this submission. The CBDT by issuing the Circular dt. 9th Feb., 1978 has treated the provision regarding furnishing of auditor’s report along with the return

JAWAHAR LAL NEHRU PORT TRUST,NAVI MUMBAI vs. ACIT PANVEL, PANVEL

In the result, all the three appeals filed by the Revenue are dismissed and all the three appeals filed by the assessee are partly allowed

ITA 1154/MUM/2016[2005-06]Status: DisposedITAT Pune30 Sept 2025AY 2005-06

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

For Appellant: S/Shri Madhur Agrawal, AdvocateFor Respondent: S/Shri Sham Walve, Special Counsel along with Tanzil Padvekar and Bhavik Chheda
Section 10(20)Section 11Section 12ASection 142Section 143(1)Section 143(3)Section 263

condone the delay for accepting the auditor’s report at a later date has only been given to the ITO and not thereafter, i.e., at the appellate stage. We find no merit in this submission. The CBDT by issuing the Circular dt. 9th Feb., 1978 has treated the provision regarding furnishing of auditor’s report along with the return

DEPUTY COMMISSIONER OF INCOME-TAX vs. THE JAWAHARLAL NEHRU PORT TRUST,, RAIGAD

In the result, all the three appeals filed by the Revenue are dismissed and all the three appeals filed by the assessee are partly allowed

ITA 544/PUN/2016[2004-05]Status: DisposedITAT Pune30 Sept 2025AY 2004-05

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

For Appellant: S/Shri Madhur Agrawal, AdvocateFor Respondent: S/Shri Sham Walve, Special Counsel along with Tanzil Padvekar and Bhavik Chheda
Section 10(20)Section 11Section 12ASection 142Section 143(1)Section 143(3)Section 263

condone the delay for accepting the auditor’s report at a later date has only been given to the ITO and not thereafter, i.e., at the appellate stage. We find no merit in this submission. The CBDT by issuing the Circular dt. 9th Feb., 1978 has treated the provision regarding furnishing of auditor’s report along with the return

JAWAHAR LAL NEHRU PORT TRUST,NAVI MUMBAI vs. ACIT PANVEL, PANVEL

In the result, all the three appeals filed by the Revenue are dismissed and all the three appeals filed by the assessee are partly allowed

ITA 1153/MUM/2016[2003-04]Status: DisposedITAT Pune30 Sept 2025AY 2003-04

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

For Appellant: S/Shri Madhur Agrawal, AdvocateFor Respondent: S/Shri Sham Walve, Special Counsel along with Tanzil Padvekar and Bhavik Chheda
Section 10(20)Section 11Section 12ASection 142Section 143(1)Section 143(3)Section 263

condone the delay for accepting the auditor’s report at a later date has only been given to the ITO and not thereafter, i.e., at the appellate stage. We find no merit in this submission. The CBDT by issuing the Circular dt. 9th Feb., 1978 has treated the provision regarding furnishing of auditor’s report along with the return

JAWAHAR LAL NEHRU PORT TRUST,NAVI MUMBAI vs. ACIT PANVEL, PANVEL

In the result, all the three appeals filed by the Revenue are dismissed and all the three appeals filed by the assessee are partly allowed

ITA 1155/MUM/2016[2004-05]Status: DisposedITAT Pune30 Sept 2025AY 2004-05

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

For Appellant: S/Shri Madhur Agrawal, AdvocateFor Respondent: S/Shri Sham Walve, Special Counsel along with Tanzil Padvekar and Bhavik Chheda
Section 10(20)Section 11Section 12ASection 142Section 143(1)Section 143(3)Section 263

condone the delay for accepting the auditor’s report at a later date has only been given to the ITO and not thereafter, i.e., at the appellate stage. We find no merit in this submission. The CBDT by issuing the Circular dt. 9th Feb., 1978 has treated the provision regarding furnishing of auditor’s report along with the return

DEPUTY COMMISSIONER OF INCOME-TAX vs. THE JAWAHARLAL NEHRU PORT TRUST,, RAIGAD

In the result, all the three appeals filed by the Revenue are dismissed and all the three appeals filed by the assessee are partly allowed

ITA 543/PUN/2016[2003-04]Status: DisposedITAT Pune30 Sept 2025AY 2003-04

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

For Appellant: S/Shri Madhur Agrawal, AdvocateFor Respondent: S/Shri Sham Walve, Special Counsel along with Tanzil Padvekar and Bhavik Chheda
Section 10(20)Section 11Section 12ASection 142Section 143(1)Section 143(3)Section 263

condone the delay for accepting the auditor’s report at a later date has only been given to the ITO and not thereafter, i.e., at the appellate stage. We find no merit in this submission. The CBDT by issuing the Circular dt. 9th Feb., 1978 has treated the provision regarding furnishing of auditor’s report along with the return

DEPUTY COMMISSIONER OF INCOME-TAX, CIRCLE 8, PUNE vs. SPICER INDIA PVT. LTD, PUNE

In the result, the appeal of Revenue is dismissed

ITA 580/PUN/2020[2015-16]Status: DisposedITAT Pune03 Jun 2021AY 2015-16

Bench: Shri R.S. Syal & Shri S.S. Viswanethra Ravi

For Appellant: Shri R.D. OnkarFor Respondent: Shri Kalika Singh
Section 37Section 37(1)Section 40A(2)(b)Section 92C

delay of 177 days are condoned. 3. The Revenue raised as many as 6 grounds amongst which the only issue emanates for our consideration is as to whether the CIT(A) is justified in deleting the adjustment of Rs.14,71,41,219/- made by the AO/TPO on account of management services fees in the facts and circumstances of the case

EMERSON CLIMATE TECHNOLOGIES (INDIA) PRIVATE LTD.,,PUNE vs. ADDL/JT/DY/ACIT., NEAC, DELHI

In the result, the appeal is partly allowed for statistical purposes

ITA 190/PUN/2021[2016-17]Status: DisposedITAT Pune15 Jul 2021AY 2016-17

Bench: Shri R.S. Syal & Shri S.S. Viswanethra Raviआयकर अपीऱ सं. / Ita No.190/Pun/2021 निर्धारण वषा / Assessment Year : 2016-17 Emerson Climate Technologies Vs. Additional/Joint/Deputy (India) Private Limited, /Assistant Commissioner Plot No.23, Of Income Tax/Income Rajiv Gandhi Infotech Park, Tax Officer, National E- Phase Ii, Hinjewadi, Assessment Centre, Delhi Pune – 411 057 Pan : Aaack7291C Appellant Respondent Assessee By Shri Dhanesh Bafna Revenue By Shri Shivraj B. Morey Date Of Hearing 14-07-2021 Date Of Pronouncement 15-07-2021 आदेश / Order Per R.S.Syal, Vp : This Appeal By The Assessee Is Directed Against The Final Assessment Order Dated 18.03.2021 Passed By The Assessing Officer (Ao) U/S.143(3) R.W.S.144C(13) Of The Income-Tax Act, 1961 (Hereinafter Also Called „The Act‟) In Relation To The Assessment Year 2016-17. 2. This Appeal Was Filed Belatedly By 3 Days. The Ld. Ar Explained The Lockdown Due To Covid-19 As The Reason For The Late Filing Of The Appeal. The Ld. Dr Did Not Object To The Condonation Of The Delay. We Are Satisfied With Such A Reason. The Delay Is 2 Emerson Climate Technologies (India) Pvt. Ltd.

Section 143(3)

delay is 2 Emerson Climate Technologies (India) Pvt. Ltd., condoned and the appeal is admitted for hearing and disposal on merits. 3. The ld. AR did not press ground nos. 5 and 6 due to smallness of the amount. Such grounds are, therefore, dismissed as „not pressed‟. 4. The only other surviving issue in this appeal through various 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

ITA 400/PUN/2020[2013-14]Status: DisposedITAT Pune11 Jun 2021AY 2013-14

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 115JSection 143(3)Section 144C(3)

delay is condoned and the appeal is admitted for hearing and disposal on merits. 3. The only assail in this appeal through various grounds is to the deletion of transfer pricing

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

ITA 334/PUN/2021[2016-17]Status: DisposedITAT Pune31 May 2023AY 2016-17

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

For Appellant: Shri Kishor PhadkeFor Respondent: Shri Naveen Gupta
Section 92C

Transfer Pricing- Corporate Guarantee (Addition Rs.5,51,37,874) 2.1 The learned I-T authorities erred in law and on facts in not appreciating that extending of corporate guarantee / Stand- by Letter of Credit (‗SBLC‘), for the benefit of subsidiary AE companies is a shareholders‘ activity and per se, and not an international transaction

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

ITA 273/PUN/2021[2016-17]Status: DisposedITAT Pune31 May 2023AY 2016-17

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

For Appellant: Shri Kishor PhadkeFor Respondent: Shri Naveen Gupta
Section 92C

Transfer Pricing- Corporate Guarantee (Addition Rs.5,51,37,874) 2.1 The learned I-T authorities erred in law and on facts in not appreciating that extending of corporate guarantee / Stand- by Letter of Credit (‗SBLC‘), for the benefit of subsidiary AE companies is a shareholders‘ activity and per se, and not an international transaction

DEPUTY COMMISSIONER OF INCOME-TAX, CIR 1(1),, PUNE vs. M/S. CITY CORPORATION LTD.,(EARLIER KNOWN AS M/S AMANORA FUTURE TOWERS P LTD), PUNE

In the result, both the appeals are partly allowed

ITA 45/PUN/2021[2015-16]Status: DisposedITAT Pune17 Aug 2021AY 2015-16

Bench: Shri R.S. Syal & Shri S.S. Viswanethra Raviआयकर अपील सं. / Ita No.619/Pun/2020 िनधा"रण वष" / Assessment Year : 2015-16 Vs. M/S. City Corporation Limited, Dcit, Circle-1(1), (Earlier Known As M/S. Amanora Pune Future Towers Pvt. Ltd.,), 917/9A, City Chambers, F.C. Road, Shivajinagar, Pune-411004 Pan : Aakca3074H Appellant Respondent आयकर अपील सं. / Ita No.45/Pun/2021 िनधा"रण वष" / Assessment Year : 2015-16

delay is hereby condoned and the appeal is admitted for hearing. 3. Succinctly, the facts of the case are that the assessee is engaged in the business of real estate development. A return was filed declaring total income of Rs.26.93 crore. The assessee reported certain international transactions and Specified Domestic transactions (SDTs) in Form No. 3CEB. The Assessing Officer

AMANORA FUTURE PVT. LTD,PUNE vs. DEPUTY COMMISSIONER OF INCOME-TAX, CIRCLE 1(1), PUNE

In the result, both the appeals are partly allowed

ITA 619/PUN/2020[2015-16]Status: DisposedITAT Pune17 Aug 2021AY 2015-16

Bench: Shri R.S. Syal & Shri S.S. Viswanethra Raviआयकर अपील सं. / Ita No.619/Pun/2020 िनधा"रण वष" / Assessment Year : 2015-16 Vs. M/S. City Corporation Limited, Dcit, Circle-1(1), (Earlier Known As M/S. Amanora Pune Future Towers Pvt. Ltd.,), 917/9A, City Chambers, F.C. Road, Shivajinagar, Pune-411004 Pan : Aakca3074H Appellant Respondent आयकर अपील सं. / Ita No.45/Pun/2021 िनधा"रण वष" / Assessment Year : 2015-16

delay is hereby condoned and the appeal is admitted for hearing. 3. Succinctly, the facts of the case are that the assessee is engaged in the business of real estate development. A return was filed declaring total income of Rs.26.93 crore. The assessee reported certain international transactions and Specified Domestic transactions (SDTs) in Form No. 3CEB. The Assessing Officer

DEPUTY COMMISSIONER OF INCOME TAX , CIRCLE 1(1), PUNE vs. FRANKE FABER INDIA PVT. LTD, PUNE

In the result, the appeal the Revenue is allowed and the cross

ITA 161/PUN/2022[2012-13]Status: DisposedITAT Pune01 Aug 2022AY 2012-13

Bench: Shri R.S. Syal & Shri S.S. Viswanethra Ravi"नधा"रण वष" / Assessment Year: 2012-13 Dcit, Circle-1(1), Vs. Franke Faber India Private Limited, Pune 1086/1 & 1086/2, Nagar Road, Village Sanaswadi, Taluka Shirur, Pune 412 208, Maharashtra Pan : Aaacf4002G Appellant Respondent

condone the delay in filing the instant cross objection and admit the same for disposal on merits. 3. The Revenue is aggrieved by the inclusion of Gorani Industries Limited (GIL) in the list of comparables. 4. Briefly stated, the facts of the case are that the assessee filed its return declaring loss of Rs.1.55 crore. Certain international transactions were reported

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

ITA 2619/PUN/2025[2025-2026]Status: DisposedITAT Pune21 Jan 2026AY 2025-2026

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

For Appellant: Shri Nikhil S PathakFor Respondent: Shri Prashant Gadekar, CIT
Section 12(1)(ac)Section 12ASection 12A(1)(ac)Section 80GSection 80G(5)

transfers the property to A for the same price at which he originally purchased it, he should be liable to pay tax on the basis as if he has received the market value of the property as on the date of resale, if, in the mean-while, the market price has shot up and exceeds the agreed price by more

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

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

ITA 2618/PUN/2025[2025-2026]Status: DisposedITAT Pune21 Jan 2026AY 2025-2026

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

For Appellant: Shri Nikhil S PathakFor Respondent: Shri Prashant Gadekar, CIT
Section 12(1)(ac)Section 12ASection 12A(1)(ac)Section 80GSection 80G(5)

transfers the property to A for the same price at which he originally purchased it, he should be liable to pay tax on the basis as if he has received the market value of the property as on the date of resale, if, in the mean-while, the market price has shot up and exceeds the agreed price by more

DEPUTY COMMISSIONER OF INCOME-TAX, CIR 1(1),, PUNE vs. M/S. CITY CORPORATION LTD.,(EARLIER KNOWN AS M/S AMANORA FUTURE TOWERS P LTD), PUNE

In the result, the appeal of the Revenue is dismissed and that

ITA 44/PUN/2021[2014-15]Status: DisposedITAT Pune17 Aug 2021AY 2014-15

Bench: Shri R.S. Syal & Shri S.S. Viswanethra Raviआयकर अपील सं. / Ita No.618/Pun/2020 िनधा"रण वष" / Assessment Year : 2014-15 Vs. M/S. City Corporation Limited, Dcit, Circle-1(1), (Earlier Known As M/S. Amanora Pune Future Towers Pvt. Ltd.,), 917/9A, City Chambers, F.C. Road, Shivajinagar, Pune-411004 Pan : Aakca3074H Appellant Respondent आयकर अपील सं. / Ita No.44/Pun/2021 िनधा"रण वष" / Assessment Year : 2014-15 Dcit, Circle-1(1), Vs. M/S. City Corporation Limited, Pune (Earlier Known As M/S. Amanora Future Towers Pvt. Ltd.,), 917/9A, City Chambers, F.C. Road, Shivajinagar, Pune-411004 Pan : Aakca3074H Appellant Respondent

delay is hereby condoned and the appeal is admitted for hearing. 3. The only issue raised by the Revenue in its appeal is against the deletion of transfer pricing