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5 results for “depreciation”+ Permanent Establishmentclear

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Key Topics

Section 72A5 Section 2634 Addition to Income4 Section 143(3)3 Section 14A3 Depreciation3 Disallowance3 Section 143(2)2 Section 92C2 Comparables/TP

THE MULE PRAVANA ELECTRIC CO-OP SOCIETY LTD,AHMEDNAGAR vs. ASSISTANT COMMISSIONER OF INCOME-TAX , AHEMDNAGAR

In the result, the appeal of assessee is dismissed

ITA 256/PUN/2020[2015-16]Status: DisposedITAT Pune08 Dec 2022AY 2015-16

Bench: Shri S.S. Viswanethra Ravi & Shri G.D. Padmahshali

For Appellant: Shri Abhay SastriFor Respondent: Shri Naveen Gupta

depreciation on assets claimed by the appellant, as there was no existence of the business which was established by the AO to have been permanently

SEMPERTRANS INDIA PRIVATE LIMITED,ROHA vs. INCOME-TAX OFFICER, PANVEL

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

ITA 1778/PUN/2024[AY 2020-21]Status: DisposedITAT Pune

2

Set Off of Losses2

14 Nov 2025

Section 144Section 144CSection 144C(8)Section 153Section 92CSection 92D

depreciation. Since there being no objection\nfrom the side of ld. DR we restore the issues raised in\nGrounds of appeal No.18, 19 and 20 regarding claim of set off\nof off of brought forward business loss and unabsorbed\ndepreciation to the file of ld. Jurisdictional Assessing Officer\nbefore whom assessee shall furnish necessary details and\nproof of brought forward

M/S GERA DEVELOPMENTS PVT. LTD,PUNE vs. PCIT (CENTRAL), PUNE, PUNE

In the result, the appeal filed by the assessee is dismissed

ITA 1053/PUN/2024[2020-21]Status: DisposedITAT Pune09 Dec 2025AY 2020-21

Bench: Dr.Manish Borad & Shri Vinay Bhamore

For Appellant: Shri Hari KrishanFor Respondent: Shri Amol Khairnar

Section 143(2)Section 143(3)Section 263

establishes the fact that before the amalgamation there was no asset in the name of goodwill either in the amalgamating company or amalgamated company. During the year under consideration, the appellant impaired the carrying amount of goodwill amounting to Rs. 18,89,24,584 in the books of accounts. On verification of record available before PCIT it was revealed that

DEPUTY COMMISSIONER OF INCOME-TAX, CIRCLE -1(1),, PUNE vs. M/S. CUMMINS SALES & SERVICES (I),LTD,(FORMERLY KNOWN AS CUMMINS DIESELS SALES & SERVICE LTD,), PUNE

In the result, the appeal filed by the Revenue stands partly allowed

ITA 2121/PUN/2017[2006-07]Status: DisposedITAT Pune27 Jun 2022AY 2006-07

For Appellant: Shri Ketan VedFor Respondent: Shri Shivraj B. Morey

Section 143(3)Section 14ASection 72ASection 72A(4)

establishes that the scheme demerger is not for genuine purpose, the respondent-assessee is not entitled for benefit of set-off of brought forward business losses and unabsorbed depreciation losses. The ld. CIT(A) had failed to appreciate the purport of the provisions of section 72A(4) of the Act. Therefore, the order of the ld. CIT(A) should

SAS RESEARCH AND DEVELOPMENT (INDIA) PVT. LTD ,PUNE vs. ADDITIONAL / JOINT/ DEPUTY/ASISTANT COMMISSIONER OF INCOME TAX (INT TAX), DELHI ADDITIONAL / JOINT/ DEPUTY/ASISTANT COMMISSIONER OF INCOME TAX (INT TAX), DELHI

In the result, appeal of the Assessee is Partly Allowed

ITA 255/PUN/2021[2016-17]Status: DisposedITAT Pune01 Nov 2022AY 2016-17

Bench: Shri S.S.Godara & Dr. Dipak P. Ripoteआयकरअपीलसं. / Ita No.255/Pun/2021 िनधा"रणवष" / Assessment Year : 2016-17 Sas Research & The Additional / Joint / Development(India) Private Vs Deputy / Assistant Limited, Commissioner Of Income Level 1, 2A & 3, Tower 5, Tax / Income-Tax Officer, Cybercity, Magarpatta City, National E-Assessment Hadapsar, Pune – 411013. Centre, Delhi. Pan: Aaecs 8099 L Appellant/ Assessee Respondent /Revenue Assessee By Shri Rajendra Agiwal– Ar Revenue By Shri Shivraj B Moray – Dr Date Of Hearing 03/08/2022 Date Of Pronouncement 01/11/2022 आदेश/ Order Per Dr. Dipak P. Ripote, Am: This Appeal Filed By The Assessee Is Directed Against The Order Of Ld. Additional/Joint/ Deputy/Assistant Commissioner Of Income Tax, National E-Assessment Centre, Delhi, Dated 06.04.2021For The A.Y. 2016-17 Emanating From The Order Of The Dispute Resolution Panel-3, Mumbai, Dated 24/03/2020. The Assessee Has Raised The Following Grounds Of Appeal: “Based On The Facts & Circumstances Of The Case, Sas Research & Development (India) Private Limited (‘Appellant’) Respectfully Craves Leave To Prefer An Appeal Against The Order Passed By The National E- Assessment Center, Delhi Under Section 143(3) R.W.S 144C(13),144C(13),143(3A) & 143(3B) Of The Income-Tax Act, 1961 (‘The Act’) Dated 6 April 2021 Pursuant To The Directions Issued By Hon’Ble Dispute Resolution Panel - 3 (‘Hon’Ble Drp’), Mumbai, Under Section 144C(5) Of The Act Dated 19 February 2021, On The Following Sas Research & Development (India) Pvt. Ltd., [A]

Section 143(3)Section 144C(5)

established more than 30 years ago. Under the software development support activity, SAS R&D supports the development of SAS software products by assisting in development of certain SAS Software Products based on the specifications of AE. AEs of SAS R&D are responsible for directing SAS R&D and allocating work to SAS R&D. Consultancy and training services