SHRINIWAS ENGINEERING AUTO COMPONENTS PVT. LTD,PUNE vs. NATIONAL FACELESS APPEAL CENTRE, PUNE

In the result, ITA Nos. 154 to 156/PUN/2025 filed by the assessee are partly allowed for statistical purposes, ITA

Bench: Dr.Manish Borad & Shri Vinay Bhamoreआयकर अपील सं. / Ita Nos.154 To 156/Pun/2025 Assessment Years : 2016-17 To 2018-19

depreciation. Please refer submissions in Annexure 'A' to Assessment Year 2016-17 and 2017-18. (B) The adjustment made is outside the scope of the specific items of adjustments permitted u/s 143(1)(a) of the Income Tax Act. has (ii) The reasons given in the adjustments made under section 143(1)(a) made under the Act can neither

SHRINIWAS ENGINEERING AUTO COMPONENTS PVT. LTD.,PUNE vs. ACIT, CIRCLE-5, PUNE, PUNE

In the result, ITA Nos. 154 to 156/PUN/2025 filed by the assessee are partly allowed for statistical purposes, ITA

Bench: Dr.Manish Borad & Shri Vinay Bhamoreआयकर अपील सं. / Ita Nos.154 To 156/Pun/2025 Assessment Years : 2016-17 To 2018-19

depreciation. Please refer submissions in Annexure 'A' to Assessment Year 2016-17 and 2017-18. (B) The adjustment made is outside the scope of the specific items of adjustments permitted u/s 143(1)(a) of the Income Tax Act. has (ii) The reasons given in the adjustments made under section 143(1)(a) made under the Act can neither

ACIT, CIRCLE-5, PUNE, PUNE vs. SHRINIWAS ENGINEERING AUTO COMPONENTS PRIVATE LIMITED, PUNE

In the result, ITA Nos. 154 to 156/PUN/2025 filed by the assessee are partly allowed for statistical purposes, ITA

Bench: Dr.Manish Borad & Shri Vinay Bhamoreआयकर अपील सं. / Ita Nos.154 To 156/Pun/2025 Assessment Years : 2016-17 To 2018-19

depreciation. Please refer submissions in Annexure 'A' to Assessment Year 2016-17 and 2017-18. (B) The adjustment made is outside the scope of the specific items of adjustments permitted u/s 143(1)(a) of the Income Tax Act. has (ii) The reasons given in the adjustments made under section 143(1)(a) made under the Act can neither

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

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

10(20) of the Act. Since, the services of the employees were utilized for earning the income of the earlier periods therefore, he held that the expenses of employee's premium for Superannuation Fund for earlier period cannot be an expenditure of the year in question, in view of the clear provisions of section

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

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

10(20) of the Act. Since, the services of the employees were utilized for earning the income of the earlier periods therefore, he held that the expenses of employee's premium for Superannuation Fund for earlier period cannot be an expenditure of the year in question, in view of the clear provisions of section

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

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

10(20) of the Act. Since, the services of the employees were utilized for earning the income of the earlier periods therefore, he held that the expenses of employee's premium for Superannuation Fund for earlier period cannot be an expenditure of the year in question, in view of the clear provisions of section

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

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

10(20) of the Act. Since, the services of the employees were utilized for earning the income of the earlier periods therefore, he held that the expenses of employee's premium for Superannuation Fund for earlier period cannot be an expenditure of the year in question, in view of the clear provisions of section

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

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

10(20) of the Act. Since, the services of the employees were utilized for earning the income of the earlier periods therefore, he held that the expenses of employee's premium for Superannuation Fund for earlier period cannot be an expenditure of the year in question, in view of the clear provisions of section

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

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

10(20) of the Act. Since, the services of the employees were utilized for earning the income of the earlier periods therefore, he held that the expenses of employee's premium for Superannuation Fund for earlier period cannot be an expenditure of the year in question, in view of the clear provisions of section

INCOME-TAX OFFICER, WARD - 6(1),, PUNE vs. SHRINIWAS ENGINEERING AUTO COMPONENTS PVT.LTD,, PUNE

In the result, the appeal filed by the Revenue stands dismissed

Bench: Shri Inturi Rama Rao & Shri S. S. Viswanethra Raviआयकर अपील सं. / Ita No.2992/Pun/2017 िनधा"रण वष" / Assessment Year: 2014-15 Ito, Ward- 6(1), Vs. Shriniwas Engineering Pune. Auto Components Pvt. Ltd., Office- 5, Manasara Apartments, 1108/4, University Road, Near Suryamukhi Datta Man, Pune- 411016. Pan : Aajcs8944F Appellant Respondent Revenue By : Shri J. P. Chadraker Assessee By : Shri Hari Krishan Date Of Hearing : 23.03.2022 Date Of Pronouncement : 27.04.2022 आदेश / Order Per Inturi Rama Rao, Am: This Is An Appeal Filed By The Revenue Directed Against The Order Of Ld. Commissioner Of Income Tax (Appeals)- 4, Pune [‘Cit(A)’ For Short] Dated 03.07.2017 For The Assessment Year 2014-15. 2. The Revenue Raised The Following Revised Grounds Of Appeal :- “1. The Cit (A) Erred Both On Facts & In Law In Passing The Order. 2. The Cit (A) Erred In Holding That There Was No Provision In Package Scheme Of Incentives, 2007 To Show That The Asseessee Is Granted Subsidy Towards Meeting A Cost Of Asset & Cit(A) Has Erred

34,02,137/-. While doing so, the Assessing Officer had reduced a sum of Rs.36,08,69,697/- being the amount of capital subsidy received from Government of Maharashtra under the Package Scheme of Incentive, 2007 from the cost of the depreciable 3 assets invoking the provisions of Explanation 10 to section

SATARA ENGINEERING PROJECTS AND EQUIPMENTS PRIVATE LIMITED,SATARA vs. DEPUTY COMMISSIONER OF INCOME TAX, CIRCLE, SATARA, SATARA

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

Bench: Dr.Manish Borad & Shri Vinay Bhamoreआयकर अपील सं. / Ita No.2450/Pun/2025 Assessment Year : 2024-25

depreciation" shall have the meaning assigned to it in clause (b) of sub-section (7) of section 72A.” 6. Now before us, ld. Counsel for the assessee contended that in compliance to section 115BAB(7) assessee has first time opted for this concessional rate of tax u/s.115BAB of the Act in the return filed

ENTRATA INDIA PVT. LTD. ,PUNE vs. DCIT, CIRCLE-1(1), PUNE, PUNE

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

Bench: Shri R. K. Panda & Shri Vinay Bhamoreआयकर अपील सं. / Ita No.133/Pun/2024 िनधा"रण वष" / Assessment Year: 2013-14 Entrata India Pvt. Ltd., Vs. Dcit, Circle-1(1), Pune. International Tech Park, Block-1, Wing-A, 14Th Floor, Kharadi, Pune- 411014. Pan : Aaacw7089A Appellant Respondent आयकर अपील सं. / Ita No.66/Pun/2024 िनधा"रण वष" / Assessment Year: 2013-14 Dcit, Circle-1(1), Pune. Vs. Entrata India Pvt. Ltd., International Tech Park, Block-1, Wing-A, 14Th Floor, Kharadi, Pune- 411014. Pan : Aaacw7089A Appellant Respondent Assessee By : Shri Kishor B. Phadke Revenue By : Shri Ramnath P. Murkunde Date Of Hearing 14.11.2024 : Date Of Pronouncement : 24.12.2024 आदेश / Order Per Vinay Bhamore, Jm: These Are The Cross Appeals Filed By The Assessee As Well As By The Revenue Are Directed Against The Order Dated 24.11.2023 Passed By Ld. Cit(A)-13, Pune [‘Cit(A)’] For The Assessment Year 2013-14. 2. First, We Shall Take Up The Appeal Of The Assessee In Ita No.133/Pun/2024 For Adjudication.

34,462/-, as the tax liability as worked out u/s 115JB of the IT Act is more than the tax liability of total income as per normal provisions of the IT Act. The tax liability of the assessee company was worked on the books profits. 6. In first appeal, after considering the reply of the assessee

DCIT CIRCLE 1(1), PUNE, SWARGATE vs. ENTRATA INDIA PVT. LTD, PUNE

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

Bench: Shri R. K. Panda & Shri Vinay Bhamoreआयकर अपील सं. / Ita No.133/Pun/2024 िनधा"रण वष" / Assessment Year: 2013-14 Entrata India Pvt. Ltd., Vs. Dcit, Circle-1(1), Pune. International Tech Park, Block-1, Wing-A, 14Th Floor, Kharadi, Pune- 411014. Pan : Aaacw7089A Appellant Respondent आयकर अपील सं. / Ita No.66/Pun/2024 िनधा"रण वष" / Assessment Year: 2013-14 Dcit, Circle-1(1), Pune. Vs. Entrata India Pvt. Ltd., International Tech Park, Block-1, Wing-A, 14Th Floor, Kharadi, Pune- 411014. Pan : Aaacw7089A Appellant Respondent Assessee By : Shri Kishor B. Phadke Revenue By : Shri Ramnath P. Murkunde Date Of Hearing 14.11.2024 : Date Of Pronouncement : 24.12.2024 आदेश / Order Per Vinay Bhamore, Jm: These Are The Cross Appeals Filed By The Assessee As Well As By The Revenue Are Directed Against The Order Dated 24.11.2023 Passed By Ld. Cit(A)-13, Pune [‘Cit(A)’] For The Assessment Year 2013-14. 2. First, We Shall Take Up The Appeal Of The Assessee In Ita No.133/Pun/2024 For Adjudication.

34,462/-, as the tax liability as worked out u/s 115JB of the IT Act is more than the tax liability of total income as per normal provisions of the IT Act. The tax liability of the assessee company was worked on the books profits. 6. In first appeal, after considering the reply of the assessee

JAIBHAGWAN BANARASIDAS JINDAL,JALNA vs. THE INCOME TAX OFFICER, WARD-1, JALNA

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

Bench: Shri R. K. Panda & Ms. Astha Chandraassessment Year : 2016-17

section is applicable (deeming provision); which is when the income has been assessed but there has been under-assessment, the income has been assessed at too low a rate, excessive relief has been provided and/or excessive loss, depreciation allowance or any other allowance has been computed under the provisions of the Act. The very fact that reasons are recorded

DEPUTY COMMISSIONER OF INCOME-TAX CIRCLE -5, PUNE vs. SERUM INSTITUTE OF INDIA PVT LTD.,, PUNE

In the result, the appeal filed by the Revenue stands dismissed

10% as against 15% claimed by the respondent-assessee. 26 On appeal before the ld. CIT(A), the ld. CIT(A) following the decision of ITAT for the assessment year 2001-02 till assessment year 2012-13 held them as forming part of Plant & Machinery, accordingly, allowed the appeal. Being aggrieved, the Revenue is in appeal before us challenging

DEPUTY COMMISSIONER OF INCOME TAX, AURANGABAD vs. ASHISH JUGALKISHOR BHALA, JALNA

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

Bench: Shri R. K. Panda & Ms. Astha Chandraassessment Year : 2021-22 Dcit, Aurangabad Ashish Jugalkishor Bhala Mamta Hospital, Shivaji Putla Road, Vs. Bharat Nagar, Jalna – 431203 Maharashtra Pan: Ahmpb3683K (Appellant) (Respondent) Assessee By : Shri Anand Partani Department By : Shri Ramnath P Murkunde Date Of Hearing : 01-04-2025 Date Of Pronouncement : 16-06-2025 O R D E R

34,67,670/- paid up capital Rs. 10/- face value of equity shares). 5.2.4 The appellant has made the submission as to why there is no scope for estimating the value of equity shares under rule 11UA of the Income Tax Rules. The factors like concept of safe harbor limit or tolerance band or discount for lack of marketability apply

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

Appeal is allowed for statistical purposes

Bench: Shri R.S.Syal, Vp & Shri Partha Sarathi Chaudhury, Jm Assessment Year:2014-15

section 271(1) (c) of the Act. Each one of the above grounds of appeal is without prejudice to the other. The Appellant requests the Hon'ble members a right to amend, alter, substitute or add to the grounds of appeal at any time before or at the time of hearing of the appeal so as to allow

CAPGEMINI TECHNOLOGY SERVICES INDIA LTD,,PUNE vs. DEPUTY COMMISSIONER OF INCOME-TAX, CIRCLE - 11,, PUNE

In the result, both the appeals are partly allowed

Bench: Shri R.S. Syal & Shri Partha Sarathi Chaudhury

depreciation of the amalgamating company in relation to the income under the head “Profit and gains of business or profession”. It is not a panacea for all the tax related issues of amalgamation, so as to have application insofar as the other tax entitlements, privileges or benefits in the hands of the amalgamating company, are concerned. 14. Section 74 deals