BHANSILAL RAMNATH AGARWAL CHARITABLE TRUST vs. DEPUTY COMMISSIONER OF INCOME-TAX,,

In the result, both the appeals of the assessee are partly allowed

Bench: Shri D.Karunakara Rao, Am & Shri Vikas Awasthy, Jm आयकर आयकर अपील आयकर आयकर अपील अपील संसंसंसं. / Ita Nos.1147, 1133, 1134 & 1136/Pun/2016 अपील िनधा"रण िनधा"रण वष" िनधा"रण िनधा"रण वष" वष" / Assessment Years : 2007-08 To 2009-10 & 2011-12 वष"

section 13(1)(c) of the Act, the AO made the following additions and determined the total income at Rs.2,76,11,529/- for this assessment year. The details of the additions as summed up by the AO in his order for A.Y. 2007-08 are extracted here as under : ( All figures in Rupees) Income as per the recasted 1

BHANSILAL RAMNATH AGARWAL CHARITABLE TRUST vs. DEPUTY COMMISSIONER OF INCOME-TAX,,

In the result, both the appeals of the assessee are partly allowed

Bench: Shri D.Karunakara Rao, Am & Shri Vikas Awasthy, Jm आयकर आयकर अपील आयकर आयकर अपील अपील संसंसंसं. / Ita Nos.1147, 1133, 1134 & 1136/Pun/2016 अपील िनधा"रण िनधा"रण वष" िनधा"रण िनधा"रण वष" वष" / Assessment Years : 2007-08 To 2009-10 & 2011-12 वष"

section 13(1)(c) of the Act, the AO made the following additions and determined the total income at Rs.2,76,11,529/- for this assessment year. The details of the additions as summed up by the AO in his order for A.Y. 2007-08 are extracted here as under : ( All figures in Rupees) Income as per the recasted 1

DEPUTY COMMISSIONER OF INCOME TAX,, PUNE vs. MUKUND BHAVAN TRUST,, PUNE

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

Bench: Shri Inturi Rama Rao & Shri S.S. Viswanethra Ravi

c)(ii) and 13(2)(b) of the Act. The Assessing Officer before deciding this issue afresh in accordance with our directions shall grant opportunity of hearing to the assessee, in accordance with law.” 4. As the issue involved in the year under consideration as well as all the material facts relevant thereto are similar

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

13. We note that post amendment in section 2(24)(xviii) of the Act, the subsidy is required to be treated as income for the year other than the subsidy or grant which is taken into account for determination of the actual cost of the asset in Shriniwas Engineering Auto Components Pvt. Ltd. A.Ys. 2016-17 to 2020-21 accordance

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

13. We note that post amendment in section 2(24)(xviii) of the Act, the subsidy is required to be treated as income for the year other than the subsidy or grant which is taken into account for determination of the actual cost of the asset in Shriniwas Engineering Auto Components Pvt. Ltd. A.Ys. 2016-17 to 2020-21 accordance

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

13. We note that post amendment in section 2(24)(xviii) of the Act, the subsidy is required to be treated as income for the year other than the subsidy or grant which is taken into account for determination of the actual cost of the asset in Shriniwas Engineering Auto Components Pvt. Ltd. A.Ys. 2016-17 to 2020-21 accordance

DY. COMMISSIONER OF INCOME-TAX, CIRCLE-5, PUNE vs. SHRINIWAS ENGINEERING AUTO COMPONENTS PVT. LTD., 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

13. We note that post amendment in section 2(24)(xviii) of the Act, the subsidy is required to be treated as income for the year other than the subsidy or grant which is taken into account for determination of the actual cost of the asset in Shriniwas Engineering Auto Components Pvt. Ltd. A.Ys. 2016-17 to 2020-21 accordance

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

13. We note that post amendment in section 2(24)(xviii) of the Act, the subsidy is required to be treated as income for the year other than the subsidy or grant which is taken into account for determination of the actual cost of the asset in Shriniwas Engineering Auto Components Pvt. Ltd. A.Ys. 2016-17 to 2020-21 accordance

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

13. Now section 80HHC provides that an assessee who is engaged in the business of export out of India of any goods or merchandise, to which the said section applies in computing his total income, deduction to the extent of profits referred to in sub-section (1)(b ) derived by the assessee from the export of such goods or merchandise

DEPUTY COMMISSIONER OF INCOME-TAX vs. SOCIETY OF SAINT URSULA,, PUNE

In the result, appeal of the Revenue is dismissed

Bench: Shri D. Karunakara Rao, Am & Shri Vikas Awasthy, Jm आयकर अपील सं. / Ita No.1714/Pun/2016 "नधा"रण वष" / Assessment Year : 2012-13

section 13(3) in violation of condition laid down u/s. 13(1)(c) & 13(2)(c)? 3. Whether on the facts and the circumstances of the case and in law, the Ld. CIT(A) was justified in deleting the addition made on the claim of depreciation

INCOME TAX OFFICER, PUNE vs. SAGAR CONSTRUCTION COMPANY, PUNE

In the result, the appeal filed by the Revenue is dismissed and the CO filed by the assessee is allowed

Bench: Shri R. K. Panda & Ms. Astha Chandraassessment Year : 2017-18

1) of section 153A. This amendment will take effect from 1st June, 2015. 55. Thus, on a bare perusal of the plain language of the above explanation in respect of the amendment introduced in the section 153C of the Act w.e.f. 01/06/2015, we find that it mandates that in case any information is found during the course of any search

DEPUTY COMMISSIONER OF INCOME-TAX vs. CHETAS CONTROL SYSTEMS PVT. LTD.,, PUNE

In the result, the appeal of Revenue is dismissed

Bench: Ms. Sushma Chowla, Jm & Shri Anil Chaturvedi, Am आयकर अपीऱ सं. / Ita No.1302/Pun/2016 यििाारण वषा / Assessment Year : 2012-13 The Dy. Commissioner Of Income Tax, अऩीऱाथी/Appellant Circle 1(1), Pune …. Vs. Chetas Control Systems Pvt. Ltd., Plot No.1, S.No.8+9, Chetas House, Shree Sidhatek Hsg. Society, Sutarwadi, Pashan, …. प्रत्यथी / Respondent Pune – 411021 Pan: Aaacc7437N अऩीऱाथी की ओर से / Appellant By : Shri Rajesh Gawli प्रत्यथी की ओर से / Respondent By : None घोषणा की तारीख / सुनवाई की तारीख / Date Of Hearing : 01.10.2018 Date Of Pronouncement: 16.10.2018

depreciation at ₹ 13 lakhs, balance amount of ₹ 1,17,00,000/- was capitalized and disallowed as revenue expenditure under section 37 of the Act. The Assessing Officer further held that the assessee has concealed particulars of its income and furnished inaccurate particulars of income, penalty proceedings under section 271(1)(c

REXEL INDIA PRIVATE LIMITED,PUNE vs. DEPUTY COMMISSIONER OF INCOME TAX, PUNE

In the result, appeal of the assessee is partly allowed for statistical\npurposes

13 (Pune\nTribunal)\n6.4 The Ld. AR further placed before us the following case laws\nsupporting the above contention of the assessee:\n(i) Disney Broadcasting (India) (P.) Ltd. Vs. Principal Commissioner of\nIncome Tax [2024] 163 taxmann.com 40 (Mumbai-Trib)\n(ii) Dow Chemical International (P.) Ltd. Vs. Deputy Commissioner of\nIncome Tax [2024] 169 taxmann.com 290 (Mumbai-Trib

SKODA AUTO INDIA PVT. LTD.,,AURANGABAD vs. ASSISTANT COMMISSIONER OF INCOME-TAX,, PUNE

In the result, appeal of the assessee in ITA No

Bench: Shri R.S.Syal, Vp & Shri Partha Sarathi Chaudhury, Jm आयकर अपीऱ सं. / Ita No.714/Pun/2011 नििाारण वषा / Assessment Year : 2005-06 The Assistant Commissioner Of Income Tax, Circle-1, Aurangabad. .......अऩीऱाथी / Appellant बिाम / V/S. Skoda Auto India Pvt. Ltd. Plot No.A1/1, Shendra Five Star Industrial Area, Midc, Aurangabad-431 201 Pan :Aaecs3749M ……प्रत्यथी / Respondent

Depreciation cannot be computed as per American rules applicable to the parent company. Therefore, Mr. Ostwal was correct in adjusting margin of profit of the taxpayer.” Thus, the Hon‟ble ITAT, Pune has also allowed adjustments made by the appellant to its profitability to account for difference and ensure comparability of the entities being compared. 10.6 The appellant has contended

ACIT,CIR.-1,, AURANGABAD vs. SKODA AUTO INDIA PVT. LTD.,, AURANGABAD

In the result, appeal of the assessee in ITA No

Bench: Shri R.S.Syal, Vp & Shri Partha Sarathi Chaudhury, Jm आयकर अपीऱ सं. / Ita No.714/Pun/2011 नििाारण वषा / Assessment Year : 2005-06 The Assistant Commissioner Of Income Tax, Circle-1, Aurangabad. .......अऩीऱाथी / Appellant बिाम / V/S. Skoda Auto India Pvt. Ltd. Plot No.A1/1, Shendra Five Star Industrial Area, Midc, Aurangabad-431 201 Pan :Aaecs3749M ……प्रत्यथी / Respondent

Depreciation cannot be computed as per American rules applicable to the parent company. Therefore, Mr. Ostwal was correct in adjusting margin of profit of the taxpayer.” Thus, the Hon‟ble ITAT, Pune has also allowed adjustments made by the appellant to its profitability to account for difference and ensure comparability of the entities being compared. 10.6 The appellant has contended

ASSISTANT COMMISSIONER OF INCOME TAX, KOLHPAUR vs. RBL BANK LTD, KOLHAPUR

In the result, the appeal of the Revenue is dismissed

Bench: SATBEER SINGH GODARA, JUDICIAL MEMBER, AND DR.DIPAK P. RIPOTE (Accountant Member)

13,37,53,975 36(l)(viia) Doubtful Debts Bad debts written off 65,97,164 36(l)(vii) 2. 46. Section 36(l)(viia) of the Act provides for deduction of provision for bad debts, while Section 36(1 )(vii) deals with deduction for bad debts actually written off. In the facts of the assessee, it has actually written

ASHOK NARAYAN BHOSALE,PUNE vs. DEPUTY COMMISSIONER OF INCOME-TAX, CIRCLE - 8,, PUNE

In the result, appeal of the Assessee is Partly Allowed

Bench: Shri Partha Sarathi Chaudhury, Jm & Dr. Dipak P. Ripote, Am आयकरअपीलसं. / Ita No.1501/Pun/2017 िनधा"रण वष" / Assessment Year : 2013-14 Ashok Narayan Bhosale, The Deputy Commissioner Of Ashok Narayan Bhosle Bunglow At Vs Income Tax, Kaveri Nagar, Pratham Housing Cirlce-8, Pune. Society, Wakad, Pune – 411057. Pan: Aaspb 3588 Q Appellant/ Assessee Respondent /Revenue Assessee By None Revenue By Shri S.P.Walimbe - Dr Date Of Hearing 10/03/2022 Date Of Pronouncement 14/03/2022

1 of Section 32 of the Act had been added which is as follows: “Provided also that where an asset referred to in clause (iia) or the first proviso to clause (iia), as the case may be, is acquired by the assessee during the previous year and is put to use for the purposes of business for a period

POONA BOTTLING COMPNAY PVT. LTD.,,PUNE vs. ASSISTANT COMMISSIONER OF INCOME-TAX,, PUNE

In the result, the appeal of the assessee is allowed

Bench: Ms. Sushma Chowla, Jm & Shri D. Karunakara Rao, Am आयकर अपील सं आयकर अपील सं. / Ita No.1484/Pun/2016 आयकर अपील सं आयकर अपील सं िनधा"रण वष" / Assessment Year : 2007-08 िनधा"रण वष" िनधा"रण वष" िनधा"रण वष"

C. Pandey, 377 ITR 363 “Held, that the sundry creditors mentioned in the balance sheet of the assessee were shown as sundry creditors for several years before the relevant assessment year and at no point of time earlier had the Assessing Officer doubted the creditworthiness or identity of the creditors. There was no remission or cessation of the liability during