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

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

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

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

SHRINIWAS ENGINEERING AUTO COMPONENTS PVT. LTD,PUNE vs. ITO WARD6(1), PUNE

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

depreciation. Please refer submissions in\nAnnexure 'A' to Assessment Year 2016-17 and 2017-18.\n\n(B) The adjustment made is outside the scope of the specific items of\nadjustments permitted u/s 143(1)(a) of the Income Tax Act.\n\nhas (ii) The reasons given in the adjustments made under section

ACIT, PUNE vs. SHRINIWAS ENGINEERING AUTO COMPONENTS PRIVATE LIMITED, PUNE

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

depreciation. Please refer submissions in\nAnnexure 'A' to Assessment Year 2016-17 and 2017-18.\n(B) The adjustment made is outside the scope of the specific items of\nadjustments permitted u/s 143(1)(a) of the Income Tax Act.\nhas (ii) The reasons given in the adjustments made under section

SHRINIWAS ENGINEERING AUTO COMPONENTS PVT. LTD,PUNE vs. ITO WARD 6(1), PUNE

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

depreciation. Please refer submissions in\nAnnexure 'A' to Assessment Year 2016-17 and 2017-18.\n(B) The adjustment made is outside the scope of the specific items of\nadjustments permitted u/s 143(1)(a) of the Income Tax Act.\nhas (ii) The reasons given in the adjustments made under section

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

section 37(1).” We also find that the AO for assessment years 2011-12 and 2012-13 pursuant to the remand made by the ITAT accepted vide order dated 26.12.2019 passed u/s 143(3) r.w.s. 254 had accepted the position that the purpose of foreign visits of the employees is only for the purpose of to take decision whether

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 142 has been issued to him, or (b) a return of income has been furnished by such other person but no notice under sub-section (2) of section 143 has been served and limitation of serving the notice under sub-section (2) of section 143 has expired, or (c) assessment or reassessment, if any, has been made

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

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

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

depreciation allowance @ of\n25% on the Goodwill amounting to Rs.14,98,78,251/- on Goodwill of Rs.\n59,95,13,004/- under the provisions of Section 32(1) of the Act. The Ld. AO\ncompleted the assessment by passing the assessment order u/s 143

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. The learned CIT Appeals (Appeals VI), Pune has erred in law as well as in facts while confirming the order of Ld. AO Circle 8, Pune making the addition of Rs.85,47,488/-- being the additional depreciation claimed of the assessee in relation to the assets purchased by the assessee in the year FY 2011-12 after

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

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

Bench: Dr.Manish Borad & Shri Vinay Bhamore

143(3) of the Income-tax Act. The said assessment order has been revised by holding that depreciation on goodwill is not allowable for the following reasons :- A. (i) The Assessing Officer has allowed the claim of depreciation on goodwill without examination of claim. (ii) The intangible asset has been impaired in the previous year and as such cannot

ROXILER SYSTEMS PRIVATE LIMITED,PUNE vs. THE INCOME TAX OFFICER, WARD5(4), PUNE

In the result the appeal of the assessee is allowed for statistical purpose

Bench: Dr.Dipak P. Ripote & Shri Vinay Bhamoreआयकर अपील सं. / Ita No.2078/Pun/2024 िनधा"रण वष" / Assessment Year: 2022-23 Roxiler Systems Pvt. Ltd., A 508, Kamal Green Leaf, Vs The Income Tax Officer, Khadakwasala, Pune – 411024. Ward-5(4), Pune. Pan: Aahcr8766J Appellant/ Assessee Respondent / Revenue Assessee By : Shri Sharad S. Vaze & Shri Amod S. Vaze – Ar’S Revenue By : Shri Arvind Desai – Add.Cit(Dr) Date Of Hearing: 18/11/2024 Date Of Pronouncement : 30/12/2024 आदेश/ Order Per Dr. Dipak P. Ripote, Am: This Is An Appeal Filed By The Assessee Against The Order Of Ld.Commissioner Of Income Tax(Appeals)Addl./Jcit(A), Mysore For Assessment Year 2022-23Dated 20/08/2024 Passed U/Sec.250 Of The Income Tax Act, 1961, Emanating From An Order U/S 143(1) Of The Act Dated 19/08/2023.The Assessee Has Raised The Following Grounds Of Appeal : “1. On The Basis Of Facts & In The Circumstances Of The Case & As Per Law, Rejection Of Claim U/S 80Iac Of The Income Tax Act 1961 (Act) Is Beyond The Powers Of Cpc, Bengaluru In The Powers Of Cps, Bengaluru In Proceedings U/S 143(1) Of The Act. 2. On The Basis Of Facts & In The Circumstances Of The Case & As Per Law, The Commissioner Of Income Tax, (Appeals)-Nfac Delhi Is Not Justified In Rejecting The Claim Of The Assessee U/S 80Iac Of The Act. 3. The Appellant Craves Leave To Add, Alter, Omit Or Substitute Any Of The Grounds At The Time Of Hearing Of The Appeal.”

143(1) of the Act. 2. On the basis of facts and in the circumstances of the case and as per law, the Commissioner of Income Tax, (Appeals)-NFAC Delhi is not justified in rejecting the claim of the assessee u/s 80IAC of the Act. 3. The appellant craves leave to add, alter, omit or substitute any of the grounds

DATTAKALA SHIKSHAN SANSTHA,PUNE vs. A.D.I.T, CPC, BANGALURU, BANGALURU

In the result, the appeal of the assessee in ITA No

Bench: SHRI MANISH BORAD (Accountant Member), MS. ASTHA CHANDRA (Judicial Member)

section 12A(1)(b) of the Act was also filed on 18.02.2021 along with the return of income. Initially, the return was processed u/s 143(1) of the Act vide intimation order dated 24.12.2021 by CPC at total income of Rs.26,70,63,238/- 3 ITA Nos. 2567 & 2459/PUN/2024, AY 2020-21 wherein the CPC disallowed the exemption claimed

DATTAKALA SHIKSHAN SANSTHA,PUNE vs. ASSESSMENT UNIT , I.TAX DEPT, NEW DELHI

In the result, the appeal of the assessee in ITA No

Bench: SHRI MANISH BORAD (Accountant Member), MS. ASTHA CHANDRA (Judicial Member)

section 12A(1)(b) of the Act was also filed on 18.02.2021 along with the return of income. Initially, the return was processed u/s 143(1) of the Act vide intimation order dated 24.12.2021 by CPC at total income of Rs.26,70,63,238/- 3 ITA Nos. 2567 & 2459/PUN/2024, AY 2020-21 wherein the CPC disallowed the exemption claimed

GENERAL INDUSTRIAL CONTROS LTD.,PUNE vs. DCIT CIRCLE 8, PUNE, PUNE

In the result, the order of the CIT(A) is set aside, and the appeal of the assessee is partly allowed

Bench: Dr.Dipak P. Ripote & Shri Vinay Bhamore

143(1) on 13/11/2022 by making addition of Rs.6,71,649/- (Rs.25,68,22,860 Rs. 25.61.51.210) thereby assessing total income at Rs.25.68,22.860/- and computed balance tax liability at Rs.2,73,95,728/- instead of refund declared in return of income of Rs.31.40,690/-.” 2.1 Aggrieved by the order u/sec.143(1) of the Act, assessee filed appeal before