EATON TECHNOLOGIES PRIVATE LIMITED,PUNE vs. PRINCIPAL COMMISSIONER OF INCOME TAX, PUNE

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

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

section 263 of the Act. The notice so issued by the PCIT reads as under : “NOTICE FOR THE HEARING M/s/Mr/Ms Subject: Notice for Hearing in respect of Revision proceedings u/s 263 of the THE INCOME TAX ACT, 1961-Assessment Year 2017- 18. In this regard, a hearing in the matter is fixed on 20/02/2024

ASSTT. COMMISSIONER OF INCOME TAX (EXEMPTIONS), CIRCLE, PUNE, PUNE vs. THE SHETKARI SHIKSHAN MANDAL, PUNE

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

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

depreciation on such assets during earlier assessment years, which indicated to the Assessing Officer that the assessee had claimed exemption in respect of acquisition of capital asset as per the provisions of section 11(6) of the Act. Since the assessee had already availed the exemption towards acquisition of capital assets which was acquired from loan fund, the application

M/S PERSISTENT SYSTEMS LIMITED,PUNE vs. ASSESSMENT UNIT, INCOME-TAX DEPARTMENT, PUNE

In the result, appeal of the Assessee is Partly Allowed

Bench: Shri S.S.Godara & Dr. Dipak P. Ripoteआयकरअपीलसं. / Ita No.692/Pun/2022 िनधा"रणवष" / Assessment Year : 2018-19 M/S.Persistent Systems Assessment Unit, Income Limited, V Tax Department. “Bhageerath” 402, Senapati S Bapat Road, Pune – 411016. Pan: Aabcp 1209 Q Appellant/ Assessee Respondent /Revenue Assessee By Shri Dhanesh Bafna& Shriaditya Vaidya– Ar’S Revenue By Shri Suhas Kulkarni - Irs Addl Commissioner Of Income Tax Date Of Hearing 26/09/2023 Date Of Pronouncement 02/11/2023 आदेश/ Order Per Dr. Dipak P. Ripote, Am: This Appeal Filed By The Assessee Is Directed Against The Assessment Order, Dated 20.07.2022 Under Section 143(3) R.W.S. 144C(13) Read With Section 144B Of The Income Tax Act, 1961 For A.Y.2018-19. The Assessee Has Raised The Following Grounds Of Appeal: “Ground 1: Order Is Invalid / Non Est  On The Facts & In The Circumstances Of The Case & In Law, The Assessment Unit (‘Au’) Has Erred In Passing The Draft Assessment M/S.Persistent Systems Limited [A]

144B of the Income Tax Act, 1961 (‘the Act’) with regard to granting an opportunity for personal hearing via video conference and without providing an opportunity to the Appellant to file a written submission in response to the Show-cause notice. Dispute Resolution Panel (‘Ld. DRP’) erred in upholding the same by contending that there was no denial of opportunity

M/S. ADLER MEDIEQUIP PVT. LTD.,,PUNE vs. DEPUTY COMMISSIONER OF INCOME-TAX, CENTRAL CIRCLE -1(1),, PUNE

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

144B of the Income-tax Act, 1961 ('the Act’) in pursuance of the directions issued by Dispute Resolution Panel-3 (DRP), Mumbai dated 23 December 2021 under section 144C(5) of the Act on the following grounds: General 1. On the facts and in the circumstances of the case and in law, the AO, based on directions

MAHATMA PHULE GRAMIN BIGARSHETI SAHAKAR PAT SANSTHA LTD,KOLHAPUR vs. PCIT-1, PUNE, PUNE

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

Bench: Shri R. K. Panda & Ms. Astha Chandraassessment Year : 2018-19 Mahatma Phule Gramin Bigarsheti Pcit-1, Pune Sahakar Pat Sanstha Vs. A/P Hattiwade, Ajara, Kolhapur – 416505 Pan: Aaaam2608K (Appellant) (Respondent) Assessee By : None (Written Submission Filed) Department By : Shri Amol Khairnar, Cit-Dr Date Of Hearing : 09-12-2025 Date Of Pronouncement : 09-01-2026 O R D E R

depreciation and investment allowance as referred to in sections 32 and 32A respectively, the Commissioner was justified in invoking revision under section 263 of the Act. The relevant observations of Hon’ble High Court from para 10 to 16 read as under: “10. The law on exercise of jurisdiction under Section 263 of the Act is settled by the decision

M/S. VISHAY COMPONENTS INDIA PRIVATE LIMITED,,PUNE vs. ASSISTANT COMMISSIONER OF INCOME-TAX, CIRCLE - 12, PUNE

The appeal of the assessee is partly allowed for statistical purposes

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

section 144B of the Income-tax Act, 1961 ('the Act') in pursuance of the directions dated 25 January 2022(received on 25 January 2022) issued by the Honorable Dispute Resolution Panel-3, Mumbai (hereinafter referred to as 'Hon'ble DRP') on the following grounds which are independent and without prejudice to each other: On the facts and in the circumstances

BANK OF MAHARASHRA,PUNE vs. THE PR. COMMISSIONER OF INCOME TAX, PUNE, PUNE

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

Bench: Shri R. K. Panda & Ms Astha Chandraassessment Year : 2018-19

Depreciation Claim v. Default in TDS vi. Default in TDS & Disallowance for such Default vii. Refund Claim viii. Business Loss ix. ICDS Compliance and Adjustment x. Disallowance u/s 40A(7) (Gratuity provision) xi. Expenses incurred for Earning Exempt Income xii. Excess Contribution to Provident Fund, Superannuation Fund or Gratuity Fund xiii. Capital Gains/Income on Sale of Property xiv. Business Expenses

KAY POWER AND PAPER LIMITED,SATARA vs. INCOME TAX OFFICER, WARD-2, SATARA

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

Bench: Shri R. K. Panda & Shri Vinay Bhamore

depreciation is of Rs.31,61,21,110/-. It was submitted that the net profit earned on derivative transactions referred to in the notice u/s 148 of the Act has been properly accounted for in the Profit and Loss Account and there is no attempt to avoid income tax. It was accordingly requested to drop the proceedings initiated

KAY POWER AND PAPER LIMITED,SATARA vs. INCOME TAX OFFICER, WARD-2, SATARA

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

Bench: Shri R. K. Panda & Shri Vinay Bhamore

depreciation is of Rs.31,61,21,110/-. It was submitted that the net profit earned on derivative transactions referred to in the notice u/s 148 of the Act has been properly accounted for in the Profit and Loss Account and there is no attempt to avoid income tax. It was accordingly requested to drop the proceedings initiated

VEGA INDIA LEVEL AND PRESSURE MEASUREMENT P LTD,PUNE vs. DEPUTY COMMISSIONER OF INCOME-TAX, CIRCLE -12, PUNE, PUNE

In the result, the appeal is partly allowed

Bench: Shri R.S. Syal & Shri Partha Sarathi Chaudhuryिनधा"रण वष" / Assessment Year: 2017-18

section 144B of the Income-tax Act, 1961 (hereinafter also called ‘the Act’) in relation to the assessment year 2017-18. 2. Pithily put, the facts of the case are that the assessee is a wholly owned Indian subsidiary of Grieshaber Verwaltungsgeselleshaft GmBH, Germany. It is engaged in Assembly, Trading, Field commissioning, Repairing and Provision 2 Vega India Level

SHAHU SHIKSHAN PRASARAK MANDAL, LATUR,LATUR vs. ACIT (EXMP.) CIRCLE, AURANGABAD, AURANGABAD

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

Section 57(iii) does not require this purpose must be fulfilled in\norder to qualify the expenditure for deduction.\n❖ It does not say that, expenditure shall be deductible only, if\nany income is made or earned. There is in fact nothing in the\nlanguage u/s. 57(iii) to suggest that, the purpose for which the\nexpenditure is made should

NATHARAM PANAJI CHOUDHARY,PUNE vs. I.T.O. WARD 8(1), PUNE, PUNE

In the result, the appeal of the assessee is allowed for statistical purposes

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

144B of the Act vide his order dated 19.03.2022 thereby making an addition of Rs.60,76,654/- as unexplained money u/s 69A of the Act. 3. Aggrieved, the assessee preferred an appeal before the Ld. CIT(A)/NFAC challenging the above addition made by the Ld. AO. The Ld. CIT(A)/NFAC dismissed the appeal of the assessee and sustained

NATHARAM PANAJI CHOUDHARY,PUNE vs. I.T.O. WARD 8(1), PUNE, PUNE

In the result, the appeal of the assessee is allowed for statistical purposes

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

144B of the Act vide his order dated 19.03.2022 thereby making an addition of Rs.60,76,654/- as unexplained money u/s 69A of the Act. 3. Aggrieved, the assessee preferred an appeal before the Ld. CIT(A)/NFAC challenging the above addition made by the Ld. AO. The Ld. CIT(A)/NFAC dismissed the appeal of the assessee and sustained

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

144B of the Act has treated the assessee as ‘local authority’, the details of which are as under: ITA Nos.1153, 1155 & 1154/MUM/2016 58. Further we find merit in the arguments of the Ld. Counsel for the assessee that the assessee is a ‘local authority’ within the meaning of Article 12 of the Constitution of India by virtue 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

144B of the Act has treated the assessee as ‘local authority’, the details of which are as under: ITA Nos.1153, 1155 & 1154/MUM/2016 58. Further we find merit in the arguments of the Ld. Counsel for the assessee that the assessee is a ‘local authority’ within the meaning of Article 12 of the Constitution of India by virtue 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

144B of the Act has treated the assessee as ‘local authority’, the details of which are as under: ITA Nos.1153, 1155 & 1154/MUM/2016 58. Further we find merit in the arguments of the Ld. Counsel for the assessee that the assessee is a ‘local authority’ within the meaning of Article 12 of the Constitution of India by virtue 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

144B of the Act has treated the assessee as ‘local authority’, the details of which are as under: ITA Nos.1153, 1155 & 1154/MUM/2016 58. Further we find merit in the arguments of the Ld. Counsel for the assessee that the assessee is a ‘local authority’ within the meaning of Article 12 of the Constitution of India by virtue 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

144B of the Act has treated the assessee as ‘local authority’, the details of which are as under: ITA Nos.1153, 1155 & 1154/MUM/2016 58. Further we find merit in the arguments of the Ld. Counsel for the assessee that the assessee is a ‘local authority’ within the meaning of Article 12 of the Constitution of India by virtue of section