SUPERFINE METALS P LTD,AHMEDNAGAR vs. ASSISTANT COMMISSIONER OF INCOME-TAX, CENTRAL CIRCLE 1(2), , PUNE

Bench: Shri S. S. Godara & Shri G. D. Padmahshaliआयकर अपीऱ सं. / Ita Nos. 631 To 634/Pun/2021 निर्धारण वर्ा / Assessment Years : 2010-2011 To 2013-14 Superfine Metals Private Ltd., E29/E39, Supa Midc, Tal. Parner, Ahmednagar – 414302 . . . . . . . अपीऱधर्थी / Appellant Pan:Aakcs6038H बनाम / V/S. Asst. Commissioner Of Income Tax, . . . . . . . . प्रत्यर्थी / Respondent Central Circle 1(2), Pune द्वारा/ Appearances Assessee By : Shri M. K. Kulkarni Revenue By : Shri M. G. Jasnani सुनवाई की तारीख / Date Of Conclusive Hearing : 28/09/2022 घोषणा की तारीख / Date Of Pronouncement : 07/10/2022 आदेश / Order Per G. D. Padmahshali, Am; Present Bunch Of Five Appeals Of The Assessee Is Assailed Against Separate Orders Of Commissioner Of Income Tax (Appeals), Pune-11 [For Short “Cit(A)”] All Dt. 16/11/2021 Passed U/S 250 Of The Income-Tax Act, 1961 [For Short “The Act”], Which Arose Out Of Rectification Orders Dt. 20/02/2021 Passed U/S 154 By The Asst. Commissioner Of Income Tax, Central Circle 1(2), Pune [For Short “Ao”] For Assessment Years [For Short “Ay”] 2010-11 To 2013-14. Itat-Pune Page 1 Of 12

depreciation u/s 32(1)(iia) of the Act for impugned assessment years, in the light of limitation casted in sub-section 7 of section 154

SUPERFINE METALS P LTD,AHMEDNAGAR vs. ASSISTANT COMMISSIONER OF INCOME-TAX, CENTRAL CIRCLE 1(2), , PUNE

Bench: Shri S. S. Godara & Shri G. D. Padmahshaliआयकर अपीऱ सं. / Ita Nos. 631 To 634/Pun/2021 निर्धारण वर्ा / Assessment Years : 2010-2011 To 2013-14 Superfine Metals Private Ltd., E29/E39, Supa Midc, Tal. Parner, Ahmednagar – 414302 . . . . . . . अपीऱधर्थी / Appellant Pan:Aakcs6038H बनाम / V/S. Asst. Commissioner Of Income Tax, . . . . . . . . प्रत्यर्थी / Respondent Central Circle 1(2), Pune द्वारा/ Appearances Assessee By : Shri M. K. Kulkarni Revenue By : Shri M. G. Jasnani सुनवाई की तारीख / Date Of Conclusive Hearing : 28/09/2022 घोषणा की तारीख / Date Of Pronouncement : 07/10/2022 आदेश / Order Per G. D. Padmahshali, Am; Present Bunch Of Five Appeals Of The Assessee Is Assailed Against Separate Orders Of Commissioner Of Income Tax (Appeals), Pune-11 [For Short “Cit(A)”] All Dt. 16/11/2021 Passed U/S 250 Of The Income-Tax Act, 1961 [For Short “The Act”], Which Arose Out Of Rectification Orders Dt. 20/02/2021 Passed U/S 154 By The Asst. Commissioner Of Income Tax, Central Circle 1(2), Pune [For Short “Ao”] For Assessment Years [For Short “Ay”] 2010-11 To 2013-14. Itat-Pune Page 1 Of 12

depreciation u/s 32(1)(iia) of the Act for impugned assessment years, in the light of limitation casted in sub-section 7 of section 154

SUPERFINE METALS P LTD,AHMEDNAGAR vs. ASSISTANT COMMISSIONER OF INCOME-TAX, CENTRAL CIRCLE 1(2), , PUNE

Bench: Shri S. S. Godara & Shri G. D. Padmahshaliआयकर अपीऱ सं. / Ita Nos. 631 To 634/Pun/2021 निर्धारण वर्ा / Assessment Years : 2010-2011 To 2013-14 Superfine Metals Private Ltd., E29/E39, Supa Midc, Tal. Parner, Ahmednagar – 414302 . . . . . . . अपीऱधर्थी / Appellant Pan:Aakcs6038H बनाम / V/S. Asst. Commissioner Of Income Tax, . . . . . . . . प्रत्यर्थी / Respondent Central Circle 1(2), Pune द्वारा/ Appearances Assessee By : Shri M. K. Kulkarni Revenue By : Shri M. G. Jasnani सुनवाई की तारीख / Date Of Conclusive Hearing : 28/09/2022 घोषणा की तारीख / Date Of Pronouncement : 07/10/2022 आदेश / Order Per G. D. Padmahshali, Am; Present Bunch Of Five Appeals Of The Assessee Is Assailed Against Separate Orders Of Commissioner Of Income Tax (Appeals), Pune-11 [For Short “Cit(A)”] All Dt. 16/11/2021 Passed U/S 250 Of The Income-Tax Act, 1961 [For Short “The Act”], Which Arose Out Of Rectification Orders Dt. 20/02/2021 Passed U/S 154 By The Asst. Commissioner Of Income Tax, Central Circle 1(2), Pune [For Short “Ao”] For Assessment Years [For Short “Ay”] 2010-11 To 2013-14. Itat-Pune Page 1 Of 12

depreciation u/s 32(1)(iia) of the Act for impugned assessment years, in the light of limitation casted in sub-section 7 of section 154

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

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

section 43 of the Act has already been taken into account the amount of subsidy for determination of the actual cost of assets for computing the depreciation in the computation of income filed along with return of income of income for the assessment year under consideration. However, ld. AO was not satisfied with these arguments and submissions

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

section 43 of the Act has already been taken into account the amount of subsidy for determination of the actual cost of assets for computing the depreciation in the computation of income filed along with return of income of income for the assessment year under consideration. However, ld. AO was not satisfied with these arguments and submissions

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

section 43 of the Act has already been taken into account the amount of subsidy for determination of the actual cost of assets for computing the depreciation in the computation of income filed along with return of income of income for the assessment year under consideration. However, ld. AO was not satisfied with these arguments and submissions

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

section 43 of the Act has already been taken into account the amount of subsidy for determination of the actual cost of assets for computing the depreciation in the computation of income filed along with return of income of income for the assessment year under consideration. However, ld. AO was not satisfied with these arguments and submissions

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

section 43 of the Act has already been taken into account the amount of subsidy for determination of the actual cost of assets for computing the depreciation in the computation of income filed along with return of income of income for the assessment year under consideration. However, ld. AO was not satisfied with these arguments and submissions

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

154/- for A.Y. 2017-18 and\nRs.60,93,292/- for A.Y. 2018-19.\n\n5.\nAggrieved assessee preferred appeal before ld.CIT(A). For\nthe disallowance u/s.36(1)(va) of the Act, 1d. CIT(A) affirmed\nthe action of the Assessing Officer placing reliance on the\njudgment of Hon'ble Apex Court in the case of Checkmate\nServices

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

Section 43(6) of the IT Act 1961\nestablishes that the depreciation on goodwill as a result of amalgamation is\nnot allowable.\nResultantly, the claims made by the appellant in support of this ground do\nnot have any merit. Therefore, the addition made by assessing officer on\naccount of disallowance of claim of depreciation on goodwill as a result

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

154/- for A.Y. 2017-18 and\nRs.60,93,292/- for A.Y. 2018-19.\n5. Aggrieved assessee preferred appeal before ld.CIT(A). For\nthe disallowance u/s.36(1)(va) of the Act, 1d. CIT(A) affirmed\nthe action of the Assessing Officer placing reliance on the\njudgment of Hon'ble Apex Court in the case of Checkmate\nServices

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

154/- for A.Y. 2017-18 and\nRs.60,93,292/- for A.Y. 2018-19.\n5.\nAggrieved assessee preferred appeal before ld.CIT(A). For\nthe disallowance u/s.36(1)(va) of the Act, 1d. CIT(A) affirmed\nthe action of the Assessing Officer placing reliance on the\njudgment of Hon'ble Apex Court in the case of Checkmate\nServices

M/S KOLTE-PATIL INTEGRATED TOWNSHIPS LIMITED,PUNE vs. DEPUTY COMMISSIONER OF INCOME TAX, CIRCLE-7, PUNE, PUNE

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

Bench: Shri R. K. Panda & Shri Vinay Bhamoreassessment Year : 2021-22

154 of the Act. We find the CPC without assigning any reasons and without giving opportunity to the assessee enhanced the tax liability by determining the tax at normal rate as against u/s 115BAA. 12. We find the provisions of section 115BAA read as under: “115BAA. (1) Notwithstanding anything contained in this Act but subject to the provisions of this

ADHAR PROJECT WELFARE SOCIETY,SANGLI vs. ITO EXEMPTION, KOLHAPUR

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

Bench: Shri Manish Borad & Ms. Astha Chandra

section 154 of the Act. The JAO, after having gone through information available, concluded that the appellant was not eligible to avail exemption u/s 11 of the Act for the AY 2016-17 as necessary approval u/s 12AA of the Act was not obtained by it. The appellant filed return of income in ITR 7 which is applicable

ZF STEERING GEAR (INDIA) LTD,,PUNE vs. DEPUTY COMMISSIONER OF INCOME-TAX, CENTRAL CIRCLE -1 (1),, PUNE

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

Bench: Shri R.S.Syal, Vp & Shri Partha Sarathi Chaudhury, Jm Assessment Year: 2013-14

section (2) of sec. 14A of the Act could be invoked only if the ld. O having regard to the accounts of the assessee, was not satisfied with the correctness of the claim of the assessee in respect of such expenditure in relation to income which does not form part of the total income under

SUPERFINE METALS P LTD,AHMEDNAGAR vs. ASSISTANT COMMISSIONER OF INCOME-TAX, CENTRAL CIRCLE 1(2), , PUNE

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

depreciation in respect of plant and machinery. The said application u/s 154 was dismissed by the Assessing Officer as barred by limitation, as prescribed under the provisions of sub-section

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