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

XVIII) to Section 2(24) of the Income Tax Act, the existing provisions of explanation (10) to section 43(1) of the Income Tax Act contained the guidance for treatment of the Government Grants/Subsidy relating to depreciation

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

XVIII) to Section 2(24) of the Income Tax Act, the existing provisions of explanation (10) to section 43(1) of the Income Tax Act contained the guidance for treatment of the Government Grants/Subsidy relating to depreciation

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

XVIII) to Section 2(24) of the Income Tax Act, the existing\nprovisions of explanation (10) to section 43(1) of the Income Tax Act\ncontained the guidance for treatment of the Government\nGrants/Subsidy relating to depreciation

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

XVIII) to Section 2(24) of the Income Tax Act, the existing\nprovisions of explanation (10) to section 43(1) of the Income Tax Act\ncontained the guidance for treatment of the Government\nGrants/Subsidy relating to depreciation

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

XVIII) to Section 2(24) of the Income Tax Act, the existing\nprovisions of explanation (10) to section 43(1) of the Income Tax Act\ncontained the guidance for treatment of the Government\nGrants/Subsidy relating to depreciation

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

XVIII) to Section 2(24) of the Income Tax Act, the existing provisions of explanation (10) to section 43(1) of the Income Tax Act contained the guidance for treatment of the Government Grants/Subsidy relating to depreciation

ADVIK HI TECH PVT LTD,CHAKAN PUNE vs. DY.COMM. OF INCOME TAX, CIRCLE 8, PUNE, AKURDI, PUNE

Bench: Shri Satbeer Singh Godara & Dr. Dipak P. Ripote

xviii) of the Act reveals that it is inserted by the Finance Act, 2015 w.e.f 01.04.2016 but this provision has also an exclusion of subsidy which is considered for determination of actual cost of the assets as per Explanation 10 to clause (1) of section 43. Therefore, the section 2(24)(xvii) is applicable for subsidy other than the subsidy

ADVIK HI TECH PVT LTD,PUNE vs. DY.COMM.OF INCOME TAX, CIRCLE 8, PUNE, AKURDI PUNE

Bench: Shri Satbeer Singh Godara & Dr. Dipak P. Ripote

xviii) of the Act reveals that it is inserted by the Finance Act, 2015 w.e.f 01.04.2016 but this provision has also an exclusion of subsidy which is considered for determination of actual cost of the assets as per Explanation 10 to clause (1) of section 43. Therefore, the section 2(24)(xvii) is applicable for subsidy other than the subsidy

DY. COMMISSIONER OF INCOME TAX , CIRCLE-8, PUNE, PUNE vs. ADVIK HI-TECH PRIVATE LIMITED , PUNE

Bench: Shri Satbeer Singh Godara & Dr. Dipak P. Ripote

xviii) of the Act reveals that it is inserted by the Finance Act, 2015 w.e.f 01.04.2016 but this provision has also an exclusion of subsidy which is considered for determination of actual cost of the assets as per Explanation 10 to clause (1) of section 43. Therefore, the section 2(24)(xvii) is applicable for subsidy other than the subsidy

ASSISTANT COMMISSIONER OF INCOME-TAX, CIRCLE - 6,, PUNE vs. M/S. SHRINIWAS ENGINEERING AUTO,, PUNE

In the result, the appeal of the Revenue is dismissed

Bench: Shri R.S. Syal & Shri Partha Sarathi Chaudhuryassessment Year : 2013-14 The Asstt. Cit Cir. 6, Pune. Appellant Vs. M/S. Shriniwas Engineering Auto C-10 Abhimanshree Society, Baner Road, Pune-411008 Pan : Aajcs 8944F Respondent Appellant By : Shri Hari Krishan Respondent By : Shri R.G. Gawli Date Of Hearing : 09-05-2022 Date Of Pronouncement : 11-05-2022 Order Per Partha Sarathi Chaudhury, Jm

Section 43(1) of the Act. In the light of the above discussion, for the purpose of computing depreciation allowable to the assessee, the subsidy amount cannot be reduced from the cost of the capital asset. Accordingly, on both the issues we are of the view that the subsidy received by the assessee is nature and it cannot be reduced

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

depreciation and the provisions to Explanation 10 to section 43(1) have no application to the facts of the present case. We are forfeited in taking this view by the decision of the Hon’ble Bombay High Court in the case of Welspun Steel Ltd. cited supra. This decision being that of Jurisdictional High Court is binding on us. Therefore

RIETER INDIA PVT.LTD,,SATARA vs. ASSISTANT COMMISSIONER OF INCOME-TAX, CIRCLE - 5,, PUNE

In the result, the appeal is partly allowed

Bench: Shri R.S. Syal & Shri S.S. Viswanethra Raviनिर्धारण वषा / Assessment Year : 2014-15 Rieter India Private Limited, Vs. Acit, Gat No.768/2, Circle-5, Shindewadi-Bhor Road, Pune Village Wing, Taluka Khandala, District Satara – 412 801 Pan : Aaacr3556P Appellant Respondent

2. Without prejudice to above ground, in case transfer pricing adjustment of INR 59,87,15,956 in relation to the international transactions pertaining to manufacturing operations is sustained, subvention receipt should be set off against transfer pricing adjustment and the transfer pricing adjustment should be restricted only to the extent it is excess of subvention receipt

JOINT COMMISSIONER OF INCOME-TAX, (OSD), CIRCLE -1,, SOLAPUR vs. M/S. LOKMANGAL AGRO INDUSTRIAL LTD,, SOLAPUR

Bench: Shri S.S. Godara & G.D. Padmahshali

section 2(24) (xviii) will have no application. In view of the foregoing discussion, we are satisfied that the subsidy received by the assessee from the Government of Maharashtra is a capital receipt and accordingly not chargeable to tax and at the same time, it is not liable to be reduced from the cost of assets for the purposes

JOINT COMMISSIONER OF INCOME-TAX, (OSD), CIRCLE -1,, SOLAPUR vs. M/S. LOKMANGAL AGRO INDUSTRIES LTD,, SOLAPUR

Bench: Shri S.S. Godara & G.D. Padmahshali

section 2(24) (xviii) will have no application. In view of the foregoing discussion, we are satisfied that the subsidy received by the assessee from the Government of Maharashtra is a capital receipt and accordingly not chargeable to tax and at the same time, it is not liable to be reduced from the cost of assets for the purposes

ATHARVA POLYMERS PRIVATE LIMITED,SHIRUR vs. DEPUTY COMMISSIONER OF INCOME-TAX, CIRCLE -1(1), PUNE

In the result, appeal of the Assessee is Partly Allowed

Bench: Shri S.S.Godara & Dr. Dipak P. Ripoteआयकरअपीलसं. / Ita No.1912/Pun/2019 िनधा"रणवष" / Assessment Year : 2014-15 Atharva Polymers Private The Dy.Commissioner Of Limited, Vs. Income Tax, Cricle-1(1), Gat No.596, Dhoksanghvi, Pune. Ranjangaon Ganpati, Tal.Shirur, Pune – 412209. Pan: Aahca 1363 L Appellant/ Assessee Respondent /Revenue Assessee By Shri Rohit Tapadiya– Ar Revenue By Shri S P Walimbe – Dr Date Of Hearing 09/06/2022 Date Of Pronouncement 06/07/2022 आदेश/ Order Per Dr. Dipak P. Ripote, Am: This Is An Appeal Filed By The Assessee Directed Against The Order Of Ld.Commissioner Of Income Tax(Appeals)-1, Punedated 25.07.2019For The A.Y.2014-15.The Assessee Has Raised The Following Grounds Of Appeal: “1. The Ld. Cit(A) Erred In Passing Ex Party Order. 2. The Ld. Ao Erred & Cit(A) Erred In Confirming The Addition Made Of Rs.1,93,452/- On Account Of Delayed Contribution Made To Pf Although The Same Was Paid Before The Due Date Of Furnishing Of Return U/S 139(1). 3. The Ld. Ao Erred & Ld. Cit(A) Erred In Confirming The Treatment Made W.R.T. Subsidy Received Of Rs.2,72,696/- Under Ip Scheme By Deducting The Receipt From Block Of Asset. 4. The Ld. Ao Erred & Ld. Cit(A) Erred In Not Treating The Subsidy Received Under Ip Scheme As Capital Receipt.

2(24) sub-clause (xviii) is not applicable to the years under consideration and thus as a natural consequence the subsidy received by the assessee would therefore, not form part of its total income. In view of the aforestated facts and circumstances and the judicial pronouncements, we do not find any reason to interfere with the findings

SHRINIWAS ENGINEERING AUTO COMPONENTS PVT. LTD,PUNE vs. ACIT CIRCLE 6, PUNE

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

Bench: Dr.Manish Borad & Shri Vinay Bhamoreआयकर अपील सं. / Ita No.201/Pun/2025 Assessment Year : 2015-16

24)(xviii) of the Act. 3. The appellant craves leave to add to or amend/modify or delete any or all of the above grounds of appeal.” 3. Brief facts of the case are that the assessee is a Private Limited Company engaged in the business of manufacturing and Job work of Automobile Goods. Loss of ₹30,26,69,877/- claimed