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

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. 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

253 (SC) and in the case\nof CIT Vs. Ponny Sugars and Chemicals Ltd. 306 ITR 392.\nLd.CIT(A) has also discussed the amendment in section\n2(24)(xviii) effective from 01.04.2016 and has held that since\nthe purpose of the subsidy is not towards acquiring of any new\nfixed assets therefore such subsidy cannot be reduced from\nthe actual

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

253 (SC) and in the case\nof CIT Vs. Ponny Sugars and Chemicals Ltd. 306 ITR 392.\nLd.CIT(A) has also discussed the amendment in section\n2(24)(xviii) effective from 01.04.2016 and has held that since\nthe purpose of the subsidy is not towards acquiring of any new\nfixed assets therefore such subsidy cannot be reduced from\nthe actual

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

253 (SC) and in the case\nof CIT Vs. Ponny Sugars and Chemicals Ltd. 306 ITR 392.\nLd.CIT(A) has also discussed the amendment in section\n2(24)(xviii) effective from 01.04.2016 and has held that since\nthe purpose of the subsidy is not towards acquiring of any new\nfixed assets therefore such subsidy cannot be reduced from\nthe actual

ASSISTANT COMMISSIONER OF INCOME TAX,, ICHALKARANJI vs. PARIKH SHANKARLAL KUNDANMAL,, KOLHAPUR

In the result, appeals of Revenue and the Cross Objections by the assessee are partly allowed

Bench: Ms. Sushma Chowla, Jm आयकर अपीऱ सं. / Ita Nos.733 To 736/Pun/2017 यििाारण वषा / Assessment Years : 2004-05 To 2006-07 & 2009-10

depreciation (UAD) of earlier years which have already been set off against the other income of the assessee, for the purpose of claiming deduction u/s 80IA(4) of the Act, 1961 thereby ignoring the provisions of section 80IA(5) ? 2. On the facts and in the circumstances of the case and in law, whether the Ld. CIT(A) is justified

ASSISTANT COMMISSIONER OF INCOME TAX,, ICHALKARANJI vs. PARIKH SHANKARLAL KUNDANMAL,, KOLHAPUR

In the result, appeals of Revenue and the Cross Objections by the assessee are partly allowed

Bench: Ms. Sushma Chowla, Jm आयकर अपीऱ सं. / Ita Nos.733 To 736/Pun/2017 यििाारण वषा / Assessment Years : 2004-05 To 2006-07 & 2009-10

depreciation (UAD) of earlier years which have already been set off against the other income of the assessee, for the purpose of claiming deduction u/s 80IA(4) of the Act, 1961 thereby ignoring the provisions of section 80IA(5) ? 2. On the facts and in the circumstances of the case and in law, whether the Ld. CIT(A) is justified

ASSISTANT COMMISSIONER OF INCOME TAX,, ICHALKARANJI vs. PARIKH SHANKARLAL KUNDANMAL,, KOLHAPUR

In the result, appeals of Revenue and the Cross Objections by the assessee are partly allowed

Bench: Ms. Sushma Chowla, Jm आयकर अपीऱ सं. / Ita Nos.733 To 736/Pun/2017 यििाारण वषा / Assessment Years : 2004-05 To 2006-07 & 2009-10

depreciation (UAD) of earlier years which have already been set off against the other income of the assessee, for the purpose of claiming deduction u/s 80IA(4) of the Act, 1961 thereby ignoring the provisions of section 80IA(5) ? 2. On the facts and in the circumstances of the case and in law, whether the Ld. CIT(A) is justified

ASSISTANT COMMISSIONER OF INCOME TAX,, ICHALKARANJI vs. PARIKH SHANKARLAL KUNDANMAL,, KOLHAPUR

In the result, appeals of Revenue and the Cross Objections by the assessee are partly allowed

Bench: Ms. Sushma Chowla, Jm आयकर अपीऱ सं. / Ita Nos.733 To 736/Pun/2017 यििाारण वषा / Assessment Years : 2004-05 To 2006-07 & 2009-10

depreciation (UAD) of earlier years which have already been set off against the other income of the assessee, for the purpose of claiming deduction u/s 80IA(4) of the Act, 1961 thereby ignoring the provisions of section 80IA(5) ? 2. On the facts and in the circumstances of the case and in law, whether the Ld. CIT(A) is justified

DEPUTY COMMISSIONER OF INCOME-TAX vs. M/S. SUNGARD SOLUTIONS (I) PVT. LTD.,, PUNE

In the result, the appeal of Revenue in ITA

Bench: Shri Anil Chaturvedi, Am & Shri S.S. Viswanethra Ravi, Jm

depreciation of INR 2,253,214 under section 40(a)(ia) on software purchased and capitalized in the books of account

DCIT, BANGALORE vs. M/S SUNGARD SOLUTIONS INDIA PVT. LTD.,, BANGALORE

In the result, the appeal of Revenue in ITA

Bench: Shri Anil Chaturvedi, Am & Shri S.S. Viswanethra Ravi, Jm

depreciation of INR 2,253,214 under section 40(a)(ia) on software purchased and capitalized in the books of account

SUNGARD SOLUTIONS (INDIA) P. LTD.,,PUNE vs. DEPUTY COMMISSIONER OF INCOME-TAX,,

In the result, the appeal of Revenue in ITA

Bench: Shri Anil Chaturvedi, Am & Shri S.S. Viswanethra Ravi, Jm

depreciation of INR 2,253,214 under section 40(a)(ia) on software purchased and capitalized in the books of account

M/S SUNGARD SOLUTIONS (INDIA) PRIVATE LIMITED,PUNE vs. DCIT, BANGALORE

In the result, the appeal of Revenue in ITA

Bench: Shri Anil Chaturvedi, Am & Shri S.S. Viswanethra Ravi, Jm

depreciation of INR 2,253,214 under section 40(a)(ia) on software purchased and capitalized in the books of account

ASSISTANT COMMISSIONER OF INCOME-TAX,, PUNE vs. NORD DRIVE SYSTEMS PVT. LTD.,, PUNE

In the result, the appeal as well as cross objection are

Bench: Shri R.S. Syal & Shri Partha Sarathi Chaudhuryआयकर अपील सं. / Ita No.825/Pun/2016 िनधा"रण वष" / Assessment Year : 2011-12 Acit, Circle-2, Vs. Nord Drive Systems Pvt. Ltd., Pune 282/2, 283/2, Plot No.15, Village Mann, Mulshi, Pune – 411 057 Pan : Aaccn0708R Appellant Respondent C.O. No.12/Pun/2018 (Arising Out Of Ita No.825/Pun/2016) िनधा"रण वष" / Assessment Year : 2011-12 Nord Drive Systems Pvt. Ltd., Vs. Acit, Circle-2, 282/2, 283/2, Plot No.15, Pune Village Mann, Taluka Mulshi, Adj. Hinjewadi Midc, Phase-Ii, Pune – 411 057 Pan : Aaccn0708R Cross Objector Appellant In The Appeal Assessee By Shri Sharad Shah & Shri Rohit Tapadia Revenue By Shri T. Vijaya Bhaskar Reddy Date Of Hearing 27-11-2019 Date Of Pronouncement 28-11-2019 आदेश / Order

depreciation, in the present case) between the controlled and the comparable controlled transaction has a likely effect of affecting the price, or cost charged/paid or profit arising therefrom. I agree with the contention of the assessee. However, the decision may be taken on merit.” 7. Thus, it is seen that though the TPO did not originally agree with the assessee

INCOME TAX OFFICER, WARD-11(1), PUNE, PUNE vs. MAHARASHTRA CRICKET ASSOCIATION, PUNE, PUNE

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

depreciation\nof Rs.17,67,439/-, capital expenditure being application of Rs.\n23,02,72,512/- and deficit brought forward of Rs.58,64,46,708/- and\nclaimed total of these of Rs.97,28,31,592/- as deduction and arrived at\ntotal income of Rs. NIL in view of exemption u/s 11 claiming application of\nincome of more than 85% and working

TETRA PAK INDIA PRIVATE LTD.,,PUNE vs. DY.CIT, CIR.7, PUNE, PUNE

The appeal of the assessee is partly allowed for statistical purposes

Bench: Shri D. Karunakara Rao, Am & Shri Vikas Awasthy, Jm आयकर अपील सं. / Ita No.111/Pun/2011 िनधा"रण वष" / Assessment Year : 2006-07 Tetra Pak India Private Ltd., Mayfair Towers, Wakdewadi, Shivajinagar, Pune-411005. .......अपीलाथ" / Appellant Pan : Aaact3467B बनाम / V/S. Dcit, Circle-7, ……""यथ" / Respondent Pune. Assessee By : Shri Nikhil Pathak Revenue By : Shri S. B. Prasad सुनवाई क" तारीख / Date Of Hearing : 02.07.2019 घोषणा क" तारीख / Date Of Pronouncement : 27.08.2019 आदेश / Order Per D. Karunakara Rao, Am: This Appeal Is Filed By The Assessee Against The Orders Of Assessing Officer/Tpo/Drp For The Assessment Year 2006-07. 2. The Grounds Raised By The Assessee Are As Under :- “Based On The Facts & Circumstances Of The Case, Tetra Pak India Private Limited (Hereinafter Referred To As ‘The Appellant’) Respectfully Craves Leave To Prefer An Appeal Under Section 253(1)(D) Of The Income- Tax Act, 1961 (Hereinafter Referred To As ‘Act’), Against The Order Dated 25 November 2010 Passed By The Deputy Commissioner Of Income Tax- Circle 7 (Hereinafter Referred To As ‘The Assessing Officer’) Under Section 143(3) Read With Section 144C(13) Of The Act In Pursuance Of The Directions Dated 20 September 2010 Issued By The Honorable Dispute Resolution Panel (Hereinafter Referred To As ‘The Honorable Drp’), On The Following Grounds: On The Facts & In The Circumstances Of The Case & In Law, The Honorable Drp & Consequentially The Learned Ao Have: I Grounds Of Objections In Respect Of Transfer Pricing Adjustment

253(1)(d) of the Income- tax Act, 1961 (hereinafter referred to as ‘Act’), against the order dated 25 November 2010 passed by the Deputy Commissioner of Income Tax- Circle 7 (hereinafter referred to as ‘the Assessing Officer’) under section 143(3) read with section 144C(13) of the Act in pursuance of the directions dated 20 September 2010 issued

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

253( 1)( d) of the Income-tax Act, 1961 (hereinafter referred to as 'Act') against the order dated 15 February 2022 (received on 15 February 2022 via email) passed by the Additional/Joint/Deputy/Assistant Commissioner of Income Taxi Income Tax Officer, National Faceless Assessment Centre, Delhi(hereinafter referred to as 'the learned AO') under section 143(3) read with section 144C