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

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

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. 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

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

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,, 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

5. In principle and as per law, the contention of the Revenue is unassailable. Rule 10B(1)(e) dealing with the determination of the ALP under the TNMM clearly provides that it is the `Net Operating Margin’ realized by the assessee as well as the comparables which should be considered for benchmarking the international transaction in relation to a common

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

253,214 under section 40(a)(ia) on software purchased and capitalized in the books of account of INR 3,755,358 while computing the taxable income of the Appellant due to non-submission of details of tax deducted at source and the Learned DRP erred in confirming the same. 1.2 Without prejudice to the ground 1.1 above, the Learned

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

253,214 under section 40(a)(ia) on software purchased and capitalized in the books of account of INR 3,755,358 while computing the taxable income of the Appellant due to non-submission of details of tax deducted at source and the Learned DRP erred in confirming the same. 1.2 Without prejudice to the ground 1.1 above, the Learned

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

253,214 under section 40(a)(ia) on software purchased and capitalized in the books of account of INR 3,755,358 while computing the taxable income of the Appellant due to non-submission of details of tax deducted at source and the Learned DRP erred in confirming the same. 1.2 Without prejudice to the ground 1.1 above, the Learned

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

253,214 under section 40(a)(ia) on software purchased and capitalized in the books of account of INR 3,755,358 while computing the taxable income of the Appellant due to non-submission of details of tax deducted at source and the Learned DRP erred in confirming the same. 1.2 Without prejudice to the ground 1.1 above, the Learned

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

BHANDARI ASSOCIATES,PUNE vs. PR. COMMISSIONER OF INCOME TAX 2, PUNE, PUNE

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

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

5. On the facts and circumstances of the case, the learned Pr. CIT 2, Pune has erred in appreciating the fact that the Appellant once again in response to the notice u/s 263 has submitted all the relevant documents determining the genuineness and creditworthiness of the unsecured loan availed by the Appellant. 6. The appellant prays that - a. Appellant seeks

MILLENNIUM ENGINEERS AND CONTRACTORS LTD,PUNE vs. DEPUTY COMMISSIONER OF INCOME-TAX, CENTRAL CIRCLE 1(3), , PUNE

The appeal of the assessee stands DISMISSED

Bench: Shri S S Viswanethra Ravi & Shri G. D. Padmahshaliआयकर अपऩल सं. / Ita No. 668/Pun/2022 निर्धारण वषा / Assessment Year : 2018-19

253(1) of the Act on a substantive & solitary ground against the denial of claim for depreciation on goodwill claimed to have arisen to it on acquisition of its subsidiary. 3. At the physical hearing, the Ld. AR Mr. Naniwadekar adverting to scheme of arrangement, share valuation report detailing the swap ratio and relevant part of Accountings Standards