ASSTT. COMMISSIONER OF INCOME TAX (EXEMPTIONS), CIRCLE, PUNE, PUNE vs. ZEAL EDUCATION SOCIETY, PUNE

In the result, appeal of the Revenue is dismissed

Bench: Shri Manish Borad & Ms. Astha Chandra

section 270A of the Act for under-reporting of income. 2.1 During the penalty proceedings, in response to show-cause notice issued u/s 274 r.w.s. 270A of the Act, the assessee vide its reply dated 30/12/2021 submitted as under:- “While the return of income was filed, it was inadvertently taken the amount of Rs. 548212549/- as the assessee's revenue

AAM INDIA MANUFACTURING CORPORATION PRIVATE LIMITED,AHMEDNAGAR vs. INCOME TAX OFFICER, WARD 1, AHMEDNAGAR

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

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

270A of the Act. Any consequential relief to which the Appellant may be entitled under the law in pursuance of the aforesaid grounds of appeal or otherwise, thus may be granted. The Appellant craves leave to add, alter, vary, omit, substitute or amend the above grounds of appeal, at any time before or at, the time of hearing

ASSISTANT COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-2(4), PUNE vs. SANGHVI BEAUTY AND TECHNOLOGIES PRIVATE LIMITED , PUNE

In the result, both the appeal filed by the Revenue as well\nas Cross Objection filed by the assessee are allowed for\nstatistical purposes

270A for the said previous year.]\n[Provided also that the provisions of this clause shall not apply on or\nafter the Ist day of April, 2025.]\n\nExplanation. For the purposes of this clause,-\n(a) the fair market value of the shares shall be the value-\n(i) as may be determined in accordance with such method

SHREEM ELECTRIC LIMITED,KOLHAPUR vs. ACIT CENTRAL CIRCLE, KOLHAPUR, KOLHAPUR

In the result, appeal of the assessee is allowed

Bench: Shri Satbeer Singh Godara & Dr.Dipak P. Ripoteआयकर अपील सं. / Ita No.898/Pun/2024 िनधा"रण वष" / Assessment Year:2017-18 Shreem Electric Limited, V The Assistant Plot No.43 To 46, S Commissioner Of Income L.K.Akiwate Industrial Tax, Estate, Jaysingpur, Shirol, Central Circle, Kolhapur. Kolhapur – 416144. Pan: Aaccs4893C Appellant / Assessee Respondent / Revenue Assessee By None Revenue By Shri Sourabh Nayak -Addl.Cit(Dr) Date Of Hearing 31/07/2024 Date Of Pronouncement 31/07/2024 आदेश/ Order Per Dr. Dipak P. Ripote, Am: This Is An Appeal Filed By Assessee Against The Order Of Ld.Commissioner Of Income Tax(Appeal), Pune-11Passed Under Section 250 Of The Income Tax Act, Dated 31.01.2024 For The A.Y.2017-18. The Assessee Has Raised The Following Grounds Of Appeal : “1. The Learned Cit(A) Erred In Confirming Penalty Under Section 270A Of Rs.3,01,124/-. Shreem Electric Limited, Kolhapur[A] 2. The Learned Cit(A) Failed To Appreciate That, Since The Addition Is Made On Adhoc Basis, No Penalty Can Be Levied. 3. The Penalty Levied May Please Be Delete. 4. The Appellant Craves Leave To Add, Alter, Amend Or Delete Any Of The Above Grounds Of Appeal.” 2. There Is A Delay Of Two Months Of Filing Appeal Before This Tribunal. Considering The Reasons Mentioned In The Affidavit, We Are Convinced With The Reasons For Delay & In The Larger Interest Of Justice, We Condone The Delay.

depreciation cannot be held to be underreporting of income in consequence of misreporting of income, as per section 270A(6) of the Act. Therefore

LIQUIDHUB ANALYTICS PVT. LTD. (NOW MERGED WITH CAPGEMINI TECHNOLOGY SERVICES INDIA LTD),PUNE vs. NFAC, PUNE

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

Bench: Shri R. K. Panda & Shri Vinay Bhamoreassessment Year : 2020-21

270A of the Act on arbitrary premise that there is under-reporting of income done by the Appellant The above grounds are without prejudice to each other The appellant craves leave to alter, amend or withdraw all or any of the grounds herein or add any further grounds as may be considered necessary either before or during the hearing

SEMPERTRANS INDIA PRIVATE LIMITED,ROHA vs. INCOME-TAX OFFICER, PANVEL

In the result, appeal filed by the assessee is partly\nallowed for statistical purposes

270A of the Act, without appreciating the fact that the\nadditions made by the Ld. AO are not in accordance with the law.\nWithout prejudice to the above grounds\n16. On the facts and circumstances of the case and in law, the\nAO has erred in passing the impugned Assessment Order under\nSection 143(3) read with Section 144C

MAN TRUCK & BUS INDIA PRIVATE LIMITED,PUNE vs. DCIT, CIRCLE 7, PUNE

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

Bench: Dr. Manish Borad & Ms. Astha Chandraआयकर अपील सं. / Ita No.814/Pun/2025 धििाारण वषा / Assessment Year: 2018-2019 Vs Dcit, Circle 7, Man Truck & Bus India Private Limited, Pune Level 3, Malpani Agile,Pan Card Club Road, Baner, Pune-411045 Maharashtra Pan-Aaecm6932E Appellant Respondent

depreciation. 6. On the facts and in the circumstances of the case and in law, the Hon'ble CIT(A) failed to appreciate that the learned AO has erred in considering the erroneous computation of total income in intimation issued under 143(1) of the Act while passing the final assessment order. 7. On the facts and in the circumstances

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]

Depreciation expenses originally absorbed by the appellant in its Segmental P&L as per TP Report. Ground 6: Non-acceptance/exclusion of overseas comparable companies On the facts and in the circumstances of the case and in law, the AU based on the directions of Ld. DRP has erred in notaccepting/excluding the overseas comparable companies operating in the regions where

DEPUTY COMMISSIONER OF INCOME TAX, AURANGABAD vs. ASHISH JUGALKISHOR BHALA, JALNA

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

Bench: Shri R. K. Panda & Ms. Astha Chandraassessment Year : 2021-22 Dcit, Aurangabad Ashish Jugalkishor Bhala Mamta Hospital, Shivaji Putla Road, Vs. Bharat Nagar, Jalna – 431203 Maharashtra Pan: Ahmpb3683K (Appellant) (Respondent) Assessee By : Shri Anand Partani Department By : Shri Ramnath P Murkunde Date Of Hearing : 01-04-2025 Date Of Pronouncement : 16-06-2025 O R D E R

section 56(2)(x) of the Income Tax Act. It is seen that the assessee has adopted fair market value of Rs.540/- per share which is not acceptable. The assessee has purchased 1,19,360 shares. Details of such purchase is as under: S.No. Name of the persons from whom you Total Number Value have purchased shares of Metarolls

M/S GIRIRAJ ENTERPRISES,PUNE vs. DCIT, CENTRAL CIRCLE 1(1), PUNE, PUNE

In the result, the appeal filed by the assessee is allowed and the appeals filed by the Revenue are dismissed

Bench: Shri R. K. Panda & Ms Astha Chandraassessment Year : 2015-16

270A(1) of the Act are initiated separately for under reporting of income.” 28. In appeal, the CIT(A) allowed the claim of deduction u/s 80IA(4) of the Act made by the assessee by observing as under: “23. In brief, as per the assessing officer, there is no mandate u/s. 80IA to treat each wind mill project as 'separate

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

270A(2) is\nseparately initiated. (Para No. 6.6 of Assessment Order dt.\n21.09.2022).\nSir, on the aforesaid issue, the assessee trust respectfully states as\nunder:\nIn order to claim the expenditure u/s. 57(iii), assessee must satisfy\nthe following conditions.\na) It should not be a capital expenditure,\nb) Expenditure incurred should be wholly and exclusively for its\nearnings

SURANA MUTHA BHANSALI,PUNE vs. ACIT-CIRCLE 5 PUNE, PUNE

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

Bench: Shri R. K. Panda & Shri Vinay Bhamoreassessment Year : 2017-18

270A(9) of the Income-tax Act, 1961 are initiated for misreporting of income to the extent of Rs. 4,00,00,000/-.” 4. The Assessing Officer further noted that the assessee was holding unsold stock of flats and unsold shops to the extent of Rs.7,04,95,180/- but has not shown any deemed rent in respect

ACIT, CIRCLE-2, PUNE, PUNE vs. BHIKSHU GRANIMART, PUNE

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

Bench: Shri R. K. Panda & Shri Vinay Bhamoreassessment Year : 2017-18

270A are hereby initiated for underreporting of income.” 4. Similarly, from the audit report filed by the assessee in form 3CB the Assessing Officer noted that the assessee has taken several unsecured loans during the year. He issued notices u/s 133(6) of the Act to the various parties from whom the assessee had shown to have taken unsecured loans