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

depreciation on the reduced amount of Fixed Assets. 30. Now against the adjustment made by CPC assessee preferred appeal before ld.CIT(A) and was able to succeed as ld.CIT(A) on one hand has held that the contention of the appellant that it was not an incorrect claim as defined u/s.143(1) of the Act is accepted and has also

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

depreciation on the reduced amount of Fixed Assets. 30. Now against the adjustment made by CPC assessee preferred appeal before ld.CIT(A) and was able to succeed as ld.CIT(A) on one hand has held that the contention of the appellant that it was not an incorrect claim as defined u/s.143(1) of the Act is accepted and has also

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

depreciation on the reduced amount of Fixed Assets. 30. Now against the adjustment made by CPC assessee preferred appeal before ld.CIT(A) and was able to succeed as ld.CIT(A) on one hand has held that the contention of the appellant that it was not an incorrect claim as defined u/s.143(1) of the Act is accepted and has also

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

depreciation. Please refer submissions in\nAnnexure 'A' to Assessment Year 2016-17 and 2017-18.\n\n(B) The adjustment made is outside the scope of the specific items of\nadjustments permitted u/s 143(1)(a) of the Income Tax Act.\n\nhas (ii) The reasons given in the adjustments made under section\n143(1)(a) made under

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 45 of the Act. Therefore, we are of the view that\nthese provisions have no relevance to the facts of the present case.\n26. The Revenue, vide its written submissions, has relied upon certain\njudicial pronouncements, which have been dealt with hereunder: -\n(a) We find that the decision in Borkar Packaging (P.) Ltd. v.\nAssistant Commissioner of Income

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

depreciation. Please refer submissions in\nAnnexure 'A' to Assessment Year 2016-17 and 2017-18.\n(B) The adjustment made is outside the scope of the specific items of\nadjustments permitted u/s 143(1)(a) of the Income Tax Act.\nhas (ii) The reasons given in the adjustments made under section\n143(1)(a) made under the Act can neither

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

depreciation. Please refer submissions in\nAnnexure 'A' to Assessment Year 2016-17 and 2017-18.\n(B) The adjustment made is outside the scope of the specific items of\nadjustments permitted u/s 143(1)(a) of the Income Tax Act.\nhas (ii) The reasons given in the adjustments made under section\n143(1)(a) made under the Act can neither

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

DY. COMMISSIONER OF INCOME TAX CIRCLE-1(1) , PUNE vs. FIAT INDIA AUTOMOBILES PRIVATE LIMITED, PUNE

In the result, the appeal filed by the assessee in ITA

Bench: SHRI MANISH BORAD (Accountant Member), SHRI VINAY BHAMORE (Judicial Member)

30 November 2014, the interest under section 234A cannot be levied. The Appellant prays that the interest levied under section 234A be deleted.  The assessee prays that the interest under section 234B, being purely consequential to the impugned denial of set off of loss of Rs. 138 crore, the same may be directed to be consequently deleted. In relation

M/S. FIAT INDIA AUTOMOBILES PRIVATE LIMITED,PUNE vs. ACIT CIRCLE 1(1), PUNE

In the result, the appeal filed by the assessee in ITA

Bench: SHRI MANISH BORAD (Accountant Member), SHRI VINAY BHAMORE (Judicial Member)

30 November 2014, the interest under section 234A cannot be levied. The Appellant prays that the interest levied under section 234A be deleted.  The assessee prays that the interest under section 234B, being purely consequential to the impugned denial of set off of loss of Rs. 138 crore, the same may be directed to be consequently deleted. In relation

INCOME-TAX OFFICER, WARD - 2(3),, SOLAPUR vs. SHRI. ULHAS MALLIKARJUN PATIL,, SOLAPUR

Appeal is partly allowed for statistical purpose in above terms

Bench: Shri S.S.Godara & Shri Inturi Rama Raoआयकर अपीलसं. / Ita No.1751/Pun/2018 िनधा"रणवष" / Assessment Year : 2013-14 The Income Tax Officer, Shri Ulhas Mallikarjun Patil, Ward-2(3), Solapur, Vs Block No.3, Sunandan . Complex, Near Dayanand College, Ravivar Peth, Solapur – 413004. Pan: Akepp 1943 P Appellant/ Assessee Respondent /Revenue Assessee By Shri Krishna V Gujarathi – Ar Revenue By Shri Ramnath P Murkunde – Dr Date Of Hearing 05/09/2022 Date Of Pronouncement 06/09/2022 आदेश/ Order Per S.S.Godara, Jm: This Revenue’S Appeal For Assessment Year 2013-14 Is Directed Against The Commissioner Of Income Tax(Appeals)-7, Pune’S Order Dated 31.08.2018 Passed In Case No.Pn/Cit(A)-7/Wd- 2(3)/10434/2016-147, In Proceedings U/S.143(3) Of The Income Tax Act, 1961 [In Short “The Act”].

30,25,000/-. The assessee submitted copy of balance sheet in and expenditure account with return of income. The AO had information that the assessee has sold immovable property of Rs. 3,39,00,000/-(stamp valuation). The AO sought details of sale and the assessee submitted that he had purchased property on 06.12.2014 and construction commenced

GARVE MOTORS PVT.LTD,,PUNE vs. ASSISTANT COMMISSIONER OF INCOME-TAX, CIRCLE - 9,, PUNE

Bench: Shri S. S. Godara & Shri G. D. Padmahshaliआयकर अपीऱ सं. / Ita No.776/Pun/2018 निर्धारण वर्ा / Assessment Year : 2013-2014 Garve Motors Pvt. Ltd., S.No.136/1A 46, B P Road, Pune – 411016 . . . . . . . अपीऱधर्थी / Appellant Pan:Aadcg4391A बनाम / V/S. Asst. Commissioner Of Income Tax, . . . . . . . . प्रत्यर्थी / Respondent Circle – 9, Pune द्वारा / Appearances Assessee By : Mrs. Deepa Khare Revenue By : Shri M. G. Jasnani सुनवाई की तारीख / Date Of Conclusive Hearing : 26/09/2022 घोषणा की तारीख / Date Of Pronouncement : 07/10/2022 आदेश / Order Per G. D. Padmahshali, Am; The Extant Appeal Challenges The Order Of Commissioner Of Income Tax (Appeals)-6, Pune [For Short “Cit(A)”] Dt. 06/12/2017 Passed U/S 250 Of The Income-Tax Act, 1961 [For Short “The Act”], Which Climbed Out Of Order Of Assessment Dt. 15/03/2016 Passed U/S 143(3) By The Asstt. Commissioner Of Income Tax, Circle-9, Pune [For Short “Ao”] For Assessment Year [For Short “Ay”] 2013-14. Itat-Pune Page 1 Of 12

depreciation thereon. 6. The learned departmental representative [for short “DR”] expressing no objection for condonation of delay, Au contraire, rebutted the first contention of the Ld. AR ITAT-Pune Page 4 of 12 Grave Motors Pvt. Ltd. ITA No.776/PUN/2018 AY: 2013-14 placing vehement arguments before the bench that, the sum of equity and reserves & surplus balance are not circulating

SUN INFRASTRUCTURES PRIVATE LIMITED,NASHIK vs. INCOME TAX OFFICER, WARD-2(1), NASHIK, NASHIK

In the result, the appeal of the assessee is dismissed

Bench: Shri Inturi Rama Rao & Shri S.S. Viswanethra Ravi

30 [in accordance with the provisions of sub-section (3) of section 139], shall be carried forward and set off under sub-section (1) of section 72 or sub-section (2) of section 7331 [or sub-section (2) of section 73A] or sub-section (1) 32[or sub-section (3)] of section 7433[or sub- section (3) of section

GENERAL INDUSTRIAL CONTROS LTD.,PUNE vs. DCIT CIRCLE 8, PUNE, PUNE

In the result, the order of the CIT(A) is set aside, and the appeal of the assessee is partly allowed

Bench: Dr.Dipak P. Ripote & Shri Vinay Bhamore

30% along with 12% surcharge and education cess, instead of computing tax at the rate of 22% along with 10% surcharge and education cess. Accordingly, CPC Bangalore passed order u/s 143(1) on 13/11/2022 by making addition of Rs.6,71,649/- (Rs.25,68,22,860 Rs. 25.61.51.210) thereby assessing total income at Rs.25.68,22.860/- and computed balance tax liability

ANANDA GORAKHANATH PAWAR,SATARA vs. ASSESSING OFFICER, WARD 3, SATARA, SATARA

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

Bench: Shri R. K. Panda & Shri Vinay Bhamoreआयकर अपील सं. / Ita No.1796/Pun/2025 िनधा"रण वष" / Assessment Year : 2018-19 Ananda Gorakhanath Pawar, Vs. Ito, Ward-3, Satara. At Post Ambawade, Khatav, Satara- 415506. Pan : Blhpp6081R Appellant Respondent Assessee By Shri R. C. Doshi : Revenue By : Shri Milind Debaje Date Of Hearing : 28.08.2025 Date Of Pronouncement : 28.08.2025 आदेश / Order Per Vinay Bhamore, Jm: This Appeal Filed By The Assessee Is Directed Against The Order Dated 30.06.2025 Passed By Ld. Cit(A)/Nfac For The Assessment Year 2018-19. 2. The Appellant Has Filed The Following Grounds Of Appeal :- “1. The Learned Cit Has Erred Both On Facts & In Law In Dismissing The Appeal Of The Appellant By Refusing To Condone The Delay Of 26 Days On Grounds Of Period Of Limitation, Notwithstanding The Fact That Appellant Has Submitted The Application & Explained The Reasons For Delay.

depreciation amounting to INR 12,908 without any basis • Disallowed genuine deductions claimed under chapter VIA amounting to INR 25,200 • Creditors amounting to INR 3,10,110 added to income despite making addition w.r.t. purchase of milk • Citing credits in current accounts amounting to INR 11,54,361 as unexplained income. Contentions of the Appellant The learned

M/S GERA DEVELOPMENTS PVT. LTD,PUNE vs. PCIT (CENTRAL), PUNE, PUNE

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

Bench: Dr.Manish Borad & Shri Vinay Bhamore

section 143(3) of the Income-tax Act. The said assessment order has been revised by holding that depreciation on goodwill is not allowable for the following reasons :- A. (i) The Assessing Officer has allowed the claim of depreciation on goodwill without examination of claim. (ii) The intangible asset has been impaired in the previous year and as such cannot

SEHGAL AUTORIDERS PVT.LTD,,PUNE vs. DEPUTY COMMISSIONER OF INCOME-TAX, CIRCLE - 10,, PUNE

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

Bench: Shri Inturi Rama Rao & Shri S. S. Viswanethra Raviआयकर अपील सं. / Ita No.162/Pun/2018 िनधा"रण वष" / Assessment Year: 2012-13 Sehgal Autoriders Pvt. Ltd., Vs. Dcit, Circle- 10, D-Ii, 64/6, Midc Telco Road, Pune. Chinchwad, Pune- 411019. Pan : Aafcs2240A Appellant Respondent Assessee By : Shri Rishi V. Lodha Revenue By : Shri S. P. Walimbe Date Of Hearing 25.01.2022 : Date Of Pronouncement 25.01.2022 : आदेश / Order Per Inturi Rama Rao, Am: This Is An Appeal Filed By The Assessee Directed Against The Order Of Ld. Commissioner Of Income Tax (Appeals)- 6, Pune [‘Cit(A)’ For Short] Dated 08.11.2017 For The Assessment Year 2012-13. 2. The Appellant Raised The Following Grounds Of Appeal :- “1. On The Facts & Circumstances Of The Case & In Law, Hon. Commissioner Of Income Tax, (Appeals), Pune-6 Erred In Disallowing The Depreciation Claimed For The Cars Used By The Directors For Official Work Of The Company But Ownership Documents In The Name Of Individual Director. 2. On The Facts & In The Circumstance Of The Case The Learned Commissioner Of Income Tax, (Appeals), Pune-6 Erred In Disallowing The Interest Paid On The Purchase Of Cars.

30,340/-. (ii) Disallowance of depreciation of vehicle of Rs.4,57,557/-. (iii) Disallowance of interest on purchase of car of Rs.53,761/-. 3 4. One of the disallowance relates to disallowance of depreciation and interest paid on car loan, the Assessing Officer disallowed both the claims on the ground that the car was held in the name

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