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

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

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

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

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

ASSISTANT COMMISSIONER OF INCOME-TAX, SATARA vs. THE KARAD URBAN CO. OP. BANK LTD KARAD, KARAD

In the result, the appeal of the Revenue is dismissed

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

depreciation” on AFS securities charged to P&L Account in AY 2018-19 under the provisions of section 37 of the Act rejecting the claim of the assessee. On appeal, the Ld. CIT(A) reversed the findings of the Ld. AO and allowed the claim of the assessee for the reasons reproduced above. Before us, the Ld. DR has argued

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)

34,573/-. Scrutiny assessment u/s 143(3) r.w.s. 144C(1) of the IT Act was completed on 23.12.2017 after making addition of Rs.3,08,92,38,550/- and setting off of brought forward losses of Rs.3,31,61,06,544/- determining income at Rs.Nil. The assessed income was taxed u/s 115JB of the IT Act. Subsequently, the Assessing Officer issued

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)

34,573/-. Scrutiny assessment u/s 143(3) r.w.s. 144C(1) of the IT Act was completed on 23.12.2017 after making addition of Rs.3,08,92,38,550/- and setting off of brought forward losses of Rs.3,31,61,06,544/- determining income at Rs.Nil. The assessed income was taxed u/s 115JB of the IT Act. Subsequently, the Assessing Officer issued

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

34,02,137/-. While doing so, the Assessing Officer had reduced a sum of Rs.36,08,69,697/- being the amount of capital subsidy received from Government of Maharashtra under the Package Scheme of Incentive, 2007 from the cost of the depreciable 3 assets invoking the provisions of Explanation 10 to section

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

DCIT, CIRCLE-8, PUNE vs. MAHLE ANAND THERMAL SYSTEMS PVT. LTD., PUNE

34,542/- on testing and validation, out of which a sum of Rs.1,02,94,971/- was recovered from the customers and balance of product development expenditure of Rs.1,42,39,571/- was claimed as revenue expenditure. However, the Assessing Officer had treated the same as capital expenditure and allowed the depreciation thereon. The explanation given before the Assessing Officer

DCIT,CIRCLE-8 , PUNE vs. MAHALE ANAND THERMAL SYSTEMS PVT. LTD. , PUNE

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

Bench: Shri R. K. Panda & Ms. Astha Chandraassessment Year : 2014-15

34,542/- on testing and validation, out of which a sum of Rs.1,02,94,971/- was recovered from the customers and balance of product development expenditure of Rs. 1,42,39,571/- was claimed as revenue expenditure. However, the Assessing Officer had treated the same as capital expenditure and allowed the depreciation thereon. The explanation given before the Assessing

MAHLE ANAND THERMAL SYSTEMS PRIVATE LIMITED,PUNE vs. DY COMMISSIONER OF INCOME TAX, PUNE

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

Bench: Shri R. K. Panda & Ms. Astha Chandraassessment Year : 2014-15

34,542/- on testing and validation, out of which a sum of Rs.1,02,94,971/- was recovered from the customers and balance of product development expenditure of Rs. 1,42,39,571/- was claimed as revenue expenditure. However, the Assessing Officer had treated the same as capital expenditure and allowed the depreciation thereon. The explanation given before the Assessing

DCIT CIRCLE 8 , PUNE vs. MAHLE ANAND THERMAL SYSTEMS PVT. LTD, PUNE

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

Bench: Shri R. K. Panda & Ms. Astha Chandraassessment Year : 2014-15

34,542/- on testing and validation, out of which a sum of Rs.1,02,94,971/- was recovered from the customers and balance of product development expenditure of Rs. 1,42,39,571/- was claimed as revenue expenditure. However, the Assessing Officer had treated the same as capital expenditure and allowed the depreciation thereon. The explanation given before the Assessing

BLUE STAR BUILDING MATERIAL PVT. LTD.,URAN PANVEL vs. ACIT CIRCLE PANVEL, PANVEL

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

Bench: MS.ASTHA CHANDRA, JUDICIAL MEMBER, AND DR.DIPAK P. RIPOTE (Accountant Member)

34,682 Unabsorbed 2011-12 2,06,05,222 2,06,05,222 Depreciation Ordinary 2012-13 1,86,65,117 1,86,65,117 Business Unabsorbed 2012-13 1,76,65,013 1,76,65,013 Depreciation Unabsorbed 2013-14 Depreciation 1,76,65,012 1,76,65,012 Unabsorbed 2014-15 Depreciation

NIRAMAYA MEDICAL FOUNDAION AND RESEARCH CENTRE PVT.LTD,,PUNE vs. INCOME-TAX OFFICER, WARD - 2(4),, PUNE

Appeal is allowed in above terms

Bench: Shri S.S.Godara & Dr. Dipak P. Ripoteआयकर अपीलसं. / Ita No.793/Pun/2018 िनधा"रणवष" / Assessment Year : 2012-13 Niramaya Medical Foundation The Ito, Ward-2(4), Pune. & Research Centre Pvt. Ltd., Vs Gat No.105, Plot No.245-249, . Jalochi Taluka, Baramati, Pune – 413102. Pan: Aabcn 3300 N Appellant/ Assessee Respondent /Revenue Assessee By Shri Nikhil Pathak – Ar Revenue By Shri Arvind Desai – Dr Date Of Hearing 12/08/2022 Date Of Pronouncement 29/08/2022 आदेश/ Order Per S.S.Godara, Jm: This Assessee’S Appeal For Assessment Year 2012-13 Is Directed Against The Commissioner Of Income Tax(Appeals)-2, Pune’S Order Dated 10.01.2017 Passed In Appeal No.Pn/Cit(A)- 2/Ito Wd-2(4)/Pn/534/2015-16, In Proceedings U/S.143(3) Of The Income Tax Act, 1961 [In Short “The Act”].

34,844 and depreciation Rs.63,78,468, The assessee accordingly adjusted depreciation of Rs.63,78,468 being the lower of loss brought forward or depreciation as per books of accounts under sub clause (iii) of Explanation 1 to Section

SHANKAR NAGAPPA JADAGOUDA,KOLHAPUR vs. NFAC, DELHI

Appeal is allowed in above terms

Bench: Shri Satbeer Singh Godara

depreciation. This question was answered in the negative. A Division Bench of the Kerala High Court held in Travancore Cements Ltd. v. CIT [2008] 305 ITR 1701 , that upon the issuance of a notice under section 148(2), when proceedings were initiated by the Assessing Officer on issues in respect of which he had formed a reason to believe that

SHRI SHANTINATH BHAGWAN JAIN SHWETAMBAR MURTIPUJAK SANGH,PUNE vs. CIT, EXEMPTION,, PUNE

Appeal is allowed

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

depreciation. This question was answered in the negative. A Division Bench of the Kerala High Court held in Travancore Cements Ltd. v. CIT [2008] 305 ITR 1701 , that upon the issuance of a notice under section 148(2), when proceedings were initiated by the Assessing Officer on issues in respect of which he had formed a reason to believe that