INCOME TAX OFFICER, WARD-1, NANDED, NANDED vs. LATUR DISTRICT CENTRAL CO OP BANK LTD, LATUR

In the result, the appeal of the Revenue is dismissed

iii) Expenses Incurred for\nEarning Exempt Income. Statutory notice(s) u/s 143(2)/142(1) of the\nIncome Tax Act, 1961 (the “Act”) were issued and duly served upon the\nassessee calling for certain details/documents/information in respect of\nthe above issues. The Ld. Assessing Officer (“AO”) while examining the\nveracity of deduction of “any other amount allowable as deduction

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. 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. 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. 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

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

36 (1) (va) of the Act against the respective amounts due for\npayment in the next month of May 2015, as these payments\ndisallowed for the month of April 2015 have been made before the\ndue dates of payment falling in the month of May 2015. Similarly,\nthe respective payments made after the due dates in May 2015 and\ndisallowed

DEPUTY COMMISSIONER OF INCOME-TAX CIRCLE -5, PUNE vs. SERUM INSTITUTE OF INDIA PVT LTD.,, PUNE

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

iii) supplying goods, or providing services, from one unit to another unit or developer, in the same or different Special Economic Zone." Therefore, the legislative history of provisions of section 10AA would clearly reveal that the provisions of section 10AA have been inserted in the Income Tax Act in order to give effect to the provisions of Special Economic Zone

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

36 (1) (va) of the Act against the respective amounts due for\npayment in the next month of May 2015, as these payments\ndisallowed for the month of April 2015 have been made before the\ndue dates of payment falling in the month of May 2015. Similarly,\nthe respective payments made after the due dates in May 2015 and\ndisallowed

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

36 (1) (va) of the Act against the respective amounts due for\npayment in the next month of May 2015, as these payments\ndisallowed for the month of April 2015 have been made before the\ndue dates of payment falling in the month of May 2015. Similarly,\nthe respective payments made after the due dates in May 2015 and\ndisallowed

INCOME TAX OFFICER, PUNE vs. SAGAR CONSTRUCTION COMPANY, PUNE

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

Bench: Shri R. K. Panda & Ms. Astha Chandraassessment Year : 2017-18

iii) Avinash R. Mahamuni vs. ITO vide ITA No.1582/PUN/2018 order dated 30.04.2019 for assessment year 2011-12 iv) Abhijit Despande vs. DCIT vide ITA No 492/PUN/2018 order dated 03.05.2019 for assessment year 2010-11 17. The Ld. Counsel for the assessee further submitted that when objections were rejected on 07.03.2022 and the re-assessment order was passed

ASSISTANT COMMISSIONER OF INCOME-TAX, CIRCLE - 6,, PUNE vs. SHARADA ERECTORS PRIVATE LIMITED., PUNE`

In the result, this appeal of the Revenue stands dismissed

Bench: Shri Partha Sarathi Chaudhury, Jm & Dr. Dipak P. Ripote, Am आयकर अपील सं. / Ita No. 2043/Pun/2017 "नधा"रणवष" / Assessment Year : 2013-14 The A.C.I.T., Sharada Erectors Pvt. Ltd. Circle-6, Vs 38, Vijayanagar Colony, Pune Pune-411030. Pan No. Aaccs 6028 D Appellant/ Assessee Respondent /Revenue Revenue By Ms. Divya Bajpai (Cit-Dr) Assessee By Shri Nikhil S Pathak Date Of Hearing 22/03/2022 Date Of Pronouncement 06/04/2022 आदेश/ Order Per: Dr. Dipak P. Ripote, Am: This Is An Appeal Filed By The Revenue Directed Against The Order Of Ld. Commissioner Of Income Tax (Appeals)-4, Pune, Appeal No.Pn/Cit(A)-4/Dcit, Circle-6, Pune/85/2016-17/152 Dated 27/03/2017 For The Assessment Year 2013- 14. The Revenue Has Raised Following Grounds Of Appeal: “1. On The Facts & The Circumstances Of The Case & In The Law, The Ld. Cit(A) Has Erred In Deleting The Addition On Account Of Disallowance Of Interest Of Rs. 7,44,78,911/- U/S 36(1)(Iii) Of The Income Tax Act, 1961, When The Funds Were Raised By Interest Bearing Loan Which Was Advanced To Sister Concern For Non Business Purpose. 2. For This An Such Other Reasons As May Be Urged At The Time Of Hearing, The Order Of The Cit(A) May Be Vacated & That Of The Assessing Officer Be Restored. 3. The Appellant Craves Leave To Add, Amend Alter Or Delete Any Of The Above Grounds Of Appeal During The Course Of Appellate Proceedings Before The Hon’Ble Tribunal.” 2. The Assessee Is A Builder-Developer. Brief Facts Of The Case Are That, In The Assessment Order, It Is Claimed That The Assessee Has Used Interest Bearing Funds For Giving Advances To Its Sister Concerns & Related Entities, Therefore, The A.O. Opined That The Funds Have Been Used For Non-Business Purposes. The Assessee Submitted Before The A.O. During The Assessment Proceedings That They Have

36(1)(iii) of Income Tax Act, amounting to Rs. 7,44,78,911/- in this year under consideration. Ground No. 1 raised by the appellant is accordingly allowed.” 4. Now the Revenue is in appeal before us. The Ld. Departmental representative (DR) strongly relied on the order of the Assessing Officer. The Ld. DR tried to distinguish the present

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

36(1)(va) for late payment of employee contribution to PF Fund (ii) Variation of Computation of tax liability The assessee opted for new tax regime u/s115BAA of Income-tax Act, 1961 In the Clause 8(a) of Tax Audit Report it has been reported that the appellant opted for the new tax regime u/s 115BAA of Income

KUMAR URBAN DEVELOPMENT PVT. LTD (SUCCESSOR KUMAR HOUSING CORPORATION PVT LTD),PUNE vs. DCIT CIRCLE 14, PUNE

36(1)(iii) and the\ndisallowance of depreciation of Rs.10,74,599/-. However, since the assessee is not\nin appeal before us on these two issues, we are not concerned with the same.\n9.\nSo far as the addition of trade advances from customers of Rs.26,90,56,640/-\nis concerned, the Ld. CIT(A) / NFAC gave part relief

CAPGEMINI TECHNOLOGY SERVICES INDIA LTD,,PUNE vs. DEPUTY COMMISSIONER OF INCOME-TAX, CIRCLE - 11,, PUNE

In the result, both the appeals are partly allowed

Bench: Shri R.S. Syal & Shri Partha Sarathi Chaudhury

depreciation of the amalgamating company in relation to the income under the head “Profit and gains of business or profession”. It is not a panacea for all the tax related issues of amalgamation, so as to have application insofar as the other tax entitlements, privileges or benefits in the hands of the amalgamating company, are concerned. 14. Section 74 deals

ASSISTANT COMMISSIONER OF INCOME-TAX, CIRCLE -11,, PUNE vs. CAPGEMINI TECHNOLOGY SERVICES INDIA LIMITED , (FORMERLY IGATE GLOBAL SOLUTIONS LTD.),, PUNE

In the result, both the appeals are partly allowed

Bench: Shri R.S. Syal & Shri Partha Sarathi Chaudhury

depreciation of the amalgamating company in relation to the income under the head “Profit and gains of business or profession”. It is not a panacea for all the tax related issues of amalgamation, so as to have application insofar as the other tax entitlements, privileges or benefits in the hands of the amalgamating company, are concerned. 14. Section 74 deals

ASSISTANT COMMISSIONER OF INCOME-TAX, CIRCLE - 10,, PUNE vs. M/S. UMW DONGSHIN MOTECH 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.610/Pun/2018 िनधा"रण वष" / Assessment Year: 2012-13 Acit, Circle-10, Vs. M/S. Umw Dongshin Motech Pune. Pvt. Ltd., Plot No.A-19, Talegaon Industrial Area, Village- Navalkhumbe, Pune- 410507. Pan : Aaccd5858L Appellant Respondent Revenue By : Shri Kalika Singh Assessee By Shri Sanjay Mehta : Date Of Hearing : 14.01.2022 Date Of Pronouncement : 14.01.2022 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)- 6, Pune [‘Cit(A)’ For Short] Dated 06.12.2017 For The Assessment Year 2012-13. 2. The Revenue Raised The Following Grounds Of Appeal :- “1. Whether On The Facts & Circumstances Of The Case & In Law The Ld.Cit(A) Erred In Deleting The Disallowance Of Interest U/S 36(1)(Iii) When The Assessee During Assessment Proceedings Has Failed To Produce The Proofs Of The Machinery Put To Use When The Onus Was On The Assessee To Prove That The Borrowed Capital Was Actually Put To Use & There Is Commencement Of A Business From The Installed

section 36(1)(iii) of the Act. Similarly, the Assessing Officer also denied the depreciation and the additional depreciation of 80% of the cost

ASSISTANT COMMISSIONER OF INCOME TAX, KOLHPAUR vs. RBL BANK LTD, KOLHAPUR

In the result, the appeal of the Revenue is dismissed

Bench: SATBEER SINGH GODARA, JUDICIAL MEMBER, AND DR.DIPAK P. RIPOTE (Accountant Member)

36(1 )(vii) amounting to Rs. 65,97,164 dis-allowed by the AO on the ground that the assessee being a bank, will not be eligible for the deduction. c. Excess depreciation inadvertently claimed by the Bank amounting to Rs 5,10,000, was dis-allowed in the course of assessment. d. Profit on sale of scrap amounting

MITHI SOFTWARE TECHNOLOGIES PRIVATE LIMITED,PUNE vs. INCOME TAX OFFICER WARD 14(3), PUNE

In the result, appeal of the assessee is allowed

Bench: Ms.Astha Chandra & Dr.Dipak P. Ripoteआयकर अपऩल सं. / Ita No.2371/Pun/2025 निर्धारण वषा / Assessment Year: 2014-15 Mithi Software Technologies V The Income Tax Private Limited, S Officer, 101, Mayfair Court, Nachiket Ward-14(3), Pune. Park, Baner Road, Pune – 411045. Pan: Aabcm9352P Appellant/ Assessee Respondent /Revenue Assessee By Shri Nikhil Pathak Revenue By Shri Ambarnath Khule – Jcit(Through Virtual) Date Of Hearing 24/11/2025 Date Of Pronouncement 12/01/2026 आदेश/ Order Per Dr. Dipak P. Ripote, Am: This Appeal Filed By The Assessee Against The Order Of Ld.Addl./Joint Commissioner Of Income Tax(Appeal), Agra Passed Under Section 250 Of The Income Tax Act, 1961 For The A.Y.2014-15 Dated 25.08.2025 Emanating From The Assessment Order U/S.143(3) Of

36 (1) (iii) of the IT Act. In the case at hand, learned CIT (A) relied upon Section 41 (1) of the IT Act and held that the Respondent had received amortization benefit. Amortization is an accounting term that refers to the process of allocating the cost of an asset over a period of time, hence, it is nothing else