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 etc." No question of law, therefore, arises in this respect. 12. Question No.3 itself records that the issue at hand is covered by the decision of this Court in case of HDFC v/s. DCIT reported in 366 ITR 505 but that, the department has not accepted the decision of the High Court. In that view, this question 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 etc." No question of law, therefore, arises in this respect. 12. Question No.3 itself records that the issue at hand is covered by the decision of this Court in case of HDFC v/s. DCIT reported in 366 ITR 505 but that, the department has not accepted the decision of the High Court. In that view, this question also

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 etc." No question of law, therefore, arises in this respect. 12. Question No.3 itself records that the issue at hand is covered by the decision of this Court in case of HDFC v/s. DCIT reported in 366 ITR 505 but that, the department has not accepted the decision of the High Court. In that view, this question 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 etc.\"\n\nNo question of law, therefore, arises in this respect.\n\n12.\nQuestion No.3 itself records that the issue at hand is\ncovered by the decision of this Court in case of HDFC_v/s.\nDCIT reported in 366 ITR 505 but that, the department has not\naccepted the decision of the High Court. In that view, this\nquestion

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 etc.\"\nNo question of law, therefore, arises in this respect.\n12.\nQuestion No.3 itself records that the issue at hand is\ncovered by the decision of this Court in case of HDFC_v/s.\nDCIT reported in 366 ITR 505 but that, the department has not\naccepted the decision of the High Court. In that view, this\nquestion also

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 etc.\"\nNo question of law, therefore, arises in this respect.\n12.\nQuestion No.3 itself records that the issue at hand is\ncovered by the decision of this Court in case of HDFC_v/s.\nDCIT reported in 366 ITR 505 but that, the department has not\naccepted the decision of the High Court. In that view, this\nquestion also

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

Section 57(iii) does not require this purpose must be fulfilled in\norder to qualify the expenditure for deduction.\n❖ It does not say that, expenditure shall be deductible only, if\nany income is made or earned. There is in fact nothing in the\nlanguage u/s. 57(iii) to suggest that, the purpose for which the\nexpenditure is made should

JAYNT VASUDEO ARADHYE,SOLAPUR vs. DCIT, CIRCLE-1, SOLAPUR, SOLAPUR

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.683/Pun/2024 िनधा"रण वष" / Assessment Year: 2022-23 Jaynt Vasudeo Aradhye, Vs. Dcit, Circle-1, Solapur. Villa No.25, Indradhanu, Laxmi Peth, Vishnu Mill Compound, Solapur- 413001. Pan : Aappa8903M Appellant Respondent Assessee By : Shri Deepak Chintaman Gadgil Revenue By Shri Ramnath P. Murkunde : Date Of Hearing 06.08.2024 : Date Of Pronouncement : 21.10.2024 आदेश / Order Per Vinay Bhamore, Jm: This Appeal Filed By The Assessee Is Directed Against The Order Dated 07.02.2024 Passed By Ld. Addl./Jcit(A)-1, Coimbatore For The Assessment Year 2022-23 2. The Appellant Has Raised The Following Grounds Of Appeal :- “I. The Cpc Was Not Correct Both Factually & Legally In Not Considering The Claim Of Brought Forwarded Short Term Capital Loss Of Rs 27,78,028/-. 11. Section 143(1) As It Stands On The Statute Books As On Today, Does Not Permit Either Cpc Or The Ao To Make Such Adjustments As They Are Beyond The Scope Of The Said Section.

57 or under any of the provisions of Chapter VI-A other than the provisions of sub-section (2) of section 80CCD or section 80JJAA; (ii) without set off of any loss, - (a) carried forward or depreciation

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.

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 of the director instead of appellant company. 5. Being aggrieved

SHREE SAMASTHA GUJARATHI SAMAJ ,,DHULE vs. COMMISSIONER OF INCOME-TAX, (EXEMPTION),, PUNE

The appeal of the assessee is ALLOWED

Bench: Hon’Ble Shri S. S. Viswanethra Ravi & Shri G. D. Padmahshaliआयकर अपऩल सं. / Ita No. 627/Pun/2019 निर्धारण वषा / Assessment Year : 2014-15 Shree Samastha Gujarathi Samaj, C/O S.M.Jain, First Floor, Maharaja Complex, Main Road, Shirpur, Dhule. Pan : Aaets 6392 M . . . . . . . अपऩलधर्थी / Appellant

section 57 of the Act was extra-territorial to the Ld. AO unless authorised by necessary prior approval. The issue of examination of transaction of income falling u/s 56 of the Act remained outside the scope of assessment proceeding for the buckshot reasons that no potential escapement came to the notice of Ld. AO, thus triggered no approval process

PRIDE PURPLE BUILDERS PRIVATE LTD.,,PUNE vs. DEPUTY COMMISSIONER OF INCOME-TAX, CENTRAL CIRCLE - 1 (1),, PUNE

In the result, the appeal of the Assessee is allowed

Bench: Shri S.S.Godara & Dr. Dipak P. Ripoteआयकर अपील सं. / Ita No.699/Pun/2022 िनधा"रण वष" / Assessment Year : 2015-16 Pride Purple Builders Private The Deputy Limited, V Commissioner Income Pride House, 5Th Floor, S Tax, Circle-1(1), Pune. S.No.108/7, Shivajinagar, Near Pune University Circle, Pune – 411016. Pan: Aadcp 4286 H Appellant / Assessee Respondent / Revenue Assessee By Shri Suhas Bora – Ar Revenue By Shri M G Jasnani, Irs - Dr Date Of Hearing 03/10/2023 Date Of Pronouncement 04/10/2023 आदेश/ Order Per Dr. Dipak P. Ripote, Am: This Appeal Filed By Assessee Is Directed Against The Order Of Ld. Commissioner Of Income Tax(Appeal), Pune-11 Dated 18.08.2022For A.Y.2015-16 Emanating From The Assessment Order Under Section 143(3) Of The Income Tax Act, 1961 Dated 30.11.2017. The Assessee Has Raised The Following Grounds Of Appeal: Pride Purple Builders Private Limited [A]

Section 57 of the Act. 5.4 The Ld. AR also relied on following decisions:  Vodafone South Ltd vs CIT ITA 334/2014 (Del High Court)  ITO vs Brahma Associates ITAT Pune ITA 133/PN/2014  DLF Info City Development vs ACIT ITA 894/Del/2018  Triumph Reality Pvt Ltd [2023] 148 taxmann.com 196 (Delhi) Submission of ld.Departmental Representative(ld.DR) : 6. The ld.Departmental Representative read

DY. COMMISSIONER OF INCOME TAX , CIRCLE-8, PUNE, PUNE vs. ADVIK HI-TECH PRIVATE LIMITED , PUNE

Bench: Shri Satbeer Singh Godara & Dr. Dipak P. Ripote

section 80AB which are all relevant while considering the deduction u/s.80IA which is falling under Chapter VIA of the I.T. Act, 1961. Where the earlier depreciation and losses have already been set off, those loss and depreciation do not go to reduce the gross total 18 ITA.No.1156, 1157 & 1203/PUN./2023 income of an assessee within the meaning

ADVIK HI TECH PVT LTD,PUNE vs. DY.COMM.OF INCOME TAX, CIRCLE 8, PUNE, AKURDI PUNE

Bench: Shri Satbeer Singh Godara & Dr. Dipak P. Ripote

section 80AB which are all relevant while considering the deduction u/s.80IA which is falling under Chapter VIA of the I.T. Act, 1961. Where the earlier depreciation and losses have already been set off, those loss and depreciation do not go to reduce the gross total 18 ITA.No.1156, 1157 & 1203/PUN./2023 income of an assessee within the meaning

ADVIK HI TECH PVT LTD,CHAKAN PUNE vs. DY.COMM. OF INCOME TAX, CIRCLE 8, PUNE, AKURDI, PUNE

Bench: Shri Satbeer Singh Godara & Dr. Dipak P. Ripote

section 80AB which are all relevant while considering the deduction u/s.80IA which is falling under Chapter VIA of the I.T. Act, 1961. Where the earlier depreciation and losses have already been set off, those loss and depreciation do not go to reduce the gross total 18 ITA.No.1156, 1157 & 1203/PUN./2023 income of an assessee within the meaning

INTERVALVE POONAWALLA PVT. LTD.,PUNE vs. DCIT, CENTRAL CIRCLE 1(1), PUNE, PUNE

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

Bench: Shri R. K. Panda & Ms. Astha Chandraassessment Year : 2013-14 Intervalve Poonawalla Pvt. Ltd. Dcit, Central Circle 1(1), Fin Div. 16/B-1, Sarosh Bhavan, Pune Vs. 2Nd Floor, Dr. Ambedkar Road, Opp. Niv, Pune – 411001 Pan: Aaaci3917P (Appellant) (Respondent) Assessee By : Shri Nikhil S Pathak & Vishnu Bhutada Department By : Shri Ramnath P Murkunde Date Of Hearing : 14-05-2025 Date Of Pronouncement : 27-05-2025 O R D E R

57,376/-. The Assessing Officer invoking the provisions of section 14A read with Rule 8D made the disallowance of Rs.4,40,375/- which was confirmed by the Ld. CIT(A) / NFAC. Therefore, the Assessing Officer levied the penalty on this amount. 4. Similarly, the Ld. CIT(A) / NFAC restricted the disallowance of depreciation

SAHYADRI FARMERS PRODUCER COMPANY LIMITED,NASHIK vs. ACIT CIRCLE - 1, NASHIK

In the result, the appeal of the assessee stands allowed

Bench: Shri Manish Borad & Shri Vinay Bhamoreआयकर अपील सं. / Ita No.951/Pun/2025 िनधा"रण वष" / Assessment Year : 2017-18 Sahyadri Farmers Producer Vs. Acit, Circle-1, Nashik. Company Limited, Survey No.1102/8, Behind Police Head Quarter, Adgaon, Nashik- 422003. Pan : Aapcs1516D Appellant Respondent Assessee By : Shri Kishor B. Phadke Revenue By : Shri Amit Bobde Date Of Hearing : 30.07.2025 Date Of Pronouncement : 08.10.2025 आदेश / Order Per Vinay Bhamore, Jm: This Appeal Filed By The Assessee Is Directed Against The Order Dated 03.03.2025 Passed By Ld. Addl./Jcit(A)-6, Delhi [‘Ld. Cit(A)’] For The Assessment Year 2017-18. 2. The Appellant Has Raised The Following Grounds Of Appeal :- “ (All The Grounds Are Without Prejudice To Each Other) 1. The Learned Addl/Jcit (A)-6 Delhi Erred In Law & Fact In Upholding Disallowance U/S Boib(114) Amounting To Rs.8,73,57,770 Made By Learned Dcit, Cpc (Hereinafter

57,767/-. However, while processing the return of income u/s 143(1) of the IT Act, the said deduction was disallowed by the CPC since audit report in Form 10CCB was furnished belatedly. Even on first appeal, Ld. CIT(A) uphold the action of the CPC and dismissed the appeal filed by the assessee. 3 4. It is this order

JANATA SAHAKARI BANK LIMITED,,PUNE vs. DEPUTY COMMISSIONER OF INCOME-TAX, CIRCLE - 6,, PUNE

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

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

depreciation in the value of investments should be allowed as a deduction. He submitted that the issue is no longer re- judicata, as it was decided in the assessee’s own case in favour of the assessee by the Coordinate Bench of the Tribunal for the assessment year 2011-12 in ITA No.1761/PUN/2017, order dated 11.02.2020 following the decision

JANATA SAHAKARI BANK LTD,,PUNE vs. DEPUTY COMMISSIONER OF INCOME-TAX, CIRCLE - 6,, PUNE

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

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

depreciation in the value of investments should be allowed as a deduction. He submitted that the issue is no longer re- judicata, as it was decided in the assessee’s own case in favour of the assessee by the Coordinate Bench of the Tribunal for the assessment year 2011-12 in ITA No.1761/PUN/2017, order dated 11.02.2020 following the decision