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

1) and Explanation-2 of Section 43(6) of the IT Act 1961\nestablishes that the depreciation on goodwill as a result of amalgamation is\nnot allowable.\nResultantly, the claims made by the appellant in support of this ground do\nnot have any merit. Therefore, the addition made by assessing officer on\naccount of disallowance of claim of depreciation

ASHOK DHANRAJ CHORDIA ,PUNE vs. PCIT, PUNE-1, PUNE

65. In the facts of the present case, the Revenue disputes that a satisfaction note\nby the AO of the searched person (Jain Brothers) was forwarded to the AO of the\nAssessee along with the requisite documents. Thus, in the facts of the present case,\nthe jurisdictional conditions to initiate further steps under Section 153C of the Act\nwere

SETH RAMDAS NATHUBHAI DHARMADAYA VISHWASTA NIDHI,,PUNE vs. INCOME-TAX OFFICER,(EXEMPTIONS) -1,, PUNE

Bench: Shri R.S. Syal & Shri Partha Sarathi Chaudhury"नधा"रण वष" / Assessment Year : 2011-12 Seth Ramdas Nathubhai Dharmadaya Vs. Ito Vishwasta Nidhi, (Exemptions)-1, C/O. Shah Khandelwal Jain & Pune Associates, Chartered Accountants, Level 3, Business Bay, Plot No.84, Wellesley Road, Near Rto, Pune 411 001 Pan : Aaatr6805N Appellant Respondent

depreciation from earlier years against the income so assessed. 3. The relevant facts in this case are that the assessee trust is registered under the Bombay Public Trust Act, 1950 vide No.E1150, Pune dated 13-10-1987. The assessee is registered u/s.12A of the Act vide registration No.4597 dated 21-06-1989. The assessee trust was formed with various aims

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

1,20,58,298 | 13,35,65,182 |\n| Expenses Debited to P&L A/c. (Sub-total C) | 3,41,34,804 | 74,95,427 | 2,66,39,378 | 3,41,34,804 |\n| Grand Total | 15,07,38,534 | 9,61,80,237 | 5,45,58,297 | 26,73,42,263 |\n\n5. It can be seen from

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

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

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

1,20,58,298 13,35,65,182 Expenses Debited to 3,41,34,804 74,95,427 2,66,39,378 3,41,34,804 P&L A/c. (Sub-total C) Grand Total 15,07,38,534 9,61,80,237 5,45,58,297 26,73,42,263 5. It can be seen from the above Table that

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

1,20,58,298 13,35,65,182 Expenses Debited to 3,41,34,804 74,95,427 2,66,39,378 3,41,34,804 P&L A/c. (Sub-total C) Grand Total 15,07,38,534 9,61,80,237 5,45,58,297 26,73,42,263 5. It can be seen from the above Table that

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

1,20,58,298 13,35,65,182 Expenses Debited to 3,41,34,804 74,95,427 2,66,39,378 3,41,34,804 P&L A/c. (Sub-total C) Grand Total 15,07,38,534 9,61,80,237 5,45,58,297 26,73,42,263 5. It can be seen from the above Table that

INDUS BIOTECH LIMITED,PUNE vs. THE ASSISTANT COMMISSIONER OF INCOME TAX, CIRCLE 1(1), PUNE, PUNE

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

1,52,65,049 under section 115-O of the Act to the Ld. AO\nwithout appreciating the fact that the said credit is also duly reflected in\nForm 26AS and relevant facts/documents are available on record with the\nLd. AO.\n4.2 The Appellant prays that the Ld. AO be directed to grant credit of DDT\nGround No. 5\n5.1

JOINT COMMISSIONER OF INCOME-TAX, (OSD), CIRCLE -1,, SOLAPUR vs. M/S. LOKMANGAL AGRO INDUSTRIES LTD,, SOLAPUR

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

depreciation claimed so as to attract section 43(1) Explanation 10 of the Act. Yet another decision Sasisri Extraction Ltd., vs., ACIT [2008] 122 ITD 428 (Vizag) also hold that mere credit of the subsidy amount in the assessee’s loan account does not attract sec.43(1) Explanation 10 of the Act. The Revenue fails in its identical former twin

JOINT COMMISSIONER OF INCOME-TAX, (OSD), CIRCLE -1,, SOLAPUR vs. M/S. LOKMANGAL AGRO INDUSTRIAL LTD,, SOLAPUR

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

depreciation claimed so as to attract section 43(1) Explanation 10 of the Act. Yet another decision Sasisri Extraction Ltd., vs., ACIT [2008] 122 ITD 428 (Vizag) also hold that mere credit of the subsidy amount in the assessee’s loan account does not attract sec.43(1) Explanation 10 of the Act. The Revenue fails in its identical former twin

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)

1 to section 115JB of the Act, the assessee is entitled to reduce its book profits by the amount of loss brought forward or unabsorbed depreciation, whichever is less, as per books of account. Factual Background as relevant for Assessment Year (AY 2013-14)  During the previous year relevant to AY 2013-14, a capital reduction scheme of the assessee

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)

1 to section 115JB of the Act, the assessee is entitled to reduce its book profits by the amount of loss brought forward or unabsorbed depreciation, whichever is less, as per books of account. Factual Background as relevant for Assessment Year (AY 2013-14)  During the previous year relevant to AY 2013-14, a capital reduction scheme of the assessee

DCIT CIRCLE 1 NASHIK, NASHIK vs. SHREE SAI PROPERTIES, NASHIK

In the result, appeal of the Revenue is dismissed

Bench: Dr. Manish Borad & Shri Vinay Bhamore

65. Naveen Kumar Gupta Follows para 39 - Pr. CIT vs Abhisar [Delhi] ITA No. 401/2022 Buildwell (P) Ltd (2023) 454 ITR 212 (SC). dtd 20-11-2024 [168 Para 20 for the issue to be decided by the taxmann.com 574 Hon. HC. (Del)(20-11-2024)] The Hon’ble Delhi High Court has not concurred with the Rajasthan High Court

MAHLE BEHR INDIA PVT. LTD.,,PUNE vs. DEPUTY COMMISSIONER OF INCOME-TAX,, PUNE

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

Section 35(1) (iv) Income Tax Act, 1961 at least to\nthe extent of One hundred percent.\n4. Facts of the case, in brief, are that the assessee is a company engaged in the\nbusiness of manufacture and sale of air conditioners, radiators, heat exchangers\nparts and components thereof which are used in cars and SUVs and in providing

ASSOCIATION OF CONSULTING CIVIL ENGINEERS,,SOLAPUR vs. COMMISSIONER OF INCOME-TAX, (EXEMPTION),, PUNE

In the result, this appeal of the appellant is allowed for statistical purpose

Bench: Shri S.S. Viswanethra Ravi, Hon’Ble Jm & Dr. Dipak P. Ripote, Hon’Ble Am आयकरअपीलसं. / Ita No.466/Pun/2019 िनधा"रण वष" / Assessment Year : N.A. Association Of Consulting Civil The Commissioner Of Income Engineers, Vs Tax, Exemption, Pune. Sthapathya Bhavan, Damani Complex, Datta Chowk, Solapur – 413 007. Pan: Aacaa 6603 L Appellant/ Assessee Respondent /Revenue

65,000.00 9,298.00 454,477.00 454,477.00 3 Association of Consulting Civil Engineers (A) As on 31ST March, 2015 Expenditure Rs. Income Rs. To Expenditure in respect - By Interest (accrued) 33,135.00 of Properties— Realized On bank account________ To Establishment Expenses 2,320,072.00 By ACCE annual fees a/c Other Expenses To Audit Fees 1,400.00 By Calender sponsorship

M/S. BILCARE LIMITED,PUNE vs. DEPUTY COMMISSIONER OF INCOME TAX CENTRAL CIRCLE-2(2), PUNE

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

Bench: Shri Inturi Rama Rao & Shri S. S. Viswanethra Raviआयकर अपीऱ सं. / Ita No.273/Pun/2021 निर्धारण वर्ा / Assessment Year: 2016-17 Dcit, Central Circle-2(2), Vs. M/S. Bilcare Limited, Pune. 601, Icc Trade Tower, Pune- 411016. Pan : Aabcb2242F Appellant Respondent आयकर अपीऱ सं. / Ita No.334/Pun/2021 निर्धारण वर्ा / Assessment Year: 2016-17 M/S. Bilcare Limited, Vs. Dcit, Central Circle- 6Th Floor, B Wing, Icc 2(2), Pune. Trade Tower, Senapati Bapat Road, Pune- 411006. Pan : Aabcb2242F Appellant Respondent

depreciation of Rs.27,20,59,980/- not made by the assessee in its original return as well as revised return of income ?‖ 37. Ground of appeal no.1 challenges the correctness of decision of the ld. CIT(A) in holding that the performance guarantee is not an international transaction. The relevant findings