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

Section 2(24) of the Income Tax Act as the subsidy is not relatable to any asset. 3. At the outset it is respectfully submitted that, if the argument of the Ld. Departmental Representative is to be accepted as correct and the subsidy is to be treated as income, the depreciation forgone/given up by the assessee by reducing the subsidy

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

Section 2(24) of the Income Tax Act as the subsidy is not relatable to any asset. 3. At the outset it is respectfully submitted that, if the argument of the Ld. Departmental Representative is to be accepted as correct and the subsidy is to be treated as income, the depreciation forgone/given up by the assessee by reducing the subsidy

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

Section 2(24) of the Income Tax Act as the subsidy is not relatable to any asset. 3. At the outset it is respectfully submitted that, if the argument of the Ld. Departmental Representative is to be accepted as correct and the subsidy is to be treated as income, the depreciation forgone/given up by the assessee by reducing the subsidy

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

Section 2(24) of the\nIncome Tax Act as the subsidy is not relatable to any asset.\n\n3.\nAt the outset it is respectfully submitted that, if the argument of\nthe Ld. Departmental Representative is to be accepted as correct and\nthe subsidy is to be treated as income, the depreciation\nforgone/given up by the assessee by reducing

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

Section 2(24) of the\nIncome Tax Act as the subsidy is not relatable to any asset.\n3. At the outset it is respectfully submitted that, if the argument of\nthe Ld. Departmental Representative is to be accepted as correct and\nthe subsidy is to be treated as income, the depreciation\nforgone/given up by the assessee by reducing the subsidy

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

Section 2(24) of the\nIncome Tax Act as the subsidy is not relatable to any asset.\n3. At the outset it is respectfully submitted that, if the argument of\nthe Ld. Departmental Representative is to be accepted as correct and\nthe subsidy is to be treated as income, the depreciation\nforgone/given up by the assessee by reducing the subsidy

M/S KOLTE-PATIL INTEGRATED TOWNSHIPS LIMITED,PUNE vs. DEPUTY COMMISSIONER OF INCOME TAX, CIRCLE-7, PUNE, PUNE

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

Bench: Shri R. K. Panda & Shri Vinay Bhamoreassessment Year : 2021-22

66 to 67 of the paper book. Referring to the copy of the intimation for assessment year 2021-22 he submitted that the CPC has accepted the return filed by the assessee and has accepted the option of the assessee to tax the income at lower rate as per section 115BAA of the Act. However, in the order passed

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)

depreciation (“UD”) were required to be reduced for the purposes of Explanation (iii) to section 115JB of the Act, on a conservative and rational basis, the assessee, in its return of income for AY 2013-14 filed on 26th November 2013,reduced the amount of INR 300 crores in the ratio of BFL and UD (refer Page

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)

depreciation (“UD”) were required to be reduced for the purposes of Explanation (iii) to section 115JB of the Act, on a conservative and rational basis, the assessee, in its return of income for AY 2013-14 filed on 26th November 2013,reduced the amount of INR 300 crores in the ratio of BFL and UD (refer Page

MAHATMA PHULE GRAMIN BIGARSHETI SAHAKAR PAT SANSTHA LTD,KOLHAPUR vs. PCIT-1, PUNE, PUNE

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

Bench: Shri R. K. Panda & Ms. Astha Chandraassessment Year : 2018-19 Mahatma Phule Gramin Bigarsheti Pcit-1, Pune Sahakar Pat Sanstha Vs. A/P Hattiwade, Ajara, Kolhapur – 416505 Pan: Aaaam2608K (Appellant) (Respondent) Assessee By : None (Written Submission Filed) Department By : Shri Amol Khairnar, Cit-Dr Date Of Hearing : 09-12-2025 Date Of Pronouncement : 09-01-2026 O R D E R

depreciation and investment allowance as referred to in sections 32 and 32A respectively, the Commissioner was justified in invoking revision under section 263 of the Act. The relevant observations of Hon’ble High Court from para 10 to 16 read as under: “10. The law on exercise of jurisdiction under Section 263 of the Act is settled by the decision

ITO, WARD-1(1), SOLAPUR, SOLAPUR vs. MS. KSHIRSAGAR FABRICS, SOLAPUR

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

Bench: Shri R. K. Panda & Ms Astha Chandraassessment Year : 2009-10

Section 40A(3). (Separate annexure attached of various related parties whom payment given by the asseessee) However, no disallowance was made despite clear legal position. Omission resulted in underassessment of income Rs 66,20,000 involving short levy of tax of Rs.20,45,580. 8 This is brought to the notice of the department for confirmation and necessary action

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)

66,902 Business Unabsorbed 2010-11 Depreciation 2,39,21,263 2,39,21,263 Ordinary 2011-12 Business 1,71,34,682 1,71,34,682 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

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

depreciation on the same goodwill cannot be disallowed in the latter Assessment Year 2020-21 under consideration. 9. The assessee craves leave to add, to modify to delete or to amend any or all of the above grounds of appeal.” 3. Assessee has also raised the following additional ground : “The impugned revision order passed u/s 263 of the Income

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

section 35(2AB) of the Income Tax Act. 1961? 2. On the facts and circumstances of the case and in law, the Ld. CIT(A) erred in holding that the expenditure incurred by the assessee of Rs.1,04,77,500/- on product development was incurred only for up-gradation of existing products without appreciating that the said expenses were incurred

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

section 35(2AB) of the Income Tax Act. 1961? 2. On the facts and circumstances of the case and in law, the Ld. CIT(A) erred in holding that the expenditure incurred by the assessee of Rs.1,04,77,500/- on product development was incurred only for up-gradation of existing products without appreciating that the said expenses were incurred

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

section 35(2AB) of the Income Tax Act. 1961?\n\n2.\nOn the facts and circumstances of the case and in law, the Ld. CIT(A) erred in holding that the expenditure incurred by the assessee of Rs.1,04,77,500/-\non product development was incurred only for up-gradation of existing products without appreciating that the said expenses were

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

section 35(2AB) of the Income Tax Act. 1961? 2. On the facts and circumstances of the case and in law, the Ld. CIT(A) erred in holding that the expenditure incurred by the assessee of Rs.1,04,77,500/- on product development was incurred only for up-gradation of existing products without appreciating that the said expenses were incurred

OLIVE TREE TRADING PVT LTD,PUNE vs. ITO, CIRCLE 2, PUNE, PUNE

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

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

section 69C of the IT Act and thereby erred in disallowing depreciation amounting to Rs. 66,39,484/- 2 ITA No.899/PUN/2024