DEPUTY COMMISSIONER OF INCOME-TAX vs. M/S. SUNGARD SOLUTIONS (I) PVT. LTD.,, PUNE

In the result, the appeal of Revenue in ITA

Bench: Shri Anil Chaturvedi, Am & Shri S.S. Viswanethra Ravi, Jm

depreciation. Thus, the ground of the assessee is allowed. 6. Ground No.2 is with respect to denial of deduction u/s 10A with respect to Unit No.I, Bangalore. 6.1 AO has noted that assessee has not claimed deduction u/s 10A of the Act for the Unit I, Bangalore in the return of income but subsequently, during the assessment proceedings

SUNGARD SOLUTIONS (INDIA) P. LTD.,,PUNE vs. DEPUTY COMMISSIONER OF INCOME-TAX,,

In the result, the appeal of Revenue in ITA

Bench: Shri Anil Chaturvedi, Am & Shri S.S. Viswanethra Ravi, Jm

depreciation. Thus, the ground of the assessee is allowed. 6. Ground No.2 is with respect to denial of deduction u/s 10A with respect to Unit No.I, Bangalore. 6.1 AO has noted that assessee has not claimed deduction u/s 10A of the Act for the Unit I, Bangalore in the return of income but subsequently, during the assessment proceedings

JAIN IRRIGATION SYSTEMS LTD,,JALGAON vs. DEPUTY COMMISSIONER OF INCOME-TAX, CIRCLE - 2,, JALGAON

Appeal is partly allowed in above terms

Bench: Shri S.S.Godara & Dr.Dipak P.Ripoteआयकरअपीलसं. / Ita No.227/Pun/2018 िनधा"रणवष" / Assessment Year : 2013-14 Jain Irrigation Systems Ltd., The Deputy Commissioner Of Jain Plastic Park, N.H No.6, Vs Income Tax, Circle-2, Jalgaon – 425001. . Jalgaon. Pan: Aaacj 7163 Q Appellant/ Assessee Respondent /Revenue Assessee By Shri Percy Pardiwala; Shri Prashant Maheshwari & Ms.Monicamulchandani – Ar’S Revenue By Shri B Koteswara Rao – Dr Date Of Hearing 23/09/2022 Date Of Pronouncement 22/12/2022 आदेश/ Order Per S.S.Godara, Jm: This Assessee’Sappeal For Assessment Year 2013-14Is Directed Against Thedeputy Commissioner Of Income Tax, Cricle-2, Jalgaon’S Assessment Order Dated 29.10.2017, Framed In Furtherance To The Dispute Resolution Panel-3, Mumbai (Drp)’S Direction Dated 25.09.2017 Passed In Objection No.78, In Proceedings U/S 143(3) R,.W.S 144C(5) Of The Income Tax Act, 1961 [In Short “The Act”].

Section 92D of the Act read with Rule 10D of the Income tax Rules, 1962 and the various submissions made by the Appellant. 2. Provision of Corporate Guarantee 2.1 On the facts and in circumstances of the case and in law, the learned AO and the learned TPO erred in concluding and the Hon’ble DRP erred in confirming

SEMPERTRANS INDIA PRIVATE LIMITED,ROHA vs. INCOME-TAX OFFICER, PANVEL

In the result, appeal filed by the assessee is partly\nallowed for statistical purposes

92D of the Act read with Rule 10D of the\nIncome Tax Rules, 1962 ('Rules').\n8. Upholding/confirming the action of Ld. TPO, in going beyond\nthe scope under section 92CA in questioning the commercial\nrationale of the legitimate business expenses incurred by the\nAppellant and further erred in determining the ALP of payment of\nservices to be NIL.\n9. Rejecting

M/S. RENISHAW METROLOGY SYSTEMS LTD.,,PUNE vs. DEPUTY COMMISSIONER OF INCOME-TAX,, PUNE

In the result, appeal of assessee is allowed and the appeal of Revenue is dismissed

Bench: Ms. Sushma Chowla, Jm & Shri Anil Chaturvedi, Am आयकर अपीऱ सं. / Ita No.376/Pun/2014 यििाारण वषा / Assessment Year : 2009-10 M/S. Renishaw Metrology Systems Ltd., S.No.283, Hissa No.2, S.No.284, Hissa No.2 & 3A, Raisoni Estate, Village Mann, Taluka Mulshi, अऩीऱाथी/Appellant Pune – 411057 …. Pan: Aabcr6361F Vs. The Dy. Commissioner Of Income Tax, …. प्रत्यथी / Respondent Circle 1(2), Pune

92D of the Act read with Rule 10D of the Rules used for determining the arm's-length price of the international transactions of the Appellant pertaining to provision of software development services to its AE; 2.7 not allowing the variation/reduction of 5 percent from the arithmetic mean while determining the arm's length price as envisaged under the proviso

DEPUTY COMMISSIONER OF INCOME-TAX, CIRCLE - 5,, PUNE vs. RENISHAW METROLOGY SYSTEMS LTD,, PUNE

In the result, appeal of assessee is allowed and the appeal of Revenue is dismissed

Bench: Ms. Sushma Chowla, Jm & Shri Anil Chaturvedi, Am आयकर अपीऱ सं. / Ita No.376/Pun/2014 यििाारण वषा / Assessment Year : 2009-10 M/S. Renishaw Metrology Systems Ltd., S.No.283, Hissa No.2, S.No.284, Hissa No.2 & 3A, Raisoni Estate, Village Mann, Taluka Mulshi, अऩीऱाथी/Appellant Pune – 411057 …. Pan: Aabcr6361F Vs. The Dy. Commissioner Of Income Tax, …. प्रत्यथी / Respondent Circle 1(2), Pune

92D of the Act read with Rule 10D of the Rules used for determining the arm's-length price of the international transactions of the Appellant pertaining to provision of software development services to its AE; 2.7 not allowing the variation/reduction of 5 percent from the arithmetic mean while determining the arm's length price as envisaged under the proviso

BAJAJ HOUSING FINANCE LIMITED,PUNE vs. ITO, WARD-8(1), PUNE, PUNE

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

Bench: Dr.Manish Borad

depreciation was reduced. Relevant finding of the Tribunal reads as under : “4. We have heard the rival submissions and perused the material available on record. The assessee is engaged in the business of manufacturing and sale of cement, manufacturing and sale of asbestos sheets, heavy engineering workshop and foundry. The assessee filed its return of income electronically