EATON TECHNOLOGIES PVT.LTD,,PUNE vs. DEPUTY COMMISSIONER OF INCOME-TAX, CIRCLE - 1(2),, PUNE

Appeal is partly allowed in above terms

Bench: Shri S. S. Godara, Jm & Shri Dr. Dipak P. Ripote, Am आयकर अपीऱ सं. / Ita No.3075/Pun/2017 ननधधारण वषा / Assessment Year : 2013-14 Eaton Technologies Pvt. Ltd. Cluster C, Wing 1, Eon Free Zone, Plot No.1, Sr. No.77, Midc Kharadi Knowledge Park, Kharadi ,Pune- 411 014. .......अपऩलधथी / Appellant Pan : Aabce4323Q बनधम / V/S. ……प्रत्यथी / Respondent Dcit, Circle-1(2), Pune Assessee By : Shri Vishal Karla Revenue By : Shri S. P. Walimbe

Disallowance under section 10AA of the Act : 2. That on the facts and circumstances of the case and in law, the AO, erred in reducing the deduction under section 10AA of the Act by INR 1,66,90,42,654 by invoking the provisions of section 10AA(9) read with section 80IA(10) of the Act, alleging

DEPUTY COMMISSIONER OF INCOME TAX CIR 1(1), PUNE vs. EATON TECHNOLOGIES PVT. LTD.,, PUNE

Appeals are partly allowed for statistical purpose in above terms

Bench: Shri S.S.Godara & Dr. Dipak P. Ripoteआयकरअपीलसं. / Ita Nos.42 & 43/Pun/2021 िनधा"रणवष" / Assessment Years : 2015-16 & 16-17 Dcit, Circle-1(1), Pune. M/S.Eaton Technologies Pvt. Ltd., Vs Cluster C Wing-1, Eon Zone, Midc Kharadi, Knowledge Park, Plot No.1, Survey No.77, Kharadi, Pune – 411014. Pan: Aabce 4323 Q Appellant/ Assessee Respondent /Revenue Assessee By Shri Vishal Kalra & Shri Ss Tomar -Ar Revenue By Shri Sunil Kumar – Cit(Dr) Date Of Hearing 24/06/2022 Date Of Pronouncement 07/07/2022 आदेश/ Order Per S.S.Godara, Jm: These Revenue’S Twin Appeals For The Assessment Years 2015- 16 & 2016-17 Arise Against The Cit(A)-13, Pune’S Separate Orders; Both Dated 29.05.2020, Passed In Case No.Pn/Cit(A)-13/Dcit, Circle-1(2), Pune/10142/2019-20/02, Pn/Cit(A)-13/Dcit, Circle- 1(2), Pune/10142/2019-20/03 Respectively, Involving Proceedings Under Section 143(3) Of The Income Tax Act, 1961. Heard Both The Parties. Case Files Perused.

10) deduction section 40(a)(i), TDS deduction disallowance(s) on account of payment of alleged royalty and section

DEPUTY COMMISSIONER OF INCOME TAX CIR 1(1), PUNE vs. EATON TECHNOLOGIES PVT. LTD.,, PUNE

Appeals are partly allowed for statistical purpose in above terms

Bench: Shri S.S.Godara & Dr. Dipak P. Ripoteआयकरअपीलसं. / Ita Nos.42 & 43/Pun/2021 िनधा"रणवष" / Assessment Years : 2015-16 & 16-17 Dcit, Circle-1(1), Pune. M/S.Eaton Technologies Pvt. Ltd., Vs Cluster C Wing-1, Eon Zone, Midc Kharadi, Knowledge Park, Plot No.1, Survey No.77, Kharadi, Pune – 411014. Pan: Aabce 4323 Q Appellant/ Assessee Respondent /Revenue Assessee By Shri Vishal Kalra & Shri Ss Tomar -Ar Revenue By Shri Sunil Kumar – Cit(Dr) Date Of Hearing 24/06/2022 Date Of Pronouncement 07/07/2022 आदेश/ Order Per S.S.Godara, Jm: These Revenue’S Twin Appeals For The Assessment Years 2015- 16 & 2016-17 Arise Against The Cit(A)-13, Pune’S Separate Orders; Both Dated 29.05.2020, Passed In Case No.Pn/Cit(A)-13/Dcit, Circle-1(2), Pune/10142/2019-20/02, Pn/Cit(A)-13/Dcit, Circle- 1(2), Pune/10142/2019-20/03 Respectively, Involving Proceedings Under Section 143(3) Of The Income Tax Act, 1961. Heard Both The Parties. Case Files Perused.

10) deduction section 40(a)(i), TDS deduction disallowance(s) on account of payment of alleged royalty and section

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

10 to section 43(1) of the Act and therefore section 2(24)(xviii) of the Act comes into operation and the subsidy received by the assessee is to be treated as income liable to be taxed for the year under consideration. We therefore fail to find any infirmity in the order of ld.CIT(A) and the common grounds

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

10 to section 43(1) of the Act and therefore section 2(24)(xviii) of the Act comes into operation and the subsidy received by the assessee is to be treated as income liable to be taxed for the year under consideration. We therefore fail to find any infirmity in the order of ld.CIT(A) and the common grounds

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

10 to section 43(1) of the Act and therefore section 2(24)(xviii) of the Act comes into operation and the subsidy received by the assessee is to be treated as income liable to be taxed for the year under consideration. We therefore fail to find any infirmity in the order of ld.CIT(A) and the common grounds

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

10 to section 43(1) of the Act and therefore section 2(24)(xviii) of the Act comes into operation and the subsidy received by the assessee is to be treated as income liable to be taxed for the year under consideration. We therefore fail to find any infirmity in the order of ld.CIT(A) and the common grounds

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

10 to section 43(1) of the Act and therefore section 2(24)(xviii) of the Act comes into operation and the subsidy received by the assessee is to be treated as income liable to be taxed for the year under consideration. We therefore fail to find any infirmity in the order of ld.CIT(A) and the common grounds

M/S. HONEWELL AUTOMATION INDIA LTD.,,PUNE vs. DEPUTY COMMISSIONER OF INCOME-TAX,,

In the result, the appeal of Revenue is dismissed

Bench: Shri R.S. Syal & Shri S.S. Viswanethra Ravi

disallow by restricting the deduction to ordinary profit. The contention of assessee is that the AO did not make any addition in terms of sub-section (7) of section 10A of the Act and enhancement proposed by the CIT(A) is not warranted u/s. 251(2) of the Act. The case of CIT(A) is that the deduction

DEPUTY COMMISSIONER OF INCOME-TAX vs. M/S. HONEYWELL AUTOMATION INDIA LTD.,, PUNE

In the result, the appeal of Revenue is dismissed

Bench: Shri R.S. Syal & Shri S.S. Viswanethra Ravi

disallow by restricting the deduction to ordinary profit. The contention of assessee is that the AO did not make any addition in terms of sub-section (7) of section 10A of the Act and enhancement proposed by the CIT(A) is not warranted u/s. 251(2) of the Act. The case of CIT(A) is that the deduction

DEPUTY COMMISSIONER OF INCOME-TAX vs. M/S. HONEYWELL AUTOMATION INDIA LTD.,, PUNE

In the result, the appeal of Revenue is dismissed as infructuous

Bench: Shri R.S. Syal & Shri S.S. Viswanethra Ravi

disallow by restricting the deduction to ordinary profit. The contention of assessee is that the AO did not make any addition in terms of sub- section (7) of section 10A of the Act and enhancement proposed by the CIT(A) is not warranted u/s. 251(2) of the Act. The case of CIT(A) is that the deduction

M/S. HONEWELL AUTOMATION INDIA LTD.,,PUNE vs. DEPUTY COMMISSIONER OF INCOME-TAX,,

In the result, the appeal of Revenue is dismissed as infructuous

Bench: Shri R.S. Syal & Shri S.S. Viswanethra Ravi

disallow by restricting the deduction to ordinary profit. The contention of assessee is that the AO did not make any addition in terms of sub- section (7) of section 10A of the Act and enhancement proposed by the CIT(A) is not warranted u/s. 251(2) of the Act. The case of CIT(A) is that the deduction

ASSISTANT COMMISSIONER OF INCOME-TAX, CIRCLE - 11,, PUNE vs. HSBC SOFTWARE DEVELOPMENT (INDIA) PVT.LTD,, PUNE

In the result, CO of assessee is allowed and the appeals of Revenue are dismissed

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

disallowance under the provisions of section 10A(7) read with section 80IA(10) of Rs.85,40,85,549/-. The factual

ASSISTANT COMMISSIONER OF INCOME-TAX, CIRCLE - 11,, PUNE vs. HSBC SOFTWARE DEVELOPMENT (INDIA) PRIVATE LIMITED,, PUNE

In the result, CO of assessee is allowed and the appeals of Revenue are dismissed

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

disallowance under the provisions of section 10A(7) read with section 80IA(10) of Rs.85,40,85,549/-. The factual

VIRENDRA SINGH SAINI,HARYANA vs. ASST. DIRECTOR OF INCOME TAX, CPC, BANGALORE, BENGALORE

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

Bench: Shri Inturi Rama Raoआयकर अपील सं. / Ita No.1483/Pun/2024 "नधा"रण वष" / Assessment Year : 2019-20

disallowance of expenditure made by the AO. It set up a case before the authorities below, including the ld. CIT(A), taking shelter of section 43B of the Act by arguing that the 10 disallowance

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

10 to clause (1) of section 43 of the Act has\nalready been taken into account the amount of subsidy for\ndetermination of the actual cost of assets for computing the\ndepreciation in the computation of income filed along with\nreturn of income of income for the assessment year under\nconsideration. However, ld. AO was not satisfied with these

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

10 to clause (1) of section 43 of the Act has\nalready been taken into account the amount of subsidy for\ndetermination of the actual cost of assets for computing the\ndepreciation in the computation of income filed along with\nreturn of income of income for the assessment year under\nconsideration. However, ld. AO was not satisfied with these

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

10 to clause (1) of section 43 of the Act has\nalready been taken into account the amount of subsidy for\ndetermination of the actual cost of assets for computing the\ndepreciation in the computation of income filed along with\nreturn of income of income for the assessment year under\nconsideration. However, ld. AO was not satisfied with these