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 Sec.43(1) and therefore, the same cannot be deemed as income in terms of Sec.2(24)(xviii), without actually examining the actual nature of the said receipt and that whether the same was granted/utilized for acquiring any asset so as to cover under the said Explanation. 3. Without prejudice to the above, on the facts and circumstances

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 Sec.43(1) and therefore, the same cannot be deemed as income in terms of Sec.2(24)(xviii), without actually examining the actual nature of the said receipt and that whether the same was granted/utilized for acquiring any asset so as to cover under the said Explanation. 3. Without prejudice to the above, on the facts and circumstances

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 Sec.43(1) and therefore, the same cannot be deemed as income in terms of Sec.2(24)(xviii), without actually examining the actual nature of the said receipt and that whether the same was granted/utilized for acquiring any asset so as to cover under the said Explanation. 3. Without prejudice to the above, on the facts and circumstances

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 or increase in income indicated in the audit report but not taken into account in computing the total income in the return’ 8. Sub-section (1) of section 143 states that a return shall be processed to compute total income by making six types of `adjustments’ as set out in sub-clauses (i) to (vi). As noted

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 Sec.43(1) and therefore, the same cannot\nbe deemed as income in terms of Sec.2(24)(xviii), without actually\nexamining the actual nature of the said receipt and that whether the\nsame was granted/utilized for acquiring any asset so as to cover\nunder the said Explanation.\n3.\nWithout prejudice to the above, on the facts and circumstances

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 Sec.43(1) and therefore, the same cannot\nbe deemed as income in terms of Sec.2(24)(xviii), without actually\nexamining the actual nature of the said receipt and that whether the\nsame was granted/utilized for acquiring any asset so as to cover\nunder the said Explanation.\n3.\nWithout prejudice to the above, on the facts and circumstances

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 Sec.43(1) and therefore, the same cannot\nbe deemed as income in terms of Sec.2(24)(xviii), without actually\nexamining the actual nature of the said receipt and that whether the\nsame was granted/utilized for acquiring any asset so as to cover\nunder the said Explanation.\n\n3.\nWithout prejudice to the above, on the facts and circumstances

VIJAY TUKARAM RAUNDAL,PUNE vs. THE DEPUTY COMMISSIONER OF INCOME TAX , CENTRAL CIRCLE-1(2), PUNE

In the result, the appeals filed by the assessee are allowed for statistical purposes

30\nof Form 10CCB with reference to clause 23(b) of the said Form\n24. A perusal of the above would show that while claiming the deduction u/s\n80IB(10), the assessee has made full disclosure of all primary facts. The\ncomputation of income itself carries a detailed note on the claim of deduction u/s\n80IB(10) giving the details

M/S. CITY CORPORATION LIMITED,PUNE vs. THE DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-1(2), PUNE

In the result, both the appeals filed by the assessee are allowed for statistical purposes

Bench: Shri R. K. Panda & Shri Vinay Bhamore

section 80IB(10)(e) and 80IB(10)(f) of the Act as pointed out by the Registered valuer and claim of pro-rata deduction u/s 80IB(10) of the Act. Since, it has been held that the appellant is not eligible for deduction u/s 80IB(10) of the Act, this issue becomes of academic nature and is not being adjudicated

M/S. CITY CORPORATION LIMITED,PUNE vs. THE DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-1(2), PUNE

In the result, both the appeals filed by the assessee are allowed for statistical purposes

Bench: Shri R. K. Panda & Shri Vinay Bhamore

section 80IB(10)(e) and 80IB(10)(f) of the Act as pointed out by the Registered valuer and claim of pro-rata deduction u/s 80IB(10) of the Act. Since, it has been held that the appellant is not eligible for deduction u/s 80IB(10) of the Act, this issue becomes of academic nature and is not being adjudicated

M/S. PIAGGIO VEHICLES PVT.LTD,,PUNE vs. ASSISTANT COMMISSIONER OF INCOME-TAX, CIRCLE - 4,, PUNE

In the result, appeal of the assessee is dismissed

Bench: Dr.Dipak P. Ripote & Shri Vinay Bhamoreआयकर अपील सं. / Ita No.868/Pun/2022 िनधा"रण वष" / Assessment Year: 2015-16 Piaggio Vehicles Private Ltd., V The Assistant Sky One Corporate Park, S Commissioner Of Income Ground Floor, Survey Tax, Circle-4, Pune. No.239/02, Near Pune Airport, Pune – 411032. Pan: Aabcp1225G Appellant/ Assessee Respondent / Revenue Assessee By Shri Siddhesh Chaugule – Ar Revenue By Shri Vidya Ratan - Dr Date Of Hearing 18/12/2024 Date Of Pronouncement 23/12/2024 आदेश/ Order Per Dr. Dipak P. Ripote, Am: This Is An Appeal Filed By The Assessee Against The Order Of Ld.Commissioner Of Income Tax(Appeals)-13, Pune For Assessment Year 2015-16 Dated 06.10.2022 Passed Under Section 250 Of The Income Tax Act, 1961. The Assessee Has Raised The Following Grounds Of Appeal : “1. Refund Of Excess Taxes Paid On Dividend Distributed On The Facts & Circumstances Of The Case & In Law, The Hon'Ble Cit(A) Has Erred In Not Granting The Benefit Of Article 11 Of The India-

30. While it is correct that Section 10(33) exempts only dividend income under Section 115-O of the Act and there are other species of dividend income on which tax is levied under the Act, we do not see how the said position in law would assist the assessee in understanding the provisions of Section 14A in the manner

DEPUTY COMMISSIONER OF INCOME-TAX vs. THE JAWAHARLAL NEHRU PORT TRUST,, RAIGAD

In the result, all the three appeals filed by the Revenue are dismissed and all the three appeals filed by the assessee are partly allowed

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

disallowance of interest expenses of Rs.157.34 crores claimed on payment basis is concerned, the Ld. CIT(A) upheld the action of the Assessing Officer on the ground that the provisions of section 14A are applicable in this case. According to him, the provisions of section 36(1)(xii) are also not applicable to the assessee as the same are applicable

DEPUTY COMMISSIONER OF INCOME-TAX vs. THE JAWAHARLAL NEHRU PORT TRUST,, RAIGAD

In the result, all the three appeals filed by the Revenue are dismissed and all the three appeals filed by the assessee are partly allowed

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

disallowance of interest expenses of Rs.157.34 crores claimed on payment basis is concerned, the Ld. CIT(A) upheld the action of the Assessing Officer on the ground that the provisions of section 14A are applicable in this case. According to him, the provisions of section 36(1)(xii) are also not applicable to the assessee as the same are applicable

DEPUTY COMMISSIONER OF INCOME-TAX vs. THE JAWAHARLAL NEHRU PORT TRUST,, RAIGAD

In the result, all the three appeals filed by the Revenue are dismissed and all the three appeals filed by the assessee are partly allowed

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

disallowance of interest expenses of Rs.157.34 crores claimed on payment basis is concerned, the Ld. CIT(A) upheld the action of the Assessing Officer on the ground that the provisions of section 14A are applicable in this case. According to him, the provisions of section 36(1)(xii) are also not applicable to the assessee as the same are applicable

JAWAHAR LAL NEHRU PORT TRUST,NAVI MUMBAI vs. ACIT PANVEL, PANVEL

In the result, all the three appeals filed by the Revenue are dismissed and all the three appeals filed by the assessee are partly allowed

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

disallowance of interest expenses of Rs.157.34 crores claimed on payment basis is concerned, the Ld. CIT(A) upheld the action of the Assessing Officer on the ground that the provisions of section 14A are applicable in this case. According to him, the provisions of section 36(1)(xii) are also not applicable to the assessee as the same are applicable

JAWAHAR LAL NEHRU PORT TRUST,NAVI MUMBAI vs. ACIT PANVEL, PANVEL

In the result, all the three appeals filed by the Revenue are dismissed and all the three appeals filed by the assessee are partly allowed

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

disallowance of interest expenses of Rs.157.34 crores claimed on payment basis is concerned, the Ld. CIT(A) upheld the action of the Assessing Officer on the ground that the provisions of section 14A are applicable in this case. According to him, the provisions of section 36(1)(xii) are also not applicable to the assessee as the same are applicable

JAWAHAR LAL NEHRU PORT TRUST,NAVI MUMBAI vs. ACIT PANVEL, PANVEL

In the result, all the three appeals filed by the Revenue are dismissed and all the three appeals filed by the assessee are partly allowed

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

disallowance of interest expenses of Rs.157.34 crores claimed on payment basis is concerned, the Ld. CIT(A) upheld the action of the Assessing Officer on the ground that the provisions of section 14A are applicable in this case. According to him, the provisions of section 36(1)(xii) are also not applicable to the assessee as the same are applicable

PIAGGIO VEHICLES PVT LTD ,PUNE vs. ACIT, CIRCLE 4, PUNE, PUNE

In the result, the appeal of the assessee is dismissed

Bench: Ms. Astha Chandra & Shree Dr. Dipak P. Ripote

30. While it is correct that Section 10(33) exempts only dividend income under Section 115-O of the Act and there are other species of dividend income on which tax is levied under the Act, we do not see how the said position in law would assist the assessee in understanding the provisions of Section 14A in the manner