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1,299 results for “disallowance”+ Section 10(30)clear

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Section 143(3)81Addition to Income58Deduction55Section 80P51Section 14A47Disallowance46Section 143(2)32Section 14830Section 143(1)25Section 263

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

ITA 590/PUN/2018[2014-15]Status: DisposedITAT Pune06 Dec 2022AY 2014-15

Bench: Shri S.S.Godara & G.D.Padmahshaliआयकरअपीलसं. / Ita No.590/Pun/2018 िनधा"रण वष" / Assessment Year: 2014-15 Eaton Technologies Private Limited, Dcit, Circle-1(2), Cluster C, Wing 1, Eon Free Zone, Vs Pune Plot No.1, Sr.No.77, Midc Kharadi Knowledge Park, Kharadi, Pune 411 014 Pan : Aabce4323Q Appellant/ Assessee Respondent /Revenue आयकरअपीलसं. / Ita No.902/Pun/2018 िनधा"रण वष" / Assessment Year: 2011-12 Eaton Technologies Private Limited, Pr.Cit-1, Cluster C, Wing 1, Eon Free Zone, Vs Pune Plot No.1, Sr.No.77, Midc Kharadi Knowledge Park, Kharadi, Pune 411 014 Pan : Aabce4323Q Appellant/ Assessee Respondent /Revenue

Section 10ASection 143(3)Section 14ASection 40Section 80I

10) deduction section 40(a)(i), TDS deduction disallowance(s) on account of payment of alleged royalty and section 14A read with rule 8D disallowance particularly to exempt income which are identical in the impugned assessment year as well since involving no distinction on facts or law at all. 6. Learned AR at this stage vehemently argued that the Assessing

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Section 80P(2)(d)23
Depreciation14

EATON TECHNOLOGIES PVT.LTD,,PUNE vs. PR. COMMISSIONER OF INCOME-TAX-1,, PUNE

ITA 902/PUN/2018[2011-12]Status: DisposedITAT Pune06 Dec 2022AY 2011-12

Bench: Shri S.S.Godara & G.D.Padmahshaliआयकरअपीलसं. / Ita No.590/Pun/2018 िनधा"रण वष" / Assessment Year: 2014-15 Eaton Technologies Private Limited, Dcit, Circle-1(2), Cluster C, Wing 1, Eon Free Zone, Vs Pune Plot No.1, Sr.No.77, Midc Kharadi Knowledge Park, Kharadi, Pune 411 014 Pan : Aabce4323Q Appellant/ Assessee Respondent /Revenue आयकरअपीलसं. / Ita No.902/Pun/2018 िनधा"रण वष" / Assessment Year: 2011-12 Eaton Technologies Private Limited, Pr.Cit-1, Cluster C, Wing 1, Eon Free Zone, Vs Pune Plot No.1, Sr.No.77, Midc Kharadi Knowledge Park, Kharadi, Pune 411 014 Pan : Aabce4323Q Appellant/ Assessee Respondent /Revenue

Section 10ASection 143(3)Section 14ASection 40Section 80I

10) deduction section 40(a)(i), TDS deduction disallowance(s) on account of payment of alleged royalty and section 14A read with rule 8D disallowance particularly to exempt income which are identical in the impugned assessment year as well since involving no distinction on facts or law at all. 6. Learned AR at this stage vehemently argued that the Assessing

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

Appeal is partly allowed in above terms

ITA 3075/PUN/2017[2013-14]Status: DisposedITAT Pune10 May 2022AY 2013-14

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

For Appellant: Shri Vishal KarlaFor Respondent: Shri S. P. Walimbe
Section 10ASection 143(3)Section 144C(8)Section 40Section 80ISection 92C

disallowance is merited under section 10AA of the Act. The basic condition for application of the said provisions of the Act are an arrangement between the parties, which is so arranged as to enable the assessee to earn super normal profits. The TPO/Assessing Officer/DRP has not pointed out any such arrangement whatsoever between the assessee and the comparable companies selected

M/S. A B KNOWLEDGE SYSTEMS,,PUNE vs. INCOME-TAX OFFICER,,

In the result, the appeal of assessee is partly allowed

ITA 894/PUN/2016[2012-13]Status: DisposedITAT Pune11 Feb 2019AY 2012-13

Bench: Ms. Sushma Chowla, Jm & Shri D. Karunakara Rao, Am आयकर अपीऱ सं. / Ita No.894/Pun/2016 यििाारण वषा / Assessment Year : 2012-13 M/S. Ab Knowledge Systems, 406, Lunkad Sky Station, Viman Nagar, अऩीऱाथी/Appellant Pune – 411014 …. Pan: Aarfa5025E Vs. The Income Tax Officer, …. प्रत्यथी / Respondent Ward 7(3), Pune

For Appellant: Shri Sunil PathakFor Respondent: Shri Sanjeev Ghei
Section 10ASection 143(3)Section 144Section 145(3)Section 80Section 80I

disallowed. He on the other hand, stressed that expenses booked by assessee under both the units were not high. The learned Authorized Representative for the assessee further stated that profits of STPI unit were not tinkered and the 8 AB Knowledge Systems profits of SEZ unit were itself higher. He then referred to the order of Assessing Officer relating

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

ITA 42/PUN/2021[2015-16]Status: DisposedITAT Pune07 Jul 2022AY 2015-16

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.

Section 10Section 10ASection 143(3)Section 14ASection 40Section 80ISection 9(1)(vi)

10) deduction section 40(a)(i), TDS deduction disallowance(s) on account of payment of alleged royalty and section 14A read with rule 8D disallowance particularly ITA Nos.42 & 43/PUN/2021 for A.Y’s: 2015-16 & 16-17 DCIT Vs. M/s.Eaton Technologies Pvt. Ltd., (R) to exempt income which are identical in the impugned assessment year as well since involving no distinction

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

ITA 43/PUN/2021[2016-17]Status: DisposedITAT Pune07 Jul 2022AY 2016-17

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.

Section 10Section 10ASection 143(3)Section 14ASection 40Section 80ISection 9(1)(vi)

10) deduction section 40(a)(i), TDS deduction disallowance(s) on account of payment of alleged royalty and section 14A read with rule 8D disallowance particularly ITA Nos.42 & 43/PUN/2021 for A.Y’s: 2015-16 & 16-17 DCIT Vs. M/s.Eaton Technologies Pvt. Ltd., (R) to exempt income which are identical in the impugned assessment year as well since involving no distinction

ASSISTANT COMMISSIONER OF INCOME-TAX vs. PERSISTENT SYSTEMS PVT. LTD.,, PUNE

In the result, the appeal of Revenue is dismissed

ITA 2336/PUN/2016[2011-12]Status: DisposedITAT Pune30 Apr 2019AY 2011-12

Bench: Ms. Sushma Chowla, Jm & Shri Anil Chaturvedi, Am आयकर अपीऱ सं. / Ita No.2336/Pun/2016 यििाारण वषा / Assessment Year : 2011-12 The Asst. Commissioner Of Income Tax, अऩीऱाथी/Appellant Circle – 4, Pune …. Vs. Persistent Systems Pvt. Ltd., Bhageerath, 402, Senapati Bapat Marg, …. प्रत्यथी / Respondent Pune – 411016 Pan: Aabcp1209Q

For Appellant: Shri Dhanesh BafnaFor Respondent: Shri S.B. Prasad, CIT
Section 10Section 10ASection 10A(7)Section 11Section 115JSection 12Section 143(3)Section 14ASection 80Section 80I

disallowance made under section 10A(7) of the Act, where the margins shown by the assessee on its transactions with associate enterprises at 26.40% were held to be higher than mean margins of comparables at 12.68%, while benchmarking 3 the arm's length price of international transactions. The Assessing Officer was of the view that applying the provisions of section

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

ITA 1423/PUN/2025[2019-20]Status: DisposedITAT Pune22 Dec 2025AY 2019-20

Bench: Dr.Manish Borad & Shri Vinay Bhamoreआयकर अपील सं. / Ita Nos.154 To 156/Pun/2025 Assessment Years : 2016-17 To 2018-19

For Respondent: Shri Amit Bobde
Section 143(1)(a)Section 143(2)Section 2(24)(xviii)Section 43

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

ITA 114/PUN/2025[2020]Status: DisposedITAT Pune22 Dec 2025

Bench: Dr.Manish Borad & Shri Vinay Bhamoreआयकर अपील सं. / Ita Nos.154 To 156/Pun/2025 Assessment Years : 2016-17 To 2018-19

For Respondent: Shri Amit Bobde
Section 143(1)(a)Section 143(2)Section 2(24)(xviii)Section 43

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

ITA 156/PUN/2025[2018-19]Status: DisposedITAT Pune22 Dec 2025AY 2018-19

Bench: Dr.Manish Borad & Shri Vinay Bhamoreआयकर अपील सं. / Ita Nos.154 To 156/Pun/2025 Assessment Years : 2016-17 To 2018-19

For Respondent: Shri Amit Bobde
Section 143(1)(a)Section 143(2)Section 2(24)(xviii)Section 43

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

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

ITA 1844/PUN/2024[2019]Status: DisposedITAT Pune22 Dec 2025

Bench: Dr.Manish Borad & Shri Vinay Bhamoreआयकर अपील सं. / Ita Nos.154 To 156/Pun/2025 Assessment Years : 2016-17 To 2018-19

For Respondent: Shri Amit Bobde
Section 143(1)(a)Section 143(2)Section 2(24)(xviii)Section 43

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

ITA 154/PUN/2025[2016-17]Status: DisposedITAT Pune22 Dec 2025AY 2016-17

Bench: Dr.Manish Borad & Shri Vinay Bhamoreआयकर अपील सं. / Ita Nos.154 To 156/Pun/2025 Assessment Years : 2016-17 To 2018-19

For Respondent: Shri Amit Bobde
Section 143(1)(a)Section 143(2)Section 2(24)(xviii)Section 43

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

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

In the result, the appeal of Revenue is dismissed

ITA 619/PUN/2015[2003-04]Status: DisposedITAT Pune03 Mar 2020AY 2003-04

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

For Appellant: Shri Ajit Kumar JainFor Respondent: Shri T. Vijaya Bhaskar Reddy
Section 10ASection 10A(7)Section 251(2)

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

ITA 583/PUN/2015[2003-04]Status: DisposedITAT Pune03 Mar 2020AY 2003-04

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

For Appellant: Shri Ajit Kumar JainFor Respondent: Shri T. Vijaya Bhaskar Reddy
Section 10ASection 10A(7)Section 251(2)

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

ITA 584/PUN/2015[2005-06]Status: DisposedITAT Pune03 Jun 2021AY 2005-06

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

For Appellant: Shri Ajit Kumar JainFor Respondent: S/Shri Kalika Singh &
Section 10ASection 10A(7)Section 251(2)

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

ITA 620/PUN/2015[2005-06]Status: DisposedITAT Pune03 Jun 2021AY 2005-06

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

For Appellant: Shri Ajit Kumar JainFor Respondent: S/Shri Kalika Singh &
Section 10ASection 10A(7)Section 251(2)

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. SKODA AUTO A.S.,, AURANGABAD

In the result, appeal of Revenue is dismissed

ITA 787/PUN/2015[2010-11]Status: DisposedITAT Pune25 May 2018AY 2010-11

Bench: Ms. Sushma Chowla, Jm & Shri Anil Chaturvedi, Am आयकर अपीऱ सं. / Ita No.787/Pun/2015 यििाारण वषा / Assessment Year : 2010-11

For Appellant: Ms. Divya Bajpai, CITFor Respondent: S/Shri Nikhil Pathak &
Section 10Section 143(3)

disallowance of ₹ 1,90,48,294/- claimed under section 10(6A) of the Act. The Revenue is aggrieved by non-fulfillment of conditions by the assessee, wherein for claiming the benefit under the said section, payment made in pursuance to the agreement was to be approved by the Govt. of India and in the case of assessee, approval granted

ASSISTANT COMMISSIONER OF INCOME-TAX vs. M/S. NAMRATA DEVELOPERS,, PUNE

In the result, all appeals of Revenue and Cross Objections of assessee in assessment year 2011-12 are dismissed and Cross Objections of assessee in assessment years 2012-13 and 2013-14 are allowed

ITA 1976/PUN/2016[2013-14]Status: DisposedITAT Pune25 Sept 2018AY 2013-14

Bench: Ms. Sushma Chowla, Jm & Shri Anil Chaturvedi, Am आयकर अपीऱ सं. / Ita Nos.1974 To 1976/Pun/2016 यििाारण वषा / Assessment Years : 2011-12 To 2013-14

For Appellant: Shri V.L. Jain
Section 143(3)Section 80I

30 mtrs for HCMTR reservation was there in between the plot and because of which the plot was divided into two parts i.e. Plot No.I and Plot No.II in the area statement. The Tribunal held that the issue regarding two plots had arisen because of the mistake of Architect where the plot was only one, but only for the sake

ASSISTANT COMMISSIONER OF INCOME-TAX vs. M/S. NAMRATA DEVELOPERS,, PUNE

In the result, all appeals of Revenue and Cross Objections of assessee in assessment year 2011-12 are dismissed and Cross Objections of assessee in assessment years 2012-13 and 2013-14 are allowed

ITA 1975/PUN/2016[2012-13]Status: DisposedITAT Pune25 Sept 2018AY 2012-13

Bench: Ms. Sushma Chowla, Jm & Shri Anil Chaturvedi, Am आयकर अपीऱ सं. / Ita Nos.1974 To 1976/Pun/2016 यििाारण वषा / Assessment Years : 2011-12 To 2013-14

For Appellant: Shri V.L. Jain
Section 143(3)Section 80I

30 mtrs for HCMTR reservation was there in between the plot and because of which the plot was divided into two parts i.e. Plot No.I and Plot No.II in the area statement. The Tribunal held that the issue regarding two plots had arisen because of the mistake of Architect where the plot was only one, but only for the sake

ASSISTANT COMMISSIONER OF INCOME-TAX vs. M/S. NAMRATA DEVELOPERS,, PUNE

In the result, all appeals of Revenue and Cross Objections of assessee in assessment year 2011-12 are dismissed and Cross Objections of assessee in assessment years 2012-13 and 2013-14 are allowed

ITA 1974/PUN/2016[2011-12]Status: DisposedITAT Pune25 Sept 2018AY 2011-12

Bench: Ms. Sushma Chowla, Jm & Shri Anil Chaturvedi, Am आयकर अपीऱ सं. / Ita Nos.1974 To 1976/Pun/2016 यििाारण वषा / Assessment Years : 2011-12 To 2013-14

For Appellant: Shri V.L. Jain
Section 143(3)Section 80I

30 mtrs for HCMTR reservation was there in between the plot and because of which the plot was divided into two parts i.e. Plot No.I and Plot No.II in the area statement. The Tribunal held that the issue regarding two plots had arisen because of the mistake of Architect where the plot was only one, but only for the sake