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1,113 results for “disallowance”+ Section 10(31)clear

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Key Topics

Section 143(3)89Addition to Income68Section 80I61Disallowance57Deduction46Section 14831Section 26330Section 143(2)26Section 14A25Section 250

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

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 claimed under section 10AA of the Act by INR 1,95,31,01,681 by invoking the provisions of section 10AA(9) read with section 80IA(10

Showing 1–20 of 1,113 · Page 1 of 56

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Section 80P(2)(d)22
Penalty12

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

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 claimed under section 10AA of the Act by INR 1,95,31,01,681 by invoking the provisions of section 10AA(9) read with section 80IA(10

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

31. No doubt, there is a close connection between assessee and the associated enterprises and to that extent section 10A(7) r.w.s. 80-IA(10) of the Act has been rightly examined by the income-tax authorities. The second aspect that the course of business was so arranged so as to result in more than ordinary profits

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 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)

31. No doubt, there is a close connection between assessee and the associated enterprises and to that extent section 10A(7) r.w.s. 80-IA(10) of the Act has been rightly examined by the income- tax authorities. The second aspect that the course of business was so arranged so as to result in more than ordinary profits

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)

31. No doubt, there is a close connection between assessee and the associated enterprises and to that extent section 10A(7) r.w.s. 80-IA(10) of the Act has been rightly examined by the income- tax authorities. The second aspect that the course of business was so arranged so as to result in more than ordinary profits

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. 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

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

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

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

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

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

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

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. 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

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

In the result, appeal of the assessee in ITA No

ITA 446/PUN/2016[2011-12]Status: DisposedITAT Pune06 Mar 2019AY 2011-12

Bench: Shri R.S.Syal, Vp & Shri Partha Sarathi Chaudhury, Jm

For Appellant: Shri Kamal ShaneyFor Respondent: Smt. Nandita Kanchan
Section 10ASection 10A(7)

31. No doubt, there is a close connection between assessee and the associated enterprises and to that extent section 10A(7) r.w.s. 80-IA(10) of the Act has been rightly examined by the income-tax authorities. The second aspect that the course of business was so arranged so as to result in more than ordinary profits

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

In the result, appeal of the assessee in ITA No

ITA 473/PUN/2016[2011-12]Status: DisposedITAT Pune06 Mar 2019AY 2011-12

Bench: Shri R.S.Syal, Vp & Shri Partha Sarathi Chaudhury, Jm

For Appellant: Shri Kamal ShaneyFor Respondent: Smt. Nandita Kanchan
Section 10ASection 10A(7)

31. No doubt, there is a close connection between assessee and the associated enterprises and to that extent section 10A(7) r.w.s. 80-IA(10) of the Act has been rightly examined by the income-tax authorities. The second aspect that the course of business was so arranged so as to result in more than ordinary profits

VIKRAM DEVELOPERS & PROMOTERS,,PUNE vs. DEPUTY COMMISSIONER OF INCOME TAX,,

In the result, the appeal of the assessee in ITA No

ITA 2796/PUN/2016[2013-14]Status: DisposedITAT Pune14 Nov 2019AY 2013-14

Bench: Shri D. Karunakara Rao, Am & Shri Partha Sarathi Chaudhury, Jm आयकर अपील सं. / Ita Nos.2795 & 2796/Pun/2016 िनधा"रण वष" / Assessment Years : 2012-13 & 2013-14 M/S. Vikram Developers & Promoters, 19, Shrikrishna Heights, Ganeshkhind Road, Shivaji Nagar, Pune-411005. .......अपीलाथ" / Appellant Pan : Aagfv4298R बनाम / V/S. Dcit, Central Circle-2(1), ……""यथ" / Respondent Pune. Assessee By : Shri Kishor Phadke Revenue By : Shri Milind Chahure सुनवाई क" तारीख / Date Of Hearing : 17.10.2019 घोषणा क" तारीख / Date Of Pronouncement : 14.11.2019 आदेश / Order Per D. Karunakara Rao, Am: There Are Two Appeals Under Consideration Filed By The Assessee Against The Common Orders Of The Cit(A)-12, Pune Dated 08.09.2016 For The Assessment Years 2012-13 & 2013-14 Respectively. Preliminary Issue - Condonation Of Delay – Both Appeals 2. Before Us, At The Outset, Ld. Counsel For The Assessee Submitted That The Both The Appeals Could Not Be Filed In Time & The Said Appeals Were Filed With The Delay Of 01 Day. In This Regard, Ld. Counsel For The Assessee Submitted That The Delay Is Unintentional & Prayed For Condoning The Same. 3. After Hearing Both The Sides & Considering The Smallness Of Delay In Filing Of Both The Appeals, We Condone The Delay & Proceed To Adjudicate The Appeals Of The Assessee In The Following Paragraphs. 4. The Facts & Grounds Are Common In Both The Appeals, Therefore, Both The Appeals Were Heard Together & Are Being Disposed Of By This Composite Order. Accordingly, The Appeal-Wise Adjudication Is Taken Up In The Following Paragraphs.

For Appellant: Shri Kishor PhadkeFor Respondent: Shri Milind Chahure
Section 132Section 68Section 80I

disallowance of non payment of MVAT and service tax under section.43B of the Act. The deduction claimed under Chapter VIA under section 80IB(10) in respect of housing project namely; KIrishna Regency at Kalyan was accepted amounting to ₹6,54,91,914/- but the Assessing Officer invoked the provisions of section 115 JC of the Act and adjusted total income