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

VII provides that all Government Grants except relating to depreciable assets shall be recognized as income. Para 5.1 of the explanatory notes has explained that the existing provisions of explanation (10) of Section 43(1) of the Income Tax Act, already contains the guidance for treatment of the Government Grants relating to acquisition of assets. However there was no specific

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

VII provides that all Government Grants except relating to depreciable assets shall be recognized as income. Para 5.1 of the explanatory notes has explained that the existing provisions of explanation (10) of Section 43(1) of the Income Tax Act, already contains the guidance for treatment of the Government Grants relating to acquisition of assets. However there was no specific

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

VII provides that all Government Grants except relating to depreciable assets shall be recognized as income. Para 5.1 of the explanatory notes has explained that the existing provisions of explanation (10) of Section 43(1) of the Income Tax Act, already contains the guidance for treatment of the Government Grants relating to acquisition of assets. However there was no specific

POONAWALLA SHARES & SECURITIES PVT.LTD,PUNE vs. ASSISTANT COMMISSIONER OF WEALTH-TAX, CIRCLE-4, PUNE

Appeal is partly allowed in above terms

Bench: Shri S.S.Godara & Dr. Dipak P. Ripoteआयकर अपीलसं. / Ita No.380/Pun/2020 िनधा"रण वष" / Assessment Year : 2016-17 Poonawalla Shares & Securities The Assistant Pvt. Ltd., Vs Commissioner Of Income 16-B,/1, Sarosh Bhavan, Tax, Dr.Ambedkar Road, Circle-4, Pune. Pune – 411001 Pan: Aaacp 6087 H Appellant/ Assessee Respondent /Revenue Assessee By Shri Percy Pardiwala – Ar Revenue By Shri M.G.Jasnani – Dr Date Of Hearing 08/07/2022 Date Of Pronouncement 29/07/2022 आदेश/ Order Per S.S.Godara, Jm: This Assessee’S Appeal For Assessment Year 2016-17 Is Directed Against The Commissioner Of Income Tax(Appeals)-3, Pune’S Order Dated 11.12.2019 Passed In Case No.Pn/Cit(A)-3/Cir 4/193/2018-19/428, In Proceedings U/S.143(3) Of The Income Tax Act, 1961 [In Short “The Act”].

6. At the outset, it is submitted that carry forward of losses arising under the head Capital gains is dealt with by section 74 of the Act, which states that where the net result of the computation under the head ‘Capital gains’ is a loss to the assessee, the whole loss shall, subject to the other provisions of the section

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

VII provides that all Government\nGrants except relating to depreciable assets shall be recognized as\nincome. Para 5.1 of the explanatory notes has explained that the\nexisting provisions of explanation (10) of Section 43(1) of the Income\nTax Act, already contains the guidance for treatment of the\nGovernment Grants relating to acquisition of assets. However there\nwas no specific

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

VII provides that all Government\nGrants except relating to depreciable assets shall be recognized as\nincome. Para 5.1 of the explanatory notes has explained that the\nexisting provisions of explanation (10) of Section 43(1) of the Income\nTax Act, already contains the guidance for treatment of the\nGovernment Grants relating to acquisition of assets. However there\nwas no specific

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

VII provides that all Government\nGrants except relating to depreciable assets shall be recognized as\nincome. Para 5.1 of the explanatory notes has explained that the\nexisting provisions of explanation (10) of Section 43(1) of the Income\nTax Act, already contains the guidance for treatment of the\nGovernment Grants relating to acquisition of assets. However there\nwas no specific

MOHAN SHRINIWAS BHISE,SANGLI vs. ITO WARD 3, SANGLI, SANGLI

In the result, the appeal of assessee is treated as allowed for statistical purposes with the above directions

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

disallowance of Rs.11,86,180/- (Rs.31,86,180/- - Rs.20,00,000/-) and Rs.20,99,740/- (Rs.23,99,740/- - Rs.3,00,000/-) on account of excess exemption claimed by the assessee for retirement gratuity and leave encashment respectively. A show cause notice was thereafter issued to the assessee requiring him to show cause as to why the assessment proceedings should

EATON TECHNOLOGIES PRIVATE LIMITED,PUNE vs. PRINCIPAL COMMISSIONER OF INCOME TAX, PUNE

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

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

vii. Deduction/Exemption u/s.10A/10AA viii. Income from house property ix. Reduction in profit due to ICDS x. International Transaction(s) xi. Loss from currency fluctuations 3. Statutory notices u/s.143(2)/142(1) were duly served upon the assessee along with detailed questionnaire and the assessee made compliance to such notices. Since the assessee had entered into certain international transactions, the Assessing

CUMMINS INDIA LTD. vs. DEPUTY COMMISSIONER OF INCOME-TAX,,

In the result, appeal of assessee is partly allowed

Bench: Ms. Sushma Chowla, Jm & Shri Anil Chaturvedi, Am आयकर अपीऱ सं. / Ita No.309/Pun/2014 यििाारण वषा / Assessment Year : 2009-10 Cummins India Limited, अऩीऱाथी/Appellant Kothrud, Pune – 411038 …. Pan: Aaacc7258B Vs. The Dy. Commissioner Of Income-Tax, …. प्रत्यथी / Respondent Circle 1(1), Pune

6 Cummins India Limited. had compared the profitability of export to associated enterprises undertaken by the assessee with domestic sales. The assessee is aggrieved by two aspects, wherein it has pointed out that because of controlled transactions, no comparison could be made and also because of FAR analysis, the most appropriate method to be applied was TNMM method

DEPUTY COMMSSIONER OF INCOME-TAX,, PUNE vs. KUMAR KONDIBA SHINGARE,, PUNE

In the result, all the five appeals of the Revenue dismissed

6. The Assessing Officer took a view that, the reimbursements of testing & development charges (T & D charges) is income which is deemed to accrue or arise in India and covered within the meaning of Fees for Technical Services (i.e. FTS) as per section 9(l)(vii) of the Act. Thus, the Assessing Officer disallowed a sum of Rs.1

DEPUTY COMMISSIONER OF INCOME-TAX vs. KUMAR KONDIBA SHINGARE,, PUNE

In the result, all the five appeals of the Revenue dismissed

6. The Assessing Officer took a view that, the reimbursements of testing & development charges (T & D charges) is income which is deemed to accrue or arise in India and covered within the meaning of Fees for Technical Services (i.e. FTS) as per section 9(l)(vii) of the Act. Thus, the Assessing Officer disallowed a sum of Rs.1

DEPUTY COMMSSIONER OF INCOME-TAX,, PUNE vs. KUMAR KONDIBA SHINGARE,, PUNE

In the result, all the five appeals of the Revenue dismissed

6. The Assessing Officer took a view that, the reimbursements of testing & development charges (T & D charges) is income which is deemed to accrue or arise in India and covered within the meaning of Fees for Technical Services (i.e. FTS) as per section 9(l)(vii) of the Act. Thus, the Assessing Officer disallowed a sum of Rs.1

DEPUTY COMMSSIONER OF INCOME-TAX,, PUNE vs. KUMAR KONDIBA SHINGARE,, PUNE

In the result, all the five appeals of the Revenue dismissed

6. The Assessing Officer took a view that, the reimbursements of testing & development charges (T & D charges) is income which is deemed to accrue or arise in India and covered within the meaning of Fees for Technical Services (i.e. FTS) as per section 9(l)(vii) of the Act. Thus, the Assessing Officer disallowed a sum of Rs.1

DEPUTY COMMSSIONER OF INCOME-TAX,, PUNE vs. KUMAR KONDIBA SHINGARE,, PUNE

In the result, all the five appeals of the Revenue dismissed

6. The Assessing Officer took a view that, the reimbursements of testing & development charges (T & D charges) is income which is deemed to accrue or arise in India and covered within the meaning of Fees for Technical Services (i.e. FTS) as per section 9(l)(vii) of the Act. Thus, the Assessing Officer disallowed a sum of Rs.1

CHANDRAKANT GULABRAO BORDE,,PUNE vs. INCOME-TAX OFFICER, WARD - 13(1),, PUNE

In the result, appeal of the assessee is allowed

Bench: Shri D.Karunakara Rao, Am & Shri Vikas Awasthy, Jm

disallowance of the exemption of Rs.80,00,000/-. The clause (ii) of section 10(17) of the Act, provides for exemption in respect of the payments made by the Governments for the specified purposes in public interest. Relevant provisions read as under : “(17A) any payment made, whether in cash or in kind,- (i) in pursuance of any award instituted

M/S. SAVA HEALTHCARE LTD,,PUNE vs. ASSISTANT COMMISSIONER OF INCOME TAX,, PUNE

In the result, 70% of world profits are added in the hands of assessee under guise of Profit Split Method

Bench: Ms. Sushma Chowla, Jm & Shri Anil Chaturvedi, Am आयकर अपीऱ सं. / Ita Nos.1062 To 1068/Pun/2017 यििाारण वषा / Assessment Years : 2007-08 To 2013-14

10 refers to the finding of investigation team in relation to functions performed by India based company for the business carried out in India and shown to be carried out in Mauritius / UAE. The same is summarized as under:- “A) Development of business: i) This business artificially shown in UAE based companies has been developed by Shri Vinod Jadhav

M/S. SAVA HEALTHCARE LTD,,PUNE vs. ASSISTANT COMMISSIONER OF INCOME TAX,, PUNE

In the result, 70% of world profits are added in the hands of assessee under guise of Profit Split Method

Bench: Ms. Sushma Chowla, Jm & Shri Anil Chaturvedi, Am आयकर अपीऱ सं. / Ita Nos.1062 To 1068/Pun/2017 यििाारण वषा / Assessment Years : 2007-08 To 2013-14

10 refers to the finding of investigation team in relation to functions performed by India based company for the business carried out in India and shown to be carried out in Mauritius / UAE. The same is summarized as under:- “A) Development of business: i) This business artificially shown in UAE based companies has been developed by Shri Vinod Jadhav