SHRI GANADHIPATI GANDHARACHARYA KUNTIUSAGAR VIDYA SODH SONSTHA,PUNE vs. ITO, EXEMPTION, PUNE, PUNE

Bench: Shri Manish Borad & Ms. Astha Chandra

3. Without prejudice to above grounds and on the facts and circumstances prevailing in the case and as per provisions & scheme AYs 2018-19 to 2021-26 of the Income-tax Act, 1961 ('The Act') it be held that the Ld. AO and Ld. Addl./J.CIT(A) erred in charging to tax entire receipts instead of surplus amount. Accordingly

SHRI GANADHIPATI GANDHARACHARYA KUNTIUSAGAR VIDYA SODH SONSTHA,KOLHAPUR vs. ITO, EXEMPTION, PUNE, KOLHAPUR

Bench: Shri Manish Borad & Ms. Astha Chandra

3. Without prejudice to above grounds and on the facts and circumstances prevailing in the case and as per provisions & scheme AYs 2018-19 to 2021-26 of the Income-tax Act, 1961 ('The Act') it be held that the Ld. AO and Ld. Addl./J.CIT(A) erred in charging to tax entire receipts instead of surplus amount. Accordingly

SHRI GANADHIPATI GANDHARACHARYA KUNTIUSAGAR VIDYA SODH SONSTHA,KOLHAPUR vs. ITO, EXEMPTION, PUNE, KOLHAPUR

Bench: Shri Manish Borad & Ms. Astha Chandra

3. Without prejudice to above grounds and on the facts and circumstances prevailing in the case and as per provisions & scheme AYs 2018-19 to 2021-26 of the Income-tax Act, 1961 ('The Act') it be held that the Ld. AO and Ld. Addl./J.CIT(A) erred in charging to tax entire receipts instead of surplus amount. Accordingly

INCOME TAX OFFICER, WARD-11(1), PUNE, PUNE vs. MAHARASHTRA CRICKET ASSOCIATION, PUNE, PUNE

In the result, the appeal of the Revenue is allowed for statistical\npurposes

disallowance of the claim of\ndeficit holding that there is no merit in the addition(s) made by the Ld. AO\nfor the reasons recorded in pars 5.1 to 5.5.2 of his impugned appellate\norder.\n5.\nDissatisfied, the Revenue is in appeal before the Tribunal and all the\ngrounds of appeal relate thereto.\n6. The Ld. DR contended that

BANSILAL RAMNATH AGARWAL CHARITABLE TRUST,PUNE vs. CIT (EXEMPTION), PUNE

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

Bench: Shri R. K. Panda & Ms. Astha Chandraassessment Year : 2020-21 Bansilal Ramnath Agarwal Charitable Trust Cit (Exemption), 251, Budhwar Peth, City Post Chowk, Vs. Pune Pune – 411002 Pan: Aaatb4383K (Appellant) (Respondent) Assessee By : Shri Kishor B Phadke Department By : Shri Amol Khairnar, Cit-Dr Date Of Hearing : 11-12-2025 Date Of Pronouncement : 28-01-2026 O R D E R Per R.K. Panda, V.P:

3) of the Act, etc. Thus, a perusal of various details furnished by the assessee clearly shows that the Assessing Officer in the instant case has passed the assessment order after a detailed scrutiny with multiple pointed queries on the very same payments to the specified persons. Further, the assessee has also filed detailed replies on account of the payment

PRECISION CAMSHAFTS LTD.,SOLAPUR vs. ASSESSMENT UNIT, INCOME TAX DEPARTMENT (NFAC), SOLAPUR

In the result, appeal of the assessee is allowed

Bench: Ms. Astha Chandra & Dr.Dipak P. Ripoteआयकर अपील सं. / Ita No.1962/Pun/2024 िनधा"रण वष" / Assessment Year: 2020-21 Precision Camshafts Ltd., V Assessment Unit, Income Tax E-102/103, Akkalkot Road, S Department (National Midc, Solapur – 413006. Faceless Assessment Center), Maharashtra. Jurisdiction Details : Pne- C(1), Range 63, Circle-1, Solapur. Pan: Aabcp1086B Appellant/ Assessee Respondent / Revenue Assessee By Shri Nikhil Pathak – Ar Revenue By Shri Prakash L Pathade – Cit(Dr) Date Of Hearing 17/06/2025 Date Of Pronouncement 10/07/2025 आदेश/ Order Per Dr. Dipak P. Ripote, Am: This Is An Appeal Filed By The Assessee Directed Against The Order Of Assessment Unit, Income Tax Department Under Section 143(3) R.W.S 144C(3) Read With Section 144B Of The Income Tax Act, 1961 For A.Y.2020-21 Dated 25.07.2024, Emanating From Order Of Dispute Resolution Panel U/S.144C(5) Of The Act For A.Y.2020-21

124 (Bombay) held as under : ITA No.1962/PUN/2024 [A] Quote ,“9. There is no perversity in the orders passed by the Commissioner (Appeals) and the ITAT on this issue. Besides in Nirved Traders (P.) Ltd. (supra), this Court has held that disallowance under section 14A of the IT Act cannot be more than the exempt income earned by the Assessee during

CAPGEMINI TECHNOLOGY SERVICES INDIA LIMITED (SUCCESSOR TO LIQUIDHUB INDIA PRIVATE LIMITED),PUNE vs. ASSISTANT COMMISSIONER OF INCOME TAX, CIRCLE 1(1), PUNE, PUNE

In the result, the Appeal filed by the Assessee is allowed

Bench: Dr.Dipak P. Ripote & Shri Vinay Bhamoreआयकर अपऩल सं. / Ita No.2753/Pun/2025 निर्धारण वषा / Assessment Year: 2020-21 Capgemini Technology V Assessment Unit, Services India S Income Tax Limited(Successor To Liquid Department. Hub India Private Limited), Plot No.14, Rajiv Gandhi Infotech Park, Hinjewadi, Phase Iii, Midc Sez, Village Man, Taluka Mulshi, District Pune – 411057. Pan: Aaacl8943J Appellant/ Assessee Respondent /Revenue Assessee By Shri Sudin Sabnis & Shri Siddhesh Khandalkar Revenue By Shri Madhukar Anand-Jcit(Through Virtual) Date Of Hearing 05/01/2026 Date Of Pronouncement 19/01/2026 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(Appeal)[Nfac], Passed Under Section 250 Of The Income Tax Act, 1961 For The A.Y.2020-21 Dated 02.09.2025 Emanating From The Penalty Order Passed Under Section

3. Less: Tax impact on account of other 32,27,62,439 retrospective amendments [e.g section 40(a)(ii) and section 36(1)(va) of Capgemini (other than sr. no. 2) 5 4. Balance MAT Credit brought forward 5,67,32,85,499 ITA No.2753/PUN/2025 [A] 2.2 Ld.AR for the Assessee relied on the following case laws : “i. Copy

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”].

disallowing the assessee’s claim to this effect seeking to carry forward the same to subsequent assessment year(s). He has also taken pains to file a detailed written note summarizing all of the assessee’s arguments regarding the instant issue as follows: “5. Grounds 3 and 4 deal with the AO’s denial of carry forward of loss

ASSISTANT COMMISSIONER OF INCOME-TAX,, KOLHAPUR vs. VIJAYKUMAR RAJARAM SHAH,, KOLHAPUR

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

Bench: Shri D. Karunakara Rao, Am & Shri S. S. Viswanethra Ravi, Jm Sl.

section 14A r.w. Rule 8D(2) of the Rules. For the assessment year 2008-09 too, the Assessing Officer disallowed a sum of Rs.2,87,333/-. The CIT(A) confirmed the same as per the discussion given in para 60 of the order of the CIT(A). In the process, both the Assessing Officer and the CIT(A) ignored

ASSISTANT COMMISSIONER OF INCOME-TAX vs. LAXMI CIVIL ENGINEERING SERVICES PVT. LTD.,, KOLHAPUR

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

Bench: Shri D. Karunakara Rao, Am & Shri S. S. Viswanethra Ravi, Jm Sl.

section 14A r.w. Rule 8D(2) of the Rules. For the assessment year 2008-09 too, the Assessing Officer disallowed a sum of Rs.2,87,333/-. The CIT(A) confirmed the same as per the discussion given in para 60 of the order of the CIT(A). In the process, both the Assessing Officer and the CIT(A) ignored

LAXMI CIVIL ENGINEERING SERVICES PVT. LTD.,,KOLHAPUR vs. ASSISTANT COMMISISONER OF INCOME-TAX,,

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

Bench: Shri D. Karunakara Rao, Am & Shri S. S. Viswanethra Ravi, Jm Sl.

section 14A r.w. Rule 8D(2) of the Rules. For the assessment year 2008-09 too, the Assessing Officer disallowed a sum of Rs.2,87,333/-. The CIT(A) confirmed the same as per the discussion given in para 60 of the order of the CIT(A). In the process, both the Assessing Officer and the CIT(A) ignored

ASSISTANT COMMISSIONER OF INCOME-TAX vs. LAXMI CIVIL ENGINEERING SERVICES PVT. LTD.,, KOLHAPUR

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

Bench: Shri D. Karunakara Rao, Am & Shri S. S. Viswanethra Ravi, Jm Sl.

section 14A r.w. Rule 8D(2) of the Rules. For the assessment year 2008-09 too, the Assessing Officer disallowed a sum of Rs.2,87,333/-. The CIT(A) confirmed the same as per the discussion given in para 60 of the order of the CIT(A). In the process, both the Assessing Officer and the CIT(A) ignored

LAXMI CIVIL ENGINEERING SERVICES PVT. LTD.,,KOLHAPUR vs. ASSISTANT COMMISISONER OF INCOME-TAX,,

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

Bench: Shri D. Karunakara Rao, Am & Shri S. S. Viswanethra Ravi, Jm Sl.

section 14A r.w. Rule 8D(2) of the Rules. For the assessment year 2008-09 too, the Assessing Officer disallowed a sum of Rs.2,87,333/-. The CIT(A) confirmed the same as per the discussion given in para 60 of the order of the CIT(A). In the process, both the Assessing Officer and the CIT(A) ignored

ASSISTANT COMMISSIONER OF INCOME-TAX vs. LAXMI CIVIL ENGINEERING SERVICES PVT. LTD.,, KOLHAPUR

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

Bench: Shri D. Karunakara Rao, Am & Shri S. S. Viswanethra Ravi, Jm Sl.

section 14A r.w. Rule 8D(2) of the Rules. For the assessment year 2008-09 too, the Assessing Officer disallowed a sum of Rs.2,87,333/-. The CIT(A) confirmed the same as per the discussion given in para 60 of the order of the CIT(A). In the process, both the Assessing Officer and the CIT(A) ignored

LAXMI CIVIL ENGINEERING SERVICES PVT. LTD.,,KOLHAPUR vs. ASSISTANT COMMISISONER OF INCOME-TAX,,

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

Bench: Shri D. Karunakara Rao, Am & Shri S. S. Viswanethra Ravi, Jm Sl.

section 14A r.w. Rule 8D(2) of the Rules. For the assessment year 2008-09 too, the Assessing Officer disallowed a sum of Rs.2,87,333/-. The CIT(A) confirmed the same as per the discussion given in para 60 of the order of the CIT(A). In the process, both the Assessing Officer and the CIT(A) ignored

SRL CONSTRUCTION PVT LTD,JALNA vs. ACIT, CENTRAL CIRCLE 2, AURANGABAD, AURANGABAD

In the result, appeal of the assessee is dismissed

Bench: Dr.Dipak P. Ripote & Shri Vinay Bhamoreआयकर अपील सं. / Ita No.847/Pun/2024 िनधा"रण वष" / Assessment Year : 2019-20 Srl Construction Pvt. Ltd., V The Acit, 197, Khasgaon, Jafrabad, S Central Circle-2, Jalna – 444203. Aurangabad. Pan: Aaqcs7227L Appellant/ Assessee Respondent /Revenue Assessee By Shri Prateekjha – Ar Revenue By Shri Ajay Kumar Keshari – Cit(Dr) Date Of Hearing 16/12/2024 Date Of Pronouncement 29/01/2025 आदेश/ Order Per Dr.Dipak P.Ripote, Am : This Is An Appeal Filed By The Assessee Against The Order Of Ld.Principal Commissioner Of Income Tax(Central)-Nagpur, Passed Under Section 263 Of The Income Tax Act, 1961; Dated 08.03.2024 For A.Y.2019-20. The Assessee Has Raised The Following Grounds Of Appeal : “1. A) On The Facts & Circumstance Prevailing In The Case & In Law, Honorable Pr. Cit (Central), Nagpur Has Erred In Not Considering The Submission Made By The Appellant In Fair And

disallow the above amount in view of the provisions of section 40A(3) of the I.T Act, the order dated 30.09.2021 passed by the AO is erroneous and prejudicial to the interest of revenue. ITA No.847/PUN/2024 [A] 4.2 On verification of the Assessment order, it was noticed that there is a discrepancy in the figures of opening WDV, closing

SHARADA ELECTORS PRIVATE LIMITED,PUNE vs. PCIT, PUNE-3, PUNE

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

Bench: Dr.Manish Borad & Shri Vinay Bhamore

3) Notwithstanding anything contained in sub-section (2), an order in revision under this section may be passed at any time in the case of an order which has been passed in consequence of, or to give effect to, any finding or direction contained in an order of the Appellate Tribunal, National Tax Tribunal, the High Court or the Supreme

PUSHPAK STEEL INDUSTRIES PRIVATE LIMITED ,PUNE vs. THE ASSISTANT COMMISSIONER OF INCOME TAX, CIRCLE-10 , PUNE

In the result, appeal of the assessee is Partly Allowed

Bench: Shri S.S.Godara & Dr. Dipak P. Ripoteआयकरअपीलसं. / Ita No.300/Pun/2023 िनधा"रणवष" / Assessment Year :2013-14 Pushpak Steel Industries The Income Tax Officer, Private Limited, V Cricle-10, Pune. Gat No.119, Alandi Markal S Road, Alandi Markal Road,Vill-Dhanore, Pune – 412105. Pan: Aabcp 0081 C Assessee / Appellant Respondent / Revenue Assessee By Shri Sarvesh Khandelwal – Ar Revenue By Shri M.G.Jasnani – Dr Date Of Hearing 16/05/2023 Date Of Pronouncement 27/06/2023 आदेश/ Order Per Dr. Dipak P. Ripote, Am: This Appeal Filed By The Assessee Is Directed Against The Order Of Ld.Commissioner Of Income Tax(Appeal)-11, Pune Dated 27.01.2023 For A.Y.2013-14 Emanating From The Order Under Section 143(3) Of The Act, Dated 13.12.2016. The Assessee Has Raised The Following Grounds Of Appeal: “1. On The Facts & Circumstances Prevailing In The Case & As Per The Provisions & The Scheme Of The Act It Be Held That The Pushpak Steel Industries Pvt. Ltd., [A]

3. Similarly, regarding 14A disallowance ld.CIT(A) allowed the appeal of the assessee for Rs.14,11,830/- which was disallowance made by the AO under Rule 8D(2)(ii). The ld.CIT(A) sustained the addition under Rule 8D(2)(iii) of Rs.1,21,498/-. Aggrieved by the order of the ld.CIT(A), the assessee filed appeal before this Tribunal. Submission