SINHGAD TECHNICAL EDUCATION SOCIETY,,PUNE vs. ASSISTANT COMMISSIONER OF INCOME-TAX,,

Accordingly, additional ground No.3 by the assessee is allowed

Bench: Ms. Sushma Chowla, Jm & Shri Anil Chaturvedi, Am आयकर अपील सं. / Ita Nos. 2075 To 2077 & 2110/Pun/2014 "नधा"रण वष" / Assessment Years: 2007-08 To 2009-10 Sinhgad Technical Education Society, S. No. 44/1, Vadgaon ( Budruk), Off. Sinhagad Road, Pune-411 041. Pan : Aabts9900Q. …....अपीलाथ" / Appellant बनाम / V/S.

8,00,000/- It is seen that the trustees of STES are trustees in two of these trusts viz. Savitribai Phule Shikshan prasarak mandal and Shrinath Shikshan prasarak mandal. Hence it is obviously a case where there is violation of section 13(1)(c). 46. The Assessing Officer had disallowed

SINHGAD TECHNICAL EDUCATION SOCIETY,,PUNE vs. DEPUTY COMMISSIONER OF INCOME-TAX,,

Accordingly, additional ground No.3 by the assessee is allowed

Bench: Ms. Sushma Chowla, Jm & Shri Anil Chaturvedi, Am आयकर अपील सं. / Ita Nos. 2075 To 2077 & 2110/Pun/2014 "नधा"रण वष" / Assessment Years: 2007-08 To 2009-10 Sinhgad Technical Education Society, S. No. 44/1, Vadgaon ( Budruk), Off. Sinhagad Road, Pune-411 041. Pan : Aabts9900Q. …....अपीलाथ" / Appellant बनाम / V/S.

8,00,000/- It is seen that the trustees of STES are trustees in two of these trusts viz. Savitribai Phule Shikshan prasarak mandal and Shrinath Shikshan prasarak mandal. Hence it is obviously a case where there is violation of section 13(1)(c). 46. The Assessing Officer had disallowed

ASSISTANT COMMISSIONER OF INCOME-TAX vs. SINHAGAD TECHNICAL EDUCATION SOCIETY,, PUNE

Accordingly, additional ground No.3 by the assessee is allowed

Bench: Ms. Sushma Chowla, Jm & Shri Anil Chaturvedi, Am आयकर अपील सं. / Ita Nos. 2075 To 2077 & 2110/Pun/2014 "नधा"रण वष" / Assessment Years: 2007-08 To 2009-10 Sinhgad Technical Education Society, S. No. 44/1, Vadgaon ( Budruk), Off. Sinhagad Road, Pune-411 041. Pan : Aabts9900Q. …....अपीलाथ" / Appellant बनाम / V/S.

8,00,000/- It is seen that the trustees of STES are trustees in two of these trusts viz. Savitribai Phule Shikshan prasarak mandal and Shrinath Shikshan prasarak mandal. Hence it is obviously a case where there is violation of section 13(1)(c). 46. The Assessing Officer had disallowed

ASSISTANT COMMISSIONER OF INCOME-TAX vs. SINHAGAD TECHNICAL EDUCATION SOCIETY,, PUNE

Accordingly, additional ground No.3 by the assessee is allowed

Bench: Ms. Sushma Chowla, Jm & Shri Anil Chaturvedi, Am आयकर अपील सं. / Ita Nos. 2075 To 2077 & 2110/Pun/2014 "नधा"रण वष" / Assessment Years: 2007-08 To 2009-10 Sinhgad Technical Education Society, S. No. 44/1, Vadgaon ( Budruk), Off. Sinhagad Road, Pune-411 041. Pan : Aabts9900Q. …....अपीलाथ" / Appellant बनाम / V/S.

8,00,000/- It is seen that the trustees of STES are trustees in two of these trusts viz. Savitribai Phule Shikshan prasarak mandal and Shrinath Shikshan prasarak mandal. Hence it is obviously a case where there is violation of section 13(1)(c). 46. The Assessing Officer had disallowed

SINHGAD TECHNICAL EDUCATION SOCIETY,,PUNE vs. DEPUTY COMMISSIONER OF INCOME-TAX,,

Accordingly, additional ground No.3 by the assessee is allowed

Bench: Ms. Sushma Chowla, Jm & Shri Anil Chaturvedi, Am आयकर अपील सं. / Ita Nos. 2075 To 2077 & 2110/Pun/2014 "नधा"रण वष" / Assessment Years: 2007-08 To 2009-10 Sinhgad Technical Education Society, S. No. 44/1, Vadgaon ( Budruk), Off. Sinhagad Road, Pune-411 041. Pan : Aabts9900Q. …....अपीलाथ" / Appellant बनाम / V/S.

8,00,000/- It is seen that the trustees of STES are trustees in two of these trusts viz. Savitribai Phule Shikshan prasarak mandal and Shrinath Shikshan prasarak mandal. Hence it is obviously a case where there is violation of section 13(1)(c). 46. The Assessing Officer had disallowed

BHANSILAL RAMNATH AGARWAL CHARITABLE TRUST vs. DEPUTY COMMISSIONER OF INCOME-TAX,,

In the result, both the appeals of the assessee are partly allowed

Bench: Shri D.Karunakara Rao, Am & Shri Vikas Awasthy, Jm आयकर आयकर अपील आयकर आयकर अपील अपील संसंसंसं. / Ita Nos.1147, 1133, 1134 & 1136/Pun/2016 अपील िनधा"रण िनधा"रण वष" िनधा"रण िनधा"रण वष" वष" / Assessment Years : 2007-08 To 2009-10 & 2011-12 वष"

section 11 to 13 and hence, the ld. CIT(A) should have directed the ld. A.O. to grant the exemption u/s.11 to the assessee trust. 3. The learned CIT(A) erred in confirming the disallowance u/s.36(i)(va) of Rs.1,64,980/- without appreciating that the assessee trust was entitled to claim exemption u/s.11 and hence, no disallowance could

BHANSILAL RAMNATH AGARWAL CHARITABLE TRUST vs. DEPUTY COMMISSIONER OF INCOME-TAX,,

In the result, both the appeals of the assessee are partly allowed

Bench: Shri D.Karunakara Rao, Am & Shri Vikas Awasthy, Jm आयकर आयकर अपील आयकर आयकर अपील अपील संसंसंसं. / Ita Nos.1147, 1133, 1134 & 1136/Pun/2016 अपील िनधा"रण िनधा"रण वष" िनधा"रण िनधा"रण वष" वष" / Assessment Years : 2007-08 To 2009-10 & 2011-12 वष"

section 11 to 13 and hence, the ld. CIT(A) should have directed the ld. A.O. to grant the exemption u/s.11 to the assessee trust. 3. The learned CIT(A) erred in confirming the disallowance u/s.36(i)(va) of Rs.1,64,980/- without appreciating that the assessee trust was entitled to claim exemption u/s.11 and hence, no disallowance could

BHANSILAL RAMNATH AGARWAL CHARITABLE TRUST vs. DEPUTY COMMISSIONER OF INCOME-TAX,,

In the result, both the appeals of the assessee are partly allowed

Bench: Shri D.Karunakara Rao, Am & Shri Vikas Awasthy, Jm आयकर आयकर अपील आयकर आयकर अपील अपील संसंसंसं. / Ita Nos.1147, 1133, 1134 & 1136/Pun/2016 अपील िनधा"रण िनधा"रण वष" िनधा"रण िनधा"रण वष" वष" / Assessment Years : 2007-08 To 2009-10 & 2011-12 वष"

section 11 to 13 and hence, the ld. CIT(A) should have directed the ld. A.O. to grant the exemption u/s.11 to the assessee trust. 3. The learned CIT(A) erred in confirming the disallowance u/s.36(i)(va) of Rs.1,64,980/- without appreciating that the assessee trust was entitled to claim exemption u/s.11 and hence, no disallowance could

BIZ SECURE LABS PVT.LTD,,PUNE vs. DEPUTY COMMISSIONER OF INCOME-TAX, CIRCLE - 1(1),, PUNE

In the result, the appeal of the Revenue is dismissed and that

Bench: Shri R.S. Syal & Shri Sonjoy Sarma"नधा"रण वष" / Assessment Year : 2012-13 Biz Secure Labs Pvt. Ltd., Vs. Dcit, 1206, Sadashiv Peth, Circle- 1(1), Pune 411 030 Pune Pan : Aadcb6188L Appellant Respondent

disallowance of the excess deduction u/s 80IC at this level. Though, the AO had initially referred to sub-section (10) of section 80IA, but later on left it from consideration, which was a right decision, since the sub-section (10) has no application to the facts of the case. During the course of the first appellate proceedings, the assessee raised

BIZ SECURE LABS PRIVATE LIMITED,,PUNE vs. DEPUTY COMMISSIONER OF INCOME TAX,, PUNE

In the result, the appeal of the Revenue is dismissed and that

Bench: Shri R.S. Syal & Shri Sonjoy Sarma"नधा"रण वष" / Assessment Year : 2012-13 Biz Secure Labs Pvt. Ltd., Vs. Dcit, 1206, Sadashiv Peth, Circle- 1(1), Pune 411 030 Pune Pan : Aadcb6188L Appellant Respondent

disallowance of the excess deduction u/s 80IC at this level. Though, the AO had initially referred to sub-section (10) of section 80IA, but later on left it from consideration, which was a right decision, since the sub-section (10) has no application to the facts of the case. During the course of the first appellate proceedings, the assessee raised

DEPUTY COMMISSIONER OF INCOME-TAX, CIRCLE - 1(1),, PUNE vs. BIZ SECURE LABS PVT.LTD,, PUNE

In the result, the appeal of the Revenue is dismissed and that

Bench: Shri R.S. Syal & Shri Sonjoy Sarma"नधा"रण वष" / Assessment Year : 2012-13 Biz Secure Labs Pvt. Ltd., Vs. Dcit, 1206, Sadashiv Peth, Circle- 1(1), Pune 411 030 Pune Pan : Aadcb6188L Appellant Respondent

disallowance of the excess deduction u/s 80IC at this level. Though, the AO had initially referred to sub-section (10) of section 80IA, but later on left it from consideration, which was a right decision, since the sub-section (10) has no application to the facts of the case. During the course of the first appellate proceedings, the assessee raised

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

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

13 substantive ground are accepted for statistical purposes therefore.” 5. There is hardly any dispute that the CIT(A) has followed various judicial precedents in assessee’s case(s) itself whilst deciding all these three issues of section 80IA(10) deduction section 40(a)(i), TDS deduction disallowance(s) on account of payment of alleged royalty and section 14A read

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

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

13 substantive ground are accepted for statistical purposes therefore.” 5. There is hardly any dispute that the CIT(A) has followed various judicial precedents in assessee’s case(s) itself whilst deciding all these three issues of section 80IA(10) deduction section 40(a)(i), TDS deduction disallowance(s) on account of payment of alleged royalty and section 14A read

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

Appeal is partly allowed in above terms

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

13,89,08,540 against an income of INR 2,40,39,25,580 declared in the return based on the directions received from DRP upholding additions / disallowances made by the AO; Corporate Tax Grounds: 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

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

In the result, the appeal of assessee is partly allowed

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

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

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

13. The ld. AR referred to section 5 of the Payment of Wages Act, 1936, to contend that deduction made from an employee’s salary for the month of October should suffer disallowance only if it is not paid by 15th December. This argument was premised on the language of section 5, which says that the wages of every person

DY. COMMISSIONER OF INCOME TAX (EXEMPTIONS), CIRCLE, PUNE, SWARGATE,PUNE vs. SHRI MUKUND BHAVAN TRUST, PUNE

In the result, the appeal of the Revenue is dismissed

Bench: Shri Manish Borad & Ms. Astha Chandraआयकर अपील सं. / Ita Nos.829 & 827/Pun/2025 धििाारण वर्ा / Assessment Years : 2017-18 & 2018-19 Dy. Commissioner Of Shri Mukund Bhavan Trust, Income Tax (Exemptions), 1105, Ravivar Peth, Pune-411002 Cirlce – Pune Vs. Pan : Aaats5170R अपीलार्थी / Appellant प्रत्यर्थी / Respondent Assesseeby : Shri V.L. Jain Department By : Shri Amol Khairnar Date Of Hearing : 24-07-2025 Date Of 08-10-2025 Pronouncement :

disallowance u/s 11 and 12 as carried out by the Ld. AO is found to be incorrect and the appellant is eligible to be assessed as Trust and not as AOP. Accordingly, Ground 1 and 2 of the appeal are allowed. 4. Dissatisfied, the Revenue is in appeal before the Tribunal raising the following grounds of appeal

DY. COMMISSIONER OF INCOME TAX (EXEMPTIONS), CIRCLE, PUNE, SWARGATE,PUNE vs. SHRI MUKUND BHAVAN TRUST, PUNE

In the result, the appeal of the Revenue is dismissed

Bench: Shri Manish Borad & Ms. Astha Chandraआयकर अपील सं. / Ita Nos.829 & 827/Pun/2025 धििाारण वर्ा / Assessment Years : 2017-18 & 2018-19 Dy. Commissioner Of Shri Mukund Bhavan Trust, Income Tax (Exemptions), 1105, Ravivar Peth, Pune-411002 Cirlce – Pune Vs. Pan : Aaats5170R अपीलार्थी / Appellant प्रत्यर्थी / Respondent Assesseeby : Shri V.L. Jain Department By : Shri Amol Khairnar Date Of Hearing : 24-07-2025 Date Of 08-10-2025 Pronouncement :

disallowance u/s 11 and 12 as carried out by the Ld. AO is found to be incorrect and the appellant is eligible to be assessed as Trust and not as AOP. Accordingly, Ground 1 and 2 of the appeal are allowed. 4. Dissatisfied, the Revenue is in appeal before the Tribunal raising the following grounds of appeal