ASSISTANT COMMISSIONER OF INCOME-TAX,CENTRAL CIRCLE - 2(2),, PUNE vs. M/S SINHGAD TECHNICAL EDUCATION SOCIETY (TRUST), PUNE

In the result, the appeal of the Revenue in ITA

Bench: Shri Inturi Rama Rao & Shri S. S. Viswanethra Ravisl. It(Ss)A No./ Name Of Appellant Name Of Respondent Asst. No.

section 13(1)(c) of the Act on account of salary paid to Shri U.Y. Pawar, who was admittedly working for a company like JSAPL as the amount of salary was reimbursed to the appellant society violation had been cured. (G). As regards to the disallowance of prior period expenses, the ld. AR submits that the prior period expenses

SHRI MANOJ MADANLAL CHHAJED,PUNE vs. ASSISTANT COMMISSIONER OF INCOME TAX, CIRCLE -1(1)PUNE, PUNE

In the result, the appeal filed by the assessee in ITA

Bench: Shri Inturi Rama Rao & Shri S. S. Viswanethra Raviआयकर अपील सं. / It(Ss)A Nos.91 To 96/Pun/2022 िनधा"रण वष" / Assessment Years : 2012-13 To 2017-18 Shri Manoj Madanlal Vs. Acit, Central Circle- Chhajed, 1(1), Pune. 601, A-8 Building, Karishma Housing Society, Near Sangam Press, Kothrud, Pune- 411029. Pan : Aalpc4991M Appellant Respondent आयकर अपील सं. / It(Ss)A Nos.97 & 98/Pun/2022 िनधा"रण वष" / Assessment Years : 2012-13 & 2015-16 Acit, Circle-1(1), Pune. Vs. Shri Manoj Madanlal Chhajed, 601, A-8 Building, Karishma Housing Society, Near Sangam Press, Kothrud, Pune- 411029. Pan : Aalpc4991M Appellant Respondent आयकर अपील सं. / Ita No.725/Pun/2022 िनधा"रण वष" / Assessment Year: 2018-19 Shri Manoj Madanlal Vs. Acit, Circle-1(1), Pune. Chhajed, 601, A-8 Building, Karishma Housing Society, Near Sangam Press, Kothrud, Pune- 411029. Pan : Aalpc4991M Appellant Respondent

disallowances, the assessee had filed an appeal before the ld. CIT(A) contenting inter alia that the Assessing Officer ought not to have treated the unsecured loans of Rs.13,27,54,925/- as bogus loans, are merely accommodation entries since the interest was paid on such loans after deducting the TDS and the loans were accepted through the mode

GARWARE TECHNICAL FIBRES LIMITED,PUNE vs. DCIT, CC-1(3), PUNE

sections": [ "139", "132", "153A", "143(2)", "142(1)", "131", "292C", "40A(3)", "69C", "37(1)", "35(2AB)", "65B", "119", "30", "36" ], "issues": "Whether the unrecorded cash receipts found during a search can be treated as income, and if so, whether only the profit element should be taxed, considering the related expenses. Whether the disallowance

GARWARE TECHNICAL FIBRES LIMITED,PUNE vs. DCIT, CC-1(3), PUNE

132 or survey under section 133A, it may, in any proceeding\nunder this Act, be presumed-\n(i) that such books of account, other documents, money, bullion,\njewellery or other valuable article or thing belongs to such person;\n(ii) that the contents of such books of account and other documents\nare true;\"\n3. 9. A plain reading of this

DCIT, CENTRAL CIRCLE- 1(3), PUNE, INCOME TAX, PUNE vs. GARWARE TECHNICAL FIBRES LIMITED, MAHARASHTRA

In the result, all the eight appeals filed by the assessee are partly\nallowed and the only appeal filed by the Revenue is dismissed

132 or survey under section 133A, it may, in any proceeding\nunder this Act, be presumed-\n\n(i)\nthat such books of account, other documents, money, bullion,\njewellery or other valuable article or thing belongs to such person;\n\n(ii)\nthat the contents of such books of account and other documents\nare true;\"\n\n3.9.\nA plain reading

GARWARE TECHNICAL FIBRES LIMITED,PUNE vs. DCIT, CC-1(3), PUNE

In the result, all the eight appeals filed by the assessee are partly allowed and the only appeal filed by the Revenue is dismissed

Bench: Shri Rama Kanta Panda & Ms. Astha Chandra

132 or survey under section 133A, it may, in any proceeding under this Act, be presumed- 8 ITA.Nos.1696 to 1703/PUN./2024 that such books of account, other documents, money, bullion, jewellery or other valuable article or thing belongs to such person; (ii) that the contents of such books of account and other documents are true;” 3.9. A plain reading

GARWARE TECHNICAL FIBRES LIMITED,PUNE vs. DCIT, CC-1(3), PUNE

In the result, all the eight appeals filed by the assessee are partly allowed and the only appeal filed by the Revenue is dismissed

Bench: Shri Rama Kanta Panda & Ms. Astha Chandra

132 or survey under section 133A, it may, in any proceeding under this Act, be presumed- 8 ITA.Nos.1696 to 1703/PUN./2024 that such books of account, other documents, money, bullion, jewellery or other valuable article or thing belongs to such person; (ii) that the contents of such books of account and other documents are true;” 3.9. A plain reading

GARWARE TECHNICAL FIBRES LIMITED,PUNE vs. DCIT, CC-1(3), PUNE

In the result, all the eight appeals filed by the assessee are partly allowed and the only appeal filed by the Revenue is dismissed

Bench: Shri Rama Kanta Panda & Ms. Astha Chandra

132 or survey under section 133A, it may, in any proceeding under this Act, be presumed- 8 ITA.Nos.1696 to 1703/PUN./2024 that such books of account, other documents, money, bullion, jewellery or other valuable article or thing belongs to such person; (ii) that the contents of such books of account and other documents are true;” 3.9. A plain reading

GARWARE TECHNICAL FIBRES LIMITED,PUNE vs. DCIT, CC-1(3), PUNE

In the result, all the eight appeals filed by the assessee are partly allowed and the only appeal filed by the Revenue is dismissed

Bench: Shri Rama Kanta Panda & Ms. Astha Chandra

132 or survey under section 133A, it may, in any proceeding under this Act, be presumed- 8 ITA.Nos.1696 to 1703/PUN./2024 that such books of account, other documents, money, bullion, jewellery or other valuable article or thing belongs to such person; (ii) that the contents of such books of account and other documents are true;” 3.9. A plain reading

GARWARE TECHNICAL FIBRES LIMITED,PUNE vs. DCIT, CC-1(3), PUNE

In the result, all the eight appeals filed by the assessee are partly allowed and the only appeal filed by the Revenue is dismissed

Bench: Shri Rama Kanta Panda & Ms. Astha Chandra

132 or survey under section 133A, it may, in any proceeding under this Act, be presumed- 8 ITA.Nos.1696 to 1703/PUN./2024 that such books of account, other documents, money, bullion, jewellery or other valuable article or thing belongs to such person; (ii) that the contents of such books of account and other documents are true;” 3.9. A plain reading

GARWARE TECHNICAL FIBRES LIMITED,PUNE vs. DCIT, CC-1(3), PUNE

In the result, all the eight appeals filed by the assessee are partly\nallowed and the only appeal filed by the Revenue is dismissed

132 or survey under section 133A, it may, in any proceeding\nunder this Act, be presumed-\n(i)\nthat such books of account, other documents, money, bullion,\njewellery or other valuable article or thing belongs to such person;\n(ii)\nthat the contents of such books of account and other documents\nare true;\"\n3. 9. A plain reading of this

RAJDEEP BUILDCON PRIVAT LIMITED, AHMEDNAGAR,AHMEDNAGAR vs. DY. COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE 1(2), PUNE, PUNE

In the result, the appeal filed by the assessee in ITA

Bench: SHRI R. K. PANDA (Vice President), SHRI VINAY BHAMORE (Judicial Member)

132 of the IT Act. It voluntarily disallowed an amount of Rs.68,86,771/- u/s 14A but this disallowance was not made by the assessee in the above return and this was not accepted by the Assessing Officer in the light of the fact that when the Assessing Officer is not free to make any addition in the absence

RAJDEEP BUILDCOM PRIVATE LIMITED,AHMEDNAGAR vs. DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE - 1(2), PUNE, PUNE

In the result, the appeal filed by the assessee in ITA

Bench: SHRI R. K. PANDA (Vice President), SHRI VINAY BHAMORE (Judicial Member)

132 of the IT Act. It voluntarily disallowed an amount of Rs.68,86,771/- u/s 14A but this disallowance was not made by the assessee in the above return and this was not accepted by the Assessing Officer in the light of the fact that when the Assessing Officer is not free to make any addition in the absence

RAJDEEP BUILDCON PVT LTD, AHMEDNAGAR,AHMEDNAGAR vs. DY. COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE 1(2), PUNE, PUNE

In the result, the appeal filed by the assessee in ITA

Bench: SHRI R. K. PANDA (Vice President), SHRI VINAY BHAMORE (Judicial Member)

132 of the IT Act. It voluntarily disallowed an amount of Rs.68,86,771/- u/s 14A but this disallowance was not made by the assessee in the above return and this was not accepted by the Assessing Officer in the light of the fact that when the Assessing Officer is not free to make any addition in the absence

DY COMMISSIONER OF INCOME TAX, SATARA vs. KAY BOUVET ENGINEERING LIMITED, SATARA

In the result, both the appeals filed by the Revenue and both the COs filed\nby the assessee are dismissed

disallowed merely on the information received from sales tax department that\nassessee was beneficiary of accommodation entries on account of bogus purchases\nwithout carrying out independent enquiry and bringing on record tangible material to\nconclusively establish the fact that purchases were bogus. Merely relying upon\ninformation from Sales Tax Department or fact that parties were not produced,\nAssessing Officer could

HETAL RAKESH MEHTA ,MUMBAI vs. ACIT, CC-1(2), PUNE

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

Bench: Shri R. K. Panda & Ms. Astha Chandraassessment Year : 2018-19 Hetal Rakesh Mehta Acit, Central Circle 1(2), 9/10, Vidya Nagar, 60 Feet Road, Vs. Pune Ghatkopar East, Mumbai – 400077 Pan: Ammpm9670L (Appellant) (Respondent)

disallowed by holding the same as bogus purchases. The A.O. has also held that the amount paid by BVG India Ltd. to the appellant as sale consideration was received back in the form of cash which was utilized by M/s. BVG India Ltd. elsewhere. It may also be mentioned that the appeal filed by M/s. BVG India Ltd. has been

DEPUTY COMMISSIONER OF INCOME, AURANGABAD vs. METAROLLS ISPAT PVT. LTD, JALNA

In the result, both the appeals filed by the Revenue are partly allowed

disallow the purchases.\n14. We have heard the rival arguments made by both the sides, perused the\norders of the Assessing Officer and Ld. CIT(A) and the paper book filed by both\nsides. We have also considered the various decisions cited before us by both sides.\nWe find the Assessing Officer in the instant case made addition of\nRs.11

DEPUTY COMMISSIONER OF INCOME TAX, AURANGABAD vs. METAROLLS ISPAT PVT. LTD., JALNA

In the result, both the appeals filed by the Revenue are partly allowed

Bench: Shri R. K. Panda & Ms. Astha Chandraassessment Year : 2020-21

disallow the purchases. 14. We have heard the rival arguments made by both the sides, perused the orders of the Assessing Officer and Ld. CIT(A) and the paper book filed by both sides. We have also considered the various decisions cited before us by both sides. We find the Assessing Officer in the instant case made addition of Rs.11

LIQUIDHUB ANALYTICS PVT. LTD. (NOW MERGED WITH CAPGEMINI TECHNOLOGY SERVICES INDIA LTD),PUNE vs. NFAC, PUNE

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

Bench: Shri R. K. Panda & Shri Vinay Bhamoreassessment Year : 2020-21

disallowance under section 36(1)(va) of the Act 13 The Ld. AO erred in initiating penalty proceedings under Section 270A of the Act on arbitrary premise that there is under-reporting of income done by the Appellant The above grounds are without prejudice to each other The appellant craves leave to alter, amend or withdraw