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

133 TTJ 308) has considered the matter in detail and held that the reduction of eligible profits of an assessee as done by the Assessing Officer by invoking the provisions of section 80- IA(10) read with section 10B(7), in the context of the Transfer Pricing Officer's order is unsustainable. The Tribunal has held that the Assessing Officer

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

133 TTJ 308) has considered the matter in detail and held that the reduction of eligible profits of an assessee as done by the Assessing Officer by invoking the provisions of section 80- IA(10) read with section 10B(7), in the context of the Transfer Pricing Officer's order is unsustainable. The Tribunal has held that the Assessing Officer

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

133 TTJ 308) has considered the matter in detail and held that the reduction of eligible profits of an assessee as done by the Assessing Officer by invoking the provisions of section 80-IA(10) read with section 10B(7), in the context of the Transfer Pricing Officer's order is unsustainable. The Tribunal has held that the Assessing Officer

DEPUTY COMMISSIONER OF INCOME TAX, AURANGABAD vs. RATHI STEEL AND METAL PVT. LTD, JALNA

In the result, the appeal filed by the Revenue is partly allowed for statistical purposes

Bench: Shri R. K. Panda & Ms. Astha Chandraassessment Year : 2021-22 Dcit, Aurangabad Rathi Steel & Metal Pvt. Ltd. Plot No.F12, Addl Midc Area, Phase-Ii, Vs. Jalna – 431203 Pan : Aabcr5546A (Appellant) (Respondent) Assessee By : Shri Anand Partani Department By : Shri Ajay Kumar Keshari - Cit Date Of Hearing : 01-04-2025 Date Of Pronouncement : 27-05-2025 O R D E R

133(6) are not complied. Detailed investigation is already made in this case. The demand for calling the record from GST department is made at the fag end of the assessment proceedings. It is clear that GST department has searched these three persons and investigation is under progress. Moreover GST department has also raided on the assessee in pursuance with

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

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.

133 TTJ 308) has considered the matter in detail and held that the reduction of eligible profits of an assessee as done by the Assessing Officer by invoking the provisions of section 80-IA(10) read with section 10B(7), in the context of the Transfer Pricing Officer's order is unsustainable. The Tribunal has held that the Assessing Officer

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

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.

133 TTJ 308) has considered the matter in detail and held that the reduction of eligible profits of an assessee as done by the Assessing Officer by invoking the provisions of section 80-IA(10) read with section 10B(7), in the context of the Transfer Pricing Officer's order is unsustainable. The Tribunal has held that the Assessing Officer

KEVAL KADU DEORE,,NASHIK vs. DEPUTY COMMISSIONER OF INCOME-TAX,,

Bench: Ms. Sushma Chowla, Jm & Shri Anil Chaturvedi, Am आयकर अपीऱ सं. / Ita No.1997/Pun/2016 यििाारण वषा / Assessment Year : 2010-11 Shri Keval Kadu Deore, Plot No.4, Shiv Parvati Bunglow, Pumping Station Road, अऩीऱाथी/Appellant Nashik – 422013 …. Pan: Adnpd3164C Vs. The Dy. Commissioner Of Income-Tax, …. प्रत्यथी / Respondent Circle 1, Nashik

disallowance made @ 25% of the amount of purchases is very high and the same may be restricted to a reasonable level considering the facts of the case. 3. The issue raised in the present appeal is against addition made on account of purchases made from alleged hawala parties on the basis of information received from Maharashtra Sales Tax Department

BECHAN SURAJBALI KUMBHAR,,NASHIK vs. INCOME-TAX OFFICER,,

In the result, appeal of assessee is allowed

Bench: Ms. Sushma Chowla, Jm & Shri Anil Chaturvedi, Am आयकर अपीऱ सं. / Ita No.2357/Pun/2016 यििाारण वषा / Assessment Year : 2011-12

section 133(6) of the Act from the party who had made the said bogus sales to the assessee. The notices were returned unserved from the addresses furnished as per PAN by the assessee. In the absence of 4 Shri Bechan Surajbali Kumbhar information being received, the Assessing Officer held the total purchases to be bogus and made addition

ANITA SANJAY AGRAWAL,,NASHIK vs. INCOME-TAX OFFICER ,,

In the result, all the appeals of assessee are allowed

Bench: Ms. Sushma Chowla, Jm & Shri D. Karunakara Rao, Am आयकर अपीऱ सं. / Ita Nos.2622 To 2624/Pun/2016 यििाारण वषा / Assessment Years : 2009-10 To 2011-12

section 133(6) of the Act to verify the genuineness of purchases made by the assessee from the said parties. The said notices were returned unserved with postal remark ‘Not Known’ / Unclaimed. Under the said circumstances, the assessee was asked to produce alleged parties for verification along with copies of original bills, transport receipts, octroi receipts, etc. Another opportunity

SHRAWAN KESHAVLAL AGRAWAL HUF,,NASHIK vs. INCOME-TAX OFFICER ,,

In the result, all the appeals of assessee are allowed

Bench: Ms. Sushma Chowla, Jm & Shri D. Karunakara Rao, Am आयकर अपीऱ सं. / Ita Nos.2622 To 2624/Pun/2016 यििाारण वषा / Assessment Years : 2009-10 To 2011-12

section 133(6) of the Act to verify the genuineness of purchases made by the assessee from the said parties. The said notices were returned unserved with postal remark ‘Not Known’ / Unclaimed. Under the said circumstances, the assessee was asked to produce alleged parties for verification along with copies of original bills, transport receipts, octroi receipts, etc. Another opportunity

SHRAWAN KESHAVLAL AGRAWAL HUF,,NASHIK vs. INCOME-TAX OFFICER ,,

In the result, all the appeals of assessee are allowed

Bench: Ms. Sushma Chowla, Jm & Shri D. Karunakara Rao, Am आयकर अपीऱ सं. / Ita Nos.2622 To 2624/Pun/2016 यििाारण वषा / Assessment Years : 2009-10 To 2011-12

section 133(6) of the Act to verify the genuineness of purchases made by the assessee from the said parties. The said notices were returned unserved with postal remark ‘Not Known’ / Unclaimed. Under the said circumstances, the assessee was asked to produce alleged parties for verification along with copies of original bills, transport receipts, octroi receipts, etc. Another opportunity

TRIMURTI FURNANCE PRIVATE LIMITED,,NASHIK vs. INCOME-TAX OFFICER ,, NASHIK

In the result, all the appeals of assessee are allowed

Bench: Ms. Sushma Chowla, Jm & Shri D. Karunakara Rao, Am आयकर अपीऱ सं. / Ita Nos.2622 To 2624/Pun/2016 यििाारण वषा / Assessment Years : 2009-10 To 2011-12

section 133(6) of the Act to verify the genuineness of purchases made by the assessee from the said parties. The said notices were returned unserved with postal remark ‘Not Known’ / Unclaimed. Under the said circumstances, the assessee was asked to produce alleged parties for verification along with copies of original bills, transport receipts, octroi receipts, etc. Another opportunity

TRIMURTI FURNANCE PRIVATE LIMITED,,NASHIK vs. INCOME-TAX OFFICER ,, NASHIK

In the result, all the appeals of assessee are allowed

Bench: Ms. Sushma Chowla, Jm & Shri D. Karunakara Rao, Am आयकर अपीऱ सं. / Ita Nos.2622 To 2624/Pun/2016 यििाारण वषा / Assessment Years : 2009-10 To 2011-12

section 133(6) of the Act to verify the genuineness of purchases made by the assessee from the said parties. The said notices were returned unserved with postal remark ‘Not Known’ / Unclaimed. Under the said circumstances, the assessee was asked to produce alleged parties for verification along with copies of original bills, transport receipts, octroi receipts, etc. Another opportunity

SANJAY SHRAWAN AGRAWAL HUF,,NASHIK vs. DEPUTY COMMISSIONER OF INCOME-TAX,,

In the result, all the appeals of assessee are allowed

Bench: Ms. Sushma Chowla, Jm & Shri D. Karunakara Rao, Am आयकर अपीऱ सं. / Ita Nos.2622 To 2624/Pun/2016 यििाारण वषा / Assessment Years : 2009-10 To 2011-12

section 133(6) of the Act to verify the genuineness of purchases made by the assessee from the said parties. The said notices were returned unserved with postal remark ‘Not Known’ / Unclaimed. Under the said circumstances, the assessee was asked to produce alleged parties for verification along with copies of original bills, transport receipts, octroi receipts, etc. Another opportunity

SHRAWAN KESHAVLAL AGRAWAL HUF,,NASHIK vs. INCOME-TAX OFFICER ,,

In the result, all the appeals of assessee are allowed

Bench: Ms. Sushma Chowla, Jm & Shri D. Karunakara Rao, Am आयकर अपीऱ सं. / Ita Nos.2622 To 2624/Pun/2016 यििाारण वषा / Assessment Years : 2009-10 To 2011-12

section 133(6) of the Act to verify the genuineness of purchases made by the assessee from the said parties. The said notices were returned unserved with postal remark ‘Not Known’ / Unclaimed. Under the said circumstances, the assessee was asked to produce alleged parties for verification along with copies of original bills, transport receipts, octroi receipts, etc. Another opportunity

TRIMURTI FURNANCE PRIVATE LIMITED,,NASHIK vs. INCOME-TAX OFFICER ,, NASHIK

In the result, all the appeals of assessee are allowed

Bench: Ms. Sushma Chowla, Jm & Shri D. Karunakara Rao, Am आयकर अपीऱ सं. / Ita Nos.2622 To 2624/Pun/2016 यििाारण वषा / Assessment Years : 2009-10 To 2011-12

section 133(6) of the Act to verify the genuineness of purchases made by the assessee from the said parties. The said notices were returned unserved with postal remark ‘Not Known’ / Unclaimed. Under the said circumstances, the assessee was asked to produce alleged parties for verification along with copies of original bills, transport receipts, octroi receipts, etc. Another opportunity

ANITA SANJAY AGRAWAL,,NASHIK vs. INCOME-TAX OFFICER ,,

In the result, all the appeals of assessee are allowed

Bench: Ms. Sushma Chowla, Jm & Shri D. Karunakara Rao, Am आयकर अपीऱ सं. / Ita Nos.2622 To 2624/Pun/2016 यििाारण वषा / Assessment Years : 2009-10 To 2011-12

section 133(6) of the Act to verify the genuineness of purchases made by the assessee from the said parties. The said notices were returned unserved with postal remark ‘Not Known’ / Unclaimed. Under the said circumstances, the assessee was asked to produce alleged parties for verification along with copies of original bills, transport receipts, octroi receipts, etc. Another opportunity

SANJAY SHRAWAN AGRAWAL HUF,,NASHIK vs. DEPUTY COMMISSIONER OF INCOME-TAX,,

In the result, all the appeals of assessee are allowed

Bench: Ms. Sushma Chowla, Jm & Shri D. Karunakara Rao, Am आयकर अपीऱ सं. / Ita Nos.2622 To 2624/Pun/2016 यििाारण वषा / Assessment Years : 2009-10 To 2011-12

section 133(6) of the Act to verify the genuineness of purchases made by the assessee from the said parties. The said notices were returned unserved with postal remark ‘Not Known’ / Unclaimed. Under the said circumstances, the assessee was asked to produce alleged parties for verification along with copies of original bills, transport receipts, octroi receipts, etc. Another opportunity

ANITA SANJAY AGRAWAL,,NASHIK vs. INCOME-TAX OFFICER ,,

In the result, all the appeals of assessee are allowed

Bench: Ms. Sushma Chowla, Jm & Shri D. Karunakara Rao, Am आयकर अपीऱ सं. / Ita Nos.2622 To 2624/Pun/2016 यििाारण वषा / Assessment Years : 2009-10 To 2011-12

section 133(6) of the Act to verify the genuineness of purchases made by the assessee from the said parties. The said notices were returned unserved with postal remark ‘Not Known’ / Unclaimed. Under the said circumstances, the assessee was asked to produce alleged parties for verification along with copies of original bills, transport receipts, octroi receipts, etc. Another opportunity