NITIN DWARKADAS NYATI,PUNE vs. ASSISTANT COMMISSIONER OF INCOME TAX, PUNE

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

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

144B of the Act on 20.09.2022 assessing the total income at Rs.40,41,76,243/- after making addition of Rs.3,05,36,389/- on account of disallowance u/s 14A of the Act and Rs.50,79,854/- on account of education cess. 3. So far as the disallowance of Rs.3,05,36,389/- u/s 14A read with Rule

SPRINGER NATURE TECHNOLOGY AND PUBLISHING SOLUTIONS PRIVATE LIMITED,PUNE vs. THE ASSESSMENT UNIT, INCOME TAX DEPARTMENT AND THE DEPUTY COMMISSIONER OF INCOME-TAX, CIRCLE 5, PUNE, PUNE

In the result, both the appeals of the assessee are allowed for statistical purposes

Bench: Dr.Manish Borad & Shri Vinay Bhamore

section 144B of the Income- tax Act, 1961 ('Act') by the Assessment Unit, Income Tax Department ('learned AO') for the aforesaid assessment year on the following amongst other grounds: 1. The order passed by the learned AO is ultra vires, illegal, bad in law and contrary to the provisions of the Act. Disallowance

SPRINGER NATURE TECHNOLOGY AND PUBLISHING SOLUTIONS PRIVATE LIMITED,PUNE vs. THE DEPUTY COMMISSIONER OF INCOME-TAX, CIRCLE 5, PUNE, PUNE

In the result, both the appeals of the assessee are allowed for statistical purposes

Bench: Dr.Manish Borad & Shri Vinay Bhamore

section 144B of the Income- tax Act, 1961 ('Act') by the Assessment Unit, Income Tax Department ('learned AO') for the aforesaid assessment year on the following amongst other grounds: 1. The order passed by the learned AO is ultra vires, illegal, bad in law and contrary to the provisions of the Act. Disallowance

DHANLAXMI MAHILA GRAMIN BIGARSHETI SAHAKARI PATSANSTHA LIMITED,PUNE vs. PCIT-1, PUNE

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

Bench: Shri Rama Kanta Panda, Vice- & Ms. Astha Chandra

144B of the Act is erroneous and prejudicial to the interests of revenue. Thus, both the conditions specified under section 263 of the Act are satisfied in this case and it is a fit case to invoke provisions of the said section. In view of the above, the assessment order dated 20/09/2022 for the A.Y. 2020-21 is hereby

FCA INDIA AUTOMOBILES PRIVATE LIMITED (SURVIVING ENTITY AFTER THE MERGER OF PCA MOTORS PVT LTD),PUNE vs. ASSESSMENT UNIT, INCOME TAX DEPARTMENT, NATIONAL FACELESS ASSESSMENT CENTRE

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

Bench: SHRI MANISH BORAD (Accountant Member), SHRI VINAY BHAMORE (Judicial Member)

section 143(3) r.w.s. 144B was passed by the AO on 26 4 September 2022. In the assessment order, the AO assessed the total income of the assessee at Rs.23,96,58,331/- and raised a tax demand of Rs.44,65,790/- on the assessee after disallowance

MRS NEHA VITTHAL DIMBLE,PUNE vs. ITO, WARD-3(3), PUNE, PUNE

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

disallowances in\nassessee's case since the financial transactions which are subject matter\nof addition, belonged to assessee's husband Mr. Vitthal Dimble. In his\ncase, the AO has already made the similar additions. So, the prayer is to\ndelete the same in assessee's case.\n4. The learned CIT Appeals has erred in dismissing assessee's appeal\nwithout affording

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

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, ITA No.1962/PUN/2024 [A] dated 10.06.2024. The Assessee has raised the following grounds of appeal : “A. Transfer Pricing Issues 1. On the facts and in the circumstances of the case

SUDHAKAR BAJIRAO SHISODE,NASHIK vs. INCOME TAX OFFICER, NASHIK

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

Bench: Dr.Manish Borad & Shri Vinay Bhamoreआयकर अपील सं. / Ita No.2780/Pun/2025 Assessment Year : 2018-19

section 144B (DIN-ITBA/AST/S/147/2022-23/1051275777(1) Dated 24/03/2023. The Assessing Officer completed the reassessment making the following additions: (a) Disallowance

DCIT, CIRCLE 8 PUNE, PUNE vs. ALFA LAVAL INDIA PVT LTD, PUNE

In the result, the appeal filed by the Revenue is dismissed

disallowances related to Section 40(a)(ia) and ICDS adjustments were also correctly deleted.", "result": "Dismissed", "sections": [ "143(1)", "143(2)", "142(1)", "92CA(3)", "143(3)", "144C(3)", "144B

ANANDA GORAKHANATH PAWAR,SATARA vs. ASSESSING OFFICER, WARD 3, SATARA, SATARA

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

Bench: Shri R. K. Panda & Shri Vinay Bhamoreआयकर अपील सं. / Ita No.1796/Pun/2025 िनधा"रण वष" / Assessment Year : 2018-19 Ananda Gorakhanath Pawar, Vs. Ito, Ward-3, Satara. At Post Ambawade, Khatav, Satara- 415506. Pan : Blhpp6081R Appellant Respondent Assessee By Shri R. C. Doshi : Revenue By : Shri Milind Debaje Date Of Hearing : 28.08.2025 Date Of Pronouncement : 28.08.2025 आदेश / Order Per Vinay Bhamore, Jm: This Appeal Filed By The Assessee Is Directed Against The Order Dated 30.06.2025 Passed By Ld. Cit(A)/Nfac For The Assessment Year 2018-19. 2. The Appellant Has Filed The Following Grounds Of Appeal :- “1. The Learned Cit Has Erred Both On Facts & In Law In Dismissing The Appeal Of The Appellant By Refusing To Condone The Delay Of 26 Days On Grounds Of Period Of Limitation, Notwithstanding The Fact That Appellant Has Submitted The Application & Explained The Reasons For Delay.

section 144B while passing the final assessment order and by not issuing show cause notice before making following addition / disallowance

BMC SOFTWARE INDIA PRIVATE LIMITED,PUNE vs. DEPUTY COMMISSIONER OF INCOME-TAX CIRCLE-1(1), PUNE

The appeal is dismissed as not pressed

Bench: Shri R.S. Syal & Shri Partha Sarathi Chaudhury

section 144B of the Act. 12. Non-consideration of adjustment for differences on account of functional and risk profile of comparable companies vis-a-vis the Appellant Erred in comparing full-fledged risk bearing entities with the Appellant's captive operations without making any risk adjustment for differences between the functional and risk profile of comparable companies

MAHATMA PHULE GRAMIN BIGARSHETI SAHAKAR PAT SANSTHA LTD,KOLHAPUR vs. PCIT-1, PUNE, PUNE

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

Bench: Shri R. K. Panda & Ms. Astha Chandraassessment Year : 2018-19 Mahatma Phule Gramin Bigarsheti Pcit-1, Pune Sahakar Pat Sanstha Vs. A/P Hattiwade, Ajara, Kolhapur – 416505 Pan: Aaaam2608K (Appellant) (Respondent) Assessee By : None (Written Submission Filed) Department By : Shri Amol Khairnar, Cit-Dr Date Of Hearing : 09-12-2025 Date Of Pronouncement : 09-01-2026 O R D E R

disallowance of deduction under section 80P, without appreciating that compliance under section 80AC is not mandatory and it is discretionary and further, by implication, AO had accepted one of the views in case of debatable issue. 3. The assessee craves leave to amend, alter or delete any of the above grounds of appeal. It is prayed that the above claims

M/S PERSISTENT SYSTEMS LIMITED,PUNE vs. ASSESSMENT UNIT, INCOME-TAX DEPARTMENT, PUNE

In the result, appeal of the Assessee is Partly Allowed

Bench: Shri S.S.Godara & Dr. Dipak P. Ripoteआयकरअपीलसं. / Ita No.692/Pun/2022 िनधा"रणवष" / Assessment Year : 2018-19 M/S.Persistent Systems Assessment Unit, Income Limited, V Tax Department. “Bhageerath” 402, Senapati S Bapat Road, Pune – 411016. Pan: Aabcp 1209 Q Appellant/ Assessee Respondent /Revenue Assessee By Shri Dhanesh Bafna& Shriaditya Vaidya– Ar’S Revenue By Shri Suhas Kulkarni - Irs Addl Commissioner Of Income Tax Date Of Hearing 26/09/2023 Date Of Pronouncement 02/11/2023 आदेश/ Order Per Dr. Dipak P. Ripote, Am: This Appeal Filed By The Assessee Is Directed Against The Assessment Order, Dated 20.07.2022 Under Section 143(3) R.W.S. 144C(13) Read With Section 144B Of The Income Tax Act, 1961 For A.Y.2018-19. The Assessee Has Raised The Following Grounds Of Appeal: “Ground 1: Order Is Invalid / Non Est  On The Facts & In The Circumstances Of The Case & In Law, The Assessment Unit (‘Au’) Has Erred In Passing The Draft Assessment M/S.Persistent Systems Limited [A]

144B of the Income Tax Act, 1961 (‘the Act’) with regard to granting an opportunity for personal hearing via video conference and without providing an opportunity to the Appellant to file a written submission in response to the Show-cause notice. Dispute Resolution Panel (‘Ld. DRP’) erred in upholding the same by contending that there was no denial of opportunity

KAMAL NAGARI SAHAKARI PATSANSTHA LTD.,ALIBAG vs. ITO, WARD-3, PANVEL, PANVEL

In the result, the appeal filed by the assessee is treated as allowed for statistical purposes

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

section 144B of the Act on 09.04.2023 disallowing the deduction claimed u/s 80P(2)(d) at Rs. 1,33,53,021/- . 4. Aggrieved

KAMAL NAGARI SAHAKARI PATSANSTHA LTD.,RAIGAD vs. ITO WARD-3, PANVEL, PANVEL

In the result, the appeal filed by the assessee is treated as allowed for statistical purposes

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

section 144B of the Act on 09.04.2023 disallowing the deduction claimed u/s 80P(2)(d) at Rs. 1,33,53,021/- . 4. Aggrieved

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

144B of the Income Tax Act, 1961 (hereinafter referred to as ‘the Act’) relating to assessment year 2020-21. 2. Facts of the case, in brief, are that the assessee, Liquidhub Analytics Pvt. Ltd. is a company and has an undertaking located in Special Economic Zone (SEZ) at Gurugram where it is engaged in the business of software development

ARISTON GROUP INDIA PRIVATE LIMITED,PUNE vs. THE ASSESSEMENT UNIT, INCOME TAX DEPARTMENT, NFAC AND THE DCIT, CIRCLE 1(1), PUNE, PUNE

In the result, appeal of the assessee is partly allowed

Bench: Shri R.K.Panda & Shri Vinay Bhamoreआयकर अपील सं. / Ita No.1680/Pun/2024 िनधा"रण वष" / Assessment Year: 2020-21 Ariston Group India Private The Assessment Unit, Limited, Income Tax Department, 1St Floor, Office No.103, V National Faceless Mayfai Tower, Wakdewadi, S. Assessment Centre, Shivaji Nagar, Pune-411005. Delhi(“Nfac”), The Dcit, Circle-1(1), Pune. Pan: Aaoca7042D Appellant/ Assessee Respondent / Revenue Assessee By Shri Ketan Ved – Ar Revenue By Shri Prakash L Pathade – Cit(Dr) Date Of Hearing 15/01/2025 Date Of Pronouncement 09/04/2025 आदेश/ Order Per Vinay Bhamore, Jm: This Is An Appeal Filed By The Assessee Against The Assessment Order Passed Under Section 143(3) R.W.S 144C(3) Read With Section 144B Of The Income Tax Act, 1961, Dated 18.06.2024 For A.Y.2020- 21. The Assessee Has Raised The Following Grounds Of Appeal : “Based On The Facts & Circumstances Of The Case, Ariston Group India Private Limited (Hereinafter Referred To As "Ariston India' Or 'The Appellant) Prefers An Appeal For The Assessment Year 2020-21 Against

144B of the Income Tax Act, 1961, dated 18.06.2024 for A.Y.2020- 21. The Assessee has raised the following grounds of appeal : “Based on the facts and circumstances of the case, Ariston Group India Private Limited (hereinafter referred to as "Ariston India' or 'the Appellant) prefers an appeal for the assessment year 2020-21 against ITA No.1680/PUN/2024 [A] the order dated

SHRI LAXMI V K S (VIKAS) SEVA SANSTHA MARYADIT BASARGE BK,KOLHAPUR vs. ITO ASSESSMENT UNIT ITD, KOLHAPUR

In the result, the appeal is allowed for statistical purposes

Bench: Shri Manish Borad & Shri Vinay Bhamoreआयकर अपील सं. / Ita No.489/Pun/2025 निर्धारण वर्ा / Assessment Year : 2015-16 Shri Laxmi Vks (Vikas) Vs. Ito, Assessment Unit, Seva Sanstha Maryadi Income Tax Department. Basarge Bk, At Basarge, Tal. Gadhinglaj, Dist. Kolhapur- 416506. Pan : Aakas3603C Appellant Respondent

disallowed the claim of deduction under section 80 P, in the light of provisions of section 80 A(5) of the IT act, since the return filed by the assesse was treated as non est. The assessing officer completed the assessment under section 144/147 rws 144B

CAPGEMINI TECHNOLOGY SERVICES INDIA LIMITED ( SUCCESSOR OF ARICENT TECHNOLOGIES HOLDINGS LIMITED),PUNE vs. ASSISTANT COMMISSIONER OF INCOME TAX, CIRCLE 1(1), PUNE, PUNE

In the result, the appeal of the assessee is allowed

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

144B of 16 ITA No.1260/PUN/2025, AY 2020-21 the Act on 16.9.2022 with a total income of Rs.128,25,28,401/- by making two disallowances in the assessment order viz. (a) disallowance of employee‘s share of provident contribution u/s 36(1)(va) of the Act amounting to Rs.16,61,049/- and (b) disallowance of education cess claimed as deduction