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

144C(13) read with section 1448 of the Income-tax Act, 1961 ["hereinafter referred to as "the Act'] on the following grounds which are independent of and without prejudice to each other. Grounds on Transfer Pricing issue 1. General Ground: Transfer pricing adjustment of INR 6,53,65,772/- 1.1 The Ld. AO/ Transfer Pricing Officer (TPO) pursuant

CAPGEMINI TECHNOLOGY SERVICES INDIA LIMITED,PUNE vs. ASSISTANT COMMISSIONER OF INCOME TAX, PUNE

sections": [ "263", "143(3)", "135", "37(1)", "142(1)", "80G", "80G(5)", "80G(1)", "37", "30", "36", "144C(13)", "143(2)", "115JB", "115JJB" ], "issues": "Whether CSR expenditure, even if disallowed

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

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, 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

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 of health and education cess, challenged the validity of assessment being made on a non-existing entity. The relevant ground before the DRP reads as under: “1.3 The Assesses company has ceased to exist pursuant to the merger with Capgemini Technology Services India Limited w.e.f. 1st April, 2020, duly approved by National Company Law Tribunal ('NCLT') order dated

M/S. PIAGGIO VEHICLES PVT.LTD,,PUNE vs. ASSISTANT COMMISSIONER OF INCOME-TAX, CIRCLE - 4,, PUNE

In the result, appeal of the assessee is dismissed

Bench: Dr.Dipak P. Ripote & Shri Vinay Bhamoreआयकर अपील सं. / Ita No.868/Pun/2022 िनधा"रण वष" / Assessment Year: 2015-16 Piaggio Vehicles Private Ltd., V The Assistant Sky One Corporate Park, S Commissioner Of Income Ground Floor, Survey Tax, Circle-4, Pune. No.239/02, Near Pune Airport, Pune – 411032. Pan: Aabcp1225G Appellant/ Assessee Respondent / Revenue Assessee By Shri Siddhesh Chaugule – Ar Revenue By Shri Vidya Ratan - Dr Date Of Hearing 18/12/2024 Date Of Pronouncement 23/12/2024 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(Appeals)-13, Pune For Assessment Year 2015-16 Dated 06.10.2022 Passed Under Section 250 Of The Income Tax Act, 1961. The Assessee Has Raised The Following Grounds Of Appeal : “1. Refund Of Excess Taxes Paid On Dividend Distributed On The Facts & Circumstances Of The Case & In Law, The Hon'Ble Cit(A) Has Erred In Not Granting The Benefit Of Article 11 Of The India-

disallowance of expenditure under section 14A of the Act. These 4 decisions, therefore, limited their observations to the applicability of section 14A of the Act on dividend income. Also, the G&B HC decision and the G&B SC decision have not laid down any principle contrary to those laid down by the Hon'ble SC in Tata Tea decision

DCIT, SWARGATE PUNE vs. CUMMINS INDIA LTD , PUNE

In the result, appeal of the assessee bearing ITA No

Disallowances u/s.14A r.w.s.\n47,55,629/-\nliii\nAssessed Book Profit\n820,03,81,663/-\n13.2 Since, the tax liability u/s.115JB of the I.T. Act, 1961 of the assessee\ncompany will come less than the tax on regular income, the tax liability of the\nassessee company is worked out under normal provisions of Income.\n14. Assessed u/s 143(3) r.w.s 144C

CUMMINS INDIA LIMITED,,PUNE vs. ASSISTANT COMMISSIONER OF INCOME-TAX, CIRCLE - 1(1),, PUNE

In the result, appeal of the assessee bearing ITA No

144C(13) read\nwith section 1448 of the Act, by the learned additional/ Joint/\nDeputy/Assistant Commissioner of Income tax, National Faceless\nAssessment Centre, Delhi (hereinafter referred to as \"Assessing\nOfficer /\"AO\") in pursuance of the directions issued by the Hon'ble\nDispute Resolution Panel - 3, Mumbai [\"hereinafter referred to as\n\"DRP\"] on the following grounds, which are independent

UTTAM ENERGY LIMITED,PUNE vs. ACIT CIRCLE-12, PUNE

Appeal of the Assessee is partly allowed

Bench: Dr.Dipak P. Ripote & Shri Vinay Bhamoreआयकर अपील सं. / Ita No.2033/Pun/2019 िनधा"रण वष" / Assessment Year: 2015-16 Uttam Energy Limited, The Acit, Circle-12, Mahendra Chamber, Mayfair V Pune. Co-Op Housing Society, S A-4, Dhole Patil Road, Pune – 411001. Pan: Aabcu4100H Appellant/ Revenue Respondent /Assessee Assessee By Shri Ch Naniwadekar & Kiran Sanmane – Ar;S Revenue By Shri Deepak Garg – Cit Date Of Hearing 16/05/2024 Date Of Pronouncement 30/05/2024 आदेश/ Order Per Dr. Dipak P. Ripote, Am: This Appeal Has Been Filed By The Assessee Against The Final Assessment Order Of The Learned Acit, Circle-12, Pune Passed U/Sec. 143(3) R.W.S. 144C(13) Of The Of The Income Tax Act, 1961 (In Short "The Act") After Giving Effect To The Learned Drp’S Order Dated 24.09.2019. 1.1 The Assessee Has Raised The Following Grounds Of Appeal :

Section 40A(2)(b), the payments made to the related parties to be disallowed.”However, in the Assessment Order u/s 143(3) r.w.s 144C

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

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]

Section 144C(6)(C) of the Act. The grounds of appeal mentioned below are without prejudice to the above ground. Transfer Pricing related grounds Ground No. 2: General Ground On the facts and in the circumstances of the case, and in law, the AU pursuant to the directions of the Ld. DRP, erred in making a TP 2 M/s.Persistent Systems

CARRARO INDIA PVT. LTD.,PUNE vs. PRINCIPAL COMMISSIONER OF INCOME-TAX-1, PUNE

In the result, appeal of the assessee is allowed

Bench: Shri S.S.Godara & Dr. Dipak P. Ripoteआयकर अपील सं. / Ita No.814/Pun/2022 िनधा"रण वष" / Assessment Years : 2017-18 Carraro India Private Limited, The Principal B 2/2, Midc, Ranjangaon V Commissioner Income Karegaon, Pune – 412220. S Tax-1, Pune. Pan: Aaacc 5292 M Appellant/ Assessee Respondent /Revenue Assessee By Shri Nikhil Mutha – Ar Revenue By Shri Ganesh Bare - Cit Date Of Hearing 26/06/2023 Date Of Pronouncement 25/07/2023 आदेश/ Order Per Dr. Dipak P. Ripote, Am: This Appeal Filed By Assessee Is Directed Against The Order Of Ld.Principal Commissioner Of Income Tax, Pune-1 Dated 15.09.2022 For A.Y. 2017-18 Under Section 263 Of The Income Tax Act, 1961. The Assessee Has Raised The Following Grounds Of Appeal: “Appeal Against Order Passed By Pr. Cit U/S 263 Of The Act Ay 2017-18

144C was erroneous and prejudicial to the interest of the Revenue. Submission of ld.AR : 3. The ld.Authorised Representative filed paper book containing 672 pages. At the outset, the ld.AR argued that ld.Pr.CIT has erred in invoking provisions of section 263 of the 3 Carraro India Private Limited [A] Act. The ld.AR read out para 9.5 of the order under section

DEPUTY COMMISSIONER OF INCOME TAX CENTRAL CIRCLE-2(2), PUNE vs. M/S. BILCARE LIMITED, PUNE

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

Bench: Shri Inturi Rama Rao & Shri S. S. Viswanethra Raviआयकर अपीऱ सं. / Ita No.273/Pun/2021 निर्धारण वर्ा / Assessment Year: 2016-17 Dcit, Central Circle-2(2), Vs. M/S. Bilcare Limited, Pune. 601, Icc Trade Tower, Pune- 411016. Pan : Aabcb2242F Appellant Respondent आयकर अपीऱ सं. / Ita No.334/Pun/2021 निर्धारण वर्ा / Assessment Year: 2016-17 M/S. Bilcare Limited, Vs. Dcit, Central Circle- 6Th Floor, B Wing, Icc 2(2), Pune. Trade Tower, Senapati Bapat Road, Pune- 411006. Pan : Aabcb2242F Appellant Respondent

144C(3) dated 30.01.2020 after making the addition on account of TP adjustment of Rs.22,76,78,495/-, addition on account of commission expenditure of Rs.16,03,019/- and addition on account of difference in returned loss as per original C.O. No.14/PUN/2021 return of income filed by the assessee company on 28.11.2016. Accordingly, the Assessing Officer assessed total loss

M/S. BILCARE LIMITED,PUNE vs. DEPUTY COMMISSIONER OF INCOME TAX CENTRAL CIRCLE-2(2), PUNE

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

Bench: Shri Inturi Rama Rao & Shri S. S. Viswanethra Raviआयकर अपीऱ सं. / Ita No.273/Pun/2021 निर्धारण वर्ा / Assessment Year: 2016-17 Dcit, Central Circle-2(2), Vs. M/S. Bilcare Limited, Pune. 601, Icc Trade Tower, Pune- 411016. Pan : Aabcb2242F Appellant Respondent आयकर अपीऱ सं. / Ita No.334/Pun/2021 निर्धारण वर्ा / Assessment Year: 2016-17 M/S. Bilcare Limited, Vs. Dcit, Central Circle- 6Th Floor, B Wing, Icc 2(2), Pune. Trade Tower, Senapati Bapat Road, Pune- 411006. Pan : Aabcb2242F Appellant Respondent

144C(3) dated 30.01.2020 after making the addition on account of TP adjustment of Rs.22,76,78,495/-, addition on account of commission expenditure of Rs.16,03,019/- and addition on account of difference in returned loss as per original C.O. No.14/PUN/2021 return of income filed by the assessee company on 28.11.2016. Accordingly, the Assessing Officer assessed total loss

DEPUTY COMMISSIONER OF INCOME TAX, PUNE vs. VASCON ENGINEERS LIMITED, PUNE

In the result, Appeal of the Revenue is Dismissed

Bench: Ms.Astha Chandra & Dr.Dipak P. Ripoteआयकर अपऩल सं. / Ita No.1105/Pun/2025 निर्धारण वषा / Assessment Years: 2013-14 Deputy Commissioner Vs. Vascon Engineers Limited, Of Income Tax, Pune. Vascon Weikfileld Chamber, Opposite Hyatt Hotel, Nagar Road, Pune – 411014. Pan: Aaacv1249F Appellant/ Revenue Respondent /Assessee Assessee By Shri Ajit Tolani & Darpan Kriplani Revenue By Smt. Indira R. Adakil – Addl.Cit(Dr) Date Of Hearing 02/12/2025 Date Of Pronouncement 27/01/2026 आदेश/ Order Per Dr. Dipak P. Ripote, Am: This Appeal Filed By The Revenue Is Against The Order Of Ld.Commissioner Of Income Tax(Appeal)[Nfac], Passed Under Section 250 Of The Income Tax Act, 1961 Dated 05.02.2025Emanating From The Assessment Order Under Section 143(3) R.W.S 144C(3/4) Of The Act, 1961 Dated 23.01.2017 For The A.Y.2013-14. The Revenue Has Raised The Following Grounds Of Appeal :

section 143(3) r.w.s 144C(3/4) of the Act, 1961 dated 23.01.2017 for the A.Y.2013-14. The Revenue has raised the following grounds of appeal : ITA No.1105/PUN/2025 [D] “1. Whether on facts and circumstances of the case, the Ld.CIT(A) was justified in deleting the disallowance

SEMPERTRANS INDIA PRIVATE LIMITED,ROHA vs. INCOME-TAX OFFICER, PANVEL

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

disallowance under section\n37(1). Accordingly, the directions of the Hon'ble DRP are bad in law\nand ought to be quashed. Consequently, the final assessment order\ndated 27 June 2024, is bad in law and ought to be quashed.\nIncome Tax Officer,\nVs. Panvel Circle, Panvel\nRespondent\n2\nITA No.1778/PUN/2024\nSempertrans India Private Limited\n2. On the facts

ASSISTANT COMMISSIONER OF INCOME-TAX, CIRCLE - 4,, PUNE vs. M/S. PIAGGIO VEHICLES PVT.LTD,, PUNE

In the result, appeal of the Revenue for A

Bench: Dr. Manish Borad & Ms. Astha Chandra

disallowed payment of Corporate Guarantee Fee (CGF). The findings of 3 ITA No. 867/PUN/2022 & ITA.No.589/PUN./2024 (M/s.Piaggio Vehicles Pvt. Ltd.) Ld. TPO vide its order dated 31/10/2018 were incorporated by the Ld.AO in his assessment order u/s. 143(3) r.w.s. 144C(3) of the Act framed on 31/01/2019. Assessee did not challenged the draft order of Ld.AO before

ASSISTANT COMMISSIONER OF INCOME TAX, PUNE vs. PIAGGIO VEHICLES PRIVATE LIMITED, BARAMATI

In the result, appeal of the Revenue for A

Bench: Dr. Manish Borad & Ms. Astha Chandra

disallowed payment of Corporate Guarantee Fee (CGF). The findings of 3 ITA No. 867/PUN/2022 & ITA.No.589/PUN./2024 (M/s.Piaggio Vehicles Pvt. Ltd.) Ld. TPO vide its order dated 31/10/2018 were incorporated by the Ld.AO in his assessment order u/s. 143(3) r.w.s. 144C(3) of the Act framed on 31/01/2019. Assessee did not challenged the draft order of Ld.AO before

BNY MELLON INTERNATIONAL OPERATIONS (INDIA) PVT. LTD.,,PUNE vs. ASSESSING OFFICER, NATIONAL E-ASSESSMENT CENTRE,, DELHI

The appeal of the assessee is PARTLY ALLOWED

Bench: Shri Satbeer Singh Godara & Shri G. D. Padmahshaliआयकर अपील सं. / Ita No. 699/Pun/2021 धििाारण वर्ा / Assessment Year : 2017-18 Bny Mellon International Operations (India) Pvt. Ltd., Tower S3, Level 1, Cybercity, Magarpatta City, Hadapsar, Pune-411013 Pan: Aadcm 9640 E . . . . . . . अपीलाथी / Appellant बिाम / V/S National E-Assessment Centre, Delhi . . . . . . .प्रत्यथी / Respondent द्वारा / Appearances Assessee By : Shri Nitesh Joshi Revenue By : Shri Rakesh Jha सुनवाई की तारीख / Date Of Conclusive Hearing : 03/08/2023 घोषणा की तारीख / Date Of Pronouncement : 08/08/2023 आदेश / Order Per G. D. Padmahshali, Am; This Appeal Is Directed Against The Order Of The National Faceless Assessment Centre, Delhi, [‘Ao’ Hereinafter] Dt. 29/10/2021 Passed U/S 143(3) R.W.S. 144C(13) R.W.S. 144B Of The Income-Tax Act, 1961 [‘The Act’ Hereinafter] For The Ay 2017-18. Itat-Pune Page 1 Of 16

144C(13) & 144B of the Income-tax Act, 1961 (the Act), in accordance with section 253(1)(d) of the said Act, on the following amongst other grounds each of which is in the alternative and without prejudice to any others; 1. That the AO erred in passing the impugned Order making an addition by way of transfer pricing adjustment

AJINKYA MADHYAMIK SHIKSHAK SEVAK SAH. PATSANSTHA, MARYADIT,SATARA vs. INCOME TAX OFFICER, WARD-2, SATARA, SATARA

In the result, the appeal of the assessee is allowed

144C of the\nincome-tax Act 1961, for which the last date of fling under that Section is 1st\nApril 2021 or thereafter may be filed within the time provided under that\nSection or by 31st May 2021, whichever is later,\nc) Income tax return in response to notice under Section 148 of the Income-\ntax Act, 1961 for which