M/S. SAVA HEALTHCARE LTD,,PUNE vs. ASSISTANT COMMISSIONER OF INCOME TAX,, PUNE

In the result, 70% of world profits are added in the hands of assessee under guise of Profit Split Method

Bench: Ms. Sushma Chowla, Jm & Shri Anil Chaturvedi, Am आयकर अपीऱ सं. / Ita Nos.1062 To 1068/Pun/2017 यििाारण वषा / Assessment Years : 2007-08 To 2013-14

145 crores, to which profit attributable to assessee which was equal to comparables profit was added. The said table is reproduced hereunder for ready reference: A.Y. Combined Profit % of Profit Profit AE’s Share Residual Profit Anagha’s Total of Anagha and earned by Attributable 3% allocated to Profit AE’s the to the Anagha Pharma Comparab Anagha

M/S. SAVA HEALTHCARE LTD,,PUNE vs. ASSISTANT COMMISSIONER OF INCOME TAX,, PUNE

In the result, 70% of world profits are added in the hands of assessee under guise of Profit Split Method

Bench: Ms. Sushma Chowla, Jm & Shri Anil Chaturvedi, Am आयकर अपीऱ सं. / Ita Nos.1062 To 1068/Pun/2017 यििाारण वषा / Assessment Years : 2007-08 To 2013-14

145 crores, to which profit attributable to assessee which was equal to comparables profit was added. The said table is reproduced hereunder for ready reference: A.Y. Combined Profit % of Profit Profit AE’s Share Residual Profit Anagha’s Total of Anagha and earned by Attributable 3% allocated to Profit AE’s the to the Anagha Pharma Comparab Anagha

M/S. SAVA HEALTHCARE LTD,,PUNE vs. ASSISTANT COMMISSIONER OF INCOME TAX,, PUNE

In the result, 70% of world profits are added in the hands of assessee under guise of Profit Split Method

Bench: Ms. Sushma Chowla, Jm & Shri Anil Chaturvedi, Am आयकर अपीऱ सं. / Ita Nos.1062 To 1068/Pun/2017 यििाारण वषा / Assessment Years : 2007-08 To 2013-14

145 crores, to which profit attributable to assessee which was equal to comparables profit was added. The said table is reproduced hereunder for ready reference: A.Y. Combined Profit % of Profit Profit AE’s Share Residual Profit Anagha’s Total of Anagha and earned by Attributable 3% allocated to Profit AE’s the to the Anagha Pharma Comparab Anagha

M/S. SAVA HEALTHCARE LTD,,PUNE vs. ASSISTANT COMMISSIONER OF INCOME TAX,, PUNE

In the result, 70% of world profits are added in the hands of assessee under guise of Profit Split Method

Bench: Ms. Sushma Chowla, Jm & Shri Anil Chaturvedi, Am आयकर अपीऱ सं. / Ita Nos.1062 To 1068/Pun/2017 यििाारण वषा / Assessment Years : 2007-08 To 2013-14

145 crores, to which profit attributable to assessee which was equal to comparables profit was added. The said table is reproduced hereunder for ready reference: A.Y. Combined Profit % of Profit Profit AE’s Share Residual Profit Anagha’s Total of Anagha and earned by Attributable 3% allocated to Profit AE’s the to the Anagha Pharma Comparab Anagha

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

section 145(3) of the Act. The CIT(A) also upheld the order of Assessing Officer in this regard. The CIT(A) also referred to submissions of assessee that appropriate disallowance

ITO, WARD-1(1), SOLAPUR, SOLAPUR vs. MS. KSHIRSAGAR FABRICS, SOLAPUR

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

Bench: Shri R. K. Panda & Ms Astha Chandraassessment Year : 2009-10

145 taxmann.com 228 (Bom), he submitted that the Hon’ble High Court in the said decision has held that when initially Assessing Officer had not accepted audit objection that as assessee was not satisfying condition of an industrial undertaking as prescribed under section 72A, set-off of brought forward losses on amalgamating company on amalgamation with assessee

R. K. WINES,PEN vs. ITO, WARD 4, PANVEL, PANVEL

In the result, appeal of the assessee is partly allowed

section (2), has not been\nregularly followed by the assessee.\nIt is submitted that none of the above-mentioned twin conditions\nprescribed by u/s 145(3) are attracted in the present case.\n3.5 The appellant accordingly prays that the rejection of book results\nu/s 145(3) is not justified and the said action may kindly not be upheld.\nGround

PURUSHOTTAM R MOGHE,PUNE vs. DEPUTY COMMISSIONER OF INCOME TAX, CIRCLE-1(2), PUNE, PUNE

Bench: Shri Satbeer Singh Godara & Shri Gd Padmahshali

section 145(2) of the Income Tax Act, 1961. (iii) The appellant has maintained quantitative details of opening and closing stock of purchases, consumption of raw material (principal items) and sale of finished goods both in terms of quality and value. No discrepancy in this regard has been detected during the course of special audit. (iv) It is a fact

DCIT, CIRCLE-5, PUNE vs. SHRI PURUSHOTTAM R MOGHE, PUNE

Bench: Shri Satbeer Singh Godara & Shri Gd Padmahshali

section 145(2) of the Income Tax Act, 1961. (iii) The appellant has maintained quantitative details of opening and closing stock of purchases, consumption of raw material (principal items) and sale of finished goods both in terms of quality and value. No discrepancy in this regard has been detected during the course of special audit. (iv) It is a fact

DCIT CIRCLE- 5, PUNE vs. SAILAB MARKETING SERVICES PVT. LTD., PUNE

Bench: Shri Satbeer Singh Godara & Shri Gd Padmahshali

section 145(2) of the Income Tax Act, 1961. (iii) The appellant has maintained quantitative details of opening and closing stock of purchases, consumption of raw material (principal items) and sale of finished goods both in terms of quality and value. No discrepancy in this regard has been detected during the course of special audit. (iv) It is a fact

DCIT, CIRCLE-5, PUNE vs. SHRI PURUSHOTTAM R MOGHE, PUNE

Bench: Shri Satbeer Singh Godara & Shri Gd Padmahshali

section 145(2) of the Income Tax Act, 1961. (iii) The appellant has maintained quantitative details of opening and closing stock of purchases, consumption of raw material (principal items) and sale of finished goods both in terms of quality and value. No discrepancy in this regard has been detected during the course of special audit. (iv) It is a fact

PURUSHOTTAM R MOGHE,PUNE vs. DEPUTY COMMISSIONER OF INCOME TAX, CIRCLE-1(2), PUNE, PUNE

Bench: Shri Satbeer Singh Godara & Shri Gd Padmahshali

section 145(2) of the Income Tax Act, 1961. (iii) The appellant has maintained quantitative details of opening and closing stock of purchases, consumption of raw material (principal items) and sale of finished goods both in terms of quality and value. No discrepancy in this regard has been detected during the course of special audit. (iv) It is a fact

SAILAB MARKETING SERVICES PVT LTD,PUNE vs. DEPUTY COMMISSIONER OF INCOME TAX, CIRCLE-1(2), PUNE, PUNE

Bench: Shri Satbeer Singh Godara & Shri Gd Padmahshali

section 145(2) of the Income Tax Act, 1961. (iii) The appellant has maintained quantitative details of opening and closing stock of purchases, consumption of raw material (principal items) and sale of finished goods both in terms of quality and value. No discrepancy in this regard has been detected during the course of special audit. (iv) It is a fact

WOCKHARDT LIMITED,,AURANGABAD vs. ASSISTAMT COMMISSIONER OF INCOME TAX, CIRCLE -3,, AURANGABAD

In the result, the appeal filed by Revenue is partly allowed, the appeal filed by assessee is partly allowed and the CO filed by assessee is dismissed as withdrawn

Bench: Shri Inturi Rama Rao & Shri S.S. Viswanethra Raviआयकर अपीऱ सं. / Ita No.775/Pun/2019 निर्धारण वषा / Assessment Year : 2013-14 Acit, Circle-3, Aurangabad .......अऩीऱाथी / Appellant बिधम / V/S. Wockhardt Ltd., R&D Centre, D-4, Midc, Chikalthana, Aurangabad. Pan: Aaacw2472M ……प्रत्यथी / Respondent आयकर अपीऱ सं. / Ita No.758/Pun/2019 निर्धारण वषा / Assessment Year : 2013-14 Wockhardt Ltd., R&D Centre, D-4, Midc, Chikalthana, Aurangabad. Pan: Aaacw2472M .......अऩीऱाथी / Appellant बिधम / V/S. Acit, Circle-3, Aurangabad ……प्रत्यथी / Respondent Co No.43/Pun/2019 निर्धारण वषा / Assessment Year : 2013-14 Wockhardt Ltd., R&D Centre, D-4, Midc, Chikalthana, Aurangabad. Pan: Aaacw2472M .......Cross Objector बिधम / V/S. Acit, Circle-3, Aurangabad ……प्रत्यथी / Respondent Co No.43/Pun/2019

3) of the Income-tax Act, 1961 (hereinafter referred to as ‘the Act’). While doing so, the AO made TP adjustment as suggested by the Transfer Pricing Officer (TPO) of Rs.109,81,22,628/-, disallowance of excess claim of deduction u/s 80IC of Rs.9,61,86,526/-, disallowance under provisions of section 35(2AB) of Rs.65,55,77,068/-, disallowance

COOPER CORPORATION PVT. LTD.,,SATARA vs. DEPUTY COMMISSIONER OF INCOME-TAX,,

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

3. Objectives of the scientific research to be conducted by in- house Research and Development facility: To identify, improve and implement new products; development of new technology; new quality assurance systems; emission compliance and cost reduction. 4. Address at which such Research & Development facility is located: M-60-1, Addl. MIDC, Kodoli, Satara (Maharashtra). 5. Ref. No. and Date

BAJAJ FINANCE LTD,,PUNE vs. DEPUTY COMMISSIONER OF INCOME-TAX, CIRCLE - 8,, PUNE

Bench: Shri S.S. Godara & Dr. Dipak P. Ripote

Section 145 of the Income Tax Act, 1961, since both the Acts operate in different fields and therefore, assessee cannot recognize interest income on NPA and yet not offer it in Profit and Loss account? (ii) Whether on the facts and in the circumstances of the case and in law, the Tribunal was correct in deleting the disallowance of Rs.71

DEPUTY COMMISSIONER OF INCOME-TAX, CIRCLE - 8,, PUNE vs. M/S. BAJAJ FINANACE LTD,, PUNE

Bench: Shri S.S. Godara & Dr. Dipak P. Ripote

Section 145 of the Income Tax Act, 1961, since both the Acts operate in different fields and therefore, assessee cannot recognize interest income on NPA and yet not offer it in Profit and Loss account? (ii) Whether on the facts and in the circumstances of the case and in law, the Tribunal was correct in deleting the disallowance of Rs.71

BAJAJ FINANCE LTD,,PUNE vs. DEPUTY COMMISSIONER OF INCOME-TAX, CIRCLE - 8,, PUNE

Bench: Shri S.S. Godara & Dr. Dipak P. Ripote

Section 145 of the Income Tax Act, 1961, since both the Acts operate in different fields and therefore, assessee cannot recognize interest income on NPA and yet not offer it in Profit and Loss account? (ii) Whether on the facts and in the circumstances of the case and in law, the Tribunal was correct in deleting the disallowance of Rs.71