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

153/- which is the share of profit in firm, dividend and interest on PPF. However, the assessee has not disallowed any amount towards expenditure in relation to income which does not form part of total income. According to the Assessing Officer as per provisions of section

VATSALABAI KARBHARI DEORE,KALWAN vs. INCOME TAX OFFICER, WARD 1(5), NASHIK

In the result, the appeal filed by the assessee is allowed as per terms indicated above

Bench: Dr.Manish Borad & Shri Vinay Bhamoreआयकर अपील सं. / Ita No.2274/Pun/2025 Assessment Year : 2011-12

sections 148 to 153 referred to as the relevant assessment year)." 6. On going through the changes, quoted above, made to s. 147 of the Act, we find that, prior to the Direct Tax Laws (Amendment) Act, 1987, reopening could be done under the above two conditions and fulfilment of the said conditions alone conferred jurisdiction

KIRLOSKAR PNEUMATIC CO.LTD,,PUNE vs. DEPUTY COMMISSIONER OF INCOME-TAX, CIRCLE - 14,, PUNE

In the result, appeal of the assessee is partly allowed

Bench: Shri S.S.Godara & Dr. Dipak P. Ripoteआयकरअपीलसं. / Ita No.983/Pun/2018 िनधा"रणवष" / Assessment Year : 2015-16 Kirloskar Pneumatic Co. Ltd., The Dcit, Circle-14, Hadapsar Industrial Estate, Vs Pune. Pune Solapur Road, Hadapsar, Pune – 411013. Pan:Aaack 2479 C Appellant/ Assessee Respondent / Revenue Assessee By Shri C.H.Naniwadeker – Ar Revenue By Shri M.G.Jasnani – Dr Date Of Hearing 13/07/2022 Date Of Pronouncement 12/09/2022 आदेश/ Order Per Dr. Dipak P. Ripote, Am: This Is An Appeal Filed By The Appellant Assessee Namely Kirloskar Pneumatic Co. Ltd. Against The Order Of Ld.Commissioner Of Income Tax(Appeals)-7, Pune Dated 09.04.2018 Emanating From The Order Of Deputy Commissioner Of Income Tax, Circle-14, Pune Under Section 143(3) Of The Act, 1961. The Grounds Of Appeal Are As Under: “1. The Learned Cit(A) Erred On Facts & In Law In Upholding Disallowance Of Rs.57,44,010/- U/S 14A R.W.R. 8D Without Appreciating The Facts & Submissions Made In This Behalf. He Also Failed To Appreciate That Before Invoking Rule 8D, The A.O. Has Not Recorded His Satisfaction As Required By Law. 2. The Learned Cit(A) Erred On Facts & In Law In Upholding 50% Ad-Hoc Disallowance Of Gift & Present Of Rs.16,06,635/- U/S

section 14A of the Act ITA No.983/PUN/2018 for A.Y. 2015-16 Kirloskar Pneumatic Co. Ltd., [A] without recording any satisfaction regarding correctness incorrectness of the suo-moto disallowance of the assessee. Accordingly, the Assessing Officer is directed to delete the said addition. Thus, the Ground No.1 of the assessee is allowed. Ground No.2 –Gift and Present Rs.16

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

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

section 40(a)(ia). He\nfurther submitted that from the books of account of the asssessee it was established\nthat these were actual expenses incurred during AY 2017-18 and not the\n\"provisions for expenses” on which TDS was not deducted. He submitted that the\nassessee failed to furnish any documentary evidence that TDS was deducted during\nthe assessment

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 are concerned, the DRP upheld the action of the AO / TPO. 6. Aggrieved with such order of the AO / TPO / DRP, the assessee is in appeal before the Tribunal by raising the following grounds: That on the facts and circumstances of the case, and in law; Legal Grounds 1. The impugned order

DEPUTY COMMISSIONER OF INCOME-TAX CIRCLE -5, PUNE vs. SERUM INSTITUTE OF INDIA PVT LTD.,, PUNE

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

Section 14A of the Income-tax Act, 1961 are squarely applicable and the same was applied correctly during the course of the assessment proceedings. 3. On the facts and circumstances of the case and in law, the Ld. CIT(A) erred in deleting the disallowance made by the Assessing Officer amounting of Rs. 2445047/- on account of foreign travel expenses

DEPUTY COMMISSIONER OF INCOME-TAX vs. CLARION TECHNOLOGIES PVT. LTD.,, PUNE

In the result, the appeal of assessee is allowed

Bench: Shri R.S. Syal & Shri S.S. Viswanethra Ravi

disallowed the said loss by holing it did not arise in the normal course of assessee‟s business. The Appellate Commissioner allowed the entire claim of loss. Thereafter, the AO issued notice u/s. 154 of the Act for rectifying the assessment as the profit from the sale of said bogus shares had been under assessed. We note that

CLARION TECHNOLOGIES PVT. LTD.,,PUNE vs. DEPUTY COMMISSIONER OF INCOME-TAX,,

In the result, the appeal of assessee is allowed

Bench: Shri R.S. Syal & Shri S.S. Viswanethra Ravi

disallowed the said loss by holing it did not arise in the normal course of assessee‟s business. The Appellate Commissioner allowed the entire claim of loss. Thereafter, the AO issued notice u/s. 154 of the Act for rectifying the assessment as the profit from the sale of said bogus shares had been under assessed. We note that

ASSTT. COMMISSIONER OF INCOME TAX (EXEMPTIONS), CIRCLE, PUNE, PUNE vs. THE SHETKARI SHIKSHAN MANDAL, PUNE

In the result, the appeal of the Revenue is allowed for statistical purposes

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

153 referred to as the relevant assessment year): Provided that where an assessment under sub-section (3) of section 143 or this section has been made for the relevant assessment year, no action shall be taken under this section after the expiry of four years from the end of the relevant assessment year, unless any 4 ITA No.1182/PUN/2024

RAJA BASHUMIYA MANIYAR,LATUR vs. ITO, WARD-1, LATUR, LATUR

In the result, appeal of the assessee is Allowed

disallowing\ndeduction U/Sec. 54F of the Act without considering the true and\ncorrect facts of the case and without appreciating the contention of the\nappellant that the appellant has purchased the property which is\neligible for deduction U/Sec. 54F of the Act.\n4.\nThe appellant craves leave to add, alter, amend or delete any of\nthe above grounds of appeal

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

153 of the Income-tax Act, 1961\nIncome escaping assessment – issue of notice for – Assessment years 1988-\n99 to 1990-91 – Petitioner-foreign company was engaged in business of oil\nexploration and providing expertise and assistance in said field – Proceeds\nfrom manning and management contracts received by petitioner were\noriginally assessed in February, 1991 under section 143(3) treating same

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

153 of the Income-tax Act, 1961\nIncome escaping assessment – issue of notice for – Assessment years 1988-\n99 to 1990-91 – Petitioner-foreign company was engaged in business of oil\nexploration and providing expertise and assistance in said field – Proceeds\nfrom manning and management contracts received by petitioner were\noriginally assessed in February, 1991 under section 143(3) treating same

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)

153. Under section 1534(1), the Assessing Officer is empowered to issue notices to the assexsee searched for a period of six years in order to assess the income on the basis of material found during the course of search. The second proviso to section 153A(1) provides that the assessment or reassessment, if any, relating to any assessment year

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)

153. Under section 1534(1), the Assessing Officer is empowered to issue notices to the assexsee searched for a period of six years in order to assess the income on the basis of material found during the course of search. The second proviso to section 153A(1) provides that the assessment or reassessment, if any, relating to any assessment year

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)

153. Under section 1534(1), the Assessing Officer is empowered to issue notices to the assexsee searched for a period of six years in order to assess the income on the basis of material found during the course of search. The second proviso to section 153A(1) provides that the assessment or reassessment, if any, relating to any assessment year

INCOME TAX OFFICER WARD HINGOLI, WARD HINGOLI (CAMP AT PARBHANI) vs. VISHWAS AGRO PRODUCT PVT LTD, PARBHANI

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

Bench: Shri R. K. Panda & Shri Vinay Bhamoreassessment Year : 2017-18

disallowed the said amount of Rs.1,62,84,153/- received from Pranav International Dubai under section 68 considering the same

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

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

Bench: Shri R. K. Panda & Ms. Astha Chandraassessment Year : 2020-21 Acit, Central Circle 2(3), Nitin Dwarkadas Nyati Pune Sr. No.103/129, Nyati Unitree, Vs. Yerwada, Nagar Road, Pune – 411006 Pan: Aabpn2601F (Appellant) (Respondent) Assessee By : Shri Krishna V Gujarathi Department By : Shri Vidya Ratan Kishore Date Of Hearing : 15-12-2025 Date Of Pronouncement : 19-12-2025 O R D E R

153/- which is the share of profit in firm, dividend and interest on PPF. However, the assessee has not disallowed any amount towards expenditure in relation to income which does not form part of total income. According to the Assessing Officer as per provisions of section

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 :

disallowed u/s 14A r.w. Rule 8D(2)(ii) under any circumstances” Unqote. (emphasis supplied) 4.3 Hon’ble Bombay High Court in the case of Pr.CIT vs Tata Capital Ltd 475 ITR 559 (Bombay)[03-04-2024] has held as under : Quote, “7. We agree with the finding of the CIT(A) and the ITAT that though the AO has stated

ASSOCIATION OF ORAL MAXILLOFACIAL SURGEONS OF INDIA,PUNE vs. ASSISTANT COMMISSIONER OF INCOME TAX,WARD-1(1), PUNE, PUNE

In the result, the appeal is allowed

Bench: Shri R.S. Syal & Shri Partha Sarathi Chaudhuryआयकर अपील सं. / Ita No.274/Pun/2023 "नधा"रण वष" / Assessment Year : 2012-13 Association Of Oral Maxillofacial Vs. Ito (Exemptions), Surgeons Of India, Ward-1, Pune Pn 38, S.No.16, Butte Patil Classic, Prabhat Road, Erandwane, Pune 411 004 Maharashtra Pan : Aabta3313P Appellant Respondent

153 a return of his income which he is required to furnish under section 139 in respect of any assessment year commencing on or after the 1st day of April, 1989, and until the expiry of the period aforesaid, no notice has been issued to him under clause (i) of sub-section (1) of section 142 or section