WOCKHARDT LIMITED,AURANGABAD vs. THE ASSISTANT COMMISSIONER OF INCOME TAX CENTRAL CIRCLE 2(1), PUNE

In the result, the appeal of the assessee is partly allowed

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

153C of the Act on 30.03.2023 making disallowance in respect of educational grants provided to IFMER amounting to Rs.1,75,68,000/-. The relevant observations and findings of the Ld. AO is as under : “Thus, in guise of the use of funds for Medical Education the funds were used for providing freebies to doctors like travel, stay

WOCKHARDT LIMITED,AURANGABAD vs. THE ASSISTANT COMMISSIONER OF INCOME TAX CENTRAL CIRCLE 2(1), PUNE

In the result, the appeal of the assessee is partly allowed

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

153C of the Act on 30.03.2023 making disallowance in respect of educational grants provided to IFMER amounting to Rs.1,75,68,000/-. The relevant observations and findings of the Ld. AO is as under : “Thus, in guise of the use of funds for Medical Education the funds were used for providing freebies to doctors like travel, stay

WOCKHARDT LIMITED,AURANGABAD vs. THE ASSISTANT COMMISSIONER OF INCOME TAX CENTRAL CIRCLE-2(1), PUNE

In the result, the appeal of the assessee is partly allowed

section 153C cannot be made basis a consolidated\nsatisfaction note:\n2. ought to have appreciated that the assessment order passed by the\nlearned AO is bad in law and hence liable to be quashed as the same is\npassed based on the consolidated satisfaction note dated 23 March 2022\nrecorded by the Deputy Commissioner of Income Tax, Circle-1, Aurangabad

DEPUTY COMMISSIONER OF INCOME TAX CIRCLE 7 PUNE, PUNE vs. KOLTE PATIL INTEGRATED TOWNSHIPS LIMITED, PUNE

In the result, both the appeals filed by the Revenue are dismissed

disallowance of interest expenditure. He held that the reopening was beyond\nthe provisions of section 149. He accordingly submitted that the order of the Ld.\nCIT(A) / NFAC on this issue also being in accordance with law has to be accepted\nand the grounds raised by the Revenue on this issue have to be dismissed.\n17. The Ld. Counsel

DEPUTY COMMISSIONER OF INCOME TAX CIRCLE-7 PUNE, PUNE vs. KOLTE PATIL INTEGRATED TOWNSHIPS LIMITED, PUNE

In the result, both the appeals filed by the Revenue are dismissed

disallowance of interest expenditure. He held that the reopening was beyond\nthe provisions of section 149. He accordingly submitted that the order of the Ld.\nCIT(A) / NFAC on this issue also being in accordance with law has to be accepted\nand the grounds raised by the Revenue on this issue have to be dismissed.\n17.\nThe Ld. Counsel

SHAKEEL ABDUL AZEEZ MOHAMMAD,JALGAON vs. ITO, WARD 1(1), JALGAON, JALGAON

In the result, appeal of the assessee is allowed for statistical purpose

Bench: Dr.Dipak P. Ripote & Shri Vinay Bhamoreआयकर अपीलसं. / Ita No.1115/Pun/2025 िनधा"रण वष" / Assessment Year: 2016-17 Shakeel Abdul Azeez V The Income Tax Officer, Mohammad, S Ward-1(1), Jalgaon. Kachchi Chawl, Indira Nagar, Shahu Nagar, Jalgaon-425001. Maharashtra. Pan: Byfpm1596K Appellant/ Assessee Respondent / Revenue Assessee By Shri Vinay V Kawdia – Ar(Virtual) Revenue By Shri Sandeep P Sathe – Jcit(Dr) Date Of Hearing 17/07/2025 Date Of Pronouncement 21/07/2025

153C is bad in law and the resultant order under section 144 r w s 147 is liable to be quashed. 2) Under the facts and circumstances of the case and in law the learned CIT(A). NFAC has erred in confirming the addition of Rs. 44,04,041/- made by AO u/s 69A of the act by treating

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

disallowing the interest expenditure claimed\nin the returns amounting to Rs.1,97,159/- and further, Ld, Commissioner of\nIncome Tax (Appeals) erred in confirming the same.\n9.\nThe Appellant craves leave to add, alter, amend, vary or delete any of the\naforesaid grounds.\n9.\nThe assessee has also filed an additional ground in ITA No.1178/PUN/2023\nwhich reads as under

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

disallowing the interest expenditure claimed\nin the returns amounting to Rs.1,97,159/- and further, Ld, Commissioner of\nIncome Tax (Appeals) erred in confirming the same.\n9.\nThe Appellant craves leave to add, alter, amend, vary or delete any of the\naforesaid grounds.\n9.\nThe assessee has also filed an additional ground in ITA No.1178/PUN/2023\nwhich reads as under

M/S. NAMRATA DEVELOPERS FLORA CITY,,PUNE vs. DEPUTY COMMISSIONER OF INCOME-TAX,,

Accordingly uphold the CIT(A) foregoing directions granting proportionate section 80IB(10) deduction to the assessee. Ordered accordingly. These Revenue’s cross appeals in ITA No.1684 to 1687/PUN/2...

Bench: Shri S.S.Godara & Shri Dipak Pandurang Ripoteआयकरअपीलसं. / Ita No’S.1679 To 1682/Pun/2016 िनधा"रण वष" / Assessment Years: 2010-11 To 2013-14 M/S. Namrata Developers Flora The Deputy Commissioner Of City, Vs Income Tax, Central Circle-2(1), 592, Ravivar Peth, Talegaon- Pune. Dabhade, Taluka Maval, Pune – 410 506. Pan: Aaaan 4708 C Appellant/ Assessee Respondent /Revenue

disallowing the assessee’s 80IB(10) deduction claim to this effect. 8. Mr.Jain does not press for assessee’s legal ground(s) challenging validity of section 153C

M/S. NAMRATA DEVELOPERS FLORA CITY,,PUNE vs. DEPUTY COMMISSIONER OF INCOME-TAX,,

Accordingly uphold the CIT(A) foregoing directions granting proportionate section 80IB(10) deduction to the assessee. Ordered accordingly. These Revenue’s cross appeals in ITA No.1684 to 1687/PUN/2...

Bench: Shri S.S.Godara & Shri Dipak Pandurang Ripoteआयकरअपीलसं. / Ita No’S.1679 To 1682/Pun/2016 िनधा"रण वष" / Assessment Years: 2010-11 To 2013-14 M/S. Namrata Developers Flora The Deputy Commissioner Of City, Vs Income Tax, Central Circle-2(1), 592, Ravivar Peth, Talegaon- Pune. Dabhade, Taluka Maval, Pune – 410 506. Pan: Aaaan 4708 C Appellant/ Assessee Respondent /Revenue

disallowing the assessee’s 80IB(10) deduction claim to this effect. 8. Mr.Jain does not press for assessee’s legal ground(s) challenging validity of section 153C

ASSISTANT COMMISSIONER OF INCOME-TAX vs. M/S. NAMRATA DEVELOPERS FLORA CITY,, PUNE

Accordingly uphold the CIT(A) foregoing directions granting proportionate section 80IB(10) deduction to the assessee. Ordered accordingly. These Revenue’s cross appeals in ITA No.1684 to 1687/PUN/2...

Bench: Shri S.S.Godara & Shri Dipak Pandurang Ripoteआयकरअपीलसं. / Ita No’S.1679 To 1682/Pun/2016 िनधा"रण वष" / Assessment Years: 2010-11 To 2013-14 M/S. Namrata Developers Flora The Deputy Commissioner Of City, Vs Income Tax, Central Circle-2(1), 592, Ravivar Peth, Talegaon- Pune. Dabhade, Taluka Maval, Pune – 410 506. Pan: Aaaan 4708 C Appellant/ Assessee Respondent /Revenue

disallowing the assessee’s 80IB(10) deduction claim to this effect. 8. Mr.Jain does not press for assessee’s legal ground(s) challenging validity of section 153C

M/S. NAMRATA DEVELOPERS FLORA CITY,,PUNE vs. DEPUTY COMMISSIONER OF INCOME-TAX,,

Accordingly uphold the CIT(A) foregoing directions granting proportionate section 80IB(10) deduction to the assessee. Ordered accordingly. These Revenue’s cross appeals in ITA No.1684 to 1687/PUN/2...

Bench: Shri S.S.Godara & Shri Dipak Pandurang Ripoteआयकरअपीलसं. / Ita No’S.1679 To 1682/Pun/2016 िनधा"रण वष" / Assessment Years: 2010-11 To 2013-14 M/S. Namrata Developers Flora The Deputy Commissioner Of City, Vs Income Tax, Central Circle-2(1), 592, Ravivar Peth, Talegaon- Pune. Dabhade, Taluka Maval, Pune – 410 506. Pan: Aaaan 4708 C Appellant/ Assessee Respondent /Revenue

disallowing the assessee’s 80IB(10) deduction claim to this effect. 8. Mr.Jain does not press for assessee’s legal ground(s) challenging validity of section 153C

ASSISTANT COMMISSIONER OF INCOME-TAX vs. M/S. NAMRATA DEVELOPERS FLORA CITY,, PUNE

Accordingly uphold the CIT(A) foregoing directions granting proportionate section 80IB(10) deduction to the assessee. Ordered accordingly. These Revenue’s cross appeals in ITA No.1684 to 1687/PUN/2...

Bench: Shri S.S.Godara & Shri Dipak Pandurang Ripoteआयकरअपीलसं. / Ita No’S.1679 To 1682/Pun/2016 िनधा"रण वष" / Assessment Years: 2010-11 To 2013-14 M/S. Namrata Developers Flora The Deputy Commissioner Of City, Vs Income Tax, Central Circle-2(1), 592, Ravivar Peth, Talegaon- Pune. Dabhade, Taluka Maval, Pune – 410 506. Pan: Aaaan 4708 C Appellant/ Assessee Respondent /Revenue

disallowing the assessee’s 80IB(10) deduction claim to this effect. 8. Mr.Jain does not press for assessee’s legal ground(s) challenging validity of section 153C

M/S. NAMRATA DEVELOPERS FLORA CITY,,PUNE vs. DEPUTY COMMISSIONER OF INCOME-TAX,,

Accordingly uphold the CIT(A) foregoing directions granting proportionate section 80IB(10) deduction to the assessee. Ordered accordingly. These Revenue’s cross appeals in ITA No.1684 to 1687/PUN/2...

Bench: Shri S.S.Godara & Shri Dipak Pandurang Ripoteआयकरअपीलसं. / Ita No’S.1679 To 1682/Pun/2016 िनधा"रण वष" / Assessment Years: 2010-11 To 2013-14 M/S. Namrata Developers Flora The Deputy Commissioner Of City, Vs Income Tax, Central Circle-2(1), 592, Ravivar Peth, Talegaon- Pune. Dabhade, Taluka Maval, Pune – 410 506. Pan: Aaaan 4708 C Appellant/ Assessee Respondent /Revenue

disallowing the assessee’s 80IB(10) deduction claim to this effect. 8. Mr.Jain does not press for assessee’s legal ground(s) challenging validity of section 153C

ASSISTANT COMMISSIONER OF INCOME-TAX vs. M/S. NAMRATA DEVELOPERS FLORA CITY,, PUNE

Accordingly uphold the CIT(A) foregoing directions granting proportionate section 80IB(10) deduction to the assessee. Ordered accordingly. These Revenue’s cross appeals in ITA No.1684 to 1687/PUN/2...

Bench: Shri S.S.Godara & Shri Dipak Pandurang Ripoteआयकरअपीलसं. / Ita No’S.1679 To 1682/Pun/2016 िनधा"रण वष" / Assessment Years: 2010-11 To 2013-14 M/S. Namrata Developers Flora The Deputy Commissioner Of City, Vs Income Tax, Central Circle-2(1), 592, Ravivar Peth, Talegaon- Pune. Dabhade, Taluka Maval, Pune – 410 506. Pan: Aaaan 4708 C Appellant/ Assessee Respondent /Revenue

disallowing the assessee’s 80IB(10) deduction claim to this effect. 8. Mr.Jain does not press for assessee’s legal ground(s) challenging validity of section 153C

ASSISTANT COMMISSIONER OF INCOME-TAX vs. M/S. NAMRATA DEVELOPERS FLORA CITY,, PUNE

Accordingly uphold the CIT(A) foregoing directions granting proportionate section 80IB(10) deduction to the assessee. Ordered accordingly. These Revenue’s cross appeals in ITA No.1684 to 1687/PUN/2...

Bench: Shri S.S.Godara & Shri Dipak Pandurang Ripoteआयकरअपीलसं. / Ita No’S.1679 To 1682/Pun/2016 िनधा"रण वष" / Assessment Years: 2010-11 To 2013-14 M/S. Namrata Developers Flora The Deputy Commissioner Of City, Vs Income Tax, Central Circle-2(1), 592, Ravivar Peth, Talegaon- Pune. Dabhade, Taluka Maval, Pune – 410 506. Pan: Aaaan 4708 C Appellant/ Assessee Respondent /Revenue

disallowing the assessee’s 80IB(10) deduction claim to this effect. 8. Mr.Jain does not press for assessee’s legal ground(s) challenging validity of section 153C

ASST. COMMISSIONER OF INCOME TAX, PANVEL CIRCLE PANVEL vs. OUTABOX MEDIA SOLUTIONS LLP, GHATKOPAR MUMBAI

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

Bench: Shri R. K. Panda & Ms Astha Chandraassessment Year : 2017-18

153C or after the completion of the assessment, whichever is earlier. (4) Subject to the provisions of sub-section (3), where an assessee calls in question the jurisdiction of an Assessing Officer, then the Assessing Officer shall, if not satisfied with the correctness of the claim, refer the matter for determination under sub-section (2) before the assessment is made

DY. COMMISSIONER OF INCOME TAX (EXEMPTIONS), CIRCLE, PUNE, SWARGATE, PUNE vs. SHREE CHANAKYA EDUCATION SOCIETY, AUNDH, PUNE

In the result, both the appeals filed by the Revenue and the Cross Objection filed by the assessee are dismissed

Bench: Shri R. K. Panda & Ms Astha Chandraassessment Year : 2014-15

disallowed, the Respondent had an excess application of Rs.5,79,77,998/- for the relevant Assessment Year. Therefore, even by doing so, there will be no income chargeable to tax for AY 2014-15. Just and proper relief be granted to the respondent in this respect. 3. The appellant prays to be allowed to add, amend, modify, rectify, delete

DY. COMMISSIONER OF INCOME TAX (EXEMPTIONS), CIRCLE, PUNE, SWARGATE, PUNE vs. SHREE CHANAKYA EDUCATION SOCIETY, AUNDH ,PUNE

In the result, both the appeals filed by the Revenue and the Cross Objection filed by the assessee are dismissed

Bench: Shri R. K. Panda & Ms Astha Chandraassessment Year : 2014-15

disallowed, the Respondent had an excess application of Rs.5,79,77,998/- for the relevant Assessment Year. Therefore, even by doing so, there will be no income chargeable to tax for AY 2014-15. Just and proper relief be granted to the respondent in this respect. 3. The appellant prays to be allowed to add, amend, modify, rectify, delete