DEPUTY COMMISSIONER OF INCOME-TAX vs. ASSOCIATED DAIRY FAB PVT. LTD.,, JALGAON

In the result, appeal of assessee is partly allowed and appeal of Revenue is dismissed

Bench: Ms. Sushma Chowla, Jm & Shri Anil Chaturvedi, Am आयकर अपीऱ सं. / Ita No.177/Pun/2014 यििाारण वषा / Assessment Year : 2009-10 Associated Dairy Fab Pvt. Ltd., B-5/1, Midc Area, Ajantha Road, अऩीऱाथी/Appellant Jalgaon – 425003 …. Pan: Aaeca3963F Vs. The Jt. Commissioner Of Income Tax, …. प्रत्यथी / Respondent Range – 2, Jalgaon

disallowance is to be made out of remuneration paid to directors under section 40A(2)(b) of the Act. The assessee has filed the copy of computation of income of directors Shri Adarsh Kothari at pages 165 to 168 of the Paper Book and Shri Amit Kothari at pages 169 to 171

ASSOCIATED DAIRY FAB PVT. LTD.,,JALGAON vs. JOINT COMMISSIONER OF INCOME-TAX,,

In the result, appeal of assessee is partly allowed and appeal of Revenue is dismissed

Bench: Ms. Sushma Chowla, Jm & Shri Anil Chaturvedi, Am आयकर अपीऱ सं. / Ita No.177/Pun/2014 यििाारण वषा / Assessment Year : 2009-10 Associated Dairy Fab Pvt. Ltd., B-5/1, Midc Area, Ajantha Road, अऩीऱाथी/Appellant Jalgaon – 425003 …. Pan: Aaeca3963F Vs. The Jt. Commissioner Of Income Tax, …. प्रत्यथी / Respondent Range – 2, Jalgaon

disallowance is to be made out of remuneration paid to directors under section 40A(2)(b) of the Act. The assessee has filed the copy of computation of income of directors Shri Adarsh Kothari at pages 165 to 168 of the Paper Book and Shri Amit Kothari at pages 169 to 171

DANA ANAND INDIA PRIVATE LIMITED,PUNE vs. DCIT, AKURDI,PUNE

Bench: Shri R. K. Panda & Shri Vinay Bhamore

171,08,51,010/- 3 Variation in respect of disallowance of deduction claimed u/s 80G of the Act 1,57,55,750/- 4 Addition u/s 41 of the Act 6,66,765/- 5 Education cess 1,59,33,528/- 6 Total variations made 3,23,56,340/- 7 Total Income 174,32,07,350/- 4. Subsequently, the Assessing Officer passed

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

171/- in respect of expenditure incurred on clinical trial expenditure. Admittedly, this expenditure was incurred outside approved facility for the purpose of section 35(2AB) of the Act. The Hon’ble Gujarat 31 High court in the case of Cadila Healthcare Ltd. (supra) while dealing the identical issue held as follows :- “15. Such explanation thus provides that for the purpose

GOVERNMENT PRINTING PRESS EMPLOYEE CREDIT CO-OPERATIVE SOCIETY LTD,PUNE vs. ITO, WARD 7(1), PUNE, PUNE

In the result, appeal of the Assessee is allowed

Bench: Ms.Astha Chandra & Dr.Dipak P. Ripoteआयकर अपऩल सं. / Ita No.793/Pun/2025 निर्धारण वषा / Assessment Year: 2019-20 Government Printing Press V The Income Tax Officer, Employee Credit Co-Operative S Ward-7(1), Pune. Society Limited, Yerawadakaragruh, Airport Road, Yerawada, Pune – 411006. Pan: Aabag2986P Appellant/ Assessee Respondent / Revenue Assessee By Mr.Sarvesh Khandelwal Revenue By Shri Ramnath P Murkunde Date Of Hearing 16/09/2025 Date Of Pronouncement 30/09/2025 आदेश/ Order Per Dr. Dipak P. Ripote, Am: This Is An Appeal Filed By The Assessee Against The Order Of Ld.Additional/Joint Commissioner Of Income Tax(Appeal)-2, Visakhapatnamunder Section 250 Of The Income Tax Act, 1961 Dated 30.01.2025 Emanating From The Assessment Order Passed Under Section 143(1) Of The Act, Dated 02.12.2020 For Ay 2019-20.The Assessee Has Raised The Following Grounds Of Appeal :

disallowance of deduction claimed u/s 80P(2)(a)(i) of Rs.1,30,92,363/-, 80P(2)(c) of Rs.28,171/- and u/s 80P(2)(d) of Rs.13,08,573/- while processing the return u/s 143(1) of the Income Tax Act, 1961 is not covered by scope of the said section

M N NAVALE BIGGER HUF,,PUNE vs. DEPUTY COMMISSIONER OF INCOME TAX,, PUNE

Appeals are partly allowed for statistical purposes

Bench: Shri D. Karunakara Rao, Am & Shri Partha Sarathi Chaudhury, Jm Sl. No.

section 131 of the Act, they were not utilized by the Assessing Officer in this proceedings. Further, the Assessing Officer further noticed that all the transactions done by HUF were in cash only and no transactions involving the banking channels were reported. That further, the brothers of Shri M.N. Navale (Karta of Bigger HUF) have borrowed various loans of small

M N NAVALE BIGGER HUF,,PUNE vs. ASSISTANT COMMISSIONER OF INCOME TAX,, PUNE

Appeals are partly allowed for statistical purposes

Bench: Shri D. Karunakara Rao, Am & Shri Partha Sarathi Chaudhury, Jm Sl. No.

section 131 of the Act, they were not utilized by the Assessing Officer in this proceedings. Further, the Assessing Officer further noticed that all the transactions done by HUF were in cash only and no transactions involving the banking channels were reported. That further, the brothers of Shri M.N. Navale (Karta of Bigger HUF) have borrowed various loans of small

M N NAVALE BIGGER HUF,,PUNE vs. ASSISTANT COMMISSIONER OF INCOME TAX,, PUNE

Appeals are partly allowed for statistical purposes

Bench: Shri D. Karunakara Rao, Am & Shri Partha Sarathi Chaudhury, Jm Sl. No.

section 131 of the Act, they were not utilized by the Assessing Officer in this proceedings. Further, the Assessing Officer further noticed that all the transactions done by HUF were in cash only and no transactions involving the banking channels were reported. That further, the brothers of Shri M.N. Navale (Karta of Bigger HUF) have borrowed various loans of small

M N NAVALE BIGGER HUF,,PUNE vs. ASSISTANT COMMISSIONER OF INCOME TAX,, PUNE

Appeals are partly allowed for statistical purposes

Bench: Shri D. Karunakara Rao, Am & Shri Partha Sarathi Chaudhury, Jm Sl. No.

section 131 of the Act, they were not utilized by the Assessing Officer in this proceedings. Further, the Assessing Officer further noticed that all the transactions done by HUF were in cash only and no transactions involving the banking channels were reported. That further, the brothers of Shri M.N. Navale (Karta of Bigger HUF) have borrowed various loans of small

M N NAVALE BIGGER HUF,,PUNE vs. ASSISTANT COMMISSIONER OF INCOME TAX,, PUNE

Appeals are partly allowed for statistical purposes

Bench: Shri D. Karunakara Rao, Am & Shri Partha Sarathi Chaudhury, Jm Sl. No.

section 131 of the Act, they were not utilized by the Assessing Officer in this proceedings. Further, the Assessing Officer further noticed that all the transactions done by HUF were in cash only and no transactions involving the banking channels were reported. That further, the brothers of Shri M.N. Navale (Karta of Bigger HUF) have borrowed various loans of small

M N NAVALE BIGGER HUF,,PUNE vs. ASSISTANT COMMISSIONER OF INCOME TAX,, PUNE

Appeals are partly allowed for statistical purposes

Bench: Shri D. Karunakara Rao, Am & Shri Partha Sarathi Chaudhury, Jm Sl. No.

section 131 of the Act, they were not utilized by the Assessing Officer in this proceedings. Further, the Assessing Officer further noticed that all the transactions done by HUF were in cash only and no transactions involving the banking channels were reported. That further, the brothers of Shri M.N. Navale (Karta of Bigger HUF) have borrowed various loans of small

M N NAVALE BIGGER HUF,,PUNE vs. ASSISTANT COMMISSIONER OF INCOME TAX,, PUNE

Appeals are partly allowed for statistical purposes

Bench: Shri D. Karunakara Rao, Am & Shri Partha Sarathi Chaudhury, Jm Sl. No.

section 131 of the Act, they were not utilized by the Assessing Officer in this proceedings. Further, the Assessing Officer further noticed that all the transactions done by HUF were in cash only and no transactions involving the banking channels were reported. That further, the brothers of Shri M.N. Navale (Karta of Bigger HUF) have borrowed various loans of small

MARUTI NIVRUTTI NAVALE, (SMALLER HUF),PUNE vs. ASSISTANT COMMISSIONER OF INCOME TAX,, PUNE

Appeals are partly allowed for statistical purposes

Bench: Shri D. Karunakara Rao, Am & Shri Partha Sarathi Chaudhury, Jm Sl. No.

section 131 of the Act, they were not utilized by the Assessing Officer in this proceedings. Further, the Assessing Officer further noticed that all the transactions done by HUF were in cash only and no transactions involving the banking channels were reported. That further, the brothers of Shri M.N. Navale (Karta of Bigger HUF) have borrowed various loans of small

M N NAVALE BIGGER HUF,,PUNE vs. ASSISTANT COMMISSIONER OF INCOME TAX,, PUNE

Appeals are partly allowed for statistical purposes

Bench: Shri D. Karunakara Rao, Am & Shri Partha Sarathi Chaudhury, Jm Sl. No.

section 131 of the Act, they were not utilized by the Assessing Officer in this proceedings. Further, the Assessing Officer further noticed that all the transactions done by HUF were in cash only and no transactions involving the banking channels were reported. That further, the brothers of Shri M.N. Navale (Karta of Bigger HUF) have borrowed various loans of small

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]

disallowance of INR 4,50,70,798 under u/s 14A of the Act r.w rule 8D(2)(ii) be deleted. Ground 10: Additional relief under section 90 On the facts and circumstances of the case, and in law, the AU based on the directions of Ld. DRP erred in disregarding Appellant’s claim for additional relief under section

INCOME TAX OFFICER , JALNA vs. VIKRAM TEA PROCESSOR PRIVATE LIMITED , JALNA

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

Bench: Shri R. K. Panda & Ms Astha Chandraassessment Year : 2013-14

171,111,019 Cost plus AND POWDER 1108536 method Kgs. 4 BHAVESH R PATEL MACHINERY HIRE 597,000 CUP 252000, RENT 345000 TOTAL 1,091,880,205 3. He noted that the assessee has adopted CPM method as the most appropriate method. However, in absence of the mark-up of non-AEs, the TPO adopted internal Comparable Uncontrolled Price

INCOME TAX OFFICER WARD 1 JALNA, JALNA vs. VIKRAM TEA PROCESSOR PRIVATE LIMITED, JALNA

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

Bench: Shri R. K. Panda & Ms Astha Chandraassessment Year : 2013-14

171,111,019 Cost plus AND POWDER 1108536 method Kgs. 4 BHAVESH R PATEL MACHINERY HIRE 597,000 CUP 252000, RENT 345000 TOTAL 1,091,880,205 3. He noted that the assessee has adopted CPM method as the most appropriate method. However, in absence of the mark-up of non-AEs, the TPO adopted internal Comparable Uncontrolled Price

MAJALGAON SAHAKARI SAKHAR KARKHANA LTD.,,BEED vs. ASSISTANT COMMISSIONER OF INCOME-TAX,,

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

Bench: Shri D. Karunakara Rao, Am & Shri Vikas Awasthy, Jm आयकर अपील सं आयकर अपील सं. / Ita No.1523/Pun/2016 आयकर अपील सं आयकर अपील सं िनधा"रण वष" / Assessment Year : 2009-10 िनधा"रण वष" िनधा"रण वष" िनधा"रण वष"

section 154 disallowing assessee’s claim of set off of unabsorbed depreciation to the extent of Rs.12,70,39,171