DCIT, CIRCLE-8, PUNE vs. MAHLE ANAND THERMAL SYSTEMS PVT. LTD., PUNE

disallowance of weighted deduction claimed on expenditure incurred outside India.\n\n5. In appeal, the Ld. CIT(A) allowed expenses incurred outside India on R&D u/s 35(1)(iv) although such claim was not under the same section but was u/s 35(2AB) by observing as under:\n\n“2.3 I have carefully considered the submission of the appellant

SURIA STEELTECH PRIVATE LIMITED (PREVIOUSLY KNOWN AS TMS ENGINEERS PRIVATE LIMITED),PUNE vs. ASSESSING OFFICER, WARD-9(4), PUNE, PUNE

Appeal is dismissed in above terms

Bench: Shri Satbeer Singh Godara & Dr. Dipak P. Ripote

disallowance is called for because of the per se late deposit of the employees’ share beyond the due date under the respective Act and section 43B is of no assistance. 4. Before proceeding further, it would be apposite to take note of the relevant statutory provision in this regard. Section 2(24) provides that `income’ includes: `(x) any sum received

DCIT,CIRCLE-8 , PUNE vs. MAHALE ANAND THERMAL SYSTEMS PVT. LTD. , PUNE

In the result, the appeal and the CO filed by the assessee are partly allowed and the appeals filed by the Revenue are dismissed

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

disallowance of weighted deduction claimed on expenditure incurred outside India. 5. In appeal, the Ld. CIT(A) allowed expenses incurred outside India on R&D u/s 35(1)(iv) although such claim was not under the same section but was u/s 35(2AB) by observing as under: “2.3 I have carefully considered the submission of the appellant in light

DCIT CIRCLE 8 , PUNE vs. MAHLE ANAND THERMAL SYSTEMS PVT. LTD, PUNE

In the result, the appeal and the CO filed by the assessee are partly allowed and the appeals filed by the Revenue are dismissed

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

disallowance of weighted deduction claimed on expenditure incurred outside India. 5. In appeal, the Ld. CIT(A) allowed expenses incurred outside India on R&D u/s 35(1)(iv) although such claim was not under the same section but was u/s 35(2AB) by observing as under: “2.3 I have carefully considered the submission of the appellant in light

MAHLE ANAND THERMAL SYSTEMS PRIVATE LIMITED,PUNE vs. DY COMMISSIONER OF INCOME TAX, PUNE

In the result, the appeal and the CO filed by the assessee are partly allowed and the appeals filed by the Revenue are dismissed

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

disallowance of weighted deduction claimed on expenditure incurred outside India. 5. In appeal, the Ld. CIT(A) allowed expenses incurred outside India on R&D u/s 35(1)(iv) although such claim was not under the same section but was u/s 35(2AB) by observing as under: “2.3 I have carefully considered the submission of the appellant in light

INCOME TAX OFFICER WARD 1 SATARA, SATARA vs. KARAD PATAN TALUKA PRATHMIK SHIKSHAK SAHAKARI SOCIETY LIMITEDTY , KARAD

In the result, Revenue’s Appeal is dismissed

Bench: Dr.Dipak P. Ripote & Shri Vinay Bhamoreआयकर अपऩल सं. / Ita No.2289/Pun/2025 निर्धारण वषा / Assessment Year: 2020-21 Income Tax Officer, V Karad Patan Taluka Prathmik Ward-1, Satara. S Shikshak Sahakari Society Limited, 190 B Shaniwar Peth, Opp.Shivneri Lodge, Karad, Satara – 415110 Pan: Aaaak0559R Appellant / Assessee Respondent / Revenue Assessee By Shri Satish U Nade Revenue By Smt Neha Thakur (Virtual) Date Of Hearing 21/01/2026 Date Of Pronouncement 23/01/2026 आदेश/ Order Per Dr. Dipak P. Ripote, Am: This Appeal Filed By The Revenue Against The Order Of Ld.Commissioner Of Income Tax(Appeal)[Nfac], Passed Under Section 250 Of The Income Tax Act, 1961 For A.Y.2020-21 Dated 21.08.2025 Emanating From The Assessment Order Passed Under Section 143(3) Read With Section 144B Of The I.T .Act, 1961 Dated

disallowed assessee’s claim for deduction u/s.80P(2) of the Act. The relevant paragraphs 4.5 to 6 of Assessment Order are reproduced here as under : 3 ITA No.2289/PUN/2025 [A] “4.5.) Further, it may be noted that the assessee for the year under consideration has claimed the deduction U's 80P of the Act to the extent of Rs. 2

INCOME TAX OFFICER WARD-2, AHMEDNAGAR, AHMEDNAGAR vs. KANIFNATH GRMAIN BIGAR SHETI SAHAKARI, MALDAD SANGAMNER

In the result, Revenue’s Appeal is dismissed

Bench: Dr.Dipak P. Ripote & Shri Vinay Bhamoreआयकर अपऩल सं. / Ita Nos.2270 & 2271/Pun/2025 निर्धारण वषा / Assessment Year: 2018-19 The Income Tax Officer, V Kanifnath Gramin Bigar Sheti Ward-2, Ahmednagar. S Sahakaripatsanstha Maryadit, At Post Malad, Taluka Sangamner, Ahmednagar – 422608. Pan: Aabak1395E Appellant/ Revenue Respondent /Assessee Assessee By Shri Pramod S Shingte – Ar Revenue By Smt Neha Thakkar (Virtual) Date Of Hearing 19/01/2026 Date Of Pronouncement 21/01/2026 आदेश/ Order Per Bench : These Two Appeals Filed By The Revenue Against The Separate Orders Of Ld.Commissioner Of Income Tax(Appeal)[Nfac],Passed Under Section 250 Of The Income Tax Act, 1961 For A.Y.2018- 19Dated 01.07.2025 Emanating From The Assessment Order Dated 30.03.2021 Under Section 143(3) R.W.S. 143(3A) & 143(3B) Of The Income Tax Act, 1961 & Order Under Section 250 Of The Income

iv) On the facts and the circumstances of the case and in law, the Ld. CIT(A)/NFAC erred in allowing the deduction u/s 80P(2)(d) of the Act without considering the decision of the Hon'ble High Court of Karnataka in the case of PCIT, Hubballi Vs. Totagars Co-operative Sale Society [395 ITR 611] dated

INCOME TAX OFFICER WARD-2, AHMEDNAGAR, AHAMEDNAGAR vs. KANIFNATH GRMAIN BIGAR SHETI SAHAKARIPATSANSTHA MARYADIT, , MALDAD

In the result, Revenue’s Appeal is dismissed

Bench: Dr.Dipak P. Ripote & Shri Vinay Bhamoreआयकर अपऩल सं. / Ita Nos.2270 & 2271/Pun/2025 निर्धारण वषा / Assessment Year: 2018-19 The Income Tax Officer, V Kanifnath Gramin Bigar Sheti Ward-2, Ahmednagar. S Sahakaripatsanstha Maryadit, At Post Malad, Taluka Sangamner, Ahmednagar – 422608. Pan: Aabak1395E Appellant/ Revenue Respondent /Assessee Assessee By Shri Pramod S Shingte – Ar Revenue By Smt Neha Thakkar (Virtual) Date Of Hearing 19/01/2026 Date Of Pronouncement 21/01/2026 आदेश/ Order Per Bench : These Two Appeals Filed By The Revenue Against The Separate Orders Of Ld.Commissioner Of Income Tax(Appeal)[Nfac],Passed Under Section 250 Of The Income Tax Act, 1961 For A.Y.2018- 19Dated 01.07.2025 Emanating From The Assessment Order Dated 30.03.2021 Under Section 143(3) R.W.S. 143(3A) & 143(3B) Of The Income Tax Act, 1961 & Order Under Section 250 Of The Income

iv) On the facts and the circumstances of the case and in law, the Ld. CIT(A)/NFAC erred in allowing the deduction u/s 80P(2)(d) of the Act without considering the decision of the Hon'ble High Court of Karnataka in the case of PCIT, Hubballi Vs. Totagars Co-operative Sale Society [395 ITR 611] dated

M/S. SHIVAMM INDUSTRIES,PUNE vs. THE DEPUTY COMMISSIONER OF INCOME TAX, CIRCLE-8, PUNE

In the result, appeal of the Assessee is Dismissed

Bench: Shri S.S.Godara & Dr. Dipak P. Ripoteआयकरअपीलसं. / Ita No.393/Pun/2023 िनधा"रणवष" / Assessment Year : 2013-14 M/S.Shivamm Industries, The Dy.Commissioner Of Plot 76, Arihant Heights, Sector Vs Income Tax, Circle-8, No.25, Pradhikaran Nigdi, Pune. Pune – 411044. Pan: Aaefs 0458 A Appellant/ Assessee Respondent /Revenue Assessee By None. Revenue By Shri M.G.Jasnani – Dr Date Of Hearing 15/05/2023 Date Of Pronouncement 26/05/2023 आदेश/ Order Per Dr. Dipak P. Ripote, Am: This Is An Appeal Filed By The Assessee I.E. Shivamm Industries For A.Y. 2013-14 Against The Order Of Ld.Commissioner Of Income Of Tax(Appeals)[Nfac] Dated 21.03.2023 Emanating From Assessing Officer’S Order Under Section 154 Of The Act Dated 22.03.2021. The Ground Of Appeal Are As Under : “1. The Order Dated 21/03/2023 Bearing No.Itba/Nfac/S/250/2022-23/1051048828[L] Passed Under Section 250 Of Income Tax Act, 1961 By The Hon’Ble Cit[Appeals], National Faceless Appeal Centre [Nfac], Delhi, Is Excessive, M/S.Shivamm Industries [A]

disallowance is called for because of the per se late deposit of the employees’ share beyond the due date under the respective Act and section 43B is of no assistance. 4. Before proceeding further, it would be apposite to take note of the relevant statutory provision in this regard. Section 2(24) provides that `income’ includes: `(x) any sum received

CAPGEMINI TECHNOLOGY SERVICES INDIA LIMITED ( SUCCESSOR OF ARICENT TECHNOLOGIES HOLDINGS LIMITED),PUNE vs. ASSISTANT COMMISSIONER OF INCOME TAX, CIRCLE 1(1), PUNE, PUNE

In the result, the appeal of the assessee is allowed

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

disallowance of health and education cess. Post amendment brought by the Finance Act, 2022, the assessee also filed Form 69 as mandated by the amended provisions withdrawing its claim of deduction towards health and education cess for AY 2020-21. Therefore, in our view, there was no error on the part of the assessee in claiming education cess

DEPUTY COMMISSIONER OF INCOME TAX CIRCLE 12 PUNE, PUNE vs. JANATA GRAHAK MADHYAWARTI SAHKARI SANGH MARYADIT, PUNE

In the result, the appeal of the Revenue in ITA No

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

disallowance of deduction claimed u/s 80P(2)(d) of the Act, to the total income of Rs.1,54,81,910/- returned by the assessee u/s 147 r.w.s. 144B of the Act vide his order dated 26.05.2023. 3. Aggrieved, the assessee filed appeal before the Ld. CIT(A). The Ld. CIT(A) in para 5.4 of his appellate order observed that

DEPUTY COMMISSIONER OF INCOME TAX CIRCLE-12 PUNE, PUNE vs. JANATA GRAHAK MADHYAWARTI SAHKARI SANGH MARYADIT, PUNE

In the result, the appeal of the Revenue in ITA No

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

disallowance of deduction claimed u/s 80P(2)(d) of the Act, to the total income of Rs.1,54,81,910/- returned by the assessee u/s 147 r.w.s. 144B of the Act vide his order dated 26.05.2023. 3. Aggrieved, the assessee filed appeal before the Ld. CIT(A). The Ld. CIT(A) in para 5.4 of his appellate order observed that

DEPUTY COMMISSIONER OF INCOME TAX CIRCLE-12 PUNE, PUNE vs. JANATA GRAHAK MADHYAWARTI SAHKARI SANGH MARYADIT, PUNE

In the result, the appeal of the Revenue in ITA No

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

disallowance of deduction claimed u/s 80P(2)(d) of the Act, to the total income of Rs.1,54,81,910/- returned by the assessee u/s 147 r.w.s. 144B of the Act vide his order dated 26.05.2023. 3. Aggrieved, the assessee filed appeal before the Ld. CIT(A). The Ld. CIT(A) in para 5.4 of his appellate order observed that

INCOME TAX OFFICER, WARD-8(3), PUNE, PUNE vs. M/S. TATA MOTORS KARMACHARI SAHAKARI PATPEDHI LIMITED, PUNE

In the result, appeal of the Revenue is dismissed

Bench: Dr.Dipak P. Ripote & Shri Vinay Bhamoreआयकर अपील सं. / Ita No.2529/Pun/2024 िनधा"रण वष" / Assessment Year: 2017-18 The Income Tax Officer, V Tata Motors Karmachari Ward-8(3), Pune. S. Sahakari Patpedhi, H 5 3Rd Floor, C/O.Tata Motors, Pune City, Pune – 411018. Pan: Aabat7682B Appellant/ Revenue Respondent / Assessee Assessee By Shri Sanket Joshi – Ar Revenue By Shri Abhinay Kumbhar – Cit(Dr) Date Of Hearing 06/05/2025 Date Of Pronouncement 08/05/2025 आदेश/ Order Per Dr. Dipak P. Ripote, Am: This Is An Appeal Filed By The Revenue Against The Order Of Ld.Commssioner Of Income Tax(Appeal)[Nfac] Passed Under Section 250 Of The Act, Dated 04.10.2024 For The A.Y.2017-18. The Revenue Has Raised The Following Grounds Of Appeal : “1. On The Facts & Circumstances Of The Case & In Law, The Learned Cit(A) Has Erred In Deleting The Disallowance Made By The Assessing Officer Of The Deduction Of Rs. 6,18,57,845/- Claimed Under Section Bop Of The Income-Tax Act, 1961 Being Interest Earned From The Investments

disallowed the entire claim of 80P of the Assessee. Assessee filed appeal before the ld.CIT(A).Ld.CIT(A) allowed the assessee’s appeal following ITAT Pune’s decision in Assessee’s own case for A.Y.2012-13 in ITA No.2596/PUN/2016. 4.2 Aggrieved by the order of the ld.CIT(A), Revenue filed appeal before this Tribunal. 4.3 Ld.DR has not brought on record

RAVINDRA DNYANESHWR BHUJBAL,PUNE vs. INCOME TAX OFFICER, WARD-14(5), PUNE, PUNE

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

disallowance is called for because of the per se late deposit of the employees’ share beyond the due date under the respective Act and section 43B is of no assistance. 4. Before proceeding further, it would be apposite to take note of the relevant statutory provision in this regard. Section 2(24) provides that `income’ includes: `(x) any sum received

M/S. THE KOTHARI WHEELS ,PUNE vs. DCIT, CPC,BANGALORE, BANGLORE

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

Bench: SHRI INTURI RAMA RAO (Accountant Member), SHRI PARTHA SARATHI CHAUDHURY (Judicial Member)

disallowance is called for because of the per se 3 late deposit of the employees’ share beyond the due date under the respective Act and section 43B is of no assistance. 4. Before proceeding further, it would be apposite to take note of the relevant statutory provision in this regard. Section 2(24) provides that `income’ includes

GORIBI ABDUL KARIM NADAF,PUNE vs. COMMISSIONER OF INCOME TAX (APPEALS), ADDL JCIT (A) 1 - AHMEDABAD, COMMISSIONER OF INCOME TAX (APPEALS), ADDL/JCIT (A) AHMEDABAD

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

Bench: Shri Inturi Rama Rao & Shri Vinay Bhamore

disallowance is called for because of the per se late deposit of the employees’ share beyond the due date under the respective Act and section 43B is of no assistance. 4. Before proceeding further, it would be apposite to take note of the relevant statutory provision in this regard. Section 2(24) provides that `income’ includes: `(x) any sum received

GORIBI ABDUL KARIM NADAF,PUNE vs. COMMISSIONER INCOME TAX (APPEALS), ADDL JCIT (A) -1 AHMEDABAD, AHMEDABAD

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

Bench: Shri Inturi Rama Rao & Shri Vinay Bhamore

disallowance is called for because of the per se late deposit of the employees’ share beyond the due date under the respective Act and section 43B is of no assistance. 4. Before proceeding further, it would be apposite to take note of the relevant statutory provision in this regard. Section 2(24) provides that `income’ includes: `(x) any sum received