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

2. On the facts and circumstances of the case and in law, the Ld. C1T(A) has erred in deleting the disallowance made by the Assessing Officer amounting of Rs.64683703/- made u/s 14A of the Income-tax Act, 1961 (hereinafter referred as 'the Act') since, the dividend and interest on bonds, share of profit from firms are the sources

ACIT, CIRCLE-5, PUNE, PUNE vs. SHRINIWAS ENGINEERING AUTO COMPONENTS PRIVATE LIMITED, PUNE

In the result, ITA Nos. 154 to 156/PUN/2025 filed by the assessee are partly allowed for statistical purposes, ITA

Bench: Dr.Manish Borad & Shri Vinay Bhamoreआयकर अपील सं. / Ita Nos.154 To 156/Pun/2025 Assessment Years : 2016-17 To 2018-19

disallowance u/s.36(1)(va) of the Act, ld. CIT(A) affirmed the action of the Assessing Officer placing reliance on the judgment of Hon’ble Apex Court in the case of Checkmate Services Pvt. Ltd. Vs. CIT (2022) 448 ITR 518 (SC). So far as the issue raised by the assessee against the addition made by ld. AO treating

SHRINIWAS ENGINEERING AUTO COMPONENTS PVT. LTD,PUNE vs. NATIONAL FACELESS APPEAL CENTRE, PUNE

In the result, ITA Nos. 154 to 156/PUN/2025 filed by the assessee are partly allowed for statistical purposes, ITA

Bench: Dr.Manish Borad & Shri Vinay Bhamoreआयकर अपील सं. / Ita Nos.154 To 156/Pun/2025 Assessment Years : 2016-17 To 2018-19

disallowance u/s.36(1)(va) of the Act, ld. CIT(A) affirmed the action of the Assessing Officer placing reliance on the judgment of Hon’ble Apex Court in the case of Checkmate Services Pvt. Ltd. Vs. CIT (2022) 448 ITR 518 (SC). So far as the issue raised by the assessee against the addition made by ld. AO treating

SHRINIWAS ENGINEERING AUTO COMPONENTS PVT. LTD,PUNE vs. NATIONAL FACELESS APPEAL CENTRE, PUNE

In the result, ITA Nos. 154 to 156/PUN/2025 filed by the assessee are partly allowed for statistical purposes, ITA

Bench: Dr.Manish Borad & Shri Vinay Bhamoreआयकर अपील सं. / Ita Nos.154 To 156/Pun/2025 Assessment Years : 2016-17 To 2018-19

disallowance u/s.36(1)(va) of the Act, ld. CIT(A) affirmed the action of the Assessing Officer placing reliance on the judgment of Hon’ble Apex Court in the case of Checkmate Services Pvt. Ltd. Vs. CIT (2022) 448 ITR 518 (SC). So far as the issue raised by the assessee against the addition made by ld. AO treating

SHRINIWAS ENGINEERING AUTO COMPONENTS PVT. LTD.,PUNE vs. ACIT, CIRCLE-5, PUNE, PUNE

In the result, ITA Nos. 154 to 156/PUN/2025 filed by the assessee are partly allowed for statistical purposes, ITA

Bench: Dr.Manish Borad & Shri Vinay Bhamoreआयकर अपील सं. / Ita Nos.154 To 156/Pun/2025 Assessment Years : 2016-17 To 2018-19

disallowance u/s.36(1)(va) of the Act, ld. CIT(A) affirmed the action of the Assessing Officer placing reliance on the judgment of Hon’ble Apex Court in the case of Checkmate Services Pvt. Ltd. Vs. CIT (2022) 448 ITR 518 (SC). So far as the issue raised by the assessee against the addition made by ld. AO treating

DY. COMMISSIONER OF INCOME-TAX, CIRCLE-5, PUNE vs. SHRINIWAS ENGINEERING AUTO COMPONENTS PVT. LTD., PUNE

In the result, ITA Nos. 154 to 156/PUN/2025 filed by the assessee are partly allowed for statistical purposes, ITA

Bench: Dr.Manish Borad & Shri Vinay Bhamoreआयकर अपील सं. / Ita Nos.154 To 156/Pun/2025 Assessment Years : 2016-17 To 2018-19

disallowance u/s.36(1)(va) of the Act, ld. CIT(A) affirmed the action of the Assessing Officer placing reliance on the judgment of Hon’ble Apex Court in the case of Checkmate Services Pvt. Ltd. Vs. CIT (2022) 448 ITR 518 (SC). So far as the issue raised by the assessee against the addition made by ld. AO treating

AURANGABAD DIVISION LIFE INSURANCE EMPLOYEES CO-OP CREDIT SOCIETY LTD,AURANBAD vs. ITO, WARD-1(1), AURANGABAD, AURANGABAD

In the result, appeal of the assessee is allowed

Bench: Dr.Dipak P. Ripote & Shri Vinay Bhamoreआयकर अपऩल सं. / Ita No.3175/Pun/2025 निर्धारण वषा / Assessment Year: 2020-21 Aurangabad Divison Life V The Income Tax Officer, Insurance Employees Co-Op S Ward-1(1), Aurangabad. Credit Society Ltd., 11, Jeevan Prakash, Lic Office Building Adalat Road, Kranti Chowk, Aurangabad -431005 Pan: Aaaaa2245A Appellant/ Assessee Respondent /Revenue Assessee By Ca Payal Rathi (Virtual) Revenue By Shri Sadananda – Jcit Date Of Hearing 09/02/2026 Date Of Pronouncement 10/02/2026 आदेश/ Order Per Dr. Dipak P. Ripote, Am: This Is An Appeal Filed By The Assessee Against The Order Of Ld.Commissioner Of Income Tax(Appeal)[Nfac], Passed Under Section 250 Of The Income Tax Act, 1961 For The A.Y.2020-21 Dated 24.09.2025 Emanating From The Assessment Order Passed Under Section 143(3) Read With Section 144B Of The Income Tax Act, 1961

disallowed by Assessing Officer. 3 ITA No.3175/PUN/2025 [A] 3.1 Thus, the issue before us is whether Assessee Co-operative Credit Society is eligible for deduction u/s.80P(2)(a)(i) of the Act, on the Interest Income earned from depositing excess funds. 3.2 The Hon’ble Supreme Court in the case of Bihar State Co- operative Bank

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, 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

37. Therefore, we are of the considered view that the petitioners are entitled to succeed. Hence, the writ petitions are allowed, and the order of the Assessing Officer, in so far as it relates to treating the interest income as something not allowable as a deduction under section 80P(2)(a), is set aside.” Unquote. 9.1 Thus, Hon’ble High

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

37. Therefore, we are of the considered view that the petitioners are entitled to succeed. Hence, the writ petitions are allowed, and the order of the Assessing Officer, in so far as it relates to treating the interest income as something not allowable as a deduction under section 80P(2)(a), is set aside.” Unquote. 9.1 Thus, Hon’ble High

HAVELI TALUKA VEEJ KAMGAR SAHAKARI PATHSANSTHA MARYADIT,PUNE vs. INCOME TAX OFFICER WARD 6 (1) PUNE, PMT BUILDING, SWARGATE

In the result, the appeal of the assessee is allowed

37,716/- on 30.11.2019 u/s 143(3) of the Act by making an\naddition of-(i) Rs.8,84,993/- on account of disallowance of claim of\ndeduction u/s 80P(2)(a)(i)/80P(2)(d) of the Act in respect of interest earned\nfrom PDCC Bank and (ii) on account of income of Rs.53,52,723/-, to the\nNil income

DCIT, CIRCLE-8 vs. M/S. BAJAJ FINANCE LTD. PUNE, AKURDI PUNE

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

2 - DISALLOWANCE OF CLAIM FOR DEDUCTION IN RESPECT OF EMPLOYEE STOCK OPTIONS (‘ESOP’) EXPENDITURE. 2.1 The CIT(A) erred in not allowing deduction in respect of ESOP expenditure of Rs.7,57,14,428 under section 37

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

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

2 - DISALLOWANCE OF CLAIM FOR DEDUCTION IN RESPECT OF EMPLOYEE STOCK OPTIONS (‘ESOP’) EXPENDITURE. 2.1 The CIT(A) erred in not allowing deduction in respect of ESOP expenditure of Rs.7,57,14,428 under section 37

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

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

2 - DISALLOWANCE OF CLAIM FOR DEDUCTION IN RESPECT OF EMPLOYEE STOCK OPTIONS (‘ESOP’) EXPENDITURE. 2.1 The CIT(A) erred in not allowing deduction in respect of ESOP expenditure of Rs.7,57,14,428 under section 37

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

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

2 - DISALLOWANCE OF CLAIM FOR DEDUCTION IN RESPECT OF EMPLOYEE STOCK OPTIONS (‘ESOP’) EXPENDITURE. 2.1 The CIT(A) erred in not allowing deduction in respect of ESOP expenditure of Rs.7,57,14,428 under section 37

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

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

2 - DISALLOWANCE OF CLAIM FOR DEDUCTION IN RESPECT OF EMPLOYEE STOCK OPTIONS ('ESOP') EXPENDITURE. 2.1. The CIT(A) erred in not allowing deduction in respect of ESOP expenditure of Rs.14,98,37,670 under section

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

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

2 - DISALLOWANCE OF CLAIM FOR DEDUCTION IN RESPECT OF EMPLOYEE STOCK OPTIONS ('ESOP') EXPENDITURE. 2.1. The CIT(A) erred in not allowing deduction in respect of ESOP expenditure of Rs.14,98,37,670 under section

DY. COMMISSIONER OF INCOME TAX, CIRCLE-1(1), PUNE, PUNE vs. HONEYWELL AUTOMATION INDIA LIMITED, PUNE

In the result, the appeal of the Revenue is dismissed

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

2 to section 37(1) of the Act, they are specifically excluded in clarification issued. There is no restriction on an expenditure being claimed under above sections to be exempt, as long as it satisfies necessary conditions under section 30 to 36 of the Act, for computing income under the head, “Income from Business and Profession”. 16. For claiming benefit