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194 results for “disallowance”+ Section 2(47)clear

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Key Topics

Section 14A90Section 143(3)69Addition to Income63Disallowance57Section 143(2)43Deduction35Section 25032Section 12A29Section 143(1)28Section 153A

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

ITA 154/PUN/2025[2016-17]Status: DisposedITAT Pune22 Dec 2025AY 2016-17

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

For Respondent: Shri Amit Bobde
Section 143(1)(a)Section 143(2)Section 2(24)(xviii)Section 43

47 Taxman 366 (Bombay). 3.1 It is further respectfully submit that the argument of the Ld. Departmental Representative is incorrect for the following reasons. Clause (XVIII) of section 2(24) was introduced in the Income Tax Act by Finance Act 2015 applicable from Assessment Year 2016-17, to include the Government Grants/Subsidy in the definition of income. The Central Board

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Section 1127
Penalty19

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

ITA 156/PUN/2025[2018-19]Status: DisposedITAT Pune22 Dec 2025AY 2018-19

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

For Respondent: Shri Amit Bobde
Section 143(1)(a)Section 143(2)Section 2(24)(xviii)Section 43

47 Taxman 366 (Bombay). 3.1 It is further respectfully submit that the argument of the Ld. Departmental Representative is incorrect for the following reasons. Clause (XVIII) of section 2(24) was introduced in the Income Tax Act by Finance Act 2015 applicable from Assessment Year 2016-17, to include the Government Grants/Subsidy in the definition of income. The Central Board

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

ITA 114/PUN/2025[2020]Status: DisposedITAT Pune22 Dec 2025

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

For Respondent: Shri Amit Bobde
Section 143(1)(a)Section 143(2)Section 2(24)(xviii)Section 43

47 Taxman 366 (Bombay). 3.1 It is further respectfully submit that the argument of the Ld. Departmental Representative is incorrect for the following reasons. Clause (XVIII) of section 2(24) was introduced in the Income Tax Act by Finance Act 2015 applicable from Assessment Year 2016-17, to include the Government Grants/Subsidy in the definition of income. The Central Board

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

ITA 1423/PUN/2025[2019-20]Status: DisposedITAT Pune22 Dec 2025AY 2019-20

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

For Respondent: Shri Amit Bobde
Section 143(1)(a)Section 143(2)Section 2(24)(xviii)Section 43

47 Taxman 366 (Bombay). 3.1 It is further respectfully submit that the argument of the Ld. Departmental Representative is incorrect for the following reasons. Clause (XVIII) of section 2(24) was introduced in the Income Tax Act by Finance Act 2015 applicable from Assessment Year 2016-17, to include the Government Grants/Subsidy in the definition of income. The Central Board

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

ITA 1844/PUN/2024[2019]Status: DisposedITAT Pune22 Dec 2025

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

For Respondent: Shri Amit Bobde
Section 143(1)(a)Section 143(2)Section 2(24)(xviii)Section 43

47 Taxman 366 (Bombay). 3.1 It is further respectfully submit that the argument of the Ld. Departmental Representative is incorrect for the following reasons. Clause (XVIII) of section 2(24) was introduced in the Income Tax Act by Finance Act 2015 applicable from Assessment Year 2016-17, to include the Government Grants/Subsidy in the definition of income. The Central Board

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

ITA 2289/PUN/2025[2020]Status: DisposedITAT Pune23 Jan 2026

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

Section 143(3)Section 144BSection 250Section 56Section 57Section 80Section 80PSection 80P(2)Section 80P(2)(a)Section 80P(2)(d)

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-1 PANDHARPUR, INCOME TAX OFFICE PANDHARPUR vs. YASHODA MAHILA NAGARI SAHAKARI PATSANSTHA , MANGALWEDHA DISTRICT SOLAPUR

ITA 2741/PUN/2024[2022-23]Status: DisposedITAT Pune03 Jun 2025AY 2022-23
Section 143(2)Section 143(3)Section 80PSection 80P(2)(a)Section 80P(2)(d)

47,581/- as against the income returned by the\nassessee at Rs.Nil.\n3. In first appeal after considering the submissions of the\nassessee co-operative society, Ld. CIT(A)/NFAC allowed the\nappeal filed by the assessee by relying on various decisions passed\nby a coordinate bench of this Tribunal. It is this order against\nwhich the Revenue

SHRINIWAS ENGINEERING AUTO COMPONENTS PVT. LTD,PUNE vs. ITO WARD6(1), PUNE

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

ITA 157/PUN/2025[2020-21]Status: DisposedITAT Pune22 Dec 2025AY 2020-21
Section 143(1)(a)Section 143(2)Section 2(24)(xviii)Section 43

47 Taxman 366 (Bombay).\n\n3.1 It is further respectfully submit that the argument of the Ld.\nDepartmental Representative is incorrect for the following reasons.\n\nClause (XVIII) of section 2(24) was introduced in the Income Tax Act\nby Finance Act 2015 applicable from Assessment Year 2016-17, to\ninclude the Government Grants/Subsidy in the definition of income

ACIT, PUNE vs. SHRINIWAS ENGINEERING AUTO COMPONENTS PRIVATE LIMITED, PUNE

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

ITA 1843/PUN/2024[2018]Status: DisposedITAT Pune22 Dec 2025
Section 2(24)(xviii)Section 43

47 Taxman 366 (Bombay).\n3.1 It is further respectfully submit that the argument of the Ld.\nDepartmental Representative is incorrect for the following reasons.\nClause (XVIII) of section 2(24) was introduced in the Income Tax Act\nby Finance Act 2015 applicable from Assessment Year 2016-17, to\ninclude the Government Grants/Subsidy in the definition of income.\nThe Central Board

SHRINIWAS ENGINEERING AUTO COMPONENTS PVT. LTD,PUNE vs. ITO WARD 6(1), PUNE

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

ITA 155/PUN/2025[2017-198]Status: DisposedITAT Pune22 Dec 2025AY 2017-198
Section 143(1)(a)Section 143(2)Section 2(24)(xviii)Section 43

47 Taxman 366 (Bombay).\n3.1 It is further respectfully submit that the argument of the Ld.\nDepartmental Representative is incorrect for the following reasons.\nClause (XVIII) of section 2(24) was introduced in the Income Tax Act\nby Finance Act 2015 applicable from Assessment Year 2016-17, to\ninclude the Government Grants/Subsidy in the definition of income.\nThe Central Board

PUNE MADHYAMIK SHIKSHAK SAHKARI PATAPEDHI MARYADIT,PUNE vs. PRINCIPAL COMMISSIONER OF INCOME TAX,PUNE 4, PUNE

In the result, the appeal filed by the assessee is allowed

ITA 909/PUN/2025[2020-21]Status: HeardITAT Pune03 Jul 2025AY 2020-21

Bench: Shri R. K. Panda & Ms Astha Chandraassessment Year : 2020-21

For Appellant: Shri Sharad A ShahFor Respondent: Shri Amit Bobde, CIT
Section 143(2)Section 143(3)Section 263Section 56Section 80Section 80PSection 80P(2)(a)Section 80P(2)(d)

section 80P(2)(a)(i) and 8 80P(2)(d) in respect of interest income earned from the co-operative banks. Therefore, the issue raised by the Ld. PCIT has already been decided in favour of the assessee. Even otherwise also, it is a highly debatable issue and the Assessing Officer has taken a plausible view, therefore, the Ld. PCIT

PUNE MATHADI HAMAL AND OTHER MANUAL WORKERS BOARD,PUNE vs. INCOME TAX OFFICER, WARD-5(1), PUNE, PUNE

In the result, appeal of the assessee is partly allowed

ITA 1012/PUN/2023[2018-19]Status: DisposedITAT Pune27 Jun 2024AY 2018-19

Bench: Shri S.S.Godara & Dr. Dipak P. Ripoteआयकर अपील सं. / Ita No.1012/Pun/2023 िनधा"रण वष" / Assessment Year : 2018-19 Pune Mathadihamal & Other The Income Tax Manual Workers Board, V Officer, Shramashakti Bhavan, S Ward-5(1), Pune. Coomercial Plot No.1, Market Yard, Pune – 411037. Pan: Aaalp0097L Appellant/ Assessee Respondent /Revenue Assessee By Shri Vipul Joshi – Ar Revenue By Shri Ajay Kumar Keshari & Shri Rajesh Gawali– Dr’S Date Of Hearing 17/04/2024 Date Of Pronouncement 27/06/2024 आदेश/ Order Per Dr. Dipak P. Ripote, Am: This Appeal Filed By The Assessee Is Against The Orders Of Ld.Commissionerof Income Tax(Appeals)[Nfac], Under Section 250 Of The Act Dated 14.07.2023 :

For Appellant: 2. The ld.AR submitted written submissions, relevant part of the same is reprodu
Section 11Section 12ASection 143(3)Section 250

section 40A (2) of the Act. The assessee i.e NLT had received services from TACL in respect of which payment had been made as per documentary evidence on record and thus, there was no warrant for disallowance paid to TACL by the assessee when the payment was adjudged on the principle of commercial expediency when viewed from the point

ITO, PUNE vs. THE GOVERNMENT SERVENTS MAHARASHTRA CO-OP CREDIT SOCIETY LIMITED PUNE, PUNE

In the result, both the appeals filed by the Revenue are\ndismissed

ITA 713/PUN/2024[2017-18]Status: DisposedITAT Pune08 Sept 2025AY 2017-18
For Appellant: Shri Pramod S. Shingte, CAFor Respondent: Shri Ramnath P. Murkunde, DR
Section 143(2)Section 250Section 80P

disallowed the entire claim of 80P deduction to the\nappellant.\n6.3 After giving finding in Para 45 for ascertaining the status of\nan entity as a co-operative society, in para 46 and 47, Hon'ble\nApex Court in Mavilayi judgment had distinguished the Kerala\nco-operative society Act vis-à-vis the Multipurpose co-operative\nsociety Act in Citizens

NERE VIBHAG NAGARI SAH. PATSANSTHA MARYADIT,PUNE vs. INCOME TAX OFFICER WARD 5(4), PUNE

In the result, appeal of the Assessee is partly allowed

ITA 2374/PUN/2025[2017-18]Status: DisposedITAT Pune29 Jan 2026AY 2017-18

Bench: Dr.Dipak P. Ripote & Shri Vinay Bhamoreआयकर अपऩल सं. / Ita No.2374/Pun/2025 निर्धारण वषा / Assessment Year: 2017-18 Nere Vibhag Nagari Sah. V Income Tax Officer, Patsanstha Maryadit, S Ward-5(4), Pune. 61, Mangalwar Peth, Tal – Bhor, Pune – 412206. Pan: Aacan2385C Appellant/ Assessee Respondent /Revenue Assessee By Shri Pramod S Shingte Revenue By Shri Ajitesh Kumar Meena – Addl.Cit Date Of Hearing 27/01/2026 Date Of Pronouncement 29/01/2026 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.2017-18 Dated 31.07.2025 Emanating From The Assessment Order Passed Under Section 144 Of The Act, Dated 04.12.2019. The Assessee Has Raised The Following Grounds Of Appeal :

Section 144Section 250Section 80PSection 80P(2)(a)Section 80P(2)(d)

47,585/-. 5. In the Ground No.2 raised by the Assessee before us, Assessee has stated that it had claimed deduction u/s.80P(2)(a)(i) of Rs.33,18,280/-, we have verified the Return of Income filed by the Assessee and noted that Assessee had claimed deduction u/s.80P(2) of Rs.33,18,277/- in the Return of Income. 6. Section

KOTHARI AGRITECH PVT. LTD,,SOLAPUR vs. THE DCIT, CIRCLE-1, SOLAPUR

In the result, the both appeals of the assessee in ITA Nos

ITA 2455/PUN/2024[2018-2019]Status: DisposedITAT Pune09 Sept 2025AY 2018-2019

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

For Appellant: Shri Nikhil TiwariFor Respondent: Shri Ramnath P Murkunde
Section 143Section 143(1)Section 143(1)(a)Section 143(3)Section 14ASection 154Section 80Section 801ASection 80ISection 80J

47,44,809. However, the Appellant vide letter dated 18/03/21 to Jurisdiction AO, Solapur copy enclosed as Annexure B, its response has already clarified that there is only a difference in the manner of presentation and the Appellant has rightfully claimed the same as deduction on payment basis under section 43B and the action of the CPC in not allowing

KOTHARI AGRITECH PRIVATE LIMITED,SOLAPUR vs. DCIT CIRCLE-1, SOLAPUR

In the result, the both appeals of the assessee in ITA Nos

ITA 2392/PUN/2024[2018-19]Status: DisposedITAT Pune09 Sept 2025AY 2018-19

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

For Appellant: Shri Nikhil TiwariFor Respondent: Shri Ramnath P Murkunde
Section 143Section 143(1)Section 143(1)(a)Section 143(3)Section 14ASection 154Section 80Section 801ASection 80ISection 80J

47,44,809. However, the Appellant vide letter dated 18/03/21 to Jurisdiction AO, Solapur copy enclosed as Annexure B, its response has already clarified that there is only a difference in the manner of presentation and the Appellant has rightfully claimed the same as deduction on payment basis under section 43B and the action of the CPC in not allowing

INCOME TAX OFFICER, PUNE vs. SAGAR CONSTRUCTION COMPANY, PUNE

In the result, the appeal filed by the Revenue is dismissed and the CO filed by the assessee is allowed

ITA 1812/PUN/2025[2017-18]Status: DisposedITAT Pune08 Jan 2026AY 2017-18

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

For Appellant: Shri Suhas Bora and Riya OswalFor Respondent: Shri S. Sadananda Singh, JCIT
Section 142(1)Section 143(1)Section 147Section 148Section 269SSection 37Section 68

disallowed the same u/s 37 of the Act. Thus, the Assessing Officer computed the total income of the assessee at Rs.2,22,86,304/-. 6. Before the Ld. CIT(A) / NFAC the assessee submitted that the reasons for reopening were communited to the assessee after 11 months of issue of notice u/s 148 of the Act although the assessee

RANAJIT SURESH RAJAMANE,SOLAPUR vs. ITO, WARD 1, PANDHARPUR, PANDHARPUR

In the result, the appeal of the assessee is allowed

ITA 1678/PUN/2024[2014-15]Status: DisposedITAT Pune13 Jan 2026AY 2014-15

Bench: Dr. Manish Borad & Ms. Astha Chandraआयकर अपील सं. / Ita No.1678/Pun/2024 धििाारण वर्ा / Assessment Year: 2014-15 Ranajit Suresh Rajamane, Vs Ito Ward 1, Shukrawar Peth, Pandharpur Tembhurni Madha Solapur- 413211 Maharashtra Pan-Bmepr3878N Appellant Respondent

For Appellant: Smt. Deepa KhareFor Respondent: Shri Aviyogi Ambadkar
Section 139Section 147Section 148Section 250Section 54Section 548Section 54BSection 54B(1)Section 69A

disallowance of exemption u/s 548 in respect of investment in agricultural land and all the conditions have been complied with (iv) The Id CIT(A) erred in law and on facts in not appreciating that the appellant had made substantial payments towards consideration for purchase of the new agricultural land and possession was obtained in prescribed time thereby proving

DEPUTY COMMISSIONER OF INCOME-TAX, CIRCLE -3, NASHIK vs. WINDSOR MACHINES LTD., MUMBAI

In the result, the appeal of Revenue is partly allowed

ITA 915/PUN/2022[2011-12]Status: DisposedITAT Pune20 Oct 2023AY 2011-12

Bench: Shri S.S. Viswanethra Ravi & Shri G.D. Padmahshali

For Appellant: Shri Kishor B. PhadkeFor Respondent: Shri Ajay Kumar Kesari
Section 3Section 32(2)

47,14,614/- was disallowed vide Clause (v) read with Note 15 ITA No. 915/PUN/2022, A.Y. 2011-12 No. 1 thereto. On verification of company’s audit report r.w. tax audit report, we find that the assessee has disallowed the amount only to the extent of contingent liability provided in the books of account, thus, leaving thereby no excess balances

SHRI ISHWARLAL GULABCHAND VARDHAMANTAP AYAMBIL TRUST,PUNE vs. ITO WARD 7(1), PUNE

In the result, the appeal filed by the assessee is allowed

ITA 1287/PUN/2025[2023-24]Status: DisposedITAT Pune22 Jul 2025AY 2023-24

Bench: Dr.Manish Borad

For Appellant: Shri Pramod S. ShingteFor Respondent: Date of hearing
Section 11Section 11(2)Section 11(3)Section 12ASection 143(1)Section 143(1)(a)Section 250

disallowance has been made for not applying set apart accumulation funds during F.Y. 2016-17 within the period of five years as provided u/s.11(2) of the Act. Ld. Counsel for the assessee further submitted that issue in Hon’ble Tribunal in the case of Yashwantrao Chavan Maharashtra Open University Vs. CIT – ITA No.505/PUN/2025 order dated 23.06.2025 wherein