M/S. L.B. KUNJIR,PUNE vs. DEPUTY COMMISSIONER OF INCOME TAX, CIRCLE 7, PUNE, PUNE

In the result, the two appeals filed by the assessee are allowed and the three appeals filed by Revenue are dismissed

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

71, READ WITH SECTION 115BBE. OF THE INCOME-TAX ACT, 1961 - LOSSES - SET OFF OF FROM ONE HEAD AGAINST INCOME FROM AN OTHER - CLARIFICATION REGARDING NON-ALLOWABILITY OF SETOFF OF LOSSES AGAINST THE DEEMED INCOME UNDER SECTION 2017-18 CIRCULAR NO. 11/2019 [F.N0.225/45/2019-ITA.II], DATED 19-6- 2019With effect from 1-4-2017, sub-section (2) of section 115BBE

DEPUTY COMMISSIONER OF INCOME TAX, CIRCLE-7, PUNE vs. LB KUNJIR, PUNE

In the result, the two appeals filed by the assessee are allowed and the three appeals filed by Revenue are dismissed

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

71, READ WITH SECTION 115BBE. OF THE INCOME-TAX ACT, 1961 - LOSSES - SET OFF OF FROM ONE HEAD AGAINST INCOME FROM AN OTHER - CLARIFICATION REGARDING NON-ALLOWABILITY OF SETOFF OF LOSSES AGAINST THE DEEMED INCOME UNDER SECTION 2017-18 CIRCULAR NO. 11/2019 [F.N0.225/45/2019-ITA.II], DATED 19-6- 2019With effect from 1-4-2017, sub-section (2) of section 115BBE

DCIT CIRCLE 7, BODHI TOWER SALISBURY PARK vs. L B KUNJIR, PUNE

In the result, the two appeals filed by the assessee are allowed and the three appeals filed by Revenue are dismissed

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

71, READ WITH SECTION 115BBE. OF THE INCOME-TAX ACT, 1961 - LOSSES - SET OFF OF FROM ONE HEAD AGAINST INCOME FROM AN OTHER - CLARIFICATION REGARDING NON-ALLOWABILITY OF SETOFF OF LOSSES AGAINST THE DEEMED INCOME UNDER SECTION 2017-18 CIRCULAR NO. 11/2019 [F.N0.225/45/2019-ITA.II], DATED 19-6- 2019With effect from 1-4-2017, sub-section (2) of section 115BBE

M/S. L.B. KUNJIR,PUNE vs. DEPUTY COMMISSIONER OF INCOME TAX, CIRCLE 7, PUNE, PUNE

In the result, the two appeals filed by the assessee are allowed and the three appeals filed by Revenue are dismissed

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

71, READ WITH SECTION 115BBE. OF THE INCOME-TAX ACT, 1961 - LOSSES - SET OFF OF FROM ONE HEAD AGAINST INCOME FROM AN OTHER - CLARIFICATION REGARDING NON-ALLOWABILITY OF SETOFF OF LOSSES AGAINST THE DEEMED INCOME UNDER SECTION 2017-18 CIRCULAR NO. 11/2019 [F.N0.225/45/2019-ITA.II], DATED 19-6- 2019With effect from 1-4-2017, sub-section (2) of section 115BBE

DCIT, PUNE vs. L B KUNJIR, PUNE

In the result, the two appeals filed by the assessee are allowed and the three appeals filed by Revenue are dismissed

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

71, READ WITH SECTION 115BBE. OF THE INCOME-TAX ACT, 1961 - LOSSES - SET OFF OF FROM ONE HEAD AGAINST INCOME FROM AN OTHER - CLARIFICATION REGARDING NON-ALLOWABILITY OF SETOFF OF LOSSES AGAINST THE DEEMED INCOME UNDER SECTION 2017-18 CIRCULAR NO. 11/2019 [F.N0.225/45/2019-ITA.II], DATED 19-6- 2019With effect from 1-4-2017, sub-section (2) of section 115BBE

PUNE ZILLA SAHAKARI DUDH UTPADAK SANGH MARYADIT,PUNE vs. DCIT, CIRCLE-5, PUNE, PUNE

In the result, appeal of the Assessee for A

Bench: Ms.Astha Chandra & Dr.Dipak P. Ripoteआयकर अपऩल सं. / Ita Nos.2194 & 2195/Pun/2025 निर्धारण वषा / Assessment Years: 2017-18 & 2018-19 Pune Zilla Sahakari Dudh V Dcit, Utpadak Sangh Maryadit, S. Circle-5, Pune. Katraj Dairy, Pune Satara Road, Katraj, Pune – 411037. Pan: Aaaap0836A Appellant/ Assessee Respondent / Revenue Assessee By Shri M.R.Bhagwat Revenue By Smt. Saumya Pandey Jain – Addl.Cit Date Of Hearing 20/11/2025 Date Of Pronouncement 08/01/2026 आदेश/ Order Per Dr. Dipak P. Ripote, Am: These Two Appeals Filed By The Assessee Are Against The Separate Orders Of Ld.Commissioner Of Income Tax(Appeal)[Nfac], Passed Under Section 250 Of The Income Tax Act, 1961 Both Dated 30.07.2025 Emanating From The Separate Assessment Orders Under Section 143(3) Of The Act, 1961 Dated 19.12.2019 & 19.01.2021 For The A.Y.2017-18 & 2018-19 Respectively. For The Sake Of Convenience, Both The Appeals Were Heard Together & Decided In A

71,993/-. It has received dividend from PDCC Bank of Rs.3,80,001/-. It has received dividend from Other Co-operative Society of Rs.24,39,000/-. Thus, the total was Rs.1,46,90,994/-. Assessing Officer held that the said income of Rs.1,46,90,994/- is not eligible for deduction under section 80P(2)(d) of the Act. Assessing

PUNE ZILLA SAHAKARI DUDH UTPADAK SANGH MARYADIT,PUNE vs. DCIT, CIRCLE-5, PUNE, PUNE

In the result, appeal of the Assessee for A

Bench: Ms.Astha Chandra & Dr.Dipak P. Ripoteआयकर अपऩल सं. / Ita Nos.2194 & 2195/Pun/2025 निर्धारण वषा / Assessment Years: 2017-18 & 2018-19 Pune Zilla Sahakari Dudh V Dcit, Utpadak Sangh Maryadit, S. Circle-5, Pune. Katraj Dairy, Pune Satara Road, Katraj, Pune – 411037. Pan: Aaaap0836A Appellant/ Assessee Respondent / Revenue Assessee By Shri M.R.Bhagwat Revenue By Smt. Saumya Pandey Jain – Addl.Cit Date Of Hearing 20/11/2025 Date Of Pronouncement 08/01/2026 आदेश/ Order Per Dr. Dipak P. Ripote, Am: These Two Appeals Filed By The Assessee Are Against The Separate Orders Of Ld.Commissioner Of Income Tax(Appeal)[Nfac], Passed Under Section 250 Of The Income Tax Act, 1961 Both Dated 30.07.2025 Emanating From The Separate Assessment Orders Under Section 143(3) Of The Act, 1961 Dated 19.12.2019 & 19.01.2021 For The A.Y.2017-18 & 2018-19 Respectively. For The Sake Of Convenience, Both The Appeals Were Heard Together & Decided In A

71,993/-. It has received dividend from PDCC Bank of Rs.3,80,001/-. It has received dividend from Other Co-operative Society of Rs.24,39,000/-. Thus, the total was Rs.1,46,90,994/-. Assessing Officer held that the said income of Rs.1,46,90,994/- is not eligible for deduction under section 80P(2)(d) of the Act. Assessing

MAHATMA GANDHI NAGRI SAHAKARI PAT SANSTHA MYDT UDGIR,LATUR vs. INCOME TAX OFFICER- WARD 1 -LATUR, LATUR

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

disallowing the deduction claimed by the appellant u/s.80P(2)(a)(i) of Rs. 3,04,88,392/-. Since all are related grounds of appeal same are adjudicated combinedly as under:- (i) The appellant is a Co-operative credit society. The funds of the appellant were deposited in different Co-operative banks and earned interest income of Rs.3

VIJAY SAHAKARI PAT SANSTHA LIMITED,ICHALKARANJI vs. ITO WARD-2, ICHALKARANJI, ICHALKARANJI

In the result, the appeal of the assessee is allowed

Bench: Shri Manish Borad & Ms. Astha Chandra

disallow the appellant's claim for a deduction of Rs. 8,81,745/- under Section 80P(2)(a)(i) of the Income Tax Act is in accordance with the provisions of the Act. Therefore, the appeal of the appellant is hereby dismissed.” 5. Dissatisfied, the assessee is in appeal before the Tribunal and all the grounds of appeal relate thereto

THE SANGLI SALARY EARNERS CO OP SOCIETY LTD,SANGLI vs. INCOME TAX OFFICER WARD 3 SANGLI, SANGLI

In the result, appeal of the assessee is allowed

Bench: Dr.Dipak P. Ripote & Shri Vinay Bhamoreआयकर अपऩल सं. / Ita No.2254/Pun/2025 निर्धारण वषा / Assessment Year: 2020-21 The Sangli Salary Earners Co V The Income Tax Officer, Op Society Ltd., S. Ward-3, Sangli. 1104 B, Harbhat Road, Main City, Sangli – 416416 Pan: Aaaat0980D Appellant/ Assessee Respondent / Revenue Assessee By Shri Amit Sudhir Shintre(Virtual) Revenue By Smt. Saumya Pandey Jain-Addl.Cit Date Of Hearing 17/11/2025 Date Of Pronouncement 17/11/2025 आदेश/ Order Per Dr. Dipak P. Ripote, Am: This Appeal Is Filed By The Assessee Against The Order Of Ld.Commissioner Of Income Tax(Appeals)[Nfac], Passed Under Section 250 Of The Income Tax Act, 1961 For A.Y.2020-21, Dated 27.08.2025 Emanating From Assessment Order U/S.143(3) Read With Section 143(3) R.W.S 144B Of The Income Tax Act, 1961 Dated 26.09.2022. The Assessee Has Raised Following Grounds Of Appeal : “1. Deduction U/S 80P(2)(A)(I) Relying On The Decision Of Totgars Co-

71,88,591/- should be allowed as a deduction under section 80P(2)(a)(i) of the Act 2. Deduction u/s 80P(2)(d) and Inapplicability of Section 80P(4) Without prejudice, on the facts and in the circumstances of the case and in law, the Ld. AO and CIT(A) erred in not granting deduction u/s 80P(2

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

In the result, the appeal of Revenue is partly allowed

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

disallowed. The CIT(A) considered various decisions and by relying the decision of Hon’ble High Court of Karnataka in the case of Compaq Electric Ltd. reported in (2011) 16 taxmann.com 385 (Kar.) held the principal amount of loan waived would neither be chargeable to tax u/s. section

M/S KOLTE PATIL DEVELOPERS LTD,PUNE vs. DCIT,CIRCLE-7, PUNE, PUNE

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

Bench: Shri R. K. Panda & Shri Vinay Bhamoreassessment Year : 2014-15

disallowing entire expenditure is not justified. 3. The first issue raised in the grounds of appeal No.1 and 2 relates to the order of the CIT(A) / NFAC in confirming the addition of Rs.14,70,250/- out of the addition of Rs.25,02,250/- made by the Assessing Officer u/s 43CA of the Act. 4. Facts of the case

KUMAR PROPERTIES AND REAL ESTATE PRIVATE LIMITED,PUNE vs. ASSISTANT COMMISSIONER OF INCOME TAX, CIRCLE 14, PUNE

In the result, the appeal filed by the assessee is allowed for statistical purposes

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

71,033, wherein disallowance is computed by allocating common admin expenses between exempt income and taxable income. Initiation of penalty under section 270A of the Act 9. The learned AO has erred in initiating penalty proceedings on the above under section 270A of the Act. The Appellant craves leave to add, alter, vary, omit, amend or delete

M/S GIRIRAJ ENTERPRISES,PUNE vs. DCIT, CENTRAL CIRCLE 1(1), PUNE, PUNE

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

Bench: Shri R. K. Panda & Ms Astha Chandraassessment Year : 2015-16

disallowed and is added back to the total income of the assessee. Penalty proceedings u/s 270A(1) of the Act are initiated separately for under reporting of income.” 28. In appeal, the CIT(A) allowed the claim of deduction u/s 80IA(4) of the Act made by the assessee by observing as under: “23. In brief, as per the assessing

INCOME TAX OFFICER, WARD 5,SANGLI., SANGLI. vs. SHREE GANESH NAGARI SAHAKARI PAT SANSTHA MARYADIT, ASHTA,, ASHTA

In the result, the appeal filed by the Revenue is dismissed

Bench: Shri Manish Borad & Shri Vinay Bhamoreआयकर अपील सं. / Ita No.2375/Pun/2025 िनधा"रण वष" / Assessment Year : 2018-19 Ito, Ward-5, Sangli. Vs. Shree Ganesh Nagari Sahakari Pat Sanstha Maryadit, Ashta, Tal. Walwa, Dist. Sangli, Sangli- 416301. Pan : Aaaas8248R Appellant Respondent C. O. No.49/Pun/2025 (Arising Out Of Ita No.2375/Pun/2025) िनधा"रण वष" / Assessment Year : 2018-19 Shree Ganesh Nagari Vs. Ito, Ward-5, Sangli. Sahakari Pat Sanstha Maryadit, Ashta, Tal. Walwa, Dist. Sangli, Sangli- 416301. Pan : Aaaas8248R Appellant Respondent Revenue By : Shri Umesh Phade Assessee By : Shri Sarang Gudhate Date Of Hearing : 25.11.2025 Date Of Pronouncement : 06.01.2026 आदेश / Order Per Vinay Bhamore, Jm: This Appeal Filed By The Revenue Is Directed Against The Order Dated 05.08.2025 Passed By Ld. Cit(A)/Nfac For The Assessment

71,620/- as against the Nil income returned by the assessee. The above assessed income includes addition of Rs.2,94,35,283/- (Rs.2,94,11,786/- interest earned from cooperative banks + Rs.23,497/- interest earned from Axis Bank) disallowance on account of deduction u/s 80P(2)(d) of the IT Act and addition of Rs.58,631/- being delayed payment

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

Disallowing the employees Contribution towards provident fund to tune of RS 71,73,633/- and Employees State Corporation of RS 49,75,899/- being paid after the Stipulated date as Mentioned in the respective act, Whereas paid before the due date of filling of return of income as per Section 139(1). 2

GENERAL INDUSTRIAL CONTROS LTD.,PUNE vs. DCIT CIRCLE 8, PUNE, PUNE

In the result, the order of the CIT(A) is set aside, and the appeal of the assessee is partly allowed

Bench: Dr.Dipak P. Ripote & Shri Vinay Bhamore

section 250 of the Income Tax Act, 1961, dated 14.03.2024 for ITA No.38/PUN/2025 [A] Assessment Year 2021-22. The assessee has raised the following grounds of appeal : “1 The learned CIT(A) erred in law and on facts in confirming tax of appellant at Rs. 2,73,95,728/as against refund of Rs. 29,71,648/- merely due to delay

INCOME TAX OFFICER, WARD - 3(1), PUNE, PUNE vs. SACHIN GOVIND APTE, PUNE

Accordingly, Grounds of appeal raised by the Revenue are dismissed

Bench: Dr.Dipak P. Ripote & Shri Vinay Bhamoreआयकर अपऩल सं. / Ita No.1720/Pun/2025 निर्धारण वषा / Assessment Years: 2013-14 The Income Tax Officer, V Sachin Govind Apte, Ward-3(1), Pune. S. 759-63, Prabhat Road, Erandwana, Pune – 411004. Pan: Aavpa9458P Appellant/ Revenue Respondent /Assessee Assessee By Ms.Vaishnavi Badwe Revenue By Shri Amit Bobde - Cit(Dr) Date Of Hearing 16/12/2025 Date Of Pronouncement 03/02/2026 आदेश/ Order Per Dr. Dipak P. Ripote, Am: This Is An 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 The A.Y.2013-14 Dated 15.05.2025 Emanating From The Assessment Order Passed Under Section 143(3) Of The Act, Dated 30.03.2016. The Revenue Has Raised The Following Grounds Of Appeal : “1. Whether On The Facts & Circumstances Of The Case & In Law The Hon'Ble Cit (A) Was Justified In Deleting The Addition Of Rs.78,72,000/- Made Under Head Stcg & Disallowance Of Deduction U/S 54F Of The It. Act, 1961? 2. Whether On The Facts & Circumstances Of The Case & In Law The Hon‟Ble Cti (A) Was Justified In Deleting The Addition Of Rs.1,20,00,000/- Made On Account Of Deemed Dividend U/S Section 2(22)(E) Of The I.T. Act, 1961?

disallowance of deduction u/s 54F of the IT. Act, 1961? 2. Whether on the facts and circumstances of the case and in law the Hon‟ble CTI (A) was justified in deleting the addition of Rs.1,20,00,000/- made on account of deemed dividend u/s Section 2(22)(e) of the I.T. Act, 1961? ITA No.1720/PUN/2025 [D] 3. Whether