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

SPRINGER NATURE TECHNOLOGY AND PUBLISHING SOLUTIONS PRIVATE LIMITED,PUNE vs. THE ASSISTANT COMMISSIONER OF INCOME TAX, CIRCLE-1(1), PUNE

The appeal of the Assessee is Partly Allowed for\nStatistical Purpose

disallowed Assessee's claim of deduction under section\n10AA of the Act, for the interest earned on fixed deposits.\nAggrieved by the assessment order, Assessee filed appeal before\nld.CIT(A).\nAssessee relied on various case laws during\nproceedings before ld.CIT(A). Ld.CIT(A) confirmed the addition\nfollowing the decision of ITAT Pune in Barclays Share Services\nPrimate Limited

SAHYADRI KARAD HOSPITALS PRIVATE LIMITED ,PUNE vs. DY. COMMISSIONER OF INCOME TAX, CIRCLE 5, PUNE , PUNE

Bench: Shri Rama Kanta Panda & Shri Satbeer Singh Godara

204/- as business loss carried forward U/s 72 and Rs.25,29,56,125/- as unabsorbed depreciation carried forward U/s 32(2) be allowed cannot be accepted because as per intimation U/s 143(1) for AY 2018-19 it is clear that in AY 2018-19 losses to the tune of only Rs.316465973/- were allowed to the appellant to be carried

SAHYADRI KARAD HOSPITALS PRIVATE LIMITED,PUNE vs. DY. COMMISSIONER OF INCOME TAX, CIRCLE 5, PUNE, PUNE

Bench: Shri Rama Kanta Panda & Shri Satbeer Singh Godara

204/- as business loss carried forward U/s 72 and Rs.25,29,56,125/- as unabsorbed depreciation carried forward U/s 32(2) be allowed cannot be accepted because as per intimation U/s 143(1) for AY 2018-19 it is clear that in AY 2018-19 losses to the tune of only Rs.316465973/- were allowed to the appellant to be carried

KIRLOSKAR PNEUMATIC COMPANY LIMITED,PUNE vs. THE DCIT CIRCLE 7 PUNE, PUNE

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

Bench: Dr.Manish Borad & Shri Vinay Bhamoreआयकर अपील सं. / Ita No.1569/Pun/2025 Assessment Year : 2020-21

204/-. 4. Aggrieved assessee preferred appeal before ld.CIT(A) but failed to succeed. Now the assessee is in appeal before this Tribunal solely against the disallowance made u/s.14A at Rs.47,08,705/-. 3 Kirloskar Pneumatic Company Limited 5. Ld. Counsel for the assessee submitted that ld. AO has not recorded proper satisfaction as mandated u/s.14A of the Act. He also

VANDERLANDE INDUSTRIES PRIVATE LIMITED,,PUNE vs. ASSISTANT COMMISSIONER OF INCOME-TAX, CIRCLE - 13,, PUNE

In the result, the appeal is allowed for statistical purposes

Bench: Shri R.S. Syal & Shri S.S. Viswanethra Raviआयकर अपील सं. / Ita No.48/Pun/2018 "नधा"रण वष" / Assessment Year : 2012-13

204/-. The Assessing Officer (AO) observed that no deduction of tax at source was made. He held that such amount was chargeable to tax in the hands of the recipient and in the absence of assessee having deducted tax at source, the amount was liable to be disallowed in terms of section

RAMDAS PANDHARINATH KALE(HUF),PUNE vs. ITO, WARD-12(3), PUNE, PUNE

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

Bench: Shri R.K.Panda & Shri Vinay Bhamoreआयकर अपील सं. / Ita No.246/Pun/2025 िनधा"रण वष" / Assessment Year: 2013-14 Ramdas Pandharinath Kale V The Income Tax Officer, (Huf), S Ward-12(3), Pune. Wagjholi, Kalewasti, Kasanand Road, Haveli, Pune – 412207. Pan: Aaqhr7916A Appellant/ Assessee Respondent /Revenue Assessee By Shri Abhay Avachat – Ar Revenue By Shri Arvind Desai – Addl.Cit(Dr) Date Of Hearing 27/03/2025 Date Of Pronouncement 28/03/2025 आदेश/ Order Per Vinay Bhamore, Jm: This Appeal Filed By The Assessee Is Directed Against The Order Of Ld.Commissioner Of Income Tax(Appeals)[Nfac], Delhi U/S.250 Of The Income Tax Act, 1961 (Hereinafter Referred To As ‘The Act’), Dated 19.10.2024 For The A.Y.2013-14. The Assessee Has Raised The Following Grounds Of Appeal : “Each Ground Is Taken Without Prejudice To Each Other.

204/- as against the income returned by the assessee at Rs.1,74,682/-. The above assessed income includes withdrawal of deduction under section 54 of the Income Tax Act of Rs.25 lakhs income from other sources of Rs.55,522/- and disallowance

DEPUTY COMMISSIONER OF INCOME-TAX, CIRCLE - 1,, NASHIK vs. POONAM DNYANESHWAR MAHAJAN,, NASHIK

In the result, the Cross Object filed by the assessee in C

204/-. Against the said return of income, the assessment was completed by the Assistant Commissioner of Income Tax, Circle-1, Nashik (‘the Assessing Officer’) vide order dated 07.12.2016 passed u/s 144 of the Income Tax Act, 1961 (‘the Act’) at total income of Rs.8,17,97,441/- by disallowing the following expenditure :- Sr. No. Expenses Amount 1 Site expenses

INCOME TAX OFFICER, BODHI TOWER vs. KUMAR BUILDERS PROJECT PUNE PRIVATE LIMITED, BUND GARDEN

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

Bench: Shri R. K. Panda & Ms Astha Chandraassessment Year : 2019-20

section 119, condone the delay in order to avoid undue hardship. 8. In the present case it cannot be said that the delay was, in any manner, mala fide. On the contrary, the assessee was vigilant enough to file the return at the midnight. We, therefore, condone the delay in filing the return

AIDS SOCIETY OF INDIA,MUMBAI vs. THE PRINCIPAL COMMISSIONER OF INCOME TAX (CENTRAL), PUNE

204 – Paper-Book-II (2 CPD hours)\nThe CPD hours granted by MMC are updated in each medical professional's REGISTER through the e-portal of MMC.\n3.11 Difference between offence v. prohibition Learned PCIT has alleged that, Appellant's activities are prohibited by other laws and, as such, Appellant violates clause (f) of section 12AB(4). It is already

AGRA OBSTETRICAL AND GYNAECOLOGICAL SOCIETY,AGRA vs. PCIT, CENTRAL, PUNE

204 – Paper-Book-II (2 CPD hours)\nThe CPD hours granted by MMC are updated in each medical\nprofessional's REGISTER through the e-portal of MMC.\n3.11 Difference between offence v. prohibition Learned PCIT has\nalleged that, Appellant's activities are prohibited by other laws and, as\nsuch, Appellant violates clause (f) of section 12AB(4). It is already

SHRI VINAY BADERA,PUNE vs. ACIT CIRCLE 3, PUNE

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

Bench: Shri R. K. Panda & Ms. Astha Chandraassessment Year : 2017-18 Shri Vinay Badera Acit, Circle 3, Pune 303, Rohan Tapovan, Sb Road, Vs. Gokhale Nagar, Pune – 411016 Pan: Abjpb1324J (Appellant) (Respondent) Assessee By : Shri B.S. Rajpurohit Department By : Shri Arvind Desai, Addl Cit-Dr Date Of Hearing : 30-01-2025 Date Of Pronouncement : 18-03-2025 O R D E R

section 57(iii) of the Act, any other expenditure (not being in the nature of capital expenditure) laid out or expended wholly and exclusively for the purpose of making or earning such income, is allowed as deduction against income shown as ‘Income from other sources’. He, therefore, asked the assessee to furnish the details of deductions claimed u/s 57 along

DY.COMMISSIONER OF INCOME TAX CIRCLE-1 NASSHIK, NASHIK vs. HARSH CONSTRUCTIONS PRIVATE LIMITED, NASHIK

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

Bench: Shri R. K. Panda & Ms Astha Chandraassessment Year : 2014-15 Dcit, Circle – 1, Harsh Constructions Pvt. Ltd. Nashik Sanskruti, Murkute Colony, Vs. New Pandit Colony, Sharanpur Road, Nashik – 422002 Pan: Aacch2277H (Appellant) (Respondent) Assessee By : Shri Dhiraj S. Dandgaval Department By : Shri Ramnath P Murkunde Date Of Hearing : 03-07-2024 Date Of Pronouncement : 10-07-2024 O R D E R Per R.K. Panda, Vp : This Appeal Filed By The Revenue Is Directed Against The Order Dated 20.12.2023 Of The Cit(A) / Nfac, Delhi Relating To Assessment Year 2014-15. 2. The Revenue In The Grounds Of Appeal Has Challenged The Order Of The Ld. Cit(A) In Restricting The Disallowance To Rs.2,24,191/- As Against Rs.1,25,51,607/- Proposed By The Assessing Officer In The Remand Report As Against Rs.4,38,96,880/- Added By Him In The Order Passed U/S.143(3) Of The Income Tax Act, 1961 (Hereinafter Referred To As ‘The Act’).

section 37 of the I.T. Act, 1961 and has added to the total income of the assessee. Penalty proceedings u/s 271(1)(c) is initiated separately for furnishing inaccurate particulars of income.” 4. Before the CIT(A), the assessee filed certain details, based on which the ld.CIT(A) sought remand report from the Assessing Officer, who proposed an addition

DEPUTY COMMISSIONER OF INCOME-TAX, CIRCLE - 3,, AURANGABAD vs. M/S. KASLIWAL NEST,, AURANGABAD

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

Bench: Shri Inturi Rama Rao & Shri S. S. Viswanethra Raviआयकर अपील सं. / Ita No.27/Pun/2019 िनधा"रण वष" / Assessment Year: 2012-13 Dcit, Circle-3, Vs. M/S. Kasliwal Nest, Aurangabad. 215/216, 1St Floor, Building No.3, Apna Bazar, Jalna Road, Aurangabad- 431005. Pan : Aajfk5915H Appellant Respondent C.O. No.09/Pun/2022 (Arising Out Of Ita No.27/Pun/2019) िनधा"रण वष" / Assessment Year: 2012-13 M/S. Kasliwal Nest, Vs. Dcit, Circle-3, 215/216, 1St Floor, Building Aurangabad. No.3, Apna Bazar, Jalna Road, Aurangabad- 431005. Pan : Aajfk5915H Appellant Respondent Revenue By : Shri Keyur Patel Assessee By : Shri S. N. Puranik Date Of Hearing : 17.11.2022 Date Of Pronouncement : 16.12.2022 आदेश / Order Per Inturi Rama Rao, Am: This Is An Appeal Filed By The Revenue Directed Against The Order Of Ld. Commissioner Of Income Tax (Appeals)- 2, Aurangabad [‘The Cit(A)’] Dated 17.10.2018 For The Assessment Year 2012-13. 2 C.O. No.09/Pun/2022 The Cross Objection Filed By The Assessee Against The Appeal Of The Revenue. 2. First, We Shall Take Up The Appeal Of The Revenue In Ita No.27/Pun/2019 For Adjudication.

section 80IB(10) of the Act. Therefore, the Assessing Officer had completed the assessment at a total income of Rs.12,35,02,325/- by disallowing the claim for deduction of profits u/s 80IB(10) of the Act. 5 C.O. No.09/PUN/2022 5. Being aggrieved by the assessment order, an appeal was filed before the ld. CIT(A) contending that the construction

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

disallowing the assessee’s claim of exempt income in the form of subsidy received from the Govt. of Maharashtra for Mega Projects under Package Scheme of Incentive, 2007 and secondly against the finding of ld.CIT(A) allowing the assessee’s appeal on merit hold that the assessee has rightly reduced the subsidy from the Fixed Assets and has claimed depreciation

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

disallowing the\nassessee's claim of exempt income in the form of subsidy\nreceived from the Govt. of Maharashtra for Mega Projects\nunder Package Scheme of Incentive, 2007 and secondly\nagainst the finding of ld.CIT(A) allowing the assessee's appeal\non merit hold that the assessee has rightly reduced the\nsubsidy from the Fixed Assets and has claimed depreciation

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

disallowing the assessee’s claim of exempt income in the form of subsidy received from the Govt. of Maharashtra for Mega Projects under Package Scheme of Incentive, 2007 and secondly against the finding of ld.CIT(A) allowing the assessee’s appeal on merit hold that the assessee has rightly reduced the subsidy from the Fixed Assets and has claimed depreciation

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

disallowing the assessee’s claim of exempt income in the form of subsidy received from the Govt. of Maharashtra for Mega Projects under Package Scheme of Incentive, 2007 and secondly against the finding of ld.CIT(A) allowing the assessee’s appeal on merit hold that the assessee has rightly reduced the subsidy from the Fixed Assets and has claimed depreciation