DCIT, PUNE vs. BAJAJ ALLIANZ LIFE INSURANCE COMPANY LIMITED, PUNE

In the result, both the appeals filed by the Revenue are dismissed

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

section 14A of the Income tax Act, 1961. iii. On the facts and the circumstances of the case and in law, the Ld.CIT(A) erred in deleting the addition made by the AO on account of disallowance of Rs.14,97,00,237

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

237/- 3. Being aggrieved by the above disallowances, an appeal was preferred before the ld. CIT(A), who vide impugned order held that the assessed income resulted @ 40% of the turnover which is impossible and had proceeded to estimate the income @ 10% of the turnover by rejecting the book results. 3 C.O. No.41/PUN/2022 4. Being aggrieved by the decision

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

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

SHRISANT SAVTAMALI GRAMIN BIGARSHETI SAHAKARI PATSANSTHA MARYADIT,AHILYANAGAR vs. PR. CIT - 1 , PUNE

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

Bench: SHRI MANISH BORAD (Accountant Member), SHRI VINAY BHAMORE (Judicial Member)

disallowances. Hence, the impugned order under section 263 may please be squashed. 3. On the facts and in the prevailing circumstances of the case, respected PCIT - Pune -1 erred passing the impugned Revision Order under section 263 without appreciating the submission made by the assessee society and the judgements of Hon'ble Jurisdictional Pune ITAT. Hence, the impugned order under

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

FOSECO INDIA LIMITED,PUNE vs. ACIT ,CIRCLE 1(1), PUNE

In the result, the appeal of the assessee for AY 2014-15 is dismissed

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

Section 115-0 of the Act and not at the rate of tax applicable to the non-resident shareholder as specified in the relevant DTAA with reference to such dividend income. Wherever the Contracting States to a tax treaty intend to extend the treaty protection to the domestic company paying DDT, only then, the domestic company can claim benefit

FOSECO INDIA LIMITED,PUNE vs. ACIT CIRCLE 1(1), PUNE

In the result, the appeal of the assessee for AY 2014-15 is dismissed

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

Section 115-0 of the Act and not at the rate of tax applicable to the non-resident shareholder as specified in the relevant DTAA with reference to such dividend income. Wherever the Contracting States to a tax treaty intend to extend the treaty protection to the domestic company paying DDT, only then, the domestic company can claim benefit

FOSECO INDIA LIMITED,PUNE vs. ACIT CIRCLE 1(1), PUNE

In the result, the appeal of the assessee for AY 2014-15 is dismissed

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

Section 115-0 of the Act and not at the rate of tax applicable to the non-resident shareholder as specified in the relevant DTAA with reference to such dividend income. Wherever the Contracting States to a tax treaty intend to extend the treaty protection to the domestic company paying DDT, only then, the domestic company can claim benefit

FOSECO INDIA LIMITED,PUNE vs. ACIT, CIRCLE 1(!), PUNE

In the result, the appeal of the assessee for AY 2014-15 is dismissed

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

Section 115-0 of the Act and not at the rate of tax applicable to the non-resident shareholder as specified in the relevant DTAA with reference to such dividend income. Wherever the Contracting States to a tax treaty intend to extend the treaty protection to the domestic company paying DDT, only then, the domestic company can claim benefit

FOSECO INDIA LIMITED,PUNE vs. ACIT, CIRCLE1(1), PUNE

In the result, the appeal of the assessee for AY 2014-15 is dismissed

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

Section 115-0 of the Act and not at the rate of tax applicable to the non-resident shareholder as specified in the relevant DTAA with reference to such dividend income. Wherever the Contracting States to a tax treaty intend to extend the treaty protection to the domestic company paying DDT, only then, the domestic company can claim benefit

FOSECO INDIA LIMITED,PUNE vs. ACIT, CIRCLE 1 (1), PUNE

In the result, the appeal of the assessee for AY 2014-15 is dismissed

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

Section 115-0 of the Act and not at the rate of tax applicable to the non-resident shareholder as specified in the relevant DTAA with reference to such dividend income. Wherever the Contracting States to a tax treaty intend to extend the treaty protection to the domestic company paying DDT, only then, the domestic company can claim benefit

FOSECO INDIA LIMITED,PUNE vs. ACIT, CIRCLE 1 (1), PUNE

In the result, the appeal of the assessee for AY 2014-15 is dismissed

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

Section 115-0 of the Act and not at the rate of tax applicable to the non-resident shareholder as specified in the relevant DTAA with reference to such dividend income. Wherever the Contracting States to a tax treaty intend to extend the treaty protection to the domestic company paying DDT, only then, the domestic company can claim benefit

ASSISTANT COMMISSIONER OF INCOME-TAX, CIRCLE - 6,, PUNE vs. M/S. JANATA SAHAKARI BANK LTD,, PUNE

In the result, the appeal filed by the Revenue in ITA

Bench: Shri Inturi Rama Rao & Shri S. S. Viswanethra Ravisl.

disallowed under section 57(i) of the Act as interest on non-SLR securities is income from other sources". 2. Clause (id) of sub-section (1) of section 56 of the Act provides that income by way of interest on securities shall be chargeable to Income-tax under the head "Income from other sources", if, the income is not chargeable

JANATA SAHAKARI BANK LIMITED,,PUNE vs. DEPUTY COMMISSIONER OF INCOME-TAX, CIRCLE - 6,, PUNE

In the result, the appeal filed by the Revenue in ITA

Bench: Shri Inturi Rama Rao & Shri S. S. Viswanethra Ravisl.

disallowed under section 57(i) of the Act as interest on non-SLR securities is income from other sources". 2. Clause (id) of sub-section (1) of section 56 of the Act provides that income by way of interest on securities shall be chargeable to Income-tax under the head "Income from other sources", if, the income is not chargeable

JANATA SAHAKARI BANK LTD,,PUNE vs. DEPUTY COMMISSIONER OF INCOME-TAX, CIRCLE - 6,, PUNE

In the result, the appeal filed by the Revenue in ITA

Bench: Shri Inturi Rama Rao & Shri S. S. Viswanethra Ravisl.

disallowed under section 57(i) of the Act as interest on non-SLR securities is income from other sources". 2. Clause (id) of sub-section (1) of section 56 of the Act provides that income by way of interest on securities shall be chargeable to Income-tax under the head "Income from other sources", if, the income is not chargeable

ITO, PUNE vs. THEGOVERNMENTSERVENTSMAHARASTRACO-OP CREDIT SOCIETY LIMITED PUNE, PUNE

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

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

TULAI NAGARI SAHAKARI PATSANSTHA MARYADIT TULJAPUR,OSMANABAD vs. ITO WARD 1 LATUR, LATUR

In the result, the appeal of the assessee is Partly Allowed

Bench: DR.DIPAK P. RIPOTE (Accountant Member), SHRI VINAY BHAMORE (Judicial Member)

disallowing the deduction U/s 80P of Rs.6,43,237/- 3. The appellant craves the permission to add, amend, modify, alter, revise, substitute, delete any or all grounds of appeal if deemed necessary at the time of hearing of the appeal.” Submission of ld.AR : 2. Ld.AR filed a paper book and written submission. Written Submission of assessee as under : “Ground