INDUS BIOTECH LIMITED,PUNE vs. THE ASSISTANT COMMISSIONER OF INCOME TAX, CIRCLE 1(1), PUNE, PUNE

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

1,52,65,049 under section 115-O of the Act to the Ld. AO\nwithout appreciating the fact that the said credit is also duly reflected in\nForm 26AS and relevant facts/documents are available on record with the\nLd. AO.\n4.2 The Appellant prays that the Ld. AO be directed to grant credit of DDT\nGround No. 5\n5.1

DCIT, CC-2(1), PUNE, PUNE vs. VINOD RAMCHANDRA JADHAV, PUNE

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

Bench: Shri R. K. Panda & Ms. Astha Chandraassessment Year : 2010-11 Dcit, Vinod Ramchandra Jadhav Central Circle 2(1), Vs. Plot No.42-44, Green Park Society, Pune Viman Nagar, Pune – 411014 Pan: Aanpj0592P (Appellant) (Respondent) Assessment Year : 2010-11 Vinod Ramchandra Jadhav Dcit, Plot No.42-44, Green Park Society, Vs. Central Circle 2(1), Pune Viman Nagar, Pune – 411014 Pan: Aanpj0592P (Appellant) (Respondent) Assessee By : Shri Kishor B Phadke Department By : Shri Ajay Kumar Keshari – Cit & Shri Arvind Desai, Addl Cit-Dr Date Of Hearing : 23-01-2025 Date Of Pronouncement : 21-04-2025 O R D E R

246 or section 246A, and the Joint Commissioner (Appeals) or the Commissioner (Appeals) passes the order on or after the 1st day of June, 2003 disposing of such appeal, an order imposing penalty shall be passed before the expiry of the financial year in which the proceedings, in the course of which action for imposition of penalty has been initiated

VINOD RAMCHANDRA JADHAV,PUNE vs. DCIT, CC-2(1), PUNE, PUNE

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

Bench: Shri R. K. Panda & Ms. Astha Chandraassessment Year : 2010-11 Dcit, Vinod Ramchandra Jadhav Central Circle 2(1), Vs. Plot No.42-44, Green Park Society, Pune Viman Nagar, Pune – 411014 Pan: Aanpj0592P (Appellant) (Respondent) Assessment Year : 2010-11 Vinod Ramchandra Jadhav Dcit, Plot No.42-44, Green Park Society, Vs. Central Circle 2(1), Pune Viman Nagar, Pune – 411014 Pan: Aanpj0592P (Appellant) (Respondent) Assessee By : Shri Kishor B Phadke Department By : Shri Ajay Kumar Keshari – Cit & Shri Arvind Desai, Addl Cit-Dr Date Of Hearing : 23-01-2025 Date Of Pronouncement : 21-04-2025 O R D E R

246 or section 246A, and the Joint Commissioner (Appeals) or the Commissioner (Appeals) passes the order on or after the 1st day of June, 2003 disposing of such appeal, an order imposing penalty shall be passed before the expiry of the financial year in which the proceedings, in the course of which action for imposition of penalty has been initiated

DEPUTY COMMISSIONER OF INCOME-TAX, CIRCLE - 1(1),, PUNE vs. M/S. IAC INTERNATIONAL AUTOMOTIVE INDIA PVT.LTD,, PUNE

In the result, the appeal of the Revenue is dismissed

Bench: Ms. Astha Chandra & Shree Dr. Dipak P. Ripote

1) of section 92C, the other method for determination of the arm's length price in relation to an international transaction or a specified domestic transaction shall be any method which takes into account the price which has been charged or paid, or would have been charged or paid, for the same or similar uncontrolled transaction, with or between

SHREENATH MHASKOBA SAKHAR KARKHANA LTD,PUNE vs. DCIT, CIRCLE-5, PUNE, PUNE

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

Bench: Shri Manish Borad & Shri Vinay Bhamoreआयकर अपील सं. / Ita No.305/Pun/2025 िनधा"रण वष" / Assessment Year : 2018-19 Shreenath Mhaskoba Sakhar Vs. Dcit, Circle-5, Pune. Karkhana Ltd., Survey No.12/2, 2Nd Floor, Meghdoot Building, Behind Bharat Petroleum Pump, Hadpasar, Pune- 411028. Pan : Aahcs3018G Appellant Respondent Assessee By : Shri B.D. Bhide Revenue By : Shri A. D. Kulkarni Date Of Hearing : 02.04.2025 Date Of Pronouncement : 30.05.2025 आदेश / Order Per Vinay Bhamore, Jm: This Appeal Filed By The Assessee Is Directed Against The Order Dated 17.12.2024 Passed By Ld. Addl/Jcit(A)-7, Kolkata [‘Ld. Cit(A)’] For The Assessment Year 2018-19. 2. The Appellant Has Raised The Following Grounds Of Appeal :- “Being Aggrieved By An Order Passed U/Sec.250 By The Ld. Cit(A)- Nfac, Delhi (Hereinafter Referred For Short As The Ld. Cit(A)) Your

disallowed belated payment of employees provident fund in respect of payment of Rs.2,99,286/- and of Rs.3,41,163/-. However, out of these two payments an amount of Rs.3,41,163/- was due on 15th August 2018 and being Independence Day it was holiday therefore the payment of Rs.3,41,163/- was made on 16th August

RAJDEEP BUILDCON PRIVAT LIMITED, AHMEDNAGAR,AHMEDNAGAR vs. DY. COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE 1(2), PUNE, PUNE

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

Bench: SHRI R. K. PANDA (Vice President), SHRI VINAY BHAMORE (Judicial Member)

1. Whether on facts and in law, disallowance u/s 14A of the Income Tax Act can be made on expenditure incurred for earning exempt income where the interest free funds were sufficient and available to make investment earning exempt income? 2. Whether on facts and in law, disallowance u/s 14A of the Income Tax Act can be made on expenditure

RAJDEEP BUILDCON PVT LTD, AHMEDNAGAR,AHMEDNAGAR vs. DY. COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE 1(2), PUNE, PUNE

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

Bench: SHRI R. K. PANDA (Vice President), SHRI VINAY BHAMORE (Judicial Member)

1. Whether on facts and in law, disallowance u/s 14A of the Income Tax Act can be made on expenditure incurred for earning exempt income where the interest free funds were sufficient and available to make investment earning exempt income? 2. Whether on facts and in law, disallowance u/s 14A of the Income Tax Act can be made on expenditure

RAJDEEP BUILDCOM PRIVATE LIMITED,AHMEDNAGAR vs. DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE - 1(2), PUNE, PUNE

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

Bench: SHRI R. K. PANDA (Vice President), SHRI VINAY BHAMORE (Judicial Member)

1. Whether on facts and in law, disallowance u/s 14A of the Income Tax Act can be made on expenditure incurred for earning exempt income where the interest free funds were sufficient and available to make investment earning exempt income? 2. Whether on facts and in law, disallowance u/s 14A of the Income Tax Act can be made on expenditure

VARDHAMAN VASUNDHARA FAMILY TRUST,PUNE vs. ITO, WARD 7(1), PUNE, PUNE

In the result, the appeal of the assessee is allowed for statistical purposes

Bench: Shri R.K. Panda & Ms. Astha Chandraआयकर अपील सं. / Ita No.741/Pun/2025 धििाारण वर्ा / Assessment Year : 2022-23 Vardhaman Vasundhara Family Trust, Income Tax Officer, S. No. 1A, F-1, Irani Market Compound, Ward – 7(1), Pune Yerwada, Pune-411006 Vs. Pan : Aactv6457E अपीलार्थी / Appellant प्रत्यर्थी / Respondent Assessee By : Shri C.H. Naniwadekar Department By : Shri Akhilesh Srivastva Date Of Hearing : 25-06-2025 Date Of 27-06-2025 Pronouncement :

disallowance: “1. In the facts and circumstances of the case and law, the CPC erred in making adjustment of Rs.52,20,899/- to the total income without issuing a notice/intimation as required by the first proviso to clause (a) of section 143(1). 2. In the facts and circumstance of the case and in law, the CPC erred

DY COMMISSIONER OF INCOME TAX, KARAD SATARA vs. THE KARAD JANATA SAHAKARI BANK LTD, KARAD SATARA

In the result, the appeal of the Revenue is dismissed

Bench: Shri R. K. Panda & Shri Vinay Bhamore

section 143(3) proceedings the AO disallowed excess expenditure of Rs 2,08,09,305/- claimed u/s 36(i)(viia) of the IT Act for which provision was not made in the books of account . The disallowance of expenditure was confirmed by CIT(A) as well as by this Tribunal . On the basis of this disallowance the then AO proceeded

ARISTON GROUP INDIA PRIVATE LIMITED,PUNE vs. THE ASSESSEMENT UNIT, INCOME TAX DEPARTMENT, NFAC AND THE DCIT, CIRCLE 1(1), PUNE, PUNE

In the result, appeal of the assessee is partly allowed

Bench: Shri R.K.Panda & Shri Vinay Bhamoreआयकर अपील सं. / Ita No.1680/Pun/2024 िनधा"रण वष" / Assessment Year: 2020-21 Ariston Group India Private The Assessment Unit, Limited, Income Tax Department, 1St Floor, Office No.103, V National Faceless Mayfai Tower, Wakdewadi, S. Assessment Centre, Shivaji Nagar, Pune-411005. Delhi(“Nfac”), The Dcit, Circle-1(1), Pune. Pan: Aaoca7042D Appellant/ Assessee Respondent / Revenue Assessee By Shri Ketan Ved – Ar Revenue By Shri Prakash L Pathade – Cit(Dr) Date Of Hearing 15/01/2025 Date Of Pronouncement 09/04/2025 आदेश/ Order Per Vinay Bhamore, Jm: This Is An Appeal Filed By The Assessee Against The Assessment Order Passed Under Section 143(3) R.W.S 144C(3) Read With Section 144B Of The Income Tax Act, 1961, Dated 18.06.2024 For A.Y.2020- 21. The Assessee Has Raised The Following Grounds Of Appeal : “Based On The Facts & Circumstances Of The Case, Ariston Group India Private Limited (Hereinafter Referred To As "Ariston India' Or 'The Appellant) Prefers An Appeal For The Assessment Year 2020-21 Against

1) of section 92C, the other method for determination of the arm's length price in relation to an ITA No.1680/PUN/2024 [A] international transaction or a specified domestic transaction shall be any method which takes into account the price which has been charged or paid, or would have been charged or paid, for the same or similar uncontrolled transaction, with

BAJAJ HOUSING FINANCE LIMITED,PUNE vs. ITO, WARD-8(1), PUNE, PUNE

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

Bench: Dr.Manish Borad

1, Mumbai vs. Bennett Coleman & Co. Ltd. [2013] 33 taxmann.com 227 (Bombay HC) Penalty not leviable in case of bona fide cause : 4. Jaypee Cement Corporation Ltd. vs. ACIT [2023] 157 taxmann.com 757 (Delhi-Trib.) [11-09-2023] Penalty not leviable in case of in absence of specifying the sub-clause of section 270A(9) of the Act 5. DCIT

T AND T INFRA LIMITED,PUNE vs. ASST.COMMISSIONER OF INCOME-TAX, CIRCLE-7, PUNE

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

Bench: Shri R. K. Panda & Ms Astha Chandraassessment Year : 2016-17 T & T Infra Limited Acit, Circle – 7, Pune A-1, Vishnu Vihar, Bibwewadi Vs. Kondhwa Road, Market Yard, Pune – 411037 Pan: Aaect3902H (Appellant) (Respondent) Assessee By : Shri Tarun Ghia Department By : S/Shri Ajay Kumar Keshari & Sourabh Nayak Date Of Hearing : 10-07-2024 Date Of Pronouncement : 01-10-2024 O R D E R Per Astha Chandra, Jm :

1. The learned CIT(A) has erred in confirming the disallowance of deduction u/s 80IA(4) made by the AO amounting to Rs.7,21,32,410/- without appreciating the contention of the appellant that: a. The appellant company qualifies for the deduction u/s 80IA(4) of the Act. b. The various infrastructure facilities/projects awarded to appellant company cannot be described

BANSILAL RAMNATH AGARWAL CHARITABLE TRUST,PUNE vs. CIT (EXEMPTION), PUNE

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

Bench: Shri R. K. Panda & Ms. Astha Chandraassessment Year : 2020-21 Bansilal Ramnath Agarwal Charitable Trust Cit (Exemption), 251, Budhwar Peth, City Post Chowk, Vs. Pune Pune – 411002 Pan: Aaatb4383K (Appellant) (Respondent) Assessee By : Shri Kishor B Phadke Department By : Shri Amol Khairnar, Cit-Dr Date Of Hearing : 11-12-2025 Date Of Pronouncement : 28-01-2026 O R D E R Per R.K. Panda, V.P:

246 ITR 452 (Guj] wherein the Hon’ble High Court has held that when the transactions between a charitable trust and its related concerns are excessive and lack commercial prudence, the trust forfeits exemption under Section 11. He further noted that in the case of M/s Agrabh also 100% of the revenue is received from the assessee only. Since

RAMESH GARWARE CHARITY TRUST,PUNE vs. EXEMPTION WARD 1(1), PUNE

In the result, appeal of the assessee is allowed for statistical purpose

Bench: Dr.Dipak P. Ripote & Shri Vinay Bhamoreआयकर अपील सं. / Ita No.776/Pun/2025 िनधा"रण वष" / Assessment Year: 2018-19 Ramesh Garware Charitable V The Exemption Ward- Trust, S. 1(1), Pune. P B Box 3, Ramesh Garware Farm, Nda Road, Khadakwasla, Pune – 411023. Maharashtra. Pan: Aaatr6365D Appellant/ Assessee Respondent / Revenue Assessee By Shri Dalpat Shah – Ar(Virtual) Revenue By Shri Vinod Pawar – Addl.Cit(Dr) Date Of Hearing 08/05/2025 Date Of Pronouncement 23/05/2025 आदेश/ Order Per Dr. Dipak P. Ripote, Am: This Appeal Filed By The Assessee Is Directed Against The Order Of Addl./Joint Commissioner Of Income Tax[Jcit(A)], Thiruvanantpura Under Section 250 Of The Income Tax Act, 1961 For The A.Y.2018-19 Dated 14.08.2024. The Assessee Has Raised The Following Grounds Of Appeal :

Disallowance of Deduction U/sec 11(2) of Rs.74,49,246/- On the facts and circumstances of the case, the said CIT(Appeals) erred in not allowing deduction claimed of accumulation of Rs. 74,49,246/- under section 11(2) of the Income tax Act following the assessment order for A.Y 2017-18 ignoring the fact that the provisions of section

AMEETSINGH AJITSINGH RAJPAL,PUNE vs. DCIT CIRCLE-5, 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.1705/Pun/2025 िनधा"रण वष" / Assessment Year : 2011-12 Ameetsingh Ajitsingh Rajpal, Vs. Dcit, Circle-5, Pune. 479, Eden Villa, Rasta Peth, Kasba Peth, Pune- 411011. Pan : Aaqpr3148E Appellant Respondent Assessee By : Shri Suhas Bora & Riya Oswal Revenue By : Smt. N. C. Shilpa Date Of Hearing : 20.11.2025 Date Of Pronouncement : 25.11.2025 आदेश / Order Per Vinay Bhamore, Jm: This Appeal Filed By The Assessee Is Directed Against The Order Dated 27.05.2025 Passed By Ld. Cit(A)/Nfac For The Assessment Year 2011-12. 2. The Appellant Has Raised The Following Grounds Of Appeal :- “1. The Ld. Cit(A) Has Erred In Upholding The Disallowance Of Deduction Claimed Under Section 54F Of The Income-Tax Act, 1961 Amounting To Rs. 92,85,214/-Solely On The Ground That The Reinvestment Was Not Made In A Residential House.

Section 54F does not restrict exemption merely because the property is situated in an agricultural zone, nor does it exclude a farmhouse from the ambit of a residential house. 6. The disallowance so sustained is contrary to the settled principles of interpretation of beneficial provisions under Chapter IV of the Income-tax Act and deserves to be deleted

RAJRSHI SHAHU NAGARI SAHAKARI PAT SANSTHA MARYADIT KURUNDWAD,KOLHAPUR vs. INCOME TAX OFFICER, ICHALKARANJI

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

Bench: Dr.Manish Borad & Shri Vinay Bhamoreआयकर अपील सं. / Ita No.1955/Pun/2025 Assessment Year 2020-21

1) were validly issued, the appellant could only furnish reply to such notice dated 20.03.2022 providing few details. Since the appellant has earned interest on investments held with banks at Rs.98,85,426/- and further appellant did not file any details for such interest income, ld. AO treated the sum as Income from Other Sources and made addition thereon

DEPUTY COMMISSIONER OF INCOME-TAX, CIRCLE - 5,, PUNE vs. SHRI SUBHASH HASTIMAL LODHA,, PUNE

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

1. On the facts and in the circumstances of the case and in law, the Ld. CIT(A) erred in holding that the AO was not justified factually and legally in denying the assessee’s claim of deduction u/s. 54B of IT Act and thereby deleting the addition made in the assessment order. 2. On the facts