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

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

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

25. For section 80AC of the Income-tax Act, the following section shall be substituted, namely:- 80AC. Deduction not to be allowed unless return furnished-Where in computing the total income of an assessee of any previous year relevant to the assessment year commencing on or after – (i) the 1st day of April, 2006 but before

NITIN DWARKADAS NYATI,PUNE vs. ASSISTANT COMMISSIONER OF INCOME TAX, PUNE

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

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

section 14A of the Act. It is also his submission that the disallowance, if any, u/s 14A read with Rule 8D should be applicable only to such expenditure which may have any nexus with earning exempt income and not extend the disallowance to expenses having direct relation to earning taxable income. 11. We find some force in the above arguments

E-ALLY SECURITIES (INDIA) PVT. LTD.,RAIGAD vs. DCIT CIRCLE, PANVEL, PANVEL

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

Bench: Shri R. K. Panda & Shri Vinay Bhamoreassessment Year : 2018-19

25-02-2025 Date of pronouncement : 26-05-2025 O R D E R PER R. K. PANDA, VP : This appeal filed by the assessee is directed against the order dated 23.04.2024 of the Ld. CIT(A) / NFAC, Delhi relating to assessment year 2018-19. 2. The only issue raised by the assessee in the grounds of appeal relates

ULTRA CORPOTECH P L EMPLOYEE GROUP GRATUITY CUM LIFE ASSURANCE SCHEME,PUNE vs. ITO, EXEMPTION, WARD-1(2), PUNE, PUNE

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

Bench: Dr.Manish Borad & Shri Vinay Bhamore

disallowance of exemption u/s 10 of ITA, 1961, amounting to Rs. 6,51,82,342 against the nil return of income. 2 Ultra Corpotech P L Employee Group Gratuity Cum Life Assurance Scheme 2. The learned ADDL/JCIT(A), Mysore erred in law and facts in denying exemption u/s 10(25)(iv) of the ITA, 1961 due to non-filing

EATON TECHNOLOGIES PRIVATE LIMITED,PUNE vs. PRINCIPAL COMMISSIONER OF INCOME TAX, PUNE

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

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

25,53,250/- wherein apart from the Transfer Pricing adjustment of Rs.9,41,77,133/- he made disallowance u/s.40(a)(i) at Rs.26,39,84,698/-. 3.1 Subsequently, the PCIT examined the record and noted that the AO has allowed deduction u/s.10AA of the Act at Rs.263,46,37,168/-. He noted that in the earlier years

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

disallowance of\nexpenditure incurred in relation to the IPO which was subsequently\naborted amounting to INR 1,17,25,562/- under section

SHRI LAXMI V K S (VIKAS) SEVA SANSTHA MARYADIT BASARGE BK,KOLHAPUR vs. ITO ASSESSMENT UNIT ITD, KOLHAPUR

In the result, the appeal is allowed for statistical purposes

Bench: Shri Manish Borad & Shri Vinay Bhamoreआयकर अपील सं. / Ita No.489/Pun/2025 निर्धारण वर्ा / Assessment Year : 2015-16 Shri Laxmi Vks (Vikas) Vs. Ito, Assessment Unit, Seva Sanstha Maryadi Income Tax Department. Basarge Bk, At Basarge, Tal. Gadhinglaj, Dist. Kolhapur- 416506. Pan : Aakas3603C Appellant Respondent

disallowance of deduction of Rs. 10,25,886/- u/s 80P(2)(a) and Rs.14,000/- u/s 80P(2)(c) on the ground that the assessee had not made the claim in the return of income and hence, in view of provisions of section

LIQUIDHUB ANALYTICS PVT. LTD. (NOW MERGED WITH CAPGEMINI TECHNOLOGY SERVICES INDIA LTD),PUNE vs. NFAC, PUNE

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

Bench: Shri R. K. Panda & Shri Vinay Bhamoreassessment Year : 2020-21

disallowance under section 36(1)(va) of the Act 13 The Ld. AO erred in initiating penalty proceedings under Section 270A of the Act on arbitrary premise that there is under-reporting of income done by the Appellant The above grounds are without prejudice to each other The appellant craves leave to alter, amend or withdraw

KEDAR SHASHANK RANADE,PUNE vs. ACIT, CIRCLE -2 , PUNE

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

Bench: Shri R. K. Panda & Ms Astha Chandraassessment Year : 2018-19

section 36(1)(iii) of the Act. Rejecting the various explanations given by the assessee, the Assessing Officer disallowed an amount of Rs.6,25

DCIT, SWARGATE PUNE vs. GRIHUM HOUSING FINANCE LIMITED, PUNE

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

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

25% is outside the scope of 143(1) of the Act since it is not falling under the prima facie adjustment covered within section 143(1) of the Act. In his alternate ground the assessee has stated that no proper opportunity was granted to the assessee and therefore, the order is bad in law. 10. Referring to the decision

DCIT, CIRCLE 8 PUNE, PUNE vs. ALFA LAVAL INDIA PVT LTD, PUNE

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

section 37 while computing income tax on Business\nIncome. Since these expenses were disallowed in earlier years it could not be held\nliable for tax in the year under consideration when they are reversed and credited\nto Profit & Loss Account. Accordingly, the assessee took the deduction of\nRs.2,02,56,631/- in the relevant year under any other amount allowable

ASST. COMMISSIONER OF INCOME TAX, PANVEL CIRCLE PANVEL vs. OUTABOX MEDIA SOLUTIONS LLP, GHATKOPAR MUMBAI

In the result, the appeal filed by the Revenue is partly allowed

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

disallowance of 25% of said claim made, by merely relying on payments made to parties through banking channels without even considering the fact that payments through banking channel are not conclusive to prove the genuinety of expenses claimed. iv. The order of the CIT(A) may be vacated and that of the Assessing Officer may be restored v. The appellant

MAHATMA PHULE GRAMIN BIGARSHETI SAHAKAR PAT SANSTHA LTD,KOLHAPUR vs. PCIT-1, PUNE, PUNE

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

Bench: Shri R. K. Panda & Ms. Astha Chandraassessment Year : 2018-19 Mahatma Phule Gramin Bigarsheti Pcit-1, Pune Sahakar Pat Sanstha Vs. A/P Hattiwade, Ajara, Kolhapur – 416505 Pan: Aaaam2608K (Appellant) (Respondent) Assessee By : None (Written Submission Filed) Department By : Shri Amol Khairnar, Cit-Dr Date Of Hearing : 09-12-2025 Date Of Pronouncement : 09-01-2026 O R D E R

disallowance of deduction under section 80P, without appreciating that compliance under section 80AC is not mandatory and it is discretionary and further, by implication, AO had accepted one of the views in case of debatable issue. 3. The assessee craves leave to amend, alter or delete any of the above grounds of appeal. It is prayed that the above claims

BAJAJ FINANCE LIMITED,PUNE vs. PRINCIPAL COMMISSIONER OF INCOME TAX-3, PUNE, PUNE

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

Bench: Shri R. K. Panda & Shri Vinay Bhamoreassessment Year : 2019-20 Bajaj Finance Limited Pcit-3, Pune 3Rd Floor, Panchshil Tech Park, Vs. Viman Nagar, Pune – 411014 Pan: Aabcb1518L (Appellant) (Respondent) Assessee By : Shri Percy Pardiwalla Department By : Shri Amol Khairnar, Cit-Dr Date Of Hearing : 06-01-2026 Date Of Pronouncement : 29-01-2026

disallowance under section 14A the interest expense debited by the assessee because the same 25 has been incurred for the purpose

SWAROOP AGROCHEMICAL INDUSTRIES,NASHIK vs. ACIT, CIRCLE-1, NASHIK

In the result, appeal of the Assessee is allowed

section 250 of the Income Tax Act,\n1961 (“Act”), which is arising out of the assessment order u/s.\n143(3) r.w.s.144B of the Act, dated 20/04/2021 for the\n Assessment Year (AY) 2018-19.\n2. The assessee has raised seven grounds of appeal, but all\nrevolve around disallowance of expenses under various heads\namounting to Rs.36,25

CAPGEMINI TECHNOLOGY SERVICES INDIA LIMITED ( SUCCESSOR OF ARICENT TECHNOLOGIES HOLDINGS LIMITED),PUNE vs. ASSISTANT COMMISSIONER OF INCOME TAX, CIRCLE 1(1), PUNE, PUNE

In the result, the appeal of the assessee is allowed

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

25,06,638 - Rs.1,39,38,45,890) after adjusting the incremental liability that may arise on disallowing health and education Cess. He, therefore, submitted that there is no basis for holding that the assessee has under-reported its income or done any act without good faith and due diligence and hence the provisions of section

PIAGGIO VEHICLES PVT LTD ,PUNE vs. ACIT, CIRCLE 4, PUNE, PUNE

In the result, the appeal of the assessee is dismissed

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

disallowance of expenditure under Section 14A of the Act. These decisions, therefore, limited their observations to the applicability of Section 14A of the Act on dividend income. Also, the G&B HC decision and the G&B SC decision have not laid down any principle contrary to those laid down by the Hon'ble SC in Tata Tea decision

ASSTT.COMMISSIONER OF INCOME TAX, PUNE vs. NITIN DWARKADAS NYATI, PUNE

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

Bench: Shri R. K. Panda & Ms. Astha Chandraassessment Year : 2020-21 Acit, Central Circle 2(3), Nitin Dwarkadas Nyati Pune Sr. No.103/129, Nyati Unitree, Vs. Yerwada, Nagar Road, Pune – 411006 Pan: Aabpn2601F (Appellant) (Respondent) Assessee By : Shri Krishna V Gujarathi Department By : Shri Vidya Ratan Kishore Date Of Hearing : 15-12-2025 Date Of Pronouncement : 19-12-2025 O R D E R

section 14A of the Act. It is also his submission that the disallowance, if any, u/s 14A read with Rule 8D should be applicable only to such expenditure which may have any nexus with earning exempt income and not extend the disallowance to expenses having direct relation to earning taxable income. 11. We find some force in the above arguments

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

disallowing the 'Payment of management service' under section 37(1) of the act disregarding the fact that the said expenses are incurred wholly and exclusively for the purposes of the business of the Appellant and hence the same is allowable under section 37(1) of the Act. 7 Initiation of Penalty Proceedings: 7.1 The Ld. AD pursuant to the direction