INDIAN MEDICAL ASSOCIATION PUNE BRANCH,SHUKRAWAR PETH vs. DCIT EXEMPTION CIRCLE, PUNE, SWARGATE

In the result, all the 5 appeals filed by the assessee are allowed

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

disallowed. 11. The Ld. DR on the other hand heavily relied on the order of the Ld. Addl. / JCIT(A). 12. We have heard the rival arguments made by both the sides, perused the orders of the Assessing Officer and Ld. Addl. / JCIT(A) and the paper book filed on behalf of the assessee. We have also considered the various

INDIAN MEDICAL ASSOCIATION PUNE BRANCH,SHUKRAWAR PETH vs. DCIT EXEMPTION CIRCLE PUNE, SWARGATE

In the result, all the 5 appeals filed by the assessee are allowed

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

disallowed. 11. The Ld. DR on the other hand heavily relied on the order of the Ld. Addl. / JCIT(A). 12. We have heard the rival arguments made by both the sides, perused the orders of the Assessing Officer and Ld. Addl. / JCIT(A) and the paper book filed on behalf of the assessee. We have also considered the various

INDIAN MEDICAL ASSOCIATION PUNE BRANCH,SHUKRAWAR PETH vs. DCIT EXEMPTION CIRCLE, PUNE, SWARGATE

In the result, all the 5 appeals filed by the assessee are allowed

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

disallowed. 11. The Ld. DR on the other hand heavily relied on the order of the Ld. Addl. / JCIT(A). 12. We have heard the rival arguments made by both the sides, perused the orders of the Assessing Officer and Ld. Addl. / JCIT(A) and the paper book filed on behalf of the assessee. We have also considered the various

DEPUTY COMMISSIONER OF INCOME TAX, CIRCLE-8, PUNE, PUNE vs. SANDVIK COROMANT INDIA PVT LTD, PUNE

In the result, appeal filed by the Revenue in ITA

Bench: Shri S.S.Godara & Dr. Dipak P. Ripoteआयकरअपीलसं. / Ita No.1072/Pun/2023 िनधा"रणवष" / Assessment Year : 2018-19 The Dy.Commissioner Of Sandvik Coromant India Pvt. Income Tax, Circle-8, Vs Ltd., Pune. Mumbai Pune Road, Dapodi, Pune – 411012. Pan: Aaccs6638K Appellant/ Revenue Respondent /Assessee Cross Objection No.7/Pun/2024 िनधा"रणवष" / Assessment Year : 2018-19 Sandvik Coromant India The Dy.Commissioner Of Pvt. Ltd., Vs Income Tax, Circle-8, Pune. Mumbai Pune Road, Dapodi, Pune – 411012. Pan: Aaccs6638K Appellant/ Assessee Respondent / Revenue Assessee By Shri Nikhil Patakh – Ar Revenue By Shri Ajay Kumar Keshari – Dr Date Of Hearing 15/04/2024 Date Of Pronouncement 07/05/2024 आदेश/ Order Per Dr. Dipak P. Ripote, Am: This Appeal Ita 1072/Pn/2023 Filed By The Revenue & Cross Objection Co No.7/Pun/2024 Filed By The Assessee Are Directed Against The Order Of Ld.Commissioner Of Income Tax(Appeal)[Nfac] U/S.250 Of The Act, For A.Y.2018-19

Section 251 of the Income Tax Act, 1961, which mandates that in an appeal against an order of assessment, the CIT(A) may confirm, reduce, enhance or annul the assessment. 3. On the facts and circumstances of the case and in law, the ld.CIT(A) erred in not disposing the same in the manner as provided in Sec.251(1

SATYAM TRANSFORMERS PRIVATE LIMITED,AURANGABAD vs. ITO WARD 2(3), AURANGABAD

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.1239/Pun/2025 धििाारण वर्ा / Assessment Year : 2015-16 Satyam Transformers Private Limited, Ito, Ward-2(3), Sharadanand, Opposite Telephone Office, Aurangabad Ajabnagar, Aurangabad-431001 Vs. Pan : Aakcs4648D अपीलार्थी / Appellant प्रत्यर्थी / Respondent Assessee By : Shri Shubham N. Rathi Department By : Shri Akhilesh Srivastva Date Of Hearing : 04-08-2025 Date Of 27-10-2025 Pronouncement : आदेश / Order

disallowance of index cost of acquisition is bad in law and therefore deserves to be allowed.” 6. The Ld. AR submitted that the assessee’s application under the Direct Tax Vivad Se Vishwas Act, 2020 (“DTVSV Act, 2020”) has been rejected by the Income Tax Department. Admittedly, there was a lapse on the part of the assessee to inform

SHRI GANADHIPATI GANDHARACHARYA KUNTIUSAGAR VIDYA SODH SONSTHA,PUNE vs. ITO, EXEMPTION, PUNE, PUNE

Bench: Shri Manish Borad & Ms. Astha Chandra

disallowing the assessee’s claim of exemption u/s 11 of the Act on the ground that the audit report in Form 10B was filed by the assessee beyond the prescribed due date of filing of return of income for the relevant AY 2018-19 under consideration. The Ld. AR submitted that both the return of income and Form 10B were

SHRI GANADHIPATI GANDHARACHARYA KUNTIUSAGAR VIDYA SODH SONSTHA,KOLHAPUR vs. ITO, EXEMPTION, PUNE, KOLHAPUR

Bench: Shri Manish Borad & Ms. Astha Chandra

disallowing the assessee’s claim of exemption u/s 11 of the Act on the ground that the audit report in Form 10B was filed by the assessee beyond the prescribed due date of filing of return of income for the relevant AY 2018-19 under consideration. The Ld. AR submitted that both the return of income and Form 10B were

SHRI GANADHIPATI GANDHARACHARYA KUNTIUSAGAR VIDYA SODH SONSTHA,KOLHAPUR vs. ITO, EXEMPTION, PUNE, KOLHAPUR

Bench: Shri Manish Borad & Ms. Astha Chandra

disallowing the assessee’s claim of exemption u/s 11 of the Act on the ground that the audit report in Form 10B was filed by the assessee beyond the prescribed due date of filing of return of income for the relevant AY 2018-19 under consideration. The Ld. AR submitted that both the return of income and Form 10B were

SHRI GANADHIPATI GANDHARACHARYA KUNTIUSAGAR VIDYA SODH SONSTHA,KOLHAPUR vs. ITO, EXEMPTION, PUNE, KOLHAPUR

Bench: Shri Manish Borad & Ms. Astha Chandra

disallowing the assessee’s claim of exemption u/s 11 of the Act on the ground that the audit report in Form 10B was filed by the assessee beyond the prescribed due date of filing of return of income for the relevant AY 2018-19 under consideration. The Ld. AR submitted that both the return of income and Form 10B were

OM J J SWA VISHWASHANTI DHAM NIRMAN SANSTHA,VERUL vs. ITO EXEMPTION WARD, AURANGABAD

In the result, appeal of the Assessee is allowed for statistical\npurpose

disallowing the\nclaim for exemption under section 11 of the Act, even though the\nappellant was a registered charitable institution under section 12AA of\nthe Act and had duly applied the income towards its charitable\nobjectives.\nCapital Nature of Donations - Not Taxable:\n6. On the facts and in the circumstances of the case and without\nprejudice to any other ground

REXEL INDIA PRIVATE LIMITED,PUNE vs. DEPUTY COMMISSIONER OF INCOME TAX, PUNE

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

251/- on Goodwill of Rs.\n59,95,13,004/- under the provisions of Section 32(1) of the Act. The Ld. AO\ncompleted the assessment by passing the assessment order u/s 143(3) of\nthe Act dated 20.12.2018 disallowing

DCIT, CIRCLE-8, PUNE vs. MAHLE ANAND THERMAL SYSTEMS PVT. LTD., PUNE

251 |\n| Manpower Cost | 6,91,701 | - | - |\n| Sub Total (A) | 4,98,21,138 | 3,39,60,518 | 1,58,60,621 | 9,96,42,277 |\n| Considered in CWIP | - | - | - |\n| Development Cost | 5,47,24,293 | 5,47,24,293 | - |\n| Tangible Investments | 6,800 | - | 6,800 |\n| Salary-Design | 1,18,45,866 | - | 1

MAHLE ANAND THERMAL SYSTEMS PRIVATE LIMITED,PUNE vs. DY COMMISSIONER OF INCOME TAX, PUNE

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

Bench: Shri R. K. Panda & Ms. Astha Chandraassessment Year : 2014-15

251 - Investments- Additions Manpower Cost 6,91,701 - - - Sub Total (A) 4,98,21,138 3,39,60,518 1,58,60,621 9,96,42,277 Considered in CWIP Development Cost 5,47,24,293 5,47,24,293 - - Tangible 6,800 - 6,800 - Investments Salary-Design 1,18,45,866 - 1,18,45,866 - Travel Expenses

DCIT,CIRCLE-8 , PUNE vs. MAHALE ANAND THERMAL SYSTEMS PVT. LTD. , PUNE

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

Bench: Shri R. K. Panda & Ms. Astha Chandraassessment Year : 2014-15

251 - Investments- Additions Manpower Cost 6,91,701 - - - Sub Total (A) 4,98,21,138 3,39,60,518 1,58,60,621 9,96,42,277 Considered in CWIP Development Cost 5,47,24,293 5,47,24,293 - - Tangible 6,800 - 6,800 - Investments Salary-Design 1,18,45,866 - 1,18,45,866 - Travel Expenses

DCIT CIRCLE 8 , PUNE vs. MAHLE ANAND THERMAL SYSTEMS PVT. LTD, PUNE

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

Bench: Shri R. K. Panda & Ms. Astha Chandraassessment Year : 2014-15

251 - Investments- Additions Manpower Cost 6,91,701 - - - Sub Total (A) 4,98,21,138 3,39,60,518 1,58,60,621 9,96,42,277 Considered in CWIP Development Cost 5,47,24,293 5,47,24,293 - - Tangible 6,800 - 6,800 - Investments Salary-Design 1,18,45,866 - 1,18,45,866 - Travel Expenses

M/S. ANGELICA PROPERTIES PRIVATE LTD.,,PUNE vs. DEPUTY COMMISSIONER INCOME-TAX,,

The appeals of the assessee are partly allowed

Bench: Shri S.S.Viswanethra Ravi, Hon’Ble Jm & Dr. Dipak P. Ripote, Hon’Ble Am आयकरअपीलसं. / Ita No: 403/Pun/2015 िनधा"रणवष" / Assessment Year : 2010-11 Vason Engineers Ltd., Theadditional Commissioner Of (Formerly Angelica Properties Pvt. Vs Income Tax, Range1, Pune. Ltd.,) 301, Phoenix, Opp.Residency Club, Bund Garden Road, Pune – 411037. Pan: Aafca 8644 J Appellant/ Assessee Respondent /Revenue आयकरअपीलसं. / Ita No: 1738/Pun/2016 िनधा"रणवष" / Assessment Year : 2011-12 Angelica Properties Pvt. Ltd., The Deputy Commissioner Of Opp. Grand Hyatt Hotel, Vs Income Tax, Circle-1(1), Pune. Vimannagar, Puune – 411 014. Pan: Aafca 8644 J Appellant/ Assessee Respondent /Revenue Assessee By Shri Dharmesh Shah – Ar Revenue By Shri Naveen Gupta – Dr Date Of Hearing 24/06/2022 Date Of Pronouncement 22/09/2022 आदेश/ Order Per Dr. Dipak P. Ripote, Am: These Two Appeals Filed By The Assessee Are Directed Against The Separate Orders Of Ld.Commissioner Of Income Tax(Appeals)-1, Pune Dated 30.01.2015 & 09.06.2016 For The Assessment Years 2010-11 & 2011-12 Respectively. 2. The Assessee In Ita No.403/Pun/2015 For The A.Y.2010-11 Has Raised Following Grounds Of Appeal: “1. The Ld. Cit(A) Has Erred In Law & In Facts Enhancing The Income From Sale Of ‘Matrix It Building’ By Changing The Head Of Income From Capital Gains To Business Income Without Complying With The Principles Of Natural Justice & Without Giving Any Opportunity Of Hearing.

disallowances to the extent of 50% of wage expenses claimed by appellant in profit and loss account and 50% of sundry creditors appearing in balance sheet of the assessee. The Hon’ble Court took a view that the power of Commissioner (Appeals) cannot be restricted on the ground of new source of income, as Section 251 clearly envisages the power

VASCON ENGINEERS LTD (SUCCESSOR TO ANGELICA PROPERTIES PVT. LTD.),PUNE vs. ADDITIONAL COMMISSIONER OF INCOME-TAX,, PUNE

The appeals of the assessee are partly allowed

Bench: Shri S.S.Viswanethra Ravi, Hon’Ble Jm & Dr. Dipak P. Ripote, Hon’Ble Am आयकरअपीलसं. / Ita No: 403/Pun/2015 िनधा"रणवष" / Assessment Year : 2010-11 Vason Engineers Ltd., Theadditional Commissioner Of (Formerly Angelica Properties Pvt. Vs Income Tax, Range1, Pune. Ltd.,) 301, Phoenix, Opp.Residency Club, Bund Garden Road, Pune – 411037. Pan: Aafca 8644 J Appellant/ Assessee Respondent /Revenue आयकरअपीलसं. / Ita No: 1738/Pun/2016 िनधा"रणवष" / Assessment Year : 2011-12 Angelica Properties Pvt. Ltd., The Deputy Commissioner Of Opp. Grand Hyatt Hotel, Vs Income Tax, Circle-1(1), Pune. Vimannagar, Puune – 411 014. Pan: Aafca 8644 J Appellant/ Assessee Respondent /Revenue Assessee By Shri Dharmesh Shah – Ar Revenue By Shri Naveen Gupta – Dr Date Of Hearing 24/06/2022 Date Of Pronouncement 22/09/2022 आदेश/ Order Per Dr. Dipak P. Ripote, Am: These Two Appeals Filed By The Assessee Are Directed Against The Separate Orders Of Ld.Commissioner Of Income Tax(Appeals)-1, Pune Dated 30.01.2015 & 09.06.2016 For The Assessment Years 2010-11 & 2011-12 Respectively. 2. The Assessee In Ita No.403/Pun/2015 For The A.Y.2010-11 Has Raised Following Grounds Of Appeal: “1. The Ld. Cit(A) Has Erred In Law & In Facts Enhancing The Income From Sale Of ‘Matrix It Building’ By Changing The Head Of Income From Capital Gains To Business Income Without Complying With The Principles Of Natural Justice & Without Giving Any Opportunity Of Hearing.

disallowances to the extent of 50% of wage expenses claimed by appellant in profit and loss account and 50% of sundry creditors appearing in balance sheet of the assessee. The Hon’ble Court took a view that the power of Commissioner (Appeals) cannot be restricted on the ground of new source of income, as Section 251 clearly envisages the power

DY. COMMISSIONER OF INCOME TAX, CIRCLE-1(1), PUNE, PUNE vs. BANK OF MAHARASHTRA, PUNE

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

sections": [ "143(1)", "143(2)", "142(1)", "143(3)", "36(1)(viia)", "14A", "Rule 8D", "115JB", "251(1)(a)", "80G", "271(1)(c)" ], "issues": "Whether various disallowances