M/S. NYATI BUILDERS PVT.LTD,,PUNE vs. DEPUTY COMMISSIONER OF INCOME TAX,, PUNE

In the result, the appeal of Revenue is dismissed and appeals of assessee are allowed

Bench: Ms. Sushma Chowla, Jm & Shri Anil Chaturvedi, Am आयकर अपीऱ सं. / Ita No.1242/Pun/2017 यििाारण वषा / Assessment Year : 2013-14 The Dy. Commissioner Of Income Tax, अऩीऱाथी/Appellant Circle 9, Pune …. Vs. M/S. Ksh International Pvt. Ltd., Gat No.11/3, 11/4, Vill-Birdewadi, Chakan, …. प्रत्यथी / Respondent Tal-Khed, Pune – 410501 Pan:Aaacb1897K

disallowance under section 14A of the Act was not permissible and the appeal of Revenue was dismissed. The Revenue filed Special Leave Petition before the Hon'ble Supreme Court and vide judgment dated 08.02.2019 in item No.33 Court No.11 Section XIV, in Special Leave Petition (Civil) Diary Nos.2755/2019, it was held that In view of the decision of this Court

DEPUTY COMMISSIONER OF INCOME TAX,, PUNE vs. M/S. KSH INTERNATIONAL PVT.LTD,, PUNE

In the result, the appeal of Revenue is dismissed and appeals of assessee are allowed

Bench: Ms. Sushma Chowla, Jm & Shri Anil Chaturvedi, Am आयकर अपीऱ सं. / Ita No.1242/Pun/2017 यििाारण वषा / Assessment Year : 2013-14 The Dy. Commissioner Of Income Tax, अऩीऱाथी/Appellant Circle 9, Pune …. Vs. M/S. Ksh International Pvt. Ltd., Gat No.11/3, 11/4, Vill-Birdewadi, Chakan, …. प्रत्यथी / Respondent Tal-Khed, Pune – 410501 Pan:Aaacb1897K

disallowance under section 14A of the Act was not permissible and the appeal of Revenue was dismissed. The Revenue filed Special Leave Petition before the Hon'ble Supreme Court and vide judgment dated 08.02.2019 in item No.33 Court No.11 Section XIV, in Special Leave Petition (Civil) Diary Nos.2755/2019, it was held that In view of the decision of this Court

FCA INDIA AUTOMOBILES PRIVATE LIMITED (SURVIVING ENTITY AFTER THE MERGER OF PCA MOTORS PVT LTD),PUNE vs. ASSESSMENT UNIT, INCOME TAX DEPARTMENT, NATIONAL FACELESS ASSESSMENT CENTRE

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

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

253 of the Income-tax Act, 1961 (hereinafter referred to as the Act'), against the 2 order dated 26 June 2024 issued by the National Faceless Appeal Centre ('NFAC') (hereinafter referred to as 'Ld. NFAC'), under Section 250 of the Act on the grounds as set out herein: 1. General ground 1.1 On the facts and circumstances of the case

DCIT, CIRCLE-8 vs. M/S. BAJAJ FINANCE LTD. PUNE, AKURDI PUNE

Bench: Shri S.S. Godara & Dr. Dipak P. Ripote

3. Question No. (i) arose in following background:- 3.1 Respondent assessee is a Non Banking Finance Company ("NBFC" for short). Respondent filed return of income for the assessment year 2009-10 in which the assessee had claimed deduction of interest on advances which had become non performing assets ("NPA" for short). The Assessing Officer disallowed the claim relying on such

DEPUTY COMMISSIONER OF INCOME-TAX, CIRCLE - 8,, PUNE vs. M/S. BAJAJ FINANACE LTD,, PUNE

Bench: Shri S.S. Godara & Dr. Dipak P. Ripote

3. Question No. (i) arose in following background:- 3.1 Respondent assessee is a Non Banking Finance Company ("NBFC" for short). Respondent filed return of income for the assessment year 2009-10 in which the assessee had claimed deduction of interest on advances which had become non performing assets ("NPA" for short). The Assessing Officer disallowed the claim relying on such

BAJAJ FINANCE LTD,,PUNE vs. DEPUTY COMMISSIONER OF INCOME-TAX, CIRCLE - 8,, PUNE

Bench: Shri S.S. Godara & Dr. Dipak P. Ripote

3. Question No. (i) arose in following background:- 3.1 Respondent assessee is a Non Banking Finance Company ("NBFC" for short). Respondent filed return of income for the assessment year 2009-10 in which the assessee had claimed deduction of interest on advances which had become non performing assets ("NPA" for short). The Assessing Officer disallowed the claim relying on such

BAJAJ FINANCE LTD,,PUNE vs. DEPUTY COMMISSIONER OF INCOME-TAX, CIRCLE - 8,, PUNE

Bench: Shri S.S. Godara & Dr. Dipak P. Ripote

3. Question No. (i) arose in following background:- 3.1 Respondent assessee is a Non Banking Finance Company ("NBFC" for short). Respondent filed return of income for the assessment year 2009-10 in which the assessee had claimed deduction of interest on advances which had become non performing assets ("NPA" for short). The Assessing Officer disallowed the claim relying on such

BMC SOFTWARE INDIA PRIVATE LIMITED,PUNE vs. DEPUTY COMMISSIONER OF INCOME-TAX CIRCLE-1(1), PUNE

The appeal is dismissed as not pressed

Bench: Shri R.S. Syal & Shri Partha Sarathi Chaudhury

253(1)(d) of the Income-tax Act, 1961 (hereinafter referred to as 'Act'), against the order dated 22 April 2021 (received on 22 April 2021) passed by the Additional/Joint / Deputy / Assistant Commissioner of Income Taxi Income- tax Officer, National e- Assessment Centre, Delhi (hereinafter referred to as 'learned AO') under section 143(3) r.w.s. section 144C(13) r.w.s. section

DEPUTY COMMISSIONER OF INCOME-TAX, CIRCLE - 8,, PUNE vs. M/S. BAJAJ FINANCE LTD,, PUNE

Bench: Shri Satbeer Singh Godara & Dr. Dipak P. Ripote

3. Question No. (i) arose in following background:- 3.1 Respondent assessee is a Non Banking Finance Company ("NBFC" for short). Respondent filed return of income for the assessment year 2009-10 in which the assessee had claimed deduction of interest on advances which had become non 15 ITA.Nos.1394 & 1722/PUN./2018 M/s. Bajaj Finance Ltd., Pune. performing assets

BAJAJ FINANCE LTD,,PUNE vs. DEPUTY COMMISSIONER OF INCOME-TAX, CIRCLE - 8,, PUNE

Bench: Shri Satbeer Singh Godara & Dr. Dipak P. Ripote

3. Question No. (i) arose in following background:- 3.1 Respondent assessee is a Non Banking Finance Company ("NBFC" for short). Respondent filed return of income for the assessment year 2009-10 in which the assessee had claimed deduction of interest on advances which had become non 15 ITA.Nos.1394 & 1722/PUN./2018 M/s. Bajaj Finance Ltd., Pune. performing assets

INCOME TAX OFFICER, WARD-11(1), PUNE, PUNE vs. MAHARASHTRA CRICKET ASSOCIATION, PUNE, PUNE

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

disallowance of the claim of\ndeficit holding that there is no merit in the addition(s) made by the Ld. AO\nfor the reasons recorded in pars 5.1 to 5.5.2 of his impugned appellate\norder.\n5.\nDissatisfied, the Revenue is in appeal before the Tribunal and all the\ngrounds of appeal relate thereto.\n6. The Ld. DR contended that

DCIT, SWARGATE PUNE vs. CUMMINS INDIA LTD , PUNE

In the result, appeal of the assessee bearing ITA No

253 of the\nincome-tax Act, 1961 (\"the Act\") against the order dated 30 June\n2022, passed under section 143(3) read with section 144C(13) read\nwith section 1448 of the Act, by the learned additional/ Joint/\nDeputy/Assistant Commissioner of Income tax, National Faceless\nAssessment Centre, Delhi (hereinafter referred to as \"Assessing\nOfficer /\"AO\") in pursuance of the directions

KIMBERLY CLARK LEVER P.LTD.,PUNE vs. ACIT, PUNE

In the result, the appeal of the assessee stands allowed

Bench: Shri Inturi Rama Rao, Am & Shri Partha Sarathi Chaudhury, Jm आयकर अपील सं. / Ita No.2481/Pun/2012 िनधा"रण वष" / Assessment Year : 2008-09 Kimberly Clark Lever P. Ltd., Gat No.934 To 937, Village Sanaswadi Off Nagar Road, Ta- Shirur, Pune-412208. .......अपीलाथ" / Appellant Pan : Aaack4647E बनाम / V/S. Acit, Circle-Xi(I), ……""यथ" / Respondent Pune. Assessee By : Shri Percy Pardiwalla Revenue By : Shri Sandeep Garg सुनवाई क" तारीख / Date Of Hearing : 08.02.2021 घोषणा क" तारीख / Date Of Pronouncement : 22.02.2021 आदेश / Order Per Inturi Rama Rao, Am: This Is An Appeal Filed By The Assessee Directed Against The Final Assessment Order U/S 143(3) R.W.S. 144C Of The Income Tax Act, 1961 (‘The Act’ For Short) Of The Asstt. Commissioner Of Income Tax, Circle-11(1), Pune (‘The Assessing Officer’ For Short) Dated 29.10.2012 For The Assessment Year 2008-09. 2. The Appellant Raised The Following Grounds Of Appeal :- “The Appellant Objects To The Order Dated 29 October 2012 Passed Under Section 143(3) R.W.S. 144(C) Of The Income-Tax Act, 1961 (‘The Act’) By The Assistant Commissioner Of Income Tax, Circle 11(1), Pune [‘Acit’ Or ‘Ao’] Following The Directions Issued By The Dispute Resolution Panel (‘Drp’) In Respect Of The Aforesaid Assessment Year On The Following Among Other Grounds:

3) of the Act, the appellant company filed objection before the Hon’ble Dispute Resolution Panel, Pune (DRP) contesting all the above proposed 8 additions/disallowances. The main contention of the appellant company before the Hon’ble DRP is as under :- “5.2 In response to the said proposal, the assessee has contended as under :-  That the proposed approach would tantamount

TETRA PAK INDIA PRIVATE LTD.,,PUNE vs. DY.CIT, CIR.7, PUNE, PUNE

The appeal of the assessee is partly allowed for statistical purposes

Bench: Shri D. Karunakara Rao, Am & Shri Vikas Awasthy, Jm आयकर अपील सं. / Ita No.111/Pun/2011 िनधा"रण वष" / Assessment Year : 2006-07 Tetra Pak India Private Ltd., Mayfair Towers, Wakdewadi, Shivajinagar, Pune-411005. .......अपीलाथ" / Appellant Pan : Aaact3467B बनाम / V/S. Dcit, Circle-7, ……""यथ" / Respondent Pune. Assessee By : Shri Nikhil Pathak Revenue By : Shri S. B. Prasad सुनवाई क" तारीख / Date Of Hearing : 02.07.2019 घोषणा क" तारीख / Date Of Pronouncement : 27.08.2019 आदेश / Order Per D. Karunakara Rao, Am: This Appeal Is Filed By The Assessee Against The Orders Of Assessing Officer/Tpo/Drp For The Assessment Year 2006-07. 2. The Grounds Raised By The Assessee Are As Under :- “Based On The Facts & Circumstances Of The Case, Tetra Pak India Private Limited (Hereinafter Referred To As ‘The Appellant’) Respectfully Craves Leave To Prefer An Appeal Under Section 253(1)(D) Of The Income- Tax Act, 1961 (Hereinafter Referred To As ‘Act’), Against The Order Dated 25 November 2010 Passed By The Deputy Commissioner Of Income Tax- Circle 7 (Hereinafter Referred To As ‘The Assessing Officer’) Under Section 143(3) Read With Section 144C(13) Of The Act In Pursuance Of The Directions Dated 20 September 2010 Issued By The Honorable Dispute Resolution Panel (Hereinafter Referred To As ‘The Honorable Drp’), On The Following Grounds: On The Facts & In The Circumstances Of The Case & In Law, The Honorable Drp & Consequentially The Learned Ao Have: I Grounds Of Objections In Respect Of Transfer Pricing Adjustment

253(1)(d) of the Income- tax Act, 1961 (hereinafter referred to as ‘Act’), against the order dated 25 November 2010 passed by the Deputy Commissioner of Income Tax- Circle 7 (hereinafter referred to as ‘the Assessing Officer’) under section 143(3) read with section 144C(13) of the Act in pursuance of the directions dated 20 September 2010 issued

JAWAHAR LAL NEHRU PORT TRUST,NAVI MUMBAI vs. ACIT PANVEL, PANVEL

In the result, all the three appeals filed by the Revenue are dismissed and all the three appeals filed by the assessee are partly allowed

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

disallowance of interest expenses of Rs.157.34 crores claimed on payment basis is concerned, the Ld. CIT(A) upheld the action of the Assessing Officer on the ground that the provisions of section 14A are applicable in this case. According to him, the provisions of section 36(1)(xii) are also not applicable to the assessee as the same are applicable

DEPUTY COMMISSIONER OF INCOME-TAX vs. THE JAWAHARLAL NEHRU PORT TRUST,, RAIGAD

In the result, all the three appeals filed by the Revenue are dismissed and all the three appeals filed by the assessee are partly allowed

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

disallowance of interest expenses of Rs.157.34 crores claimed on payment basis is concerned, the Ld. CIT(A) upheld the action of the Assessing Officer on the ground that the provisions of section 14A are applicable in this case. According to him, the provisions of section 36(1)(xii) are also not applicable to the assessee as the same are applicable

JAWAHAR LAL NEHRU PORT TRUST,NAVI MUMBAI vs. ACIT PANVEL, PANVEL

In the result, all the three appeals filed by the Revenue are dismissed and all the three appeals filed by the assessee are partly allowed

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

disallowance of interest expenses of Rs.157.34 crores claimed on payment basis is concerned, the Ld. CIT(A) upheld the action of the Assessing Officer on the ground that the provisions of section 14A are applicable in this case. According to him, the provisions of section 36(1)(xii) are also not applicable to the assessee as the same are applicable

JAWAHAR LAL NEHRU PORT TRUST,NAVI MUMBAI vs. ACIT PANVEL, PANVEL

In the result, all the three appeals filed by the Revenue are dismissed and all the three appeals filed by the assessee are partly allowed

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

disallowance of interest expenses of Rs.157.34 crores claimed on payment basis is concerned, the Ld. CIT(A) upheld the action of the Assessing Officer on the ground that the provisions of section 14A are applicable in this case. According to him, the provisions of section 36(1)(xii) are also not applicable to the assessee as the same are applicable