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

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

disallowance for the earlier assessment years which were on the ground that the assessee which was following the mercantile system of banking had to pay tax on interest on accrual basis. 3.2 The issue eventually reached the Tribunal. The Tribunal, by the impugned judgment, allowed the assessee's claim, upon which, the Revenue has filed this appeal. 4. Learned counsel

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

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

disallowance for the earlier assessment years which were on the ground that the assessee which was following the mercantile system of banking had to pay tax on interest on accrual basis. 3.2 The issue eventually reached the Tribunal. The Tribunal, by the impugned judgment, allowed the assessee's claim, upon which, the Revenue has filed this appeal. 4. Learned counsel

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

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

disallowance for the earlier assessment years which were on the ground that the assessee which was following the mercantile system of banking had to pay tax on interest on accrual basis. 3.2 The issue eventually reached the Tribunal. The Tribunal, by the impugned judgment, allowed the assessee's claim, upon which, the Revenue has filed this appeal. 4. Learned counsel

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

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

disallowance for the earlier assessment years which were on the ground that the assessee which was following the mercantile system of banking had to pay tax on interest on accrual basis. 3.2 The issue eventually reached the Tribunal. The Tribunal, by the impugned judgment, allowed the assessee's claim, upon which, the Revenue has filed this appeal. 4. Learned counsel

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

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

disallowance for the earlier assessment years which were on the ground that the assessee which was following the mercantile system of banking had to pay tax on interest on accrual basis. 3.2 The issue eventually reached the Tribunal. The Tribunal, by the impugned judgment, allowed the assessee's claim, upon which, the Revenue has filed this appeal. 4. Learned counsel

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

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

disallowance for the earlier assessment years which were on the ground that the assessee which was following the mercantile system of banking had to pay tax on interest on accrual basis. 3.2 The issue eventually reached the Tribunal. The Tribunal, by the impugned judgment, allowed the assessee's claim, upon which, the Revenue has filed this appeal. 4. Learned counsel

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:

4. The appellant company also submitted TP study report wherein it sought to benchmark the above international transactions. The appellant applied Transactional Net Margin Method (TNMM) which was considered as most appropriate method for the purpose of benchmarking the international transactions of finished goods with its foreign AE i.e. Kimberly Clark Asia Pacific Pte Limited. As regards to the payment

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

253, after the expiry of the financial year in which the proceedings, in the course of which action for the imposition of penalty has been initiated, are completed, or six months from the end of the month in which the order of the Joint Commissioner (Appeals) or the Commissioner (Appeals) or, as the case may be, the Appellate Tribunal

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

253, after the expiry of the financial year in which the proceedings, in the course of which action for the imposition of penalty has been initiated, are completed, or six months from the end of the month in which the order of the Joint Commissioner (Appeals) or the Commissioner (Appeals) or, as the case may be, the Appellate Tribunal

DEPUTY COMMISSIONER OF INCOME TAX, AURANGABAD vs. JHAVERI FLEXO INDIA PVT LTD, AURANGABAD

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

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

section 37 of the Act. Even if the expenses are for the directors of the company, so far as the appellant is concerned the same is legitimate business expenses. 8 C.O. No.14/PUN/2024 In view of the above reasons, this ground of appeal is allowed and the disallowance of expenses of Rs. 4,00,000/- stands deleted.” 12. As regards disallowance

SHRI SANT SENA MAHARAJ NABHIK SAMAJACHI NAGARI SAHAKARI PATSANSTHA, MARYADIT,JALGAON vs. INCOME TAX OFFICER, WRD-1(4), JALGAON, JALGAON

The appeal of the assessee is DISMISSED

Bench: Shri Satbeer Singh Godara & Shri G. D. Padmahshaliआयकर अपऩल सं. / Ita No. 841/Pun/2023 निर्धारण वषा / Assessment Year : 2019-20 Shri Sant Sena Maharaj Nabhik Samajachi Nagari Sahkari Patsanstha Maryadit, Behind Shani Mandir, Radhabai Chal, Chalisgaon – 424 101 Pan: Aabas8462N . . . . . . . अपीलार्थी / Appellant बिधम / V/S Income Tax Officer- 1(4), Jalgaon . . . . . . . प्रत्यर्थी / Respondent द्वधरध / Appearances Assessee By : Shri Abhay Avachat [‘Ld. Ar’] Revenue By : Shri R Y Balawade [‚Ld. Dr] सुनवाई की तारीख / Date Of Conclusive Hearing : 10/08/2023 घोषणा की तारीख / Date Of Pronouncement : 01/09/2023 आदेश / Order Per G. D. Padmahshali, Am; The Present Appeal Instituted U/S 253(1) Of Income-Tax Act, 1961 [‘The Act’ Hereafter] Challenges Din & Order No. Itba/Nfsc/S/250/2023- 24/1052715471(1) Dt. 10/05/2023 Passed U/S 250 Of The Act By National Faceless Appeal Centre, Delhi [‘Nfac’ Hereafter].

253(1) of Income-tax Act, 1961 [‘the Act’ hereafter] challenges DIN & Order No. ITBA/NFSC/S/250/2023- 24/1052715471(1) dt. 10/05/2023 passed u/s 250 of the Act by National Faceless Appeal Centre, Delhi [‘NFAC’ hereafter]. 2. Tersely stated facts of the case are; 2.1 The appellant assessee is a credit co-operative society and for assessment year 2019-20 [‘AY’ hereafter

M/S GIRIRAJ ENTERPRISES,PUNE vs. DCIT, CC.1(1), PUNE, PUNE

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

Bench: Shri R. K. Panda & Ms. Astha Chandraassessment Year : 2021-22

disallowance of deduction claimed u/s 80IA(4) of Rs.18,01,430/-. 4. Subsequently the Assessing Officer initiated penalty proceedings u/s 271AAB of the Act. The assessee submitted that the declaration made during the course of search on account of sale of Gai Chap tobacco and other products was well before the due date for filing the return of income

ASST. COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-1(1), PUNE, PUNE vs. GIRIRAJ ENTERPRISES, PUNE

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

Bench: Shri R. K. Panda & Ms. Astha Chandraassessment Year : 2021-22

disallowance of deduction claimed u/s 80IA(4) of Rs.18,01,430/-. 4. Subsequently the Assessing Officer initiated penalty proceedings u/s 271AAB of the Act. The assessee submitted that the declaration made during the course of search on account of sale of Gai Chap tobacco and other products was well before the due date for filing the return of income

ASSISTANT COMMISSIONER OF INCOME TAX CIRCLE 12, PUNE vs. VARUN JAIN, PUNE

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

Bench: Dr.Dipak P. Ripote & Shri Vinay Bhamorecross Objection No.14/Pun/2025 (Arising Out Of Ita No.2720/Pun/2024) िनधा"रण वष" / Assessment Year: 2018-19 Varun Jain, The Acit, P-024, Forest County, Kharadi, V Circle-12, Pune. Pune – 411014. S. Maharashtra. Pan:Aexpj0171J Appellant/ Assessee Respondent / Revenue आयकर अपील सं. / Ita No.2720/Pun/2024 िनधा"रण वष" / Assessment Year: 2018-19 The Acit, Varun Jain, Circle-12, Pune. Vs. P-024, Forest County, Kharadi, Pune – 411014. Maharashtra. Pan:Aexpj0171J Appellant / Revenue Respondent / Assessee Assessee By Shri Fenil Bhatt – Ar(Virtual) Revenue By Shri Abhinay Kumbhar - Dr Date Of Hearing 05/05/2025 Date Of Pronouncement 07/05/2025 आदेश/ Order Per Dr. Dipak P. Ripote, Am: In This Case, Revenue Has Filed An Appeal Against The Order Of Ld.Commissioner Of Income Tax(Appeal)[Nfac] Passed Under C.O.No.14/Pun/2025 [A] & Ita No.2720/Pun/2024 [R]

253(4) of the Act. 1.1 Revenue has raised the following Grounds of appeal “a. Whether on facts and circumstances of the case, the CITIA) was justified in allowing the dividend income of ₹5,59,37,863 as exempt under Section 10(35). overlooking the evidence obtained during the survey on JM Financial Asset Management Ltd., which confirmed violations

DEPUTY COMMISSIONER OF INCOME TAX , CIRCLE-8, PUNE vs. NEELIMA PANKAJ THORAT, PUNE

In the result, the appeal of the Revenue is allowed and the

Bench: Shri R.S. Syal & Shri Partha Sarathi Chaudhuryआयकर अपील सं. / Ita No.153/Pun/2023 "नधा"रण वष" / Assessment Year : 2019-20 Dcit, Circle-8, Vs. Neelima Pankaj Thorat, Pune Flat No.C/1201, The Metropolitan, Pimpri Chinchwad Link Road, Chinchwad, Pune 411 033 Pan : Aegpt 3582C Appellant Respondent

section 253(2), it becomes manifest that the AO, having territorial jurisdiction over the assessee, is authorized to file appeal before the Tribunal. The ld. AR fairly admitted that the JCIT (OSD), Circle-8, Pune is the 5 and CO No.13/PUN/2023 Neelima Pankaj Thorat territorial Assessing Officer of the assessee, who in the present case had filed the appeal

DCIT EXMP CIRCLE PUNE, SWARGATE PMT BLDG vs. ASHIRWAD CHARITABLE TRUST, MUMBAI

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

Bench: Shri Manish Borad & Shri Vinay Bhamoreआयकर अपील सं. / Ita Nos.224 & 225/Pun/2024 िनधा"रण वष" / Assessment Year : 2014-15 Dcit (Exemptions) Circle, Vs. Ashirwad Charitable Pune. Trust, 402, Pascal Martin Road, Regent Chambers, Nariman Point, Mumbai- 400021. Pan : Aabta4479Q Appellant Respondent Revenue By : Shri Ramnath P. Murkunde Assessee By : Shri Raja B. Singh & Mohd. Obaid Ansari Date Of Hearing : 18.02.2025 Date Of Pronouncement : 16.05.2025 आदेश / Order Per Vinay Bhamore, Jm: Both The Above Captioned Appeals Filed By The Revenue Are Directed Against The Separate Orders Dated 06.12.2023 Passed By Ld. Cit(A)/Nfac For The Assessment Year 2014-15 Respectively. 2. Since The Facts Are Identical & Both The Above Captioned Appeals Were Heard Together, Therefore, We Proceed To Dispose Of The Same By This Common Order. 3. First, We Shall Take Up The Appeal In Ita No.224/Pun/2024 For Adjudication.

disallowing the deduction of income accumulated/set apart under section 11(2) of the Act is found to be untenable and the Ld. AO is directed to delete the same accordingly. Further, the Ld. AO has made addition by adding Rs.4,93,72,616/- as the assessee trust did not provide list of corpus donors and the genuineness of the donors

DY COMMISSIONER OF INCOME TAX EXMP CIRCLE PUNE, SWARGATE PMT BLDG vs. ASHRIWAD CHARITABLE TRUST, MUMBAI

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

Bench: Shri Manish Borad & Shri Vinay Bhamoreआयकर अपील सं. / Ita Nos.224 & 225/Pun/2024 िनधा"रण वष" / Assessment Year : 2014-15 Dcit (Exemptions) Circle, Vs. Ashirwad Charitable Pune. Trust, 402, Pascal Martin Road, Regent Chambers, Nariman Point, Mumbai- 400021. Pan : Aabta4479Q Appellant Respondent Revenue By : Shri Ramnath P. Murkunde Assessee By : Shri Raja B. Singh & Mohd. Obaid Ansari Date Of Hearing : 18.02.2025 Date Of Pronouncement : 16.05.2025 आदेश / Order Per Vinay Bhamore, Jm: Both The Above Captioned Appeals Filed By The Revenue Are Directed Against The Separate Orders Dated 06.12.2023 Passed By Ld. Cit(A)/Nfac For The Assessment Year 2014-15 Respectively. 2. Since The Facts Are Identical & Both The Above Captioned Appeals Were Heard Together, Therefore, We Proceed To Dispose Of The Same By This Common Order. 3. First, We Shall Take Up The Appeal In Ita No.224/Pun/2024 For Adjudication.

disallowing the deduction of income accumulated/set apart under section 11(2) of the Act is found to be untenable and the Ld. AO is directed to delete the same accordingly. Further, the Ld. AO has made addition by adding Rs.4,93,72,616/- as the assessee trust did not provide list of corpus donors and the genuineness of the donors

SUVARNAYUG SAHAKARI BANK LTD, PUNE,PUNE vs. AO, CIRCLE 6, INCOME TAX, PUNE, PUNE

Appeal stands ALLOWED

Bench: Shri S. S. Viswanethra Ravi & Shri G. D. Padmahshaliआयकर अपीऱ सं. / Ita No. 526/Pun/2022 धििाारण वर्ा / Assessment Year : 2016-17 Suvarnayug Sahakari Bank Ltd., 1102/10/11 Mane Heights, Budhwar Peth, Pune-411002 . . . . . . . अपीऱार्थी / Appellant Pan : Aacas 4805 L बिाम / V/S. Asstt. Commissioner Of Income Tax, . . . . . . .प्रत्यर्थी / Respondent Circle-6, Pune द्वारा / Appearances Assessee By : Shri Vijay D Kendhe Revenue By : Shri Abdhesh Kumar Jha सुनवाई की तारीख / Date Of Conclusive Hearing : 26/07/2023 घोषणा की तारीख / Date Of Pronouncement : 14/08/2023 आदेश / Order Per G. D. Padmahshali, Am; The Present Appeal Of The Assessee Is Arisen Out Of Din & Order No. Itab/Nfac/S/250/2022-2023/1042794299(1) Dt. 24/04/2022 Passed U/S 250 Of The Income-Tax Act, 1961 [‘The Act’ Hereafter] By National Faceless Appeal Centre Delhi [‘Nfac’ Hereafter] For Assessment Year 2016-17 [‘Ay’ Hereafter]

253(1)(a) of the Act challenging the disallowance of part of total interest provided @4% p.a. on an outstanding overdue/matured TDRs/FDRs. 3. Heard rival contentions, perused the material placed on record in light of rule 18 of Income Tax Appellate Rules, 1963 and we note that, 3.1 Following Mercantile System of Accounting [i.e. ‘accrual system’] assessee created a provision

SHAARP ALUMINUM,PUNE vs. THE ASSISTANT COMMISSIONER OF INCOME TAX, CIRCLE-2, PUNE

The appeal of the assessee is allowed for statistical purposes

Bench: Hon’Ble Shri Partha Sarathi Choudhury & Shri G. D. Padmahshaliआयकर अपऩल सं. / Ita No.957/Pun/2023 निर्धारण वषा / Assessment Year : 2019-20 M/S Sharp Aluminium F-41, S.No. 28/29 Shrushti, Guruganesh Nagar, Kothrud Pune-411038. Pan: Aczfs2580G . . . . . . .अपऩलधर्थी / Appellant

253(1)(a) of the Income-tax Act, 1961 [for short ‘the Act’] challenges DIN & order No. ITBA/NFAC/S/250/2023- 24/1054132806(1) dt. 05/07/2023 passed by National Faceless Appeal Centre [for short ‘Ld. NFAC’] u/s 250(6) of the Act which in turn ascended out of order of intimation passed u/s 143(1) of the Act by Centralised Processing Centre, Bengaluru