ASSISTANT COMMISSIONER OF INCOME TAX, PUNE vs. PERSISTENT SYSTEMS LIMITED, PUNE

In the result, appeal of the Revenue in ITA

Bench: Satbeer Singh Godara & Dr.Dipak P. Ripoteआयकर अपील सं. / Ita Nos.590, 595 & 1478/Pun/2024 िनधा"रण वष" / Assessment Years: 2016-17, 2014-15 & 2015-16 The Assistant V Persistent Systems Limited, Commissioner Of Income S 402, Bhageerath, Senapati Tax,Pune. Bapat Road, Pune – 411016. Pan: Aabcp1209Q Appellant/ Revenue Respondent / Assessee Assessee By Shri R.D.Onkar – Ar Revenue By Shri Arvind Desai – Addl.Cit(Dr) Date Of Hearing 17/09/2024 Date Of Pronouncement 24/10/2024 आदेश/ Order Per Dr. Dipak P. Ripote, Am: These Three Appeals Filed By The Revenue Are Against The Separate Orders Of Ld.Commissioner Of Income Tax(Appeal)[Nfac], Under Section 250 Of The Income Tax Act, 1961 Dated 31.01.2024 & 06.05.2024, For The A.Y.2015-16, 2016-17 & 2014-15; Respectively. The Revenue For A.Y.2016- 17Has Raised The Following Grounds Of Appeal : “1. Whether In. The Facts & Circumstances Of The Case & In Law

Section 14A r.w.r.8D of the Rules with the facts of the assessee’s case and further that why such disallowance was required that has also been explained by the Assessing Officer. This findings sans satisfaction is not the case here. That further, he has made disallowance only one half percent of the average value of investment i.e. 0.50% of Rs.406

ASSISTANT COMMISSIONER OF INCOME-TAX, PUNE vs. PERSISTENT SYSTEMS LIMITED, PUNE

In the result, appeal of the Revenue in ITA

Bench: Satbeer Singh Godara & Dr.Dipak P. Ripoteआयकर अपील सं. / Ita Nos.590, 595 & 1478/Pun/2024 िनधा"रण वष" / Assessment Years: 2016-17, 2014-15 & 2015-16 The Assistant V Persistent Systems Limited, Commissioner Of Income S 402, Bhageerath, Senapati Tax,Pune. Bapat Road, Pune – 411016. Pan: Aabcp1209Q Appellant/ Revenue Respondent / Assessee Assessee By Shri R.D.Onkar – Ar Revenue By Shri Arvind Desai – Addl.Cit(Dr) Date Of Hearing 17/09/2024 Date Of Pronouncement 24/10/2024 आदेश/ Order Per Dr. Dipak P. Ripote, Am: These Three Appeals Filed By The Revenue Are Against The Separate Orders Of Ld.Commissioner Of Income Tax(Appeal)[Nfac], Under Section 250 Of The Income Tax Act, 1961 Dated 31.01.2024 & 06.05.2024, For The A.Y.2015-16, 2016-17 & 2014-15; Respectively. The Revenue For A.Y.2016- 17Has Raised The Following Grounds Of Appeal : “1. Whether In. The Facts & Circumstances Of The Case & In Law

Section 14A r.w.r.8D of the Rules with the facts of the assessee’s case and further that why such disallowance was required that has also been explained by the Assessing Officer. This findings sans satisfaction is not the case here. That further, he has made disallowance only one half percent of the average value of investment i.e. 0.50% of Rs.406

ASSISTANT COMMISSIONER OF INCOME TAX, PUNE vs. PERSISTENT SYSTEMS LIMITED, PUNE

In the result, appeal of the Revenue in ITA

Bench: Satbeer Singh Godara & Dr.Dipak P. Ripoteआयकर अपील सं. / Ita Nos.590, 595 & 1478/Pun/2024 िनधा"रण वष" / Assessment Years: 2016-17, 2014-15 & 2015-16 The Assistant V Persistent Systems Limited, Commissioner Of Income S 402, Bhageerath, Senapati Tax,Pune. Bapat Road, Pune – 411016. Pan: Aabcp1209Q Appellant/ Revenue Respondent / Assessee Assessee By Shri R.D.Onkar – Ar Revenue By Shri Arvind Desai – Addl.Cit(Dr) Date Of Hearing 17/09/2024 Date Of Pronouncement 24/10/2024 आदेश/ Order Per Dr. Dipak P. Ripote, Am: These Three Appeals Filed By The Revenue Are Against The Separate Orders Of Ld.Commissioner Of Income Tax(Appeal)[Nfac], Under Section 250 Of The Income Tax Act, 1961 Dated 31.01.2024 & 06.05.2024, For The A.Y.2015-16, 2016-17 & 2014-15; Respectively. The Revenue For A.Y.2016- 17Has Raised The Following Grounds Of Appeal : “1. Whether In. The Facts & Circumstances Of The Case & In Law

Section 14A r.w.r.8D of the Rules with the facts of the assessee’s case and further that why such disallowance was required that has also been explained by the Assessing Officer. This findings sans satisfaction is not the case here. That further, he has made disallowance only one half percent of the average value of investment i.e. 0.50% of Rs.406

BAJAJ ALLIANZ GENERAL INSURANCE COMPANY LTD.,,PUNE vs. DEPUTY COMMISSIONER OF INCOME-TAX,,

disallowance of ₹ 70,31,561/- relating to contribution to the Environment Fund Liability under section 43B of the Act. However, during the course of assessment proceedings, the assessee filed revised computation of income and claimed the said amount as deductible. The plea of the assessee was that the Environment Relief Fund Liability is a contribution collected under Public Liability Fund

DEPUTY COMMISSIONER OF INCOME-TAX vs. BAJAJ ALLIANZ GENERAL INSURANCE COMPANY LTD.,, PUNE

disallowance of ₹ 70,31,561/- relating to contribution to the Environment Fund Liability under section 43B of the Act. However, during the course of assessment proceedings, the assessee filed revised computation of income and claimed the said amount as deductible. The plea of the assessee was that the Environment Relief Fund Liability is a contribution collected under Public Liability Fund

BLUE RIDGE UNIT B TOWER 9 TO 14,PUNE vs. ITO, WARD-2(4),PUNE, PUNE

In the result, appeal of the assessee in ITA No

Section 80P of the Income Tax Act,\n1961:\n2.1\nBECAUSE the Ld. CIT(A) has erred in disallowing the deduction\nof Rs.71,254

M/S. EAGLE FLASK INDUSTRIES LTD.,,PUNE vs. ASST. CIT, CIRCLE-8, PUNE

In the result, appeal of assessee for assessment year 1997-98 is partly allowed and appeal of assessee for assessment year 2000-01 is allowed

Bench: Ms. Sushma Chowla, Jm & Shri Anil Chaturvedi, Am आयकर अपीऱ सं. / Ita Nos.808 & 809/Pun/2013 यििाारण वषा / Assessment Years : 1997-98 & 2000-01

254 of the Act, but takes action under section 148 of the Act and concludes by holding that since the business income was loss in the hands of assessee, so no deduction to be allowed under section 80HHC of the Act. ITA Nos.808 & 809/PUN/2013 6 M/s. Eagle Flask Industries Ltd. 16. The learned Authorized Representative for the assessee took

BLUE RIDGE UNIT B TOWER 9 TO 14,PUNE vs. ITO, WARD-2(4),PUNE, PUNE

In the result, appeal of the assessee in ITA No

Bench: Ms.Astha Chandra & Dr.Dipak P. Ripoteआयकर अपऩल सं. / Ita Nos.2385, 2386 & 2387/Pun/2025 निर्धारण वषा / Assessment Years: 2015-16, 2016-17 & 2017-18 Blue Ridge Unit B Tower 9 Vs The Income Tax Officer, To 14 Co-Operative Housiong Ward-2(4), Pune. Society Ltd., Unit B Society Office, Rajiv Gandhi It Park, Phase I, Hinjewadi, Pune – 411057. Maharashtra. Pan: Aacab2693P Appellant/ Assessee Respondent / Revenue Assessee By Ms.Ayesha Ansari & Shri Sandesh Ps – Ar’S Revenue By Shri Harish Bist – Addl.Cit(Through Virtual Hearing) Date Of Hearing 01/12/2025 Date Of Pronouncement 12/12/2025 आदेश/ Order Per Dr. Dipak P. Ripote, Am: This Bunch Of Three Appeals Filed By The Assessee Against The Separate Orders Of Ld.Commissioner Of Income Tax(Appeal)[Nfac] Passed Under Section 250 Of The Income Tax Act, 1961 For The A.Y.2015-16, 2016-17 & 2017-18 All Dated 26.08.2024 Emanating From The Separate Assessment Orders Passed Under Section 147 R.W.S

Section 80P of the Income Tax Act, 1961: 2.1 BECAUSE the Ld. CIT(A) has erred in disallowing the deduction of without Rs.71,254

BLUE RIDGE UNIT B TOWER 9 TO 14,PUNE vs. ITO, WARD-2(4),PUNE, PUNE

In the result, appeal of the assessee in ITA No

Bench: Ms.Astha Chandra & Dr.Dipak P. Ripoteआयकर अपऩल सं. / Ita Nos.2385, 2386 & 2387/Pun/2025 निर्धारण वषा / Assessment Years: 2015-16, 2016-17 & 2017-18 Blue Ridge Unit B Tower 9 Vs The Income Tax Officer, To 14 Co-Operative Housiong Ward-2(4), Pune. Society Ltd., Unit B Society Office, Rajiv Gandhi It Park, Phase I, Hinjewadi, Pune – 411057. Maharashtra. Pan: Aacab2693P Appellant/ Assessee Respondent / Revenue Assessee By Ms.Ayesha Ansari & Shri Sandesh Ps – Ar’S Revenue By Shri Harish Bist – Addl.Cit(Through Virtual Hearing) Date Of Hearing 01/12/2025 Date Of Pronouncement 12/12/2025 आदेश/ Order Per Dr. Dipak P. Ripote, Am: This Bunch Of Three Appeals Filed By The Assessee Against The Separate Orders Of Ld.Commissioner Of Income Tax(Appeal)[Nfac] Passed Under Section 250 Of The Income Tax Act, 1961 For The A.Y.2015-16, 2016-17 & 2017-18 All Dated 26.08.2024 Emanating From The Separate Assessment Orders Passed Under Section 147 R.W.S

Section 80P of the Income Tax Act, 1961: 2.1 BECAUSE the Ld. CIT(A) has erred in disallowing the deduction of without Rs.71,254

BAJAJ ALLIANZ GENERAL INSURANCE COMPANY LTD.,,PUNE vs. DEPUTY COMMISSIONER OF INCOME-TAX,,

In the result, the appeal of assessee is allowed

Bench: Ms. Sushma Chowla, Jm & Shri Anil Chaturvedi, Am आयकर अपीऱ सं. / Ita No.1653/Pun/2015 यििाारण वषा / Assessment Year : 2006-07 Bajaj Allianz General Insurance Company Ltd., 1St Floor, Ge Plaza, Airport Road, Yerawada, अऩीऱाथी/Appellant Pune – 411006 …. Pan: Aabcb5730G Vs. The Dy. Commissioner Of Income Tax, …. प्रत्यथी / Respondent Circle 1(1), Pune

section 143(3) / 254 of the Income-tax Act, 1961 (in short „the Act‟). 2 2. The assessee has raised the following ground of appeal:- On the facts and in the circumstances of the case and in law, the learned CIT(A): Ground No.1: Disallowance

DEPUTY COMMISSIONER OF INCOME-TAX CIRCLE -5, PUNE vs. SERUM INSTITUTE OF INDIA PVT LTD.,, PUNE

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

disallowing the claim of the assessee for deduction under section 37(1).” We also find that the AO for assessment years 2011-12 and 2012-13 pursuant to the remand made by the ITAT accepted vide order dated 26.12.2019 passed u/s 143(3) r.w.s. 254

MAHARASHTRA STATE WAREHOUSING CORPORATION,,PUNE vs. DEPUTY COMMISSIONER OF INCOME-TAX, CIRCLE - 14,, PUNE

In the result, all the appeals of assessee are allowed

Bench: Shri D. Karunakara Rao, Am & Shri Vikas Awasthy, Jm

disallowance u/s. 14A r.w. Rule 8D. The Assessing Officer while giving effect to the order of Tribunal recomputed the total income, as a result there was net business loss of Rs.13,00,25,239/-. The Assessing Officer vide order dated 14-12-2009 passed u/s. 143(3) r.w.s. 254 held that the business loss is allowed to be carried forward

MAHARASHTRA STATE WAREHOUSING CORPORATION,,PUNE vs. DEPUTY COMMISSIONER OF INCOME-TAX, CIRCLE - 14,, PUNE

In the result, all the appeals of assessee are allowed

Bench: Shri D. Karunakara Rao, Am & Shri Vikas Awasthy, Jm

disallowance u/s. 14A r.w. Rule 8D. The Assessing Officer while giving effect to the order of Tribunal recomputed the total income, as a result there was net business loss of Rs.13,00,25,239/-. The Assessing Officer vide order dated 14-12-2009 passed u/s. 143(3) r.w.s. 254 held that the business loss is allowed to be carried forward

MAHARASHTRA STATE WAREHOUSING CORPORATION,,PUNE vs. DEPUTY COMMISSIONER OF INCOME-TAX, CIRCLE - 14,, PUNE

In the result, all the appeals of assessee are allowed

Bench: Shri D. Karunakara Rao, Am & Shri Vikas Awasthy, Jm

disallowance u/s. 14A r.w. Rule 8D. The Assessing Officer while giving effect to the order of Tribunal recomputed the total income, as a result there was net business loss of Rs.13,00,25,239/-. The Assessing Officer vide order dated 14-12-2009 passed u/s. 143(3) r.w.s. 254 held that the business loss is allowed to be carried forward

MAHARASHTRA STATE WAREHOUSING CORPORATION,,PUNE vs. DEPUTY COMMISSIONER OF INCOME-TAX, CIRCLE - 14,, PUNE

In the result, all the appeals of assessee are allowed

Bench: Shri D. Karunakara Rao, Am & Shri Vikas Awasthy, Jm

disallowance u/s. 14A r.w. Rule 8D. The Assessing Officer while giving effect to the order of Tribunal recomputed the total income, as a result there was net business loss of Rs.13,00,25,239/-. The Assessing Officer vide order dated 14-12-2009 passed u/s. 143(3) r.w.s. 254 held that the business loss is allowed to be carried forward

ASSISTANT COMMISSIONER OF INCOME-TAX vs. LAXMI CIVIL ENGINEERING SERVICES PVT. LTD.,, KOLHAPUR

In the result, the appeal of the Revenue in ITA No

Bench: Shri D. Karunakara Rao, Am & Shri S. S. Viswanethra Ravi, Jm Sl.

section 10A the addition made on account of the disallowance of the provident fund/ESIC payments ought to be ignored cannot be accepted. No statutory provision to that effect having been made, the plain consequence of the disallowance made by the Assessing Officer must follow. The second question shall accordingly stand answered against the Revenue and in favour of the assessee

ASSISTANT COMMISSIONER OF INCOME-TAX vs. LAXMI CIVIL ENGINEERING SERVICES PVT. LTD.,, KOLHAPUR

In the result, the appeal of the Revenue in ITA No

Bench: Shri D. Karunakara Rao, Am & Shri S. S. Viswanethra Ravi, Jm Sl.

section 10A the addition made on account of the disallowance of the provident fund/ESIC payments ought to be ignored cannot be accepted. No statutory provision to that effect having been made, the plain consequence of the disallowance made by the Assessing Officer must follow. The second question shall accordingly stand answered against the Revenue and in favour of the assessee

LAXMI CIVIL ENGINEERING SERVICES PVT. LTD.,,KOLHAPUR vs. ASSISTANT COMMISISONER OF INCOME-TAX,,

In the result, the appeal of the Revenue in ITA No

Bench: Shri D. Karunakara Rao, Am & Shri S. S. Viswanethra Ravi, Jm Sl.

section 10A the addition made on account of the disallowance of the provident fund/ESIC payments ought to be ignored cannot be accepted. No statutory provision to that effect having been made, the plain consequence of the disallowance made by the Assessing Officer must follow. The second question shall accordingly stand answered against the Revenue and in favour of the assessee