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

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

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

KALYANI STEELS LTD,,PUNE vs. DEPUTY COMMISSIONER OF INCOME-TAX, CIRCLE - 14,, PUNE

The appeal of the assesse is allowed in terms of our aforesaid observations

Bench: Shri Inturi Rama Rao() & Shri Ravish Sood () Assessment Year: 2015-16 Kalyani Steels Ltd. Dy. Commissioner Of Income-Tax, Mundhwa, Vs. Income-Tax Circle-14, Pune – 411 036 Aaykarsadan, Bodhi Tower, 548/2B, Salisbury Park, Gultekdi, Pune – 411 037. Pan No. Aaack7315D (Appellant) (Respondent)

disallowable expenditure under Section 40(a)(ii) of the IT Act. Ms. Linhares was unable to state whether the Revenue has appealed this decision. Mr. Ramani, learned Senior Advocate submitted that his research did not suggest that any appeal was instituted by the Revenue against this decision, which is directly on the point and favours the Assessee. 31. Mr. Ramani

ASSISTANT COMMISSIONER OF INCOME TAX , AHMEDNAGAR CIRCLE,, AHMEDNAGAR vs. SANJAY NEMICHAND LOHADE,, AHMEDNAGAR

Bench: Shri S.S. Godara & Shri G.D. Padmahshali

254 of the Income Tax Act, 1961; in short “the Act”. Heard both the parties. Case file perused. 2 ITA No.982/PUN/2019, A.Y. 2008-09 2. Coming to the Revenue’s sole substantive grievance seeking to revive the assessee’s section 54F deduction disallowance

MR POPATRAO DASHRATHRAO SURYAWANSHI,PUNE vs. INCOME TAX OFFICER, WARD-7(4), PUNE, PUNE

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

Bench: Shri R. K. Panda & Ms. Astha Chandraassessment Year : 2017-18 Mr. Popatrao Dashrathrao Suryawanshi Ito, Ward 7(4), Pune S.No.38, Tingre Nagar, Havaldar Mala, Vs. Vishrantwadi, Pune – 411015 Pan: Adhps2643F (Appellant) (Respondent) Assessee By : Shri Suhas Bora Department By : Shri Manish Mehta, Addl.Cit Date Of Hearing : 19-01-2026 Date Of Pronouncement : 21-01-2026 O R D E R

disallowance of deduction of Rs.2,89,64,823/- claimed by assessee under section 54B of the Income Tax Act 1961 against the capital gain on transfer of land. 3. On facts and circumstances of the case and in law, the learned AO and the CIT (Appeals) have erred in considering year of transfer of capital asset and charging

C G MARKETING PVT LTD,PUNE vs. DCIT, CIRCLE 1(1),PUNE, PUNE

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

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

254 of the Act. The relevant observations of Hon'ble Supreme Court read as under: “2. The question raised in this appeal relates to whether the appellant assessee could make a claim for deduction other than by filing a revised return. The assessment year in question was 1995-96. The return was filed on 30-11-1995, by the appellant

M/S. BILCARE LIMITED,PUNE vs. DEPUTY COMMISSIONER OF INCOME TAX CENTRAL CIRCLE-2(2), PUNE

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

Bench: Shri Inturi Rama Rao & Shri S. S. Viswanethra Raviआयकर अपीऱ सं. / Ita No.273/Pun/2021 निर्धारण वर्ा / Assessment Year: 2016-17 Dcit, Central Circle-2(2), Vs. M/S. Bilcare Limited, Pune. 601, Icc Trade Tower, Pune- 411016. Pan : Aabcb2242F Appellant Respondent आयकर अपीऱ सं. / Ita No.334/Pun/2021 निर्धारण वर्ा / Assessment Year: 2016-17 M/S. Bilcare Limited, Vs. Dcit, Central Circle- 6Th Floor, B Wing, Icc 2(2), Pune. Trade Tower, Senapati Bapat Road, Pune- 411006. Pan : Aabcb2242F Appellant Respondent

disallowed the claim of loss arising on sale of shares of BSPL held by the assessee company, sold to its another wholly owned subsidiary foreign company holding the same to be non-genuine. While holding so, the Assessing Officer had made the following observations:- (i) The assessee company had not made the claim for allowance of capital loss

DEPUTY COMMISSIONER OF INCOME TAX CENTRAL CIRCLE-2(2), PUNE vs. M/S. BILCARE LIMITED, PUNE

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

Bench: Shri Inturi Rama Rao & Shri S. S. Viswanethra Raviआयकर अपीऱ सं. / Ita No.273/Pun/2021 निर्धारण वर्ा / Assessment Year: 2016-17 Dcit, Central Circle-2(2), Vs. M/S. Bilcare Limited, Pune. 601, Icc Trade Tower, Pune- 411016. Pan : Aabcb2242F Appellant Respondent आयकर अपीऱ सं. / Ita No.334/Pun/2021 निर्धारण वर्ा / Assessment Year: 2016-17 M/S. Bilcare Limited, Vs. Dcit, Central Circle- 6Th Floor, B Wing, Icc 2(2), Pune. Trade Tower, Senapati Bapat Road, Pune- 411006. Pan : Aabcb2242F Appellant Respondent

disallowed the claim of loss arising on sale of shares of BSPL held by the assessee company, sold to its another wholly owned subsidiary foreign company holding the same to be non-genuine. While holding so, the Assessing Officer had made the following observations:- (i) The assessee company had not made the claim for allowance of capital loss

SHRI GANESH SAHAKARI SAKHAR KHARKHANA LIMITED,AHMEDNAGAR vs. DCIT AHMEDNAGAR CIRCLE, AHMEDNAGAR

254 and section\n144B of the Act vide his order dated 30.09.2021 thereby making addition(s)\non account of (i) sale of sugar at concessional rate to its members at\nRs.1,05,81,183/- and (ii) excess sugarcane payment to the farmers of\nRs.21,83,24,806/-.\n3.\nAggrieved by such order of the Ld. AO, the carried the matter

SHRI GANESH SSK LTD,AHMEDNAGAR vs. D.C.I.T, AHMEDNAGAR, CIRCLE-AHMEDNAGAR, AHMEDNAGAR

254 and section\n144B of the Act vide his order dated 30.09.2021 thereby making addition(s)\non account of (i) sale of sugar at concessional rate to its members at\nRs.1,05,81,183/- and (ii) excess sugarcane payment to the farmers of\nRs.21,83,24,806/-.\n3. Aggrieved by such order of the Ld. AO, the carried the matter

SHRI GANESH SSK LTD,AHMEDNAGAR vs. D.C.I.T, AHMEDNAGAR, CIRCLE-AHMEDNAGAR, AHMEDNAGAR

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

254 and section 144B of the Act vide his order dated 30.09.2021 thereby making addition(s) on account of – (i) sale of sugar at concessional rate to its members at Rs.1,05,81,183/- and (ii) excess sugarcane payment to the farmers of Rs.21,83,24,806/-. 3. Aggrieved by such order of the Ld. AO, the carried the matter

SHRI GANESH SSK LTD,AHMEDNAGAR vs. D.C.I.T, AHMEDNAGAR, CIRCLE-AHMEDNAGAR, AHMEDNAGAR

254 and section\n144B of the Act vide his order dated 30.09.2021 thereby making addition(s)\non account of (i) sale of sugar at concessional rate to its members at\nRs.1,05,81,183/- and (ii) excess sugarcane payment to the farmers of\nRs.21,83,24,806/-.\n3.\nAggrieved by such order of the Ld. AO, the carried the matter

SHRI VITTHAL SAHAKARI SAKHAR K LTD..,SOLAPUR vs. THE DEPUTY COMMISSIONER OF INCOME TAX CIRCLE-1, SOLAPUR

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

Bench: Shri Satbeer Singh Godara & Dr.Dipak P. Ripoteआयकर अपील सं. / Ita No.580/Pun/2023 िनधा"रण वष" / Assessment Year:2010-11 Shri Vitthal Vs Dcit, Sahakarisakharkarakhana Circle-1, Solapur. Limited, At Gursale Post Gursale, Tal Pandarpur District, Solapur – 413304. Pan: Aaaas3892H Appellant/ Assessee Respondent / Revenue Assessee By Shri Hanmant D Dhavle – Ar Revenue By Shri Sourabh Nayak – Addl.Cit(Dr) Date Of Hearing 18/06/2024 Date Of Pronouncement 02/09/2024 आदेश/ Order Per Dr. Dipak P. Ripote, Am: This Appeal Filed By The Assessee Is Against The Order Of Ld.Commissioner Of Income Tax(Appeal)[Nfac], Under Section 250 Of The Income Tax Act, 1961 Dated 17.03.2023 For The Assessment Year 2010-11. The Assessee Has Raised The Following Grounds Of Appeal : Shri Vitthal Sahakari Sakhar Ltd., [A]

section 250 of the Income Tax Act, 1961 dated 17.03.2023 for the Assessment Year 2010-11. The assessee has raised the following grounds of appeal : Shri Vitthal Sahakari Sakhar Ltd., [A] “1. On the facts and in the circumstances of the case and in law of the learned NFAC – Commissioner of Income Tax (Appeals) Delhi, has erred in disallowing