E-ALLY SECURITIES (INDIA) PVT. LTD.,RAIGAD vs. DCIT CIRCLE, PANVEL, PANVEL

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

Bench: Shri R. K. Panda & Shri Vinay Bhamoreassessment Year : 2018-19

Disallowance under Section 14A of Rs.2,48,85,000/- as expenses to earn exempted Dividend income of Rs.1,80,30,965/- is per se absurd and 1 378 ITR 33 2 [2018] 256

DY. COMMISSIONER OF INCOME TAX, CIRCLE-1(1), PUNE, PUNE vs. HONEYWELL AUTOMATION INDIA LIMITED, PUNE

In the result, the appeal of the Revenue is dismissed

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

disallowance of deduction claimed u/s 80G of the Act. 3. Aggrieved by such order of the Ld. AO, the assessee preferred an appeal before the Ld. CIT(A)/NFAC. The Ld. CIT(A)/NFAC after considering the submissions of the assessee and relying on various decisions involving the impugned issue in favour of the assessee, deleted the addition of Rs.4

RANAJIT SURESH RAJAMANE,SOLAPUR vs. ITO, WARD 1, PANDHARPUR, PANDHARPUR

In the result, the appeal of the assessee is allowed

Bench: Dr. Manish Borad & Ms. Astha Chandraआयकर अपील सं. / Ita No.1678/Pun/2024 धििाारण वर्ा / Assessment Year: 2014-15 Ranajit Suresh Rajamane, Vs Ito Ward 1, Shukrawar Peth, Pandharpur Tembhurni Madha Solapur- 413211 Maharashtra Pan-Bmepr3878N Appellant Respondent

disallowance of exemption u/s 548 in respect of investment in agricultural land and all the conditions have been complied with (iv) The Id CIT(A) erred in law and on facts in not appreciating that the appellant had made substantial payments towards consideration for purchase of the new agricultural land and possession was obtained in prescribed time thereby proving

WARANA INDUSRIES LTD,,KOLHAPUR vs. ASSISTANT COMMISSIONER OF INCOME-TAX, CIRCLE - 1, , KOLHAPUR

In the result, the appeal filed by the assessee is allowed for statistical purposes and the Cross Objection filed by the assessee is dismissed

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

256/- d) Disallowance of foreign tour expenses of the director Smt. Surekha S. Gulave to USA Rs.9,28,290/- 4. So far as the disallowance of interest of Rs.4,15,71,718/- is concerned, the Ld. CIT(A) sustained an amount of Rs.27,01,163/- disallowed by the Assessing Officer u/s 36(1)(iii) of the Act by observing

PRAJ INDUSTRIES LIMITED,PUNE vs. DCIT, CENTRAL CIRCLE 1(1), PUNE, PUNE

In the result, the appeal of assessee is allowed

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

1. The Learned CIT(A) erred in confirming the disallowance of Rs.33,20,874/- u/s 14A r.w.r. 8D. 2. The Learned CIT(A) failed to appreciate the fact that : a) The appellant has suo-moto computed disallowance u/s 14A at Rs.51,41,522/- in accordance with law and hence no further disallowance was called for. b) Disallowance

BALKRISHNA RATHI FINANCE PRIVATE LIMITED,PUNE vs. ITO, PUNE

In the result, appeal of the assessee is allowed

Bench: SHRI VINAY BHAMORE (Judicial Member)

1 Disallowance as per clause clause(i) : Rs. NIL Total amount of interest directly attributable to income which does not form part of total income 2 Clause(ii) A: An amount of expenditure by way of Rs.70,87,256/- interest other than the amount of interest included in clause(i) incurred during the previous year 3 B: Average value

ADHERE FOUNDATION,PUNE vs. AO, EXEMPTION WARD , PUNE

In the result, the appeal of the assessee is allowed for statistical purposes

Bench: Dr.Manish Borad & Shri Vinay Bhamoreआयकर अपील सं. / Ita No.954/Pun/2024 Assessment Year : 2021-22

1) Disallowed the aggregate income referred to in section 11, 12 and sections 10(23C)(iv), 10(23C)(v), 10(23C) (vi) and 10(23C)(via) derived during the previous year. 2) Disallowed the application of income for charitable or religious purpose or for the stated objects of the company/institution. without giving nature of the above disallowance and more

SHAH CONSTRUCTIO,SATARA vs. ACIT, CIRCLE-SATARA, SATARA

In the result appeal of the assessee is allowed for statistical purposes

Bench: Dr. Manish Borad & Shri Vinay Bhamoreआयकर अपील सं. / Ita No.617/Pun/2024 धििाारण वषा / Assessment Year: 2022-23 Shah Construction, Vs Acit, Satara Parag, 286 2, Circle, Satara Budhwar Peth, Tal Karad, Dist Satara- 415110 Maharashtra Pan-Aaffs0461E Appellant Respondent

disallowance of deduction us 80-1A of Rs 67,25,256/- can be made as adjustment u/s 143(1) as a permissible adjustment falling within the scope of adjustment when the same is debatable in view of the decisions of different court and indicating that two views are possible. 2. On the facts and in the circumstances

BANSILAL RAMNATH AGARWAL CHARITABLE TRUST,PUNE vs. CIT (EXEMPTION), PUNE

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

Bench: Shri R. K. Panda & Ms. Astha Chandraassessment Year : 2020-21 Bansilal Ramnath Agarwal Charitable Trust Cit (Exemption), 251, Budhwar Peth, City Post Chowk, Vs. Pune Pune – 411002 Pan: Aaatb4383K (Appellant) (Respondent) Assessee By : Shri Kishor B Phadke Department By : Shri Amol Khairnar, Cit-Dr Date Of Hearing : 11-12-2025 Date Of Pronouncement : 28-01-2026 O R D E R Per R.K. Panda, V.P:

1) of the Act were issued from time to time through Faceless assessment scheme in response to which the assessee filed the requisite details. The Assessing Officer completed the assessment on 20.09.2022 determining the total income of the assessee at Nil. 4. Subsequently the Ld. CIT(Exemption), Pune perused the assessment order and submissions of the assessee made from time

DEPUTY COMMISSIONER OF INCOME TAX, AURANGABAD vs. VISTA NIRMAN PVT. LTD., MUMBAI

Bench: Shri R. K. Panda & Ms Astha Chandraassessment Year : 2011-12

1. Peass Industrial Engineers (P.) Ltd. v. Deputy Commissioner of Income-tax (2016) 76 taxmann.com 106 (Gujarat) 2. Dr. Amin’s Pathology Laboratory vs. P.N. Prasad, Joint Commissioner of Income-tax (2001) 252 ITR 673 (Bom) 3. ACIT v. M.P. Laghu Udyog Nigam Ltd. (2017) 83 taxmann.com 160 (Indore-Trib) 4. ITO v. TechSpan India (P.) Ltd. (2018) 92 taxmann.com

ITO, WARD-1(1), SOLAPUR, SOLAPUR vs. MS. KSHIRSAGAR FABRICS, SOLAPUR

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

Bench: Shri R. K. Panda & Ms Astha Chandraassessment Year : 2009-10

Section 40A(3). (Separate annexure attached of various related parties whom payment given by the asseessee) However, no disallowance was made despite clear legal position. Omission resulted in underassessment of income Rs 66,20,000 involving short levy of tax of Rs.20,45,580. 8 This is brought to the notice of the department for confirmation and necessary action

KAPIL ALCOTECH LLP,AURANGABAD vs. DEPUTY COMMISSIONER OF INCOME TAX CIRCLE - 1, AURANGABAD

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

Bench: Shri R. K. Panda & Ms Astha Chandraassessment Year : 2020-21

256 1,31,730.00 61,300.00 70,430.00 01/04/2019 Good Drop Wine Cellers Pvt Ltd Journal 253 90,606.00 90,606.00 01/04/2019 FARTELLI WINES PVT LTD Journal 127 86,753.00 86,753.00 01/04/2019 United Breweries Limited Journal 120 - 3,12,889.40 (3,12,889.40) Round Off (6.60) Grand Total 21. Although the assessee had given detailed submission before

THE JOINT COMMISSIONER OF INCOME TAX (OSD), CIRCLE-12, PUNE vs. RAJ SURENDRA MOHAN HAJELA, PUNE

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

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

256/- on the ground that the assessee has not filed form No.67 on or before the due date specified for furnishing the return of income under sub-section (1) of section 139 of the Act. According to the Assessing Officer, as per CBDT’s Notification No.9, dated 19.09.2017, form No.67 shall precede the filing of return of income. Accordingly

NASHIK DISTRICT POLICE CO OPERATIVE CREDIT SOCIETY LTD NASHIK,NASHIK vs. INCOME TAX OFFICER, NATIONAL E ASSESSMENT CANTER, DELHI

In the result, appeal of the assessee is allowed

Bench: Dr.Dipak P. Ripote & Shri Vinay Bhamoreआयकर अपऩल सं. / Ita No.727/Pun/2025 निर्धारण वषा / Assessment Years: 2018-19 Nashik District Police Co- V The Income Tax Officer, Operative Credit Society Ltd., S National E Assessment Sagar Plaza, Third Floor, Above Centre, Delhi. Axis Bank, Audumbar Nagar, Mumbai Agra Road, Nashik – 422003. Pan: Aacan6075F Appellant/ Assessee Respondent / Revenue Assessee By Shri Pramod Shingte Revenue By Smt Neha Thakur – (Virtual) Date Of Hearing 20/01/2026 Date Of Pronouncement 21/01/2026 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] Passed Under Section 250 Of The Income Tax Act, 1961 For A.Y.2018-19 Dated 23.02.2024 Emanating From Assessment Order U/S.143(3) Read With Section 143(3A) & 143(3B) Of The I.T.Act, Dated 31.03.2021. The Assessee Has Raised The Following Grounds Of Appeal :

section 143(3A) & 143(3B) of the I.T.Act, dated 31.03.2021. The Assessee has raised the following grounds of appeal : ITA No.727/PUN/2025 [A] “1. On the facts and in the prevailing circumstances of the case and in law, the learned CIT Appeal, erred in disallowing the deduction of Rs.1,14,84,355/- on account of interest income earned out of fixed

SHREE SANT SAVTA GRAMIN BIGAR SETI SAHAKARI PATHSANSTA MARAYADIT,NASHIK vs. ASSESSMENT UNIT, INCOME TAX DEPARTMENT, DELHI

In the result, appeal of the Assessee is partly allowed

Bench: Dr.Dipak P. Ripote & Shri Vinay Bhamoreआयकर अपऩल सं. / Ita No.1625/Pun/2025 निर्धारण वषा / Assessment Year: 2017-18 Shree Sant Savta Gramin Bigar V Assessment Unit, Seti Sahakari Pathsanstha S. Income Tax Department, Maryadit, Delhi. Pimpalgaon, Niphad, Nashik – 422209. Pan: Aacas4098M Appellant/ Assessee Respondent / Revenue Assessee By None Revenue By Shri Dayanand Jawalikar – Addl.Cit Date Of Hearing 14/10/2025 Date Of Pronouncement 31/10/2025 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], Passed Under Section 250 Of The Income Tax Act, 1961 For A.Y.2017-18, Dated 27.11.2024 Emanating From Assessment Order U/S.143(3) Of The I.T.Act, Dated 15.12.2019. The Assessee Has Raised Following Grounds Of Appeal :

section 250 of the Income Tax Act, 1961 for A.Y.2017-18, dated 27.11.2024 emanating from Assessment Order u/s.143(3) of the I.T.Act, dated 15.12.2019. The assessee has raised following grounds of appeal : ITA No.1625/PUN/2025 [A] “1. On the facts and in the prevailing circumstances of the case and in law, the learned CIT Appeal, erred in disallowing the deduction of Rs.60

SHREE SANT SAVTA GRAMIN BIGAR SETI SAHAKARI PATHASANSTHA MARYADIT,PIMPALGAON vs. ASSESSING OFFICER, NASHIK

In the result, appeal of the Assessee for A

Bench: Dr.Dipak P. Ripote & Shri Vinay Bhamoreआयकर अपऩलसं. / Ita Nos.1596 & 1598/Pun/2025 निर्धारण वषा / Assessment Years: 2017-18 & 2018-19 Shree Sant Savta Gramin Bigar V Assessment Unit, Income Seti Sahakari Pathasanstha S Tax Department, Delhi. Maryadit, Pimpalgaon, Niphad, Nashik – 422209. Pan: Aacas4098M Appellant/ Assessee Respondent / Revenue Assessee By Shri Sanket Joshi Revenue By Shri Madhukar Anand – Jcit(Through Virtual) Date Of Hearing 07/01/2026 Date Of Pronouncement 08/01/2026 आदेश/ Order Per Dr. Dipak P. Ripote, Am: These Two Appeals Filed By The Assessee Are Against The Common Order Of Ld.Commissioner Of Income Tax(Appeal)[Nfac] Passed Under Section 250 Of The Income Tax Act, 1961 For A.Y.2017-18 & 2018-19, Both Dated 27.11.2024 Emanating From Separate Assessment Order U/S.143(3) Of The I.T.Act, Dated 15.12.2019 & 24.02.2021 Respectively. For The Sake Of

1. On the facts and in the prevailing circumstances of the case and in law, the learned CIT Appeal, erred in disallowing the deduction of Rs.60,32,500/- on account of unexplained cash and Rs.6,48,075/on account of interest income earned out of Investments with Cooperative/Nationalized Bank and which is eligible for deduction

SHREE SANT SAVTA GRAMIN BIGAR SETI SAHAKARI PATHASANSTHA MARYADIT,PIMAPALGAON vs. ASSESSING OFFICER, NASHIK

In the result, appeal of the Assessee for A

Bench: Dr.Dipak P. Ripote & Shri Vinay Bhamoreआयकर अपऩलसं. / Ita Nos.1596 & 1598/Pun/2025 निर्धारण वषा / Assessment Years: 2017-18 & 2018-19 Shree Sant Savta Gramin Bigar V Assessment Unit, Income Seti Sahakari Pathasanstha S Tax Department, Delhi. Maryadit, Pimpalgaon, Niphad, Nashik – 422209. Pan: Aacas4098M Appellant/ Assessee Respondent / Revenue Assessee By Shri Sanket Joshi Revenue By Shri Madhukar Anand – Jcit(Through Virtual) Date Of Hearing 07/01/2026 Date Of Pronouncement 08/01/2026 आदेश/ Order Per Dr. Dipak P. Ripote, Am: These Two Appeals Filed By The Assessee Are Against The Common Order Of Ld.Commissioner Of Income Tax(Appeal)[Nfac] Passed Under Section 250 Of The Income Tax Act, 1961 For A.Y.2017-18 & 2018-19, Both Dated 27.11.2024 Emanating From Separate Assessment Order U/S.143(3) Of The I.T.Act, Dated 15.12.2019 & 24.02.2021 Respectively. For The Sake Of

1. On the facts and in the prevailing circumstances of the case and in law, the learned CIT Appeal, erred in disallowing the deduction of Rs.60,32,500/- on account of unexplained cash and Rs.6,48,075/on account of interest income earned out of Investments with Cooperative/Nationalized Bank and which is eligible for deduction

SHREE SANT SAVTA GRAMIN BIGAR SETI SAHAKARI PATSANSTHA MARYADIT,PIMPALGAON vs. ASSESSING OFFICER, NASHIK

In the result, appeal of the Assessee is allowed

Bench: Dr.Dipak P. Ripote & Shri Vinay Bhamoreआयकर अपऩल सं. / Ita No.1597/Pun/2025 निर्धारण वषा / Assessment Year: 2016-17 Shree Sant Savta Gramin Bigar V Assessment Unit, Seti Sahakari Patsanstha S Income Tax Maryadit, Department, Delhi. Pimpalgaon, Niphad, Maharashtra – 422209. Pan: Aacas4098M Appellant/ Assessee Respondent /Revenue Assessee By Shri Sanket Joshi (Virtual) Revenue By Shri Sadananda – Jcit Date Of Hearing 10/02/2026 Date Of Pronouncement 11/02/2026 आदेश/ Order Per Dr. Dipak P. Ripote, Am: This Is An Appeal Filed By The Assessee Against The Order Of Ld.Commissioner Of Income Tax(Appeal)[Nfac], Passed Under Section 250 Of The Income Tax Act, 1961 For The A.Y.2016-17 Dated 27.11.2024 Emanating From The Assessment Order Passed Under Section 144 Of The I.T.Act, Dated 05.03.2024. The Assessee Has Raised The Following Grounds Of Appeal :

section 144 of the I.T.Act, dated 05.03.2024. The Assessee has raised the following grounds of appeal : ITA No.1597/PUN/2025 [A] “1. On the facts and in the prevailing circumstances of the case and in law, the learned CIT Appeal, erred in disallowing the deduction of Rs.10,90,953/- on account of interest income earned out of fixed deposit with Cooperative/Nationalized Bank