M/S GERA DEVELOPMENTS PVT. LTD,PUNE vs. PCIT (CENTRAL), PUNE, PUNE

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

Bench: Dr.Manish Borad & Shri Vinay Bhamore

disallowance u/s.14A r.w. Rule 8D at ₹3,82,623, and assessed the income at ₹1,83,60,35,564. 5. Subsequently, ld. PCIT (Central) invoked provisions of section 263

GOEL EISHA CAPITALS,PUNE vs. PCIT(CENTRAL), PUNE, PUNE

disallow the same during the\nassessment proceedings for the year under consideration.\n04. In view of the above, it is found that the no verification on the aforesaid issues\nhas been done in the assessment proceedings by the AO. As per explanation (2) to\nsection 263(1) of the Act an order without making inquiries or verification which\nshould have

INCOME TAX OFFICER, PUNE vs. SAGAR CONSTRUCTION COMPANY, PUNE

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

Bench: Shri R. K. Panda & Ms. Astha Chandraassessment Year : 2017-18

disallowed the same u/s 37 of the Act. Thus, the Assessing Officer computed the total income of the assessee at Rs.2,22,86,304/-. 6. Before the Ld. CIT(A) / NFAC the assessee submitted that the reasons for reopening were communited to the assessee after 11 months of issue of notice u/s 148 of the Act although the assessee

EATON TECHNOLOGIES PRIVATE LIMITED,PUNE vs. PRINCIPAL COMMISSIONER OF INCOME TAX, PUNE

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

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

263,46,37,168/-, the FAO has allowed further deduction under the said section at Rs. 1,23,15,523/- in respect of the disallowance

INDUS BIOTECH LIMITED,PUNE vs. THE ASSISTANT COMMISSIONER OF INCOME TAX, CIRCLE 1(1), PUNE, PUNE

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

1,52,65,049 under section 115-O of the Act to the Ld. AO\nwithout appreciating the fact that the said credit is also duly reflected in\nForm 26AS and relevant facts/documents are available on record with the\nLd. AO.\n4.2 The Appellant prays that the Ld. AO be directed to grant credit of DDT\nGround No. 5\n5.1

MAHATMA PHULE GRAMIN BIGARSHETI SAHAKAR PAT SANSTHA LTD,KOLHAPUR vs. PCIT-1, PUNE, PUNE

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

Bench: Shri R. K. Panda & Ms. Astha Chandraassessment Year : 2018-19 Mahatma Phule Gramin Bigarsheti Pcit-1, Pune Sahakar Pat Sanstha Vs. A/P Hattiwade, Ajara, Kolhapur – 416505 Pan: Aaaam2608K (Appellant) (Respondent) Assessee By : None (Written Submission Filed) Department By : Shri Amol Khairnar, Cit-Dr Date Of Hearing : 09-12-2025 Date Of Pronouncement : 09-01-2026 O R D E R

1. Jurisdictional Error in invoking Section 263 Whether on the facts and circumstances of case and in Law, the PCIT is correct in invoking provision under Section 263 for disallowance

REXEL INDIA PRIVATE LIMITED,PUNE vs. DEPUTY COMMISSIONER OF INCOME TAX, PUNE

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

Section 43(6) of the IT Act 1961\nestablishes that the depreciation on goodwill as a result of amalgamation is\nnot allowable.\nResultantly, the claims made by the appellant in support of this ground do\nnot have any merit. Therefore, the addition made by assessing officer on\naccount of disallowance of claim of depreciation on goodwill as a result

SRL CONSTRUCTION PVT LTD,JALNA vs. ACIT, CENTRAL CIRCLE 2, AURANGABAD, AURANGABAD

In the result, appeal of the assessee is dismissed

Bench: Dr.Dipak P. Ripote & Shri Vinay Bhamoreआयकर अपील सं. / Ita No.847/Pun/2024 िनधा"रण वष" / Assessment Year : 2019-20 Srl Construction Pvt. Ltd., V The Acit, 197, Khasgaon, Jafrabad, S Central Circle-2, Jalna – 444203. Aurangabad. Pan: Aaqcs7227L Appellant/ Assessee Respondent /Revenue Assessee By Shri Prateekjha – Ar Revenue By Shri Ajay Kumar Keshari – Cit(Dr) Date Of Hearing 16/12/2024 Date Of Pronouncement 29/01/2025 आदेश/ Order Per Dr.Dipak P.Ripote, Am : This Is An Appeal Filed By The Assessee Against The Order Of Ld.Principal Commissioner Of Income Tax(Central)-Nagpur, Passed Under Section 263 Of The Income Tax Act, 1961; Dated 08.03.2024 For A.Y.2019-20. The Assessee Has Raised The Following Grounds Of Appeal : “1. A) On The Facts & Circumstance Prevailing In The Case & In Law, Honorable Pr. Cit (Central), Nagpur Has Erred In Not Considering The Submission Made By The Appellant In Fair And

1. The Ld Principal Commissioner erred in passing his order u/s 263 of the IT Act without granting the assessee reasonable opportunity of being heard which has rendered the impugned order bad in law. 2. The Ld Principal Commissioner erred in initiating revisionary proceedings and passing order u/s 263 solely on the basis of proposal of the Ld Assessing Officer

MR. CHITTARANJAN TRIMBAK GAIKWAD,PUNE vs. THE ASST. COMMISSIONER OF INCOME TAX, CIRCLE-4, PUNE, PUNE

In the result, the appeal of the assessee is allowed

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

disallowed in computing the total income of such person as a result thereof shall, for the purposes of clause (c) of this sub- section, be deemed to represent the income in respect of which particulars have been concealed." 5.6 Thus, when the appellant has concealed particulars of his income or furnished inaccurate particulars, conditions laid down in Explanation-1 (supra

BAJAJ HOUSING FINANCE LIMITED,PUNE vs. THE PRINCIPAL COMMISSIONER OF INCOME TAX-3, PUNE, PUNE

In the result, appeal of the assessee is allowed

Bench: Shri S.S.Godara & Dr. Dipak P. Ripoteआयकर अपील सं. / Ita No.564/Pun/2023 िनधा"रण वष" / Assessment Year : 2018-19 Bajaj Housing Finance Limited, The Principal 3Rd Floor, Panchsil Tech Park, V Commissioner Of Income Viman Nagar, Pune – 411014. S Tax-3, Pune. Pan: Aadcb6018P Appellant/ Assessee Respondent /Revenue Assessee By Shri Percy Pardiwala & Ms.Vasanti B.Patel – Ar’S Revenue By Shri Keyur Patel – Cit(Dr) Date Of Hearing 12/01/2024 Date Of Pronouncement 26/02/2024 आदेश/ Order Per Dr. Dipak P. Ripote, Am: This Is An Appeal Filed By The Assessee Against The Order Under Section 263 Of The Income Tax Act, 1961, Passed By Ld.Principal Commissioner Of Income Tax, Pune-3 On 14.03.2023. In This Case, Assessment Order Was Passed On 26.02.2021. The Assessee Has Raised The Following Grounds Of Appeal : 1. Ground I: Challenging The Validity Of Revision Proceedings Under Section 263 Of The Act 1.1. The Learned Pcit Failed To Appreciate That The Assessment Order Passed By The Assistant Commissioner Of Income Tax, Circle 8, Pune (Hereinafter Referred To As Learned Ao) Under Section 143(3) Of The Act Bajaj Housing Finance Limited [A]

disallowance under section 14A. Even if one assumes that he has, after reading of the order expressed his views, but still the position is two views therefore were possible. Therefore, if one of the two 9 Bajaj Housing Finance Limited [A] possible views was taken by the Assessing Officer, the PCIT could not have exercised his powers under section 263

M.M. PATEL PUBLIC CHARITABLE TRUST,SOLAPUR vs. PCIT- CENTRAL, PUNE, PUNE

In the result, the appeal of the assessee is partly allowed

section (3) of section 143 for any\nprevious year; or\nc) Such case has been selected in accordance with the risk\nmanagement strategy, formulated by the Board from time to\ntime, for any previous year;\nThe Principal Commissioner or Commissioner shall—\ni.\ncall for such documents or information from the trust\nor institution, or make such inquiry as he thinks

CAPGEMINI TECHNOLOGY SERVICES INDIA LIMITED,PUNE vs. ASSISTANT COMMISSIONER OF INCOME TAX, PUNE

sections": [ "263", "143(3)", "135", "37(1)", "142(1)", "80G", "80G(5)", "80G(1)", "37", "30", "36", "144C(13)", "143(2)", "115JB", "115JJB" ], "issues": "Whether CSR expenditure, even if disallowed

BAJAJ FINANCE LIMITED,PUNE vs. PRINCIPAL COMMISSIONER OF INCOME TAX-3, PUNE, PUNE

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

Bench: Shri R. K. Panda & Shri Vinay Bhamoreassessment Year : 2019-20 Bajaj Finance Limited Pcit-3, Pune 3Rd Floor, Panchshil Tech Park, Vs. Viman Nagar, Pune – 411014 Pan: Aabcb1518L (Appellant) (Respondent) Assessee By : Shri Percy Pardiwalla Department By : Shri Amol Khairnar, Cit-Dr Date Of Hearing : 06-01-2026 Date Of Pronouncement : 29-01-2026

disallowance under section 14A. Even if one assumes that he has, after reading of the order expressed his views, but still the position is two views therefore were possible. Therefore, if one of the two possible views was taken by the Assessing Officer, the PCIT could not have exercised his powers under section 263 of the Act. 8.” Unquote

SONAL SANDEEP SATAV,PUNE vs. PCIT, PUNE-2, PUNE

In the result, the appeal of the assessee is dismissed

Bench: Ms. Astha Chandra & Shree G.D. Padmahshali

1) of the Income Tax Act, 1961, the assessment order passed by the FAO on 13.04.2021 is erroneous in so far as it is prejudicial to the interest of revenue. 7. My finding that the assessment order under consideration in the present proceedings falls within the ambit of the provisions of section 263 is supported by many judicial precedents

DESAI INFRA PROJECTS(I) PRIVATE LIMITED,PUNE vs. PCIT, CENTRAL PUNE, PUNE

In the result, appeal of the assessee is allowed

Bench: Dr. Manish Borad & Ms. Astha Chandra

1,44,42,319/- received from AOP/BOI. Further, Rs. 4,71,825/-was also not disallowed by the assessee company. Also no verification on the aforesaid issues has been done in the assessment proceedings by the AO. As per explanation (2) to section 263

BANK OF MAHARASHRA,PUNE vs. THE PR. COMMISSIONER OF INCOME TAX, PUNE, PUNE

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

Bench: Shri R. K. Panda & Ms Astha Chandraassessment Year : 2018-19

disallowance under section 36(1)(viia) to the total provision on account of bad and doubtful debts instead of restricting the same only to the extent of actual provision related to rural advances, has not been accepted by the Department and the Department has filed appeal before the Hon'ble High Court for A.Y.s

DCIT, CIRCLE-8, PUNE vs. MAHLE ANAND THERMAL SYSTEMS PVT. LTD., PUNE

1,20,58,298 | 13,35,65,182 |\n| Expenses Debited to P&L A/c. (Sub-total C) | 3,41,34,804 | 74,95,427 | 2,66,39,378 | 3,41,34,804 |\n| Grand Total | 15,07,38,534 | 9,61,80,237 | 5,45,58,297 | 26,73,42,263 |\n\n5. It can be seen from

SHETH CHIMANLAL GOVINDDAS MEMORIAL TRUST,PUNE vs. CIT(EXEMPTION), PUNE, PUNE

In the result, appeal of the assessee is dismissed

1)(d), 13(2)(a). 13(2)(g), and 13(2)(h), as well as the\nprescribed modes of investment under Section 11(5). Therefore, the\nFAO was required to disallow the entire investment of Rs 32,75,0007-\nand tax it at the Maximum Marginal Rate (MMR). The FAO was also\nrequired to reject the assessee's claim

DHANLAXMI MAHILA GRAMIN BIGARSHETI SAHAKARI PATSANSTHA LIMITED,PUNE vs. PCIT-1, PUNE

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

Bench: Shri Rama Kanta Panda, Vice- & Ms. Astha Chandra

section 263 of the Income Tax Act, 1961 (“Act”) for the Assessment Year (AY) 2020-21. 2 ITA.No.1024/PUN/2025 (Dhanalaxmi Mahila Gramin Bigarsheti Sahakari Patsanstha Ltd.) 2. Although, a number of grounds have been raised by the assessee, however, these all relate to the validity of the order passed u/s. 263 of the Income Tax Act, 1961 by the Ld.PCIT