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

27,035/-, after considering the suo-moto disallowance of Rs.16,74,667/-. Therefore, the AO has already considered the suo- moto disallowance made by AO. Accordingly, disallowance made under section

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

section 14A read with Rule 8D and relying on certain decisions and distinguishing the decisions cited by the assessee, he made the disallowance of Rs.40,53,508/-. 3 6. In appeal the Ld. CIT(A) / NFAC though noted that the assessee has received the exempt income of only Rs.2,000/-, however, dismissed the grounds raised by the assessee by directing

LIQUIDHUB ANALYTICS PVT. LTD. (NOW MERGED WITH CAPGEMINI TECHNOLOGY SERVICES INDIA LTD),PUNE vs. NFAC, PUNE

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

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

section 6 10AA of the Act on account of disallowance of INR 27,38,849 under section 36(1)(va) of the Act and withdrawal

CTR MANUFACTURING INDUSTRIES PRIVATE LIMITED,PUNE vs. THE DEPUTY COMMISSIONER OF INCOME TAX, CIRCLE 1(1), PUNE, PUNE

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

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

27,450/- u/s 14A of the Act r.w. Rule 8D of the Rules and reducing therefrom Rs.15,000/- of suo-moto disallowance made by the assessee, disallowed Rs.5,12,450/- and added it to the income of the assessee. 4.2 The Ld. AO found that the assessee has claimed weighted deduction of Rs.2

RAVINDRA DNYANESHWAR BHUJBAL,PUNE vs. ITO, WARD 14(5), PUNE, PUNE

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

27,49,780/- after\nmaking disallowance of Rs.10,07,934/- u/s 36(1)(va) of the IT Act\nbeing disallowance on account of delayed payment towards\nemployees' contribution towards Provident Fund & ESIC on the\nbasis of details provided in the audit report. Thereafter, the\nassessee filed an application for rectification u/s 154 of the IT Act\nand consequently the order

SUDHAKAR BAJIRAO SHISODE,NASHIK vs. INCOME TAX OFFICER, NASHIK

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

Bench: Dr.Manish Borad & Shri Vinay Bhamoreआयकर अपील सं. / Ita No.2780/Pun/2025 Assessment Year : 2018-19

Disallowance of deduction under section 80C of ₹1,50,000; (b) Addition of ₹12,27,400 treating the purchase of a motor

SAI SERVICE PRIVATE LIMITED,PUNE vs. THE DEPUTY COMMISSIONER OF INCOME TAX, CIRCLE-10, PUNE

In the result, appeal of the assessee is partly allowed

Bench: Shri S.S.Godara & Dr. Dipak P. Ripoteआयकर अपील सं. / Ita Nos.1074 & 1075/Pun/2023 िनधा"रण वष" / Assessment Years : 2017-18 & 2018-19 Sai Service Private Limited, Dcit, Circle-10, Mumbai Pune Road, Vs Pune Phugewadi, Pune 411 012 Maharashtra Pan : Aabcs4998M Appellant/ Assessee Respondent /Revenue Assessee By Smt. Deepa Khare– Ar Revenue By Shri Sourabh Nayak- Dr Date Of Hearing 22/02/2024 Date Of Pronouncement 16/04/2024 आदेश/ Order Per Dr. Dipak P. Ripote, Am: These Two Appeals Filed By Assessee Are Against The Separate Orders Of Commissioner Of Income-Tax (Appeals) In The National Faceless Appeal Centre, Delhi Passed U/S.250 Of The Income-Tax Act, 1961 (Hereinafter Referred To As ‘The Act’) On 04.09.2023 & 18.09.2023 Respectively For Assessment Years 2017-18 & 2018-19. Since Some Grounds Of Appeal Are Common In All These Appeals, We Proceed To Dispose Of These Appeals By This Consolidated Order For The Sake Of Convenience. We Are Discussing A.Y.2017-18 Hereonwards.

27,085/-. The Assessee claimed the said income as exempt u/s.10 of the Act. In the computation of Income the assessee had suo-moto disallowed Rs.5,00,000/- under Section

SAI SERVICE PRIVATE LIMITED ,PUNE vs. THE DEPUTY COMMISSIONER OF INCOME TAX, CIRCLE-10, PUNE

In the result, appeal of the assessee is partly allowed

Bench: Shri S.S.Godara & Dr. Dipak P. Ripoteआयकर अपील सं. / Ita Nos.1074 & 1075/Pun/2023 िनधा"रण वष" / Assessment Years : 2017-18 & 2018-19 Sai Service Private Limited, Dcit, Circle-10, Mumbai Pune Road, Vs Pune Phugewadi, Pune 411 012 Maharashtra Pan : Aabcs4998M Appellant/ Assessee Respondent /Revenue Assessee By Smt. Deepa Khare– Ar Revenue By Shri Sourabh Nayak- Dr Date Of Hearing 22/02/2024 Date Of Pronouncement 16/04/2024 आदेश/ Order Per Dr. Dipak P. Ripote, Am: These Two Appeals Filed By Assessee Are Against The Separate Orders Of Commissioner Of Income-Tax (Appeals) In The National Faceless Appeal Centre, Delhi Passed U/S.250 Of The Income-Tax Act, 1961 (Hereinafter Referred To As ‘The Act’) On 04.09.2023 & 18.09.2023 Respectively For Assessment Years 2017-18 & 2018-19. Since Some Grounds Of Appeal Are Common In All These Appeals, We Proceed To Dispose Of These Appeals By This Consolidated Order For The Sake Of Convenience. We Are Discussing A.Y.2017-18 Hereonwards.

27,085/-. The Assessee claimed the said income as exempt u/s.10 of the Act. In the computation of Income the assessee had suo-moto disallowed Rs.5,00,000/- under Section

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

27-06-2024 Pronouncement : आदेश / ORDER PER ASTHA CHANDRA, JM : The appeal filed by the assessee is directed against the order dated 02.11.2023 of the Ld. Commissioner of Income Tax (Appeals), Pune-11 [“CIT(A)”] pertaining to Assessment Year (“AY”) 2017-18. 2. The assessee has raised the following grounds of appeal:- “I. CONFIRMATION OF DISALLOWNACE U/S 14A R.W. RULE

CAPGEMINI TECHNOLOGY SERVICES INDIA LIMITED ( SUCCESSOR OF ARICENT TECHNOLOGIES HOLDINGS LIMITED),PUNE vs. ASSISTANT COMMISSIONER OF INCOME TAX, CIRCLE 1(1), PUNE, PUNE

In the result, the appeal of the assessee is allowed

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

27. In the present case, neither in the assessment order dated 22.09.2022 nor in the subsequent show-cause notices, the Assessing Officer has specified that the case of the petitionercompany is covered under which part of sub-section (9) of Section 270A of the Act. Even in the impugned order dated 31.03.2023 also, it is not specified that which part

VEERACHARYA BABASAHEB KUCHNURE ZILLA NAGARI SAHAKARI PAT SANSTHA LTD.,SANGLI vs. INCOME TAX OFFICER 1(1), SANGLI

In the result, the appeal of the assessee is allowed

Bench: Shri Manish Borad & Ms. Astha Chandra

section 80P(2)(d). 5.7 Accordingly, the addition of Rs.5,64,27,046 made by the Assessing Officer by assessing the impugned interest under the head "Income from Other Sources" and disallowing

VEERACHARYA BABASAHEB KUCHNURE ZILLA NAGARI SAHAKARI PAT SANSTHA LIMITED,SANGLI vs. INCOME TAX OFFICER 1(1), SANGLI

In the result, the appeal of the assessee is allowed

Bench: Shri Manish Borad & Ms. Astha Chandra

section 80P(2)(d). 5.7 Accordingly, the addition of Rs.5,64,27,046 made by the Assessing Officer by assessing the impugned interest under the head "Income from Other Sources" and disallowing

ANNAPURNA NAGARI SAHKARI PATHSANSTHA MARYADIT,JALGAON vs. ITO, WARD 1(4), JALGAON, JALGAON

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

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

27,28,099/- earned by the assessee out of fixed deposits / investments made with other co-operative banks, the reasons of which have already been reproduced in the preceding paragraphs. We find in appeal the Ld. CIT(A) / NFAC sustained the addition made by the Assessing Officer. 9. We find an identical issue has already been decided

CAPGEMINI TECHNOLOGY SERVICES INDIA LIMITED (SUCCESSOR TO LIQUIDHUB INDIA PRIVATE LIMITED),PUNE vs. ASSISTANT COMMISSIONER OF INCOME TAX, CIRCLE 1(1), PUNE, PUNE

In the result, the Appeal filed by the Assessee is allowed

Bench: Dr.Dipak P. Ripote & Shri Vinay Bhamoreआयकर अपऩल सं. / Ita No.2753/Pun/2025 निर्धारण वषा / Assessment Year: 2020-21 Capgemini Technology V Assessment Unit, Services India S Income Tax Limited(Successor To Liquid Department. Hub India Private Limited), Plot No.14, Rajiv Gandhi Infotech Park, Hinjewadi, Phase Iii, Midc Sez, Village Man, Taluka Mulshi, District Pune – 411057. Pan: Aaacl8943J Appellant/ Assessee Respondent /Revenue Assessee By Shri Sudin Sabnis & Shri Siddhesh Khandalkar Revenue By Shri Madhukar Anand-Jcit(Through Virtual) Date Of Hearing 05/01/2026 Date Of Pronouncement 19/01/2026 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.2020-21 Dated 02.09.2025 Emanating From The Penalty Order Passed Under Section

27,62,439 retrospective amendments [e.g section 40(a)(ii) and section 36(1)(va) of Capgemini (other than sr. no. 2) 5 4. Balance MAT Credit brought forward 5,67,32,85,499 ITA No.2753/PUN/2025 [A] 2.2 Ld.AR for the Assessee relied on the following case laws : “i. Copy of the order passed by the ITAT "A" Bench, Pune

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

JAIBHAGWAN BANARASIDAS JINDAL,JALNA vs. THE INCOME TAX OFFICER, WARD-1, JALNA

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

Bench: Shri R. K. Panda & Ms. Astha Chandraassessment Year : 2016-17

section 10(38). 27. Referring to the decision of Hon'ble Supreme Court in the case of Principal Commissioner of Income-tax Vs Renu Aggarwal, 153 taxmann.com 579, he submitted that the Hon’ble Supreme Court in the said decision has dismissed the SLP filed against order of High Court that where Assessing Officer disallowed

DEPUTY COMMISSIONER OF INCOME TAX CIRCLE-7 PUNE, PUNE vs. L B KUNJIR, PUNE

In the result, appeal of the Revenue is dismissed

Bench: Shri Partha Sarathi Chaudhury & Dr. Dipak P. Ripoteआयकर अपील सं. / Ita No.1255/Pun/2023 िनधा"रण वष" / Assessment Year : 2020-21 The Deputy Commissioner L B Kunjir, Of Income Tax, V S.No.52/1 Swanand Circle-7, Pune. S Building, Shree Ram Hsg Society, Kharadi, Chandanagar, Pune – 411037. Pan: Aabfl9816E Appellant / Revenue Respondent / Assessee Assessee By Shri Nikhil Pathak – Ar Revenue By Shri R.Y.Balawade – Addl.Cit Date Of Hearing 12/03/2024 Date Of Pronouncement 26/03/2024 आदेश/ Order

disallowed assessee’s claim of deduction under section 80IA(4) of 2 L B Kunjir [R] the Act. It is observed in the assessment order that assessee had installed wind mills and solar power plants. Assessee had claimed deduction under section 80IA(4) of the Act on these wind mills and solar power plants. The details of the wind mills

DEPUTY COMMISSIONER OF INCOME TAX, PUNE vs. VASCON ENGINEERS LIMITED, PUNE

In the result, Appeal of the Revenue is Dismissed

Bench: Ms.Astha Chandra & Dr.Dipak P. Ripoteआयकर अपऩल सं. / Ita No.1105/Pun/2025 निर्धारण वषा / Assessment Years: 2013-14 Deputy Commissioner Vs. Vascon Engineers Limited, Of Income Tax, Pune. Vascon Weikfileld Chamber, Opposite Hyatt Hotel, Nagar Road, Pune – 411014. Pan: Aaacv1249F Appellant/ Revenue Respondent /Assessee Assessee By Shri Ajit Tolani & Darpan Kriplani Revenue By Smt. Indira R. Adakil – Addl.Cit(Dr) Date Of Hearing 02/12/2025 Date Of Pronouncement 27/01/2026 आदेश/ Order Per Dr. Dipak P. Ripote, Am: This Appeal Filed By The Revenue Is Against The Order Of Ld.Commissioner Of Income Tax(Appeal)[Nfac], Passed Under Section 250 Of The Income Tax Act, 1961 Dated 05.02.2025Emanating From The Assessment Order Under Section 143(3) R.W.S 144C(3/4) Of The Act, 1961 Dated 23.01.2017 For The A.Y.2013-14. The Revenue Has Raised The Following Grounds Of Appeal :

27. The aforesaid discussion and the cited judgments advise this Court to conclude that the proportionate disallowance of interest is not warranted, under section