EATON TECHNOLOGIES PVT.LTD,,PUNE vs. DEPUTY COMMISSIONER OF INCOME-TAX, CIRCLE - 1(2),, PUNE

Appeal is partly allowed in above terms

Bench: Shri S. S. Godara, Jm & Shri Dr. Dipak P. Ripote, Am आयकर अपीऱ सं. / Ita No.3075/Pun/2017 ननधधारण वषा / Assessment Year : 2013-14 Eaton Technologies Pvt. Ltd. Cluster C, Wing 1, Eon Free Zone, Plot No.1, Sr. No.77, Midc Kharadi Knowledge Park, Kharadi ,Pune- 411 014. .......अपऩलधथी / Appellant Pan : Aabce4323Q बनधम / V/S. ……प्रत्यथी / Respondent Dcit, Circle-1(2), Pune Assessee By : Shri Vishal Karla Revenue By : Shri S. P. Walimbe

disallowance under section 14A read with Rule 8D(2)(iii) of the Rules. 13. Notwithstanding and without prejudice to the above and on facts and circumstances of the case and in law, the AO has erred in not accepting the claim of the Appellant that only expenditure amounting to INR 78,301

DEPUTY COMMISSIONER OF INCOME TAX CIR 1(1), PUNE vs. EATON TECHNOLOGIES PVT. LTD.,, PUNE

Appeals are partly allowed for statistical purpose in above terms

Bench: Shri S.S.Godara & Dr. Dipak P. Ripoteआयकरअपीलसं. / Ita Nos.42 & 43/Pun/2021 िनधा"रणवष" / Assessment Years : 2015-16 & 16-17 Dcit, Circle-1(1), Pune. M/S.Eaton Technologies Pvt. Ltd., Vs Cluster C Wing-1, Eon Zone, Midc Kharadi, Knowledge Park, Plot No.1, Survey No.77, Kharadi, Pune – 411014. Pan: Aabce 4323 Q Appellant/ Assessee Respondent /Revenue Assessee By Shri Vishal Kalra & Shri Ss Tomar -Ar Revenue By Shri Sunil Kumar – Cit(Dr) Date Of Hearing 24/06/2022 Date Of Pronouncement 07/07/2022 आदेश/ Order Per S.S.Godara, Jm: These Revenue’S Twin Appeals For The Assessment Years 2015- 16 & 2016-17 Arise Against The Cit(A)-13, Pune’S Separate Orders; Both Dated 29.05.2020, Passed In Case No.Pn/Cit(A)-13/Dcit, Circle-1(2), Pune/10142/2019-20/02, Pn/Cit(A)-13/Dcit, Circle- 1(2), Pune/10142/2019-20/03 Respectively, Involving Proceedings Under Section 143(3) Of The Income Tax Act, 1961. Heard Both The Parties. Case Files Perused.

section 14A r.w.s. Rule 8D(2)(iii) disallowance of administrative expenditure of Rs.1,44,88,051/- in relates to its exempt income. We note that the learned lower authorities have neither considered assessee’s suo moto expenditure of Rs.78,301

DEPUTY COMMISSIONER OF INCOME TAX CIR 1(1), PUNE vs. EATON TECHNOLOGIES PVT. LTD.,, PUNE

Appeals are partly allowed for statistical purpose in above terms

Bench: Shri S.S.Godara & Dr. Dipak P. Ripoteआयकरअपीलसं. / Ita Nos.42 & 43/Pun/2021 िनधा"रणवष" / Assessment Years : 2015-16 & 16-17 Dcit, Circle-1(1), Pune. M/S.Eaton Technologies Pvt. Ltd., Vs Cluster C Wing-1, Eon Zone, Midc Kharadi, Knowledge Park, Plot No.1, Survey No.77, Kharadi, Pune – 411014. Pan: Aabce 4323 Q Appellant/ Assessee Respondent /Revenue Assessee By Shri Vishal Kalra & Shri Ss Tomar -Ar Revenue By Shri Sunil Kumar – Cit(Dr) Date Of Hearing 24/06/2022 Date Of Pronouncement 07/07/2022 आदेश/ Order Per S.S.Godara, Jm: These Revenue’S Twin Appeals For The Assessment Years 2015- 16 & 2016-17 Arise Against The Cit(A)-13, Pune’S Separate Orders; Both Dated 29.05.2020, Passed In Case No.Pn/Cit(A)-13/Dcit, Circle-1(2), Pune/10142/2019-20/02, Pn/Cit(A)-13/Dcit, Circle- 1(2), Pune/10142/2019-20/03 Respectively, Involving Proceedings Under Section 143(3) Of The Income Tax Act, 1961. Heard Both The Parties. Case Files Perused.

section 14A r.w.s. Rule 8D(2)(iii) disallowance of administrative expenditure of Rs.1,44,88,051/- in relates to its exempt income. We note that the learned lower authorities have neither considered assessee’s suo moto expenditure of Rs.78,301

SHRI. DUDHGANGA VEDGANGA SAHAKARI SAKHAR KARKHANA LTD,,KOLHAPUR vs. ASSISTANT COMMISSIONER OF INCOME-TAX, CIRCLE -1,, KOLHAPUR

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

disallowed under section 40A(2)(b) of the Act, despite the fact that profit was one of the components in the price. 4. Referring to the facts and issues, the Ld. Authorised Representatives appearing on behalf of the assessees and Ld. Departmental Representatives representing the Department, submitted, at the outset, that the issue of excess sugarcane price raised in present

VAIDYANATH KEDESHWAR SAKHAR UDYOG,,BEED vs. DEPUTY COMMISSIONER OF INCOME-TAX, AHMEDNAGAR CIRCLE,, AHMEDNAGAR

Appeal is allowed for statistical purposes in above terms

disallowed under section 40A(2)(b) of the Act, despite the fact that profit was one of the components in the price. 4. Referring to the facts and issues, the Ld. Authorised Representatives appearing on behalf of the assessees and Ld. Departmental Representatives representing the Department, submitted, at the outset, that the issue of excess sugarcane price raised in present

SHREE ADINATH SSK LTD,,SOLAPUR vs. ASSISTANT COMMISSIONER OF INCOME-TAX, CIRCLE -1, , SOLAPUR

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

disallowed under section 40A(2)(b) of the Act, despite the fact that profit was one of the components in the price. 4. Referring to the facts and issues, the Ld. Authorised Representatives appearing on behalf of the assessees and Ld. Departmental Representatives representing the Department, submitted, at the outset, that the issue of excess sugarcane price raised in present

SHREE CHHATRAPATI SHAHU SSK LTD,,KOLHAPUR vs. ASSISTANT COMMISSIONER OF INCOME-TAX, CIRCLE -1, , KOLHAPUR

In the result, all the appeals of assessee are allowed for statistical purposes

disallowed under section 40A(2)(b) of the Act, despite the fact that profit was one of the components in the price. 4. Referring to the facts and issues, the Ld. Authorised Representatives appearing on behalf of the assessees and Ld. Departmental Representatives representing the Department, submitted, at the outset, that the issue of excess sugarcane price raised in present

SHREE CHHATRAPATI SHAHU SSK LTD,,KOLHAPUR vs. ASSISTANT COMMISSIONER OF INCOME-TAX, CIRCLE -1, , KOLHAPUR

In the result, all the appeals of assessee are allowed for statistical purposes

disallowed under section 40A(2)(b) of the Act, despite the fact that profit was one of the components in the price. 4. Referring to the facts and issues, the Ld. Authorised Representatives appearing on behalf of the assessees and Ld. Departmental Representatives representing the Department, submitted, at the outset, that the issue of excess sugarcane price raised in present

LOKNETE BALASAHEB DESAI SAHAKARI SAKHAR KARKHANA LTD,,SATARA vs. DEPUTY COMMISSIONER OF INCOME-TAX, SATARA CIRCLE,, SATARA

In the result, all the appeals of assessee are allowed for statistical purposes

disallowed under section 40A(2)(b) of the Act, despite the fact that profit was one of the components in the price. 4. Referring to the facts and issues, the Ld. Authorised Representatives appearing on behalf of the assessees and Ld. Departmental Representatives representing the Department, submitted, at the outset, that the issue of excess sugarcane price raised in present

LOKNETE BALASAHEB DESAI SAHAKARI SAKHAR KARKHANA LTD,,SATARA vs. DEPUTY COMMISSIONER OF INCOME-TAX, SATARA CIRCLE,, SATARA

In the result, all the appeals of assessee are allowed for statistical purposes

disallowed under section 40A(2)(b) of the Act, despite the fact that profit was one of the components in the price. 4. Referring to the facts and issues, the Ld. Authorised Representatives appearing on behalf of the assessees and Ld. Departmental Representatives representing the Department, submitted, at the outset, that the issue of excess sugarcane price raised in present

LOKNETE BALASAHEB DESAI SAHAKARI SAKHAR KARKHANA LTD,,SATARA vs. DEPUTY COMMISSIONER OF INCOME-TAX, SATARA CIRCLE,, SATARA

In the result, all the appeals of assessee are allowed for statistical purposes

disallowed under section 40A(2)(b) of the Act, despite the fact that profit was one of the components in the price. 4. Referring to the facts and issues, the Ld. Authorised Representatives appearing on behalf of the assessees and Ld. Departmental Representatives representing the Department, submitted, at the outset, that the issue of excess sugarcane price raised in present

LOKNETE BALASAHEB DESAI SAHAKARI SAKHAR KARKHANA LTD,,SATARA vs. DEPUTY COMMISSIONER OF INCOME-TAX, SATARA CIRCLE,, SATARA

In the result, all the appeals of assessee are allowed for statistical purposes

disallowed under section 40A(2)(b) of the Act, despite the fact that profit was one of the components in the price. 4. Referring to the facts and issues, the Ld. Authorised Representatives appearing on behalf of the assessees and Ld. Departmental Representatives representing the Department, submitted, at the outset, that the issue of excess sugarcane price raised in present

SONHIRA SAHAKARI SAKHAR KARKHANA LTD,,SANGLI vs. ASSISTANT COMMISSIONER OF INCOME-TAX, CIRCLE - 2,, SANGLI

In the result, both the appeals of assessee are allowed for statistical purposes

disallowed under section 40A(2)(b) of the Act, despite the fact that profit was one of the components in the price. 4. Referring to the facts and issues, the Ld. Authorised Representatives appearing on behalf of the assessees and Ld. Departmental Representatives representing the Department, submitted, at the outset, that the issue of excess sugarcane price raised in present

SONHIRA SAHAKARI SAKHAR KARKHANA LTD,,SANGLI vs. ASSISTANT COMMISSIONER OF INCOME-TAX, CIRCLE - 2,, SANGLI

In the result, both the appeals of assessee are allowed for statistical purposes

disallowed under section 40A(2)(b) of the Act, despite the fact that profit was one of the components in the price. 4. Referring to the facts and issues, the Ld. Authorised Representatives appearing on behalf of the assessees and Ld. Departmental Representatives representing the Department, submitted, at the outset, that the issue of excess sugarcane price raised in present

HUTATMA KISAN AHIR SAHAKARI SAKHAR KARKHANA LTD,,SANGLI vs. ASSISTANT COMMISSIONER OF INCOME-TAX, CIRCLE - 2,, SANGLI

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

disallowed under section 40A(2)(b) of the Act, despite the fact that profit was one of the components in the price. 4. Referring to the facts and issues, the Ld. Authorised Representatives appearing on behalf of the assessees and Ld. Departmental Representatives representing the Department, submitted, at the outset, that the issue of excess sugarcane price 3 Hutatma Kisan

SHRI MURLI MANOHAR NAGARI SAHAKARI PATSANSTHA MARYADIT,MAHAD vs. INCOME-TAX OFFICER, PANVEL

In the result, appeal of the assessee is partly allowed

Bench: Dr.Dipak P. Ripote & Shri Vinay Bhamoreआयकर अपऩल सं. / Ita No.934/Pun/2025 निर्धारण वषा / Assessment Year: 2017-18 Shri Murli Manohar Nagari V Income Tax Officer. Sahakaripatsansthamaryadit, S. 1295, Pimpal Par, M.G.Road, Juni Peth, Mahad, Mahad – 402301. Maharashtra. Pan: Aabas5404L Appellant/ Assessee Respondent / Revenue Assessee By Shri Anup Shaha Revenue By Shri Dayanand Jawalikar–Addl.Cit(Dr) Date Of Hearing 14/10/2025 Date Of Pronouncement 30/10/2025 आदेश/ Order Per Dr. Dipak P. Ripote, Am: This Appeal Is 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 A.Y.2017-18, Dated 11.03.2024 Emanating From Assessment Order U/S.143(3) R.W.S 263 Read With Section 144B Of The I.T.Act, Dated 17.03.2023. The Assessee Has Raised Following Grounds Of Appeal :

disallowed assessee’s claim of deduction u/s.80P of the Act. 3. Aggrieved by the Assessment Order the Assessee filed appeal before the Ld.CIT(A) who confirmed the Assessment Order.It is an admitted fact that the Assessee is a co-operative credit society registered under Maharashtra Cooperative societies Act. 4. As per the submission of the Assessee dated 16.11.2019 made during

M/S PERSISTENT SYSTEMS LIMITED,PUNE vs. ASSESSMENT UNIT, INCOME-TAX DEPARTMENT, PUNE

In the result, appeal of the Assessee is Partly Allowed

Bench: Shri S.S.Godara & Dr. Dipak P. Ripoteआयकरअपीलसं. / Ita No.692/Pun/2022 िनधा"रणवष" / Assessment Year : 2018-19 M/S.Persistent Systems Assessment Unit, Income Limited, V Tax Department. “Bhageerath” 402, Senapati S Bapat Road, Pune – 411016. Pan: Aabcp 1209 Q Appellant/ Assessee Respondent /Revenue Assessee By Shri Dhanesh Bafna& Shriaditya Vaidya– Ar’S Revenue By Shri Suhas Kulkarni - Irs Addl Commissioner Of Income Tax Date Of Hearing 26/09/2023 Date Of Pronouncement 02/11/2023 आदेश/ Order Per Dr. Dipak P. Ripote, Am: This Appeal Filed By The Assessee Is Directed Against The Assessment Order, Dated 20.07.2022 Under Section 143(3) R.W.S. 144C(13) Read With Section 144B Of The Income Tax Act, 1961 For A.Y.2018-19. The Assessee Has Raised The Following Grounds Of Appeal: “Ground 1: Order Is Invalid / Non Est  On The Facts & In The Circumstances Of The Case & In Law, The Assessment Unit (‘Au’) Has Erred In Passing The Draft Assessment M/S.Persistent Systems Limited [A]

disallowance of INR 4,50,70,798 under u/s 14A of the Act r.w rule 8D(2)(ii) be deleted. Ground 10: Additional relief under section 90 On the facts and circumstances of the case, and in law, the AU based on the directions of Ld. DRP erred in disregarding Appellant’s claim for additional relief under section

RAJARAMBAPU PATIL SSK LTD, ,SANGLI vs. ASSISTANT COMMISSIONER OF INCOME-TAX, CIRCLE - 2,, SANGLI

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

Bench: Shri Partha Sarathi Chaudhury, Jm & Dr. Dipak P. Ripote, Am आयकरअपीलसं. / Ita No.1867/Pun/2017 िनधा"रणवष" / Assessment Year : 2012-13 Rajarambapu Patil Ssk Ltd, The Assistant Commissioner Of Sakharale, Islampur, Vs Income Tax, Circle-2, Sangli. Dist. Sangli – 415 414. Pan: Aaaar 0790 D Appellant/ Revenue Respondent/ Assessee Assessee By Shri Prasanna L Joshi – Ar Revenue By Shri Deepak Garg - Dr Date Of Hearing 07/03/2022 Date Of Pronouncement 22/04/2022 आदेश/ Order Per Dr. Dipak P. Ripote, Am: This Is An Appeal Filed By The Assessee Directed Against The Order Of Ld.Commissioner Of Income Tax(Appeals)-2, Kolhapur Dated 16.05.2017For The Assessment Year 2012-13. The Assessee Raised The Following Grounds Of Appeal: “1. Ld. Cit(A) Ought To Have Followed The Judgement Of Itat, Mumbai Dated 16/5/1968 In Pravara Ssk In Ita No. 10939-42 Upheld By Hon’Ble Supreme Court, 94 Itr 321, Which Was Accepted By It Dept, For Over 3 Decades & As Held By Supreme Court In Radhasoami Satsang, 193 Itr 321, It Would Not Be Appropriate To Allow The Position To Be Changed In A Subsequent Year, As Re- Confirmed By Hon’Ble Supreme Court In Municipal Corp. Of Thane V. Vidyut Metalics (2007) 8 Scc 688. 2. Ld. Cit(A) Ought To Have Held That It Is Government’S Policy To Encourage Co-Operatives & Appellant’S Business Which Is Run On Co- Operative Principles & Policy & Has Its Aims & Objects That Are

301 Mt disallowance of Rs 475.40/Mt = Rs 1,63,06,695 c) For Karandwadi on Cane Crush of 7,296 Mt disallowance of Rs 486.80/Mt = Rs 35,51,692 ii) For season 2011-12 out cane purchases at a uniform price of Rs 2490/Mt - a) For Sakharale on Cane Crush of 8,11,843 Mt disallowance