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

In the result, the appeal of assessee is allowed

Bench: Shri Anil Chaturvedi & Shri Partha Sarathi Chaudhury

section 32(1)(ii) of the I.T. Act, 1961 for entitlement of depreciation. It is also seen that ratio of intangible to tangible asset is quite high which. only shows that the appellant has tried to allocate the balance amount other than tangible assets in the category of intangibles in order to claim depreciation. This can be seen from

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

In the result, the appeal of assessee is allowed

Bench: Shri Anil Chaturvedi & Shri Partha Sarathi Chaudhury

section 32(1)(ii) of the I.T. Act, 1961 for entitlement of depreciation. It is also seen that ratio of intangible to tangible asset is quite high which. only shows that the appellant has tried to allocate the balance amount other than tangible assets in the category of intangibles in order to claim depreciation. This can be seen from

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

32(1) and Explanation (3) thereof, read with Explanation (7) of\nSection 43(1) and Explanation-2 of 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

DCIT, SWARGATE PUNE vs. CUMMINS INDIA LTD , PUNE

In the result, appeal of the assessee bearing ITA No

ii) of\nsub-section (1) of section 10AA by the Finance Act,\n2023, w.e.f. 1-4-2024:\nProvided that no such deduction shall be allowed to an\nassessee who does not furnish a return of income on or\nbefore the due date specified under sub-section (1) of\nsection 139\".\n15. The Memorandum to the Finance Bill, 2023 clearly states

INDIAN MEDICAL ASSOCIATION PUNE BRANCH,SHUKRAWAR PETH vs. DCIT EXEMPTION CIRCLE, PUNE, SWARGATE

In the result, all the 5 appeals filed by the assessee are allowed

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

ii) In all other cases of belated applications in filing Form No. 10B for years prior to AY. 2018-19, The commissioner of Income-tax are authorized to admit and dispose off by 31-3-2020 such applications for condonation of delay u/s 119(2)(b)of the Act The Commissioner will while entertaining such belated applications in filing Form

INDIAN MEDICAL ASSOCIATION PUNE BRANCH,SHUKRAWAR PETH vs. DCIT EXEMPTION CIRCLE, PUNE, SWARGATE

In the result, all the 5 appeals filed by the assessee are allowed

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

ii) In all other cases of belated applications in filing Form No. 10B for years prior to AY. 2018-19, The commissioner of Income-tax are authorized to admit and dispose off by 31-3-2020 such applications for condonation of delay u/s 119(2)(b)of the Act The Commissioner will while entertaining such belated applications in filing Form

INDIAN MEDICAL ASSOCIATION PUNE BRANCH,SHUKRAWAR PETH vs. DCIT EXEMPTION CIRCLE PUNE, SWARGATE

In the result, all the 5 appeals filed by the assessee are allowed

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

ii) In all other cases of belated applications in filing Form No. 10B for years prior to AY. 2018-19, The commissioner of Income-tax are authorized to admit and dispose off by 31-3-2020 such applications for condonation of delay u/s 119(2)(b)of the Act The Commissioner will while entertaining such belated applications in filing Form

INDIAN MEDICAL ASSOCIATION PUNE BRANCH,SHUKRAWAR PETH vs. DCIT EXEMPTION CIRCLE, PUNE, SWARGATE

In the result, all the 5 appeals filed by the assessee are allowed

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

ii) In all other cases of belated applications in filing Form No. 10B for years prior to AY. 2018-19, The commissioner of Income-tax are authorized to admit and dispose off by 31-3-2020 such applications for condonation of delay u/s 119(2)(b)of the Act The Commissioner will while entertaining such belated applications in filing Form

INDIAN MEDICAL ASSOCIATION PUNE BRANCH,SHUKRAWAR PETH vs. DCIT EXEMPTION CIRCLE, PUNE, SWARGATE

In the result, all the 5 appeals filed by the assessee are allowed

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

ii) In all other cases of belated applications in filing Form No. 10B for years prior to AY. 2018-19, The commissioner of Income-tax are authorized to admit and dispose off by 31-3-2020 such applications for condonation of delay u/s 119(2)(b)of the Act The Commissioner will while entertaining such belated applications in filing Form

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 of the Act regarding the claim of depreciation on intangible assets at ₹1,86,95,184 giving reference of the generation of goodwill at the time of amalgamation

ZF STEERING GEAR (INDIA) LTD,,PUNE vs. DEPUTY COMMISSIONER OF INCOME-TAX, CENTRAL CIRCLE -1 (1),, PUNE

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

Bench: Shri R.S.Syal, Vp & Shri Partha Sarathi Chaudhury, Jm Assessment Year: 2013-14

disallowing the claim for depreciation of Rs. 1,83,59,602/- which pertains to additional depreciation claimed u/s 32(1)(iia) of the Act at 20% in respect of eligible assets put to use for less than 180 days, as against the rate of 10% (i.e. restricted to 50% of the additional depreciation. (iii) Being aggrieved by the assessment order

SHRINIWAS ENGINEERING AUTO COMPONENTS PVT. LTD,PUNE vs. NATIONAL FACELESS APPEAL CENTRE, PUNE

In the result, ITA Nos. 154 to 156/PUN/2025 filed by the assessee are partly allowed for statistical purposes, ITA

Bench: Dr.Manish Borad & Shri Vinay Bhamoreआयकर अपील सं. / Ita Nos.154 To 156/Pun/2025 Assessment Years : 2016-17 To 2018-19

section 2(24)(xviii) of the Act comes into operation and the subsidy received by the assessee is to be treated as income liable to be taxed for the year under consideration. We therefore fail to find any infirmity in the order of ld.CIT(A) and the common grounds of appeal No.2 raised by the assessee for the Assessment Years

SHRINIWAS ENGINEERING AUTO COMPONENTS PVT. LTD,PUNE vs. NATIONAL FACELESS APPEAL CENTRE, PUNE

In the result, ITA Nos. 154 to 156/PUN/2025 filed by the assessee are partly allowed for statistical purposes, ITA

Bench: Dr.Manish Borad & Shri Vinay Bhamoreआयकर अपील सं. / Ita Nos.154 To 156/Pun/2025 Assessment Years : 2016-17 To 2018-19

section 2(24)(xviii) of the Act comes into operation and the subsidy received by the assessee is to be treated as income liable to be taxed for the year under consideration. We therefore fail to find any infirmity in the order of ld.CIT(A) and the common grounds of appeal No.2 raised by the assessee for the Assessment Years

DY. COMMISSIONER OF INCOME-TAX, CIRCLE-5, PUNE vs. SHRINIWAS ENGINEERING AUTO COMPONENTS PVT. LTD., PUNE

In the result, ITA Nos. 154 to 156/PUN/2025 filed by the assessee are partly allowed for statistical purposes, ITA

Bench: Dr.Manish Borad & Shri Vinay Bhamoreआयकर अपील सं. / Ita Nos.154 To 156/Pun/2025 Assessment Years : 2016-17 To 2018-19

section 2(24)(xviii) of the Act comes into operation and the subsidy received by the assessee is to be treated as income liable to be taxed for the year under consideration. We therefore fail to find any infirmity in the order of ld.CIT(A) and the common grounds of appeal No.2 raised by the assessee for the Assessment Years

SHRINIWAS ENGINEERING AUTO COMPONENTS PVT. LTD.,PUNE vs. ACIT, CIRCLE-5, PUNE, PUNE

In the result, ITA Nos. 154 to 156/PUN/2025 filed by the assessee are partly allowed for statistical purposes, ITA

Bench: Dr.Manish Borad & Shri Vinay Bhamoreआयकर अपील सं. / Ita Nos.154 To 156/Pun/2025 Assessment Years : 2016-17 To 2018-19

section 2(24)(xviii) of the Act comes into operation and the subsidy received by the assessee is to be treated as income liable to be taxed for the year under consideration. We therefore fail to find any infirmity in the order of ld.CIT(A) and the common grounds of appeal No.2 raised by the assessee for the Assessment Years

ACIT, CIRCLE-5, PUNE, PUNE vs. SHRINIWAS ENGINEERING AUTO COMPONENTS PRIVATE LIMITED, PUNE

In the result, ITA Nos. 154 to 156/PUN/2025 filed by the assessee are partly allowed for statistical purposes, ITA

Bench: Dr.Manish Borad & Shri Vinay Bhamoreआयकर अपील सं. / Ita Nos.154 To 156/Pun/2025 Assessment Years : 2016-17 To 2018-19

section 2(24)(xviii) of the Act comes into operation and the subsidy received by the assessee is to be treated as income liable to be taxed for the year under consideration. We therefore fail to find any infirmity in the order of ld.CIT(A) and the common grounds of appeal No.2 raised by the assessee for the Assessment Years

CUMMINS INDIA LIMITED,,PUNE vs. DEPUTY COMMISSIONER OF INCOME TAX,, PUNE

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

Bench: Shri R.S.Syal, Vp & Shri Partha Sarathi Chaudhury, Jm आयकर अपीऱ सं. / Ita No.685/Pun/2017 नििाारण वषा / Assessment Year : 2012-13

disallowed the additional depreciation claimed by the assessee and added back the same to the total income of the assessee. While doing so, the Assessing Officer has referred amendment of Section 32 of the Act reproducing the provision in his order and mentioning thereto that in this regard claim of the assessee that it is clarificatory in nature

JOHN DEERE EQIPMENT P. LTD.,,PUNE vs. DEPUTY DIRECTOR OF INCOME-TAX,,

In the result, all the appeals of assessee are allowed

Bench: Ms. Sushma Chowla, Jm & Shri Anil Chaturvedi, Am आयकर अपीऱ सं. / Ita Nos.905 & 906/Pun/2015 यििाारण वषा / Assessment Years :2007-08 & 2008-09

32. He further continued his arguments on the next date and pointed out that the issue in Allianz SE Vs. ADIT (IT) (supra) was whether it is royalty or not. He admitted that the issue in Allianz SE Vs. ADIT (IT) (supra) was royalty or not however, he pointed out that reliance placed upon on the said decision was misplaced