SPRINGER NATURE TECHNOLOGY AND PUBLISHING SOLUTIONS PRIVATE LIMITED,PUNE vs. THE DEPUTY COMMISSIONER OF INCOME-TAX, CIRCLE 5, PUNE, PUNE

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

Bench: Dr.Manish Borad & Shri Vinay Bhamore

disallowance. Levy of Interest under section 234A and 2348 of the Act 9. The learned ADIT-CPC has levied an interest under section 234A of the Act of Rs. 7,17,497, without assigning any reason whatsoever. 10. The learned ADIT-CPC has erred in levying excess interest under section 2348 of INR 1,26,84,174, without assigning

SPRINGER NATURE TECHNOLOGY AND PUBLISHING SOLUTIONS PRIVATE LIMITED,PUNE vs. THE ASSESSMENT UNIT, INCOME TAX DEPARTMENT AND THE DEPUTY COMMISSIONER OF INCOME-TAX, CIRCLE 5, PUNE, PUNE

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

Bench: Dr.Manish Borad & Shri Vinay Bhamore

disallowance. Levy of Interest under section 234A and 2348 of the Act 9. The learned ADIT-CPC has levied an interest under section 234A of the Act of Rs. 7,17,497, without assigning any reason whatsoever. 10. The learned ADIT-CPC has erred in levying excess interest under section 2348 of INR 1,26,84,174, without assigning

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

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.

33,187 (-) 44,19,568/-) is confirmed as discussed above. 9.3. Accordingly, the Ground No.2 is partly allowed. Ground No.3: 10. It is regarding disallowance u/s.14A read with Rule 8D. During the year the Assessee had received Dividend of Rs.2,86,27,085/-. The Assessee claimed the said income as exempt u/s.10 of the Act. In the computation of Income

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.

33,187 (-) 44,19,568/-) is confirmed as discussed above. 9.3. Accordingly, the Ground No.2 is partly allowed. Ground No.3: 10. It is regarding disallowance u/s.14A read with Rule 8D. During the year the Assessee had received Dividend of Rs.2,86,27,085/-. The Assessee claimed the said income as exempt u/s.10 of the Act. In the computation of Income

PRECISION CAMSHAFTS LTD.,SOLAPUR vs. ASSESSMENT UNIT, INCOME TAX DEPARTMENT (NFAC), SOLAPUR

In the result, appeal of the assessee is allowed

Bench: Ms. Astha Chandra & Dr.Dipak P. Ripoteआयकर अपील सं. / Ita No.1962/Pun/2024 िनधा"रण वष" / Assessment Year: 2020-21 Precision Camshafts Ltd., V Assessment Unit, Income Tax E-102/103, Akkalkot Road, S Department (National Midc, Solapur – 413006. Faceless Assessment Center), Maharashtra. Jurisdiction Details : Pne- C(1), Range 63, Circle-1, Solapur. Pan: Aabcp1086B Appellant/ Assessee Respondent / Revenue Assessee By Shri Nikhil Pathak – Ar Revenue By Shri Prakash L Pathade – Cit(Dr) Date Of Hearing 17/06/2025 Date Of Pronouncement 10/07/2025 आदेश/ Order Per Dr. Dipak P. Ripote, Am: This Is An Appeal Filed By The Assessee Directed Against The Order Of Assessment Unit, Income Tax Department Under Section 143(3) R.W.S 144C(3) Read With Section 144B Of The Income Tax Act, 1961 For A.Y.2020-21 Dated 25.07.2024, Emanating From Order Of Dispute Resolution Panel U/S.144C(5) Of The Act For A.Y.2020-21

Section 14A disallowance can be more than the exempt income and whether amendment brought by Finance Act, 2022 will be applicable to A.Y.2020-21 or not! 7.1 The ITAT Pune Bench in the case of Deepak Pandurang Gadre vs. ACIT in ITA No.1117/PUN/2023 has dealt with these issues. The relevant paragraph 7 and 8 of the ITAT order are reproduced here

THE PIMPALGAON MERCHANTS CO.OP. BANK LTD.,,NASHIK vs. ACIT CIRCLE-1, NASHIK

In the result, appeal of the Assessee is partly allowed

Section 14A of the Income Tax Act. The Assessing Officer (AO) disallowed ₹31,33,380 based on Rule 8D, arguing

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

disallowance made by the assessee u/s 14A along with calculation and justification why the section 14A should not be applied in the case of the assessee. The Ld. AR submitted that the assessee received dividend on equity mutual funds of Rs.4,33

VINAYAK HANUMANTRAO GHORPADE,PUNE vs. INCOME TAX OFFICER, PUNE

In the result, appeal in ITA No

Bench: Dr.Dipak P. Ripote & Shri Vinay Bhamoreआयकर अपऩल सं. / Ita Nos.1438 & 1439/Pun/2024 निर्धारण वषा / Assessment Years: 2019-20 & 2020-21 Vinayak Hanumantrao V Vaishnavi Satish Bankar, Ghorpade, S. Pune. F.No.7, Plot No.60/61, S.No.165/1B, Shivanjali, Near Central Circle-1(3), Pune. Mahadev Temple, Indira Nagar, Pune – 411033. Pan: Afdpg6919A Appellant/ Assessee Respondent / Revenue Assessee By Shri Pramod S Shingte Revenue By Shri Aviyogi Ambadkar –Addl.Cit Date Of Hearing 11/09/2025 Date Of Pronouncement 08/12/2025 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), Pune-11 Passed Under Section 250 Of The Income Tax Act, 1961 For A.Y.2019-20 & 2020-21, Both Dated 02.05.2024 Emanating From Separate Assessment Order U/S.153A R.W.S 144 Of The I.T.Act, Both Dated 23.09.2021.For The Sake Of Convenience, These Two Appeals

disallowed assessee’s claim of deduction u/s.24(b) of the Act. Before the appellate proceedings before the ld.CIT(A), Assessee again failed to produce copy of the Interest Certificate and Loan Sanction Letter from Bank. Ld.CIT(A) has discussed this issue in paragraph 11 of the order, the same is reproduced here as under : 6 ITA Nos.1438 & 1439/PUN/2024

VINAYAK HANUMANTRAO GHORPADE,PUNE vs. VAISHNAVI SATISH BANKAR, PUNE

In the result, appeal in ITA No

Bench: Dr.Dipak P. Ripote & Shri Vinay Bhamoreआयकर अपऩल सं. / Ita Nos.1438 & 1439/Pun/2024 निर्धारण वषा / Assessment Years: 2019-20 & 2020-21 Vinayak Hanumantrao V Vaishnavi Satish Bankar, Ghorpade, S. Pune. F.No.7, Plot No.60/61, S.No.165/1B, Shivanjali, Near Central Circle-1(3), Pune. Mahadev Temple, Indira Nagar, Pune – 411033. Pan: Afdpg6919A Appellant/ Assessee Respondent / Revenue Assessee By Shri Pramod S Shingte Revenue By Shri Aviyogi Ambadkar –Addl.Cit Date Of Hearing 11/09/2025 Date Of Pronouncement 08/12/2025 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), Pune-11 Passed Under Section 250 Of The Income Tax Act, 1961 For A.Y.2019-20 & 2020-21, Both Dated 02.05.2024 Emanating From Separate Assessment Order U/S.153A R.W.S 144 Of The I.T.Act, Both Dated 23.09.2021.For The Sake Of Convenience, These Two Appeals

disallowed assessee’s claim of deduction u/s.24(b) of the Act. Before the appellate proceedings before the ld.CIT(A), Assessee again failed to produce copy of the Interest Certificate and Loan Sanction Letter from Bank. Ld.CIT(A) has discussed this issue in paragraph 11 of the order, the same is reproduced here as under : 6 ITA Nos.1438 & 1439/PUN/2024

RAJUMAR PREMCHAND TULSANI,PUNE vs. PR COMMISSIONER OF INCOME-TAX -5, PUNE

In the result, appeal of the assessee is dismissed

Bench: Shri S.S.Godara & Dr. Dipak P. Ripoteआयकर अपीलसं. / Ita No.136/Pun/2021 िनधा"रण वष" / Assessment Year : 2015-16 Rajkumar Premchand Tulsani, The Pr.Commissioner Of Sr.No.46/8, Bombay Pune V Income Tax-5, Pune. Road, Akurdi, Pune – 411038. S Pan: Aawpt 8002 B Assessee/ Appellant Respondent /Revenue Assessee By Shri M.K.Kulkaani – Ar/Advocate Revenue By Shri Sardar Singh Meena,Irs – Dr Commissioner Of Income Tax. Date Of Hearing 03/05/2023 Date Of Pronouncement 06/07/2023

disallow the discharge of this legal fiction which contrary to provision of law. The expenditure which assessee is entitled to pay by the provisions of law be allowed to the assessee by cancelling the Revision order passed under s. 263 of the Act. 5. The appellant craves to leave, add/amend or alter any of the above grounds of appeal

DCIT, CENTRAL CIRCLE-2(2), PUNE vs. KAKADE INFRASTRUCTURE PRIVATE LIMITED, MUMBAI

In the result, appeal of the Revenue is dismissed

Bench: Dr.Dipak P. Ripote & Shri Vinay Bhamoreआयकर अपऩल सं. / Ita Nos.2275 & 2277/Pun/2025 निर्धारण वषा / Assessment Years: 2013-14 & 2014-15 Dcit, V Kakade Infrastructure Private Limited,20Th Floor, A Wing, Central Circle-2(2), S Pune. Marathon Futurx, N.M.Joshi Marg Lower Parel, Mumbai – 400013. Pan: Aadck5852G Appellant / Revenue Respondent / Assessee Assessee By Shri Jay Bhansali (Virtual) Revenue By Shri Amol Khairnar – Cit(Dr) Date Of Hearing 19/01/2026 Date Of Pronouncement 29/01/2026 आदेश/ Order Per Dr. Dipak P. Ripote, Am: These Two Appeals Filed By The Revenue Against The Separate Orders Of Ld.Commissioner Of Income Tax(Appeal)[Nfac], Passed Under Section 250 Of The Income Tax Act, 1961 For The A.Y.2013-14 A.Y.2014-15 Both Dated 30.07.2025 Emanating From The Assessment Order Passed Under Section 143(3) Of The Act, Dated 28.03.2016 & 30.12.2016 Respectively. For The Sake Of Convenience, These Two

disallowance under section 14A read with Rule 8D(ii) of Rs.4,03,41,761/-. Ld.CIT(A) allowed assessee’s appeal. Aggrieved by the order of the ld.CIT(A), Revenue filed appeal before this Tribunal. Ld.CIT(A) for A.Y.2013-14 has noted that Assessee had not earned any exempt ITA Nos.2275 & 2277/PUN/2025 [D] income during the year. Therefore, ld.CIT(A) relied

DCIT, CENTRAL CIRCLE-2(2), PUNE, PUNE vs. KAKADE INFRASTRUCTURE PRIVATE LIMITED, MUMBAI

In the result, appeal of the Revenue is dismissed

Bench: Dr.Dipak P. Ripote & Shri Vinay Bhamoreआयकर अपऩल सं. / Ita Nos.2275 & 2277/Pun/2025 निर्धारण वषा / Assessment Years: 2013-14 & 2014-15 Dcit, V Kakade Infrastructure Private Limited,20Th Floor, A Wing, Central Circle-2(2), S Pune. Marathon Futurx, N.M.Joshi Marg Lower Parel, Mumbai – 400013. Pan: Aadck5852G Appellant / Revenue Respondent / Assessee Assessee By Shri Jay Bhansali (Virtual) Revenue By Shri Amol Khairnar – Cit(Dr) Date Of Hearing 19/01/2026 Date Of Pronouncement 29/01/2026 आदेश/ Order Per Dr. Dipak P. Ripote, Am: These Two Appeals Filed By The Revenue Against The Separate Orders Of Ld.Commissioner Of Income Tax(Appeal)[Nfac], Passed Under Section 250 Of The Income Tax Act, 1961 For The A.Y.2013-14 A.Y.2014-15 Both Dated 30.07.2025 Emanating From The Assessment Order Passed Under Section 143(3) Of The Act, Dated 28.03.2016 & 30.12.2016 Respectively. For The Sake Of Convenience, These Two

disallowance under section 14A read with Rule 8D(ii) of Rs.4,03,41,761/-. Ld.CIT(A) allowed assessee’s appeal. Aggrieved by the order of the ld.CIT(A), Revenue filed appeal before this Tribunal. Ld.CIT(A) for A.Y.2013-14 has noted that Assessee had not earned any exempt ITA Nos.2275 & 2277/PUN/2025 [D] income during the year. Therefore, ld.CIT(A) relied

SWAROOP AGROCHEMICAL INDUSTRIES,NASHIK vs. ACIT, CIRCLE-1, NASHIK

In the result, appeal of the Assessee is allowed

section 250 of the Income Tax Act,\n1961 (“Act”), which is arising out of the assessment order u/s.\n143(3) r.w.s.144B of the Act, dated 20/04/2021 for the\n Assessment Year (AY) 2018-19.\n2. The assessee has raised seven grounds of appeal, but all\nrevolve around disallowance of expenses under various heads\namounting to Rs.36,25,944/-.\n3. Facts

DANA ANAND INDIA PRIVATE LIMITED,PUNE vs. DCIT, AKURDI,PUNE

33,528/-\n6\nTotal variations made\n3,23,56,340/-\n7\nTotal Income\n174,32,07,350/-\n4.\nSubsequently, the Assessing Officer passed the order u/s 154 of the Act\ndeleting certain additions.\n5.\nAggrieved with such order of the Assessing Officer/TPO/DRP, the assessee\nis in appeal before the Tribunal by raising the following grounds:\nOn the facts and circumstances

CHAPHEKAR SUSPENSIONS PVT.LTD,PUNE vs. DEPUTY COMMISSIONER OF INCOME TAX, CIRCLE 1(1), PUNE

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

Bench: Shri R. K. Panda & Ms Astha Chandraassessment Year : 2022-23

33 Vishal Phaltankar AIWPP2683E 59,184.00 19-10-2022 Online 34 Abhishek Shelar JMLPS1733L 19,866.54 19-10-2022 Online 35 Sunil Dass BBGPD2786Q 17,987.69 19-10-2022 Online 36 Mahendra Kakade EWJPK3515D 17,227.88 19-10-2022 Online 37 Himanshu Lokhande ATJPL1032D 10,603.80 19-10-2022 Online 38 Kiran Raul DODPR6095J 12,536.77 19-10-2022 Online

ASSISTANT COMMISSIONER OF INCOME TAX, PUNE vs. PRAJ INDUSTRIES LIMITED , PUNE

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

Bench: Dr.Manish Borad & Shri Vinay Bhamoreआयकर अपील सं. / Ita No.2096/Pun/2025 Assessment Year 2018-19

33,65,925/- from investments in equity mutual funds and claimed it exempt. It made suomoto disallowance of Rs.51,41,522/- u/s 14A of the Act, being administrative expenses which, according to the assessee may be related to exempt income. Sub-section

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