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

In the result, the appeal and the CO filed by the assessee are partly allowed and the appeals filed by the Revenue are dismissed

Bench: Shri R. K. Panda & Ms. Astha Chandraassessment Year : 2014-15

disallowance of weighted deduction claimed on expenditure incurred outside India. 5. In appeal, the Ld. CIT(A) allowed expenses incurred outside India on R&D u/s 35(1)(iv) although such claim was not under the same section but was u/s 35(2AB) by observing as under: “2.3 I have carefully considered the submission of the appellant in light

MAHLE ANAND THERMAL SYSTEMS PRIVATE LIMITED,PUNE vs. DY COMMISSIONER OF INCOME TAX, PUNE

In the result, the appeal and the CO filed by the assessee are partly allowed and the appeals filed by the Revenue are dismissed

Bench: Shri R. K. Panda & Ms. Astha Chandraassessment Year : 2014-15

disallowance of weighted deduction claimed on expenditure incurred outside India. 5. In appeal, the Ld. CIT(A) allowed expenses incurred outside India on R&D u/s 35(1)(iv) although such claim was not under the same section but was u/s 35(2AB) by observing as under: “2.3 I have carefully considered the submission of the appellant in light

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

In the result, the appeal and the CO filed by the assessee are partly allowed and the appeals filed by the Revenue are dismissed

Bench: Shri R. K. Panda & Ms. Astha Chandraassessment Year : 2014-15

disallowance of weighted deduction claimed on expenditure incurred outside India. 5. In appeal, the Ld. CIT(A) allowed expenses incurred outside India on R&D u/s 35(1)(iv) although such claim was not under the same section but was u/s 35(2AB) by observing as under: “2.3 I have carefully considered the submission of the appellant in light

DCIT, SWARGATE PUNE vs. CUMMINS INDIA LTD , PUNE

In the result, appeal of the assessee bearing ITA No

disallowance u/s.14A of the Act for the\nyear under consideration.\n11.2 The Appellant submits that considering the facts and\ncircumstances of its case and the law prevailing on the subject no\nadjustment whatsoever can be made to its \"book profits\" while\ncomputing its income u/s.115JB of the Act and the stand taken by\nthe Ld. AO/Hon'ble_DRP in this

CUMMINS INDIA LIMITED,,PUNE vs. ASSISTANT COMMISSIONER OF INCOME-TAX, CIRCLE - 1(1),, PUNE

In the result, appeal of the assessee bearing ITA No

ii) and before\nthe Explanation, the following proviso shall be\ninserted, namely:—\n“Provided that no such deduction shall be allowed\nto an assessee who does not furnish a return of\nincome on or before the due date specified under\nsub-section (1) of section 139.”;\n\n10.5 It is important to note that the AO in his order

AJINKYA MADHYAMIK SHIKSHAK SEVAK SAH. PATSANSTHA, MARYADIT,SATARA vs. INCOME TAX OFFICER, WARD-2, SATARA, SATARA

In the result, the appeal of the assessee is allowed

35, are that the assessee is a patsanstha and\nengaged in accepting deposits from its members and in turn providing\ncredit facilities to its members. It provides its members with loans and\nearns interest thereon. The income of the assessee is eligible for claim of\ndeduction u/s 80P of the Income

MAHLE BEHR INDIA PVT. LTD.,,PUNE vs. DEPUTY COMMISSIONER OF INCOME-TAX,, PUNE

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

Section 35(1) (iv) Income Tax Act, 1961 at least to\nthe extent of One hundred percent.\n4. Facts of the case, in brief, are that the assessee is a company engaged in the\nbusiness of manufacture and sale of air conditioners, radiators, heat exchangers\nparts and components thereof which are used in cars and SUVs and in providing

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

35,312/- are attached herewith. 5. PRAYER It is accordingly prayed that the above additional ground of appeal may be admitted for adjudication of the appeal in the interest of justice. In this regard reliance is placed on the following judgements. (i) NTPC Ltd. [2017] 88 taxmann.com 561 (SC). (ii) Jute Corpn. of India Ltd. [1990] 53 Taxman

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

35,312/- are attached herewith. 5. PRAYER It is accordingly prayed that the above additional ground of appeal may be admitted for adjudication of the appeal in the interest of justice. In this regard reliance is placed on the following judgements. (i) NTPC Ltd. [2017] 88 taxmann.com 561 (SC). (ii) Jute Corpn. of India Ltd. [1990] 53 Taxman

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

35,312/- are attached herewith. 5. PRAYER It is accordingly prayed that the above additional ground of appeal may be admitted for adjudication of the appeal in the interest of justice. In this regard reliance is placed on the following judgements. (i) NTPC Ltd. [2017] 88 taxmann.com 561 (SC). (ii) Jute Corpn. of India Ltd. [1990] 53 Taxman

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

35,312/- are attached herewith. 5. PRAYER It is accordingly prayed that the above additional ground of appeal may be admitted for adjudication of the appeal in the interest of justice. In this regard reliance is placed on the following judgements. (i) NTPC Ltd. [2017] 88 taxmann.com 561 (SC). (ii) Jute Corpn. of India Ltd. [1990] 53 Taxman

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

35,312/- are attached herewith. 5. PRAYER It is accordingly prayed that the above additional ground of appeal may be admitted for adjudication of the appeal in the interest of justice. In this regard reliance is placed on the following judgements. (i) NTPC Ltd. [2017] 88 taxmann.com 561 (SC). (ii) Jute Corpn. of India Ltd. [1990] 53 Taxman

DEPUTY COMMISSIONER OF INCOME TAX, CIRCLE-1, AURANGABAD, AURANGABAD vs. ENDURANCE TECHNOLOGIES LIMITED, AURANGABAD

In the result, all the appeals filed by the Revenue are dismissed

1) in relation to approval of in-house R&D\nfacility in part A of form No.3CL and (ii) quantifying the expenditure incurred on\nin-house R & D facility by the company during the previous year and eligible for\nweighted deduction under sub-section 2AB of section 35 of the Act in part B of\nform No.3CL In other words

DEPUTY COMMISSIONER OF INCOME TAX, CIRCLE-1, AURANGABAD, AURANGABAD vs. ENDURANCE TECHNOLOGIES LIMITED, AURANGABAD

In the result, all the appeals filed by the Revenue are dismissed

1) in relation to approval of in-house R&D\nfacility in part A of form No.3CL and (ii) quantifying the expenditure incurred on\nin-house R & D facility by the company during the previous year and eligible for\nweighted deduction under sub-section 2AB of section 35 of the Act in part B of\nform No.3CL In other words

DEPUTY COMMISSIONER OF INCOME TAX, CIRCLE-1, AURANGABAD, AURANGABAD vs. ENDURANCE TECHNOLOGIES LIMITED, AURANGABAD

In the result, all the appeals filed by the Revenue are dismissed

1) in relation to approval of in-house R&D\nfacility in part A of form No.3CL and (ii) quantifying the expenditure incurred on\nin-house R & D facility by the company during the previous year and eligible for\nweighted deduction under sub-section 2AB of section 35 of the Act in part B of\nform No.3CL In other words

M/S. SHIVAMM INDUSTRIES,PUNE vs. THE DEPUTY COMMISSIONER OF INCOME TAX, CIRCLE-8, PUNE

In the result, appeal of the Assessee is Dismissed

Bench: Shri S.S.Godara & Dr. Dipak P. Ripoteआयकरअपीलसं. / Ita No.393/Pun/2023 िनधा"रणवष" / Assessment Year : 2013-14 M/S.Shivamm Industries, The Dy.Commissioner Of Plot 76, Arihant Heights, Sector Vs Income Tax, Circle-8, No.25, Pradhikaran Nigdi, Pune. Pune – 411044. Pan: Aaefs 0458 A Appellant/ Assessee Respondent /Revenue Assessee By None. Revenue By Shri M.G.Jasnani – Dr Date Of Hearing 15/05/2023 Date Of Pronouncement 26/05/2023 आदेश/ Order Per Dr. Dipak P. Ripote, Am: This Is An Appeal Filed By The Assessee I.E. Shivamm Industries For A.Y. 2013-14 Against The Order Of Ld.Commissioner Of Income Of Tax(Appeals)[Nfac] Dated 21.03.2023 Emanating From Assessing Officer’S Order Under Section 154 Of The Act Dated 22.03.2021. The Ground Of Appeal Are As Under : “1. The Order Dated 21/03/2023 Bearing No.Itba/Nfac/S/250/2022-23/1051048828[L] Passed Under Section 250 Of Income Tax Act, 1961 By The Hon’Ble Cit[Appeals], National Faceless Appeal Centre [Nfac], Delhi, Is Excessive, M/S.Shivamm Industries [A]

ii) and (iii) having details of due date for payment and the actual date of payment indicate about `disallowance of expenditure’ if the assessee does not make suo motu disallowance in computing total income. Right now, there is no case of `increase in income’ because the AO did not make adjustment for non-offering of income of the `Sums received

DEPUTY COMMISSIONER OF INCOME TAX, CIRCLE-1, AURANGABAD, AURANGABAD vs. ENDURANCE TECHNOLIGIES LIMITED, AURANGABAD

In the result, all the appeals filed by the Revenue are dismissed

1) in relation to approval of in-house R&D\nfacility in part A of form No.3CL and (ii) quantifying the expenditure incurred on\nin-house R & D facility by the company during the previous year and eligible for\nweighted deduction under sub-section 2AB of section 35 of the Act in part B of\nform No.3CL In other words

SHRINIWAS ENGINEERING AUTO COMPONENTS PVT. LTD,PUNE vs. ITO WARD6(1), PUNE

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

section 43(1) of the Act and therefore\nsection 2(24)(xviii) of the Act comes into operation and the\nsubsidy received by the assessee is to be treated as income\nliable to be taxed for the year under consideration.\ntherefore fail to find any infirmity in the order of ld.CIT(A) and\nthe common grounds of appeal No.2 raised