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

disallowance of weighted deduction claimed on expenditure incurred outside India.\n\n5. 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:\n\n“2.3 I have carefully considered the submission of the appellant

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 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

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

2) to section 35 of the Act provides that no deduction\nshall be allowed in respect of expenditure mentioned in clause (1) under any\nprovisions of the Act. Clause (3) further lays down that no company shall be\nentitled for deduction under clause (1) unless it enters into agreement with\nprescribed authority for co-operation in such R & D facility

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

2) to section 35 of the Act provides that no deduction\nshall be allowed in respect of expenditure mentioned in clause (1) under any\nprovisions of the Act. Clause (3) further lays down that no company shall be\nentitled for deduction under clause (1) unless it enters into agreement with\nprescribed authority for co-operation in such R & D facility

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

2) to section 35 of the Act provides that no deduction\nshall be allowed in respect of expenditure mentioned in clause (1) under any\nprovisions of the Act. Clause (3) further lays down that no company shall be\nentitled for deduction under clause (1) unless it enters into agreement with\nprescribed authority for co-operation in such R & D facility

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

2) to section 35 of the Act provides that no deduction\nshall be allowed in respect of expenditure mentioned in clause (1) under any\nprovisions of the Act. Clause (3) further lays down that no company shall be\nentitled for deduction under clause (1) unless it enters into agreement with\nprescribed authority for co-operation in such R & D facility

ASST COMMISSIONER OF INCOME TAX , PANVEL vs. EPYGEN BIOTECH PRIVATE LIMITED, NAVI MUMBAI

In the result, appeal of the Revenue is allowed

Bench: Dr. Manish Borad & Shri Vinay Bhamore

2) of the Act. We, therefore, are of the considered view that Ld.CIT(A) erred in allowing the assessee’s claim u/s. 35(1)(iv) of the Act without examining the fact that business activity as required for the purpose of claiming section 35(1)(iv) of the Act has not commenced during the year under consideration and therefore conditions

AHMEDNAGAR ZILLA GRAMSEVAKANCHI SAHAKAR PATSANSTHA MARYADIT,AHILYANAGAR vs. PCIT, PUNE-1, PUNE

In the result, the appeal of the assessee is allowed

35 of the Act. The Society is working as\nper provisions of co-operative societies Act 1960 & Bye laws prescribed by co-operative societies\nAct 1960, authenticated by District Deputy registrar Ahmednagar. The loan installments are\ndeducted from their salaries directly by the society.\nThe Honorable Supreme Court in civil appeal no 10245 of 2017 in the case

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

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

2), it is manifested that any expenditure of capital\nnature incurred on scientific research, other than the cost of land etc., qualifies for\nfull one time deduction in the year of such incurring. Unlike sub-section (2AB),\nsub-section (1) does not require any specific approval from the prescribed\nauthority for this purpose. Further, there is no stipulation that

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

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

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

AURANGABAD DIVISION LIFE INSURANCE EMPLOYEES CO-OP CREDIT SOCIETY LTD,AURANBAD vs. ITO, WARD-1(1), AURANGABAD, AURANGABAD

In the result, appeal of the assessee is allowed

Bench: Dr.Dipak P. Ripote & Shri Vinay Bhamoreआयकर अपऩल सं. / Ita No.3175/Pun/2025 निर्धारण वषा / Assessment Year: 2020-21 Aurangabad Divison Life V The Income Tax Officer, Insurance Employees Co-Op S Ward-1(1), Aurangabad. Credit Society Ltd., 11, Jeevan Prakash, Lic Office Building Adalat Road, Kranti Chowk, Aurangabad -431005 Pan: Aaaaa2245A Appellant/ Assessee Respondent /Revenue Assessee By Ca Payal Rathi (Virtual) Revenue By Shri Sadananda – Jcit Date Of Hearing 09/02/2026 Date Of Pronouncement 10/02/2026 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 24.09.2025 Emanating From The Assessment Order Passed Under Section 143(3) Read With Section 144B Of The Income Tax Act, 1961

section 80P(2)(a)(i) without appreciating the submission made by the assessee and the covered judgements of the Jurisdictional Hon'ble Pune ITAT. Hence, such disallowance of Rs. 35.43.169 may please be deleted and allowed to be deducted to the assessee society 2 On the facts and in the prevailing circumstances of the case and in Law, the learned

INCOME TAX OFFICER WARD 1 SATARA, SATARA vs. KARAD PATAN TALUKA PRATHMIK SHIKSHAK SAHAKARI SOCIETY LIMITEDTY , KARAD

In the result, Revenue’s Appeal is dismissed

Bench: Dr.Dipak P. Ripote & Shri Vinay Bhamoreआयकर अपऩल सं. / Ita No.2289/Pun/2025 निर्धारण वषा / Assessment Year: 2020-21 Income Tax Officer, V Karad Patan Taluka Prathmik Ward-1, Satara. S Shikshak Sahakari Society Limited, 190 B Shaniwar Peth, Opp.Shivneri Lodge, Karad, Satara – 415110 Pan: Aaaak0559R Appellant / Assessee Respondent / Revenue Assessee By Shri Satish U Nade Revenue By Smt Neha Thakur (Virtual) Date Of Hearing 21/01/2026 Date Of Pronouncement 23/01/2026 आदेश/ Order Per Dr. Dipak P. Ripote, Am: This Appeal Filed By The Revenue Against The Order Of Ld.Commissioner Of Income Tax(Appeal)[Nfac], Passed Under Section 250 Of The Income Tax Act, 1961 For A.Y.2020-21 Dated 21.08.2025 Emanating From The Assessment Order Passed Under Section 143(3) Read With Section 144B Of The I.T .Act, 1961 Dated

disallowed assessee’s claim for deduction u/s.80P(2) of the Act. The relevant paragraphs 4.5 to 6 of Assessment Order are reproduced here as under : 3 ITA No.2289/PUN/2025 [A] “4.5.) Further, it may be noted that the assessee for the year under consideration has claimed the deduction U's 80P of the Act to the extent of Rs. 2

INCOME TAX OFFICER WARD-2, AHMEDNAGAR, AHMEDNAGAR vs. KANIFNATH GRMAIN BIGAR SHETI SAHAKARI, MALDAD SANGAMNER

In the result, Revenue’s Appeal is dismissed

Bench: Dr.Dipak P. Ripote & Shri Vinay Bhamoreआयकर अपऩल सं. / Ita Nos.2270 & 2271/Pun/2025 निर्धारण वषा / Assessment Year: 2018-19 The Income Tax Officer, V Kanifnath Gramin Bigar Sheti Ward-2, Ahmednagar. S Sahakaripatsanstha Maryadit, At Post Malad, Taluka Sangamner, Ahmednagar – 422608. Pan: Aabak1395E Appellant/ Revenue Respondent /Assessee Assessee By Shri Pramod S Shingte – Ar Revenue By Smt Neha Thakkar (Virtual) Date Of Hearing 19/01/2026 Date Of Pronouncement 21/01/2026 आदेश/ Order Per Bench : 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 A.Y.2018- 19Dated 01.07.2025 Emanating From The Assessment Order Dated 30.03.2021 Under Section 143(3) R.W.S. 143(3A) & 143(3B) Of The Income Tax Act, 1961 & Order Under Section 250 Of The Income

35. But, as rightly contended by the learned senior counsel for the petitioners, the investment made by the petitioners in fixed deposits in nationalised banks, were of their own monies. If the petitioners had invested those amounts in fixed deposits in other co-operative societies or in the construction of godowns and warehouses, the respondents would have granted the benefit