DEPUTY COMMISSIONER OF INCOME-TAX, CIRCLE -3, NASHIK vs. WINDSOR MACHINES LTD., MUMBAI

In the result, the appeal of Revenue is partly allowed

Bench: Shri S.S. Viswanethra Ravi & Shri G.D. Padmahshali

disallowed. The CIT(A) considered various decisions and by relying the decision of Hon’ble High Court of Karnataka in the case of Compaq Electric Ltd. reported in (2011) 16 taxmann.com 385 (Kar.) held the principal amount of loan waived would neither be chargeable to tax u/s. section 41

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

41,01,660/-. The assessee itself has disallowed an amount of Rs.2,000/- u/s 14A. Since the assessee has huge investments and having borrowed funds, the Assessing Officer asked the assessee to explain as to why the provisions of section

NITIN DWARKADAS NYATI,PUNE vs. ASSISTANT COMMISSIONER OF INCOME TAX, PUNE

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

Bench: Shri R. K. Panda & Ms. Astha Chandraassessment Year : 2020-21

41,76,243/- after making addition of Rs.3,05,36,389/- on account of disallowance u/s 14A of the Act and Rs.50,79,854/- on account of education cess. 3. So far as the disallowance of Rs.3,05,36,389/- u/s 14A read with Rule 8D of the Income Tax Rules, 1962 is concerned, the Assessing Officer noted that

EATON TECHNOLOGIES PRIVATE LIMITED,PUNE vs. PRINCIPAL COMMISSIONER OF INCOME TAX, PUNE

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

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

41,77,133/- he made disallowance u/s.40(a)(i) at Rs.26,39,84,698/-. 3.1 Subsequently, the PCIT examined the record and noted that the AO has allowed deduction u/s.10AA of the Act at Rs.263,46,37,168/-. He noted that in the earlier years, i.e. for A.Y. 2013-14 to A.Y. 2016-17 such claim of deduction u/s.10AA

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

Disallowance under section 41(1) of the Act\n3.\nThe learned AO erred adding back an amount of Rs.6,66,765/- to the total

HARSHAD HIMMATLAL RUPANI,PUNE vs. ITO WARD 5(2), PUNE

In the result the ground number 3 is allowed for Statistical

Bench: Dr.Dipak P. Ripote & Shri Vinay Bhamoreआयकर अपऩल सं. / Ita No.920/Pun/2025 निर्धारण वषा / Assessment Year: 2014-15 Harshad Himmatlal Rupani, V The Income Tax Officer, 101/102, Ashoka Building, S Ward-5(1), Pune. Green Valley Housing Society, Wanwadi, Pune – 411040. Pan: Adopr6163Q Appellant/ Assessee Respondent / Revenue Assessee By Shri Mahavir Jain Revenue By Smt Neha Thakur – (Virtual) Date Of Hearing 21/01/2026 Date Of Pronouncement 28/01/2026 आदेश/ Order Per Dr. Dipak P. Ripote, Am: This Appeal Filed By The Assessee Is Against The Order Of Ld.Commissioner Of Income Tax(Appeal)[Nfac], Passed Under Section 250 Of The Income Tax Act, 1961 For A.Y.2014-15 Dated 26.08.2024 Emanating From The Assessment Order Passed Under Section 143(3) Of The Income Tax Act, 1961, Dated 22.11.2016. The Assessee Has Raised The Following Grounds Of Appeal :

section 143(3) of the Income Tax Act, 1961, dated 22.11.2016. The Assessee has raised the following grounds of appeal : ITA No.920/PUN/2025 [A] “1] The learned CIT(A) has erred in confirming the additions aggregating Rs.12,62,833/- in respect of amount of sundry creditors and differential gross receipts without appreciating the facts of the case 21 The learned

DCIT, CIRCLE 8 PUNE, PUNE vs. ALFA LAVAL INDIA PVT LTD, PUNE

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

section\n37(1), provided data is systematically maintained by assessee Held, yes\nWithout prejudice to above, if Your Honour considers to disallow the\ndeduction claimed amounting to Rs.5,34,41

DILIP JAWAHARLAL VARYANI,PUNE vs. DCIT CIRCLE-8, PUNE

In the result, appeal of the assessee is partly allowed

Bench: Dr.Dipak P. Ripote & Shri Vinay Bhamoreआयकरअपऩलसं. / Ita No.643/Pun/2025 निर्धारणवषा / Assessment Year:2011-12 Dilip Jawaharlal Varyani, V The Dy.Commissioner Of S.No.9/2B, Cts No.905, S Income Tax, Circle-8, Vaibhav Vihar, Near Vikram Pune. Vihar, Pimpri, Pune – 411017. Pan: Acapv0521H Appellant/ Assessee Respondent / Revenue Assessee By Shri Sarad Vaze, Ca – Ar Revenue By Shri Ramnath P Murkunde, Irs–Dr Date Of Hearing 12/08/2025 Date Of Pronouncement 28/10/2025 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], Delhi Passed Under Section 250 Of The Income Tax Act, 1961 Dated 19.06.2024 For The A.Y.2011-12 Emanating From The Assessment Order Under Section 143(3)Of The Income Tax Act, 1961, Dated 26.03.2014. The Assessee Has Raised The Following Grounds Of Appeal :

section 37 cannot be granted. 12. Taking note of all these circumstances, we find no ground to interfere into the matter as no substantial question of law as alleged arise for consideration.” 15. In these facts and circumstances of the case and in the interest of justice, we estimate the disallowance on account of labour expenditure to Rs.1

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.

Section 80AC does not apply to deductions u/s 80G of the Act and hence the Assessee can claim the deduction u/s 80G even if not claimed in the return of income. Therefore, respectfully following the order in the case of Sai Services Agency (Bombay) Pvt. Ltd., ITA 490/PUN/2021, we direct the AO to verify the claim of the Assessee

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.

Section 80AC does not apply to deductions u/s 80G of the Act and hence the Assessee can claim the deduction u/s 80G even if not claimed in the return of income. Therefore, respectfully following the order in the case of Sai Services Agency (Bombay) Pvt. Ltd., ITA 490/PUN/2021, we direct the AO to verify the claim of the Assessee

LIQUIDHUB ANALYTICS PVT. LTD. (NOW MERGED WITH CAPGEMINI TECHNOLOGY SERVICES INDIA LTD),PUNE vs. NFAC, PUNE

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

Bench: Shri R. K. Panda & Shri Vinay Bhamoreassessment Year : 2020-21

Section 4 of the Limitation Act, 1963. 11 The Ld DRP and the Ld. AO have grossly erred in considering the income u/s 143(1)(a) of the Act and consequently disallowing INR 41

RAVINDRA DNYANESHWAR BHUJBAL,PUNE vs. ITO, WARD 14(5), PUNE, PUNE

In the result, the appeal filed by the assessee stands dismissed

41,840/-. The return was processed u/s 143(1) of the IT\nAct by CPC on 29.11.2021 on an income of Rs.1,27,49,780/- after\nmaking disallowance of Rs.10,07,934/- u/s 36(1)(va) of the IT Act\nbeing disallowance on account of delayed payment towards\nemployees' contribution towards Provident Fund & ESIC on the\nbasis of details provided

SAI SERVICE PRIVATE LIMITED,PUNE vs. THE DEPUTY COMMISSIONER OF INCOME TAX, CIRCLE-10, PUNE

In the result, appeal of the assessee partly allowed

Bench: Shri S.S.Godara & Dr. Dipak P. Ripoteआयकर अपील सं. / Ita No.1076/Pun/2023 िनधा"रण वष" / Assessment Year : 2020-21 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: This Appeal Filed By Assessee Is Against The Order Of Ld.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 For Assessment Year 2020-21. The Grounds Of Appeal Raised By The Assessee For A.Y. 2020-21 Are As Under : “The Appellant Being Aggrieved By The Order & Decision Of The Commissioner Of Income Tax (Appeals), National Faceless Appeal Centre, Delhi, Vide Order Dated 04/09/2023 Bearing Din & Order No. Itba/Nfac/S/250/2023-24/1055706047(1) Is Filing This Appeal On The Following Grounds Of Appeal. 1. The Commissioner Of Income Tax (Appeals) Erred In Confirming The Additional Disallowance Of Rs.78,20,410/-

41. Having regard to the language of Section 14A(2) of the Act, read with Rule 8D of the Rules, we also make it clear that before applying the theory of apportionment, the AO needs to record satisfaction that having regard to the kind of the assessee, suo moto disallowance

BANK OF MAHARASHTRA ,PUNE vs. ASST COMMISSIONER OF INCOME TAX, CIRCLE 1(1), PUNE, PUNE

In the result, the appeal filed by the Revenue is partly allowed for statistical purposes and the appeal filed by the assessee is partly allowed for statistical purposes

Bench: Shri R. K. Panda & Shri Vinay Bhamoreassessment Year : 2016-17

section 251(1)(a) of the Act and send the matter back to the AO for verification on the issue of disallowance of write back provision for standard assets amounting to Rs.31,14,41

DY. COMMISSIONER OF INCOME TAX, CIRCLE-1(1), PUNE, PUNE vs. CTR MANUFACTURING INDUSTRIES PRIVATE LIMITED , PUNE

Bench: Shri S.S.Godara & Dr. Dipak P. Ripoteआयकरअपीलसं. / Ita No.998/Pun/2023 िनधा"रणवष" / Assessment Year : 2014-15 The Dy.Commissioner Ctr Manufacturing Of Income Tax, Circle- Vs Industries Private Limited, 1(1), Pune. Nagar Road, Vadgaon Sheri, S.O. Pune City, Pune – 411014. Pan: Aaacc7256R Appellant/ Revenue Respondent /Assessee

41,465/-, made to income as per revised computation submitted during assessment proceedings; Disallowance of Rs. 2,48,780 under section

DY. COMMISSIONER OF INCOME TAX, CIRCLE-1(1), PUNE, PUNE vs. BANK OF MAHARASHTRA, PUNE

In the result, the appeal filed by the Revenue is partly allowed for statistical purposes and the appeal filed by the assessee is partly allowed for statistical purposes

section 251(1)(a) of the Act and send the matter back to the AO for verification on the issue of disallowance of write back provision for standard assets amounting to Rs.31,14,41

DEPUTY COMMISSIONER OF INCOME TAX CENTRAL CIRCLE-2(2), PUNE vs. M/S. BILCARE LIMITED, PUNE

In the result, the appeal filed by the Revenue in ITA

Bench: Shri Inturi Rama Rao & Shri S. S. Viswanethra Raviआयकर अपीऱ सं. / Ita No.273/Pun/2021 निर्धारण वर्ा / Assessment Year: 2016-17 Dcit, Central Circle-2(2), Vs. M/S. Bilcare Limited, Pune. 601, Icc Trade Tower, Pune- 411016. Pan : Aabcb2242F Appellant Respondent आयकर अपीऱ सं. / Ita No.334/Pun/2021 निर्धारण वर्ा / Assessment Year: 2016-17 M/S. Bilcare Limited, Vs. Dcit, Central Circle- 6Th Floor, B Wing, Icc 2(2), Pune. Trade Tower, Senapati Bapat Road, Pune- 411006. Pan : Aabcb2242F Appellant Respondent

section 259 of the Companies Act of Singapore. The Hon‟ble High Court of Republic Singapore was pleased to grant the permission vide order dated 02.10.2015. Subsequently, the assessee company transferred the shares of 79,33,50,000 ordinary shares of BSPL held by the assessee company for total consideration of Singapore Dollar 1 to Bilcare Packaging Ltd., which

M/S. BILCARE LIMITED,PUNE vs. DEPUTY COMMISSIONER OF INCOME TAX CENTRAL CIRCLE-2(2), PUNE

In the result, the appeal filed by the Revenue in ITA

Bench: Shri Inturi Rama Rao & Shri S. S. Viswanethra Raviआयकर अपीऱ सं. / Ita No.273/Pun/2021 निर्धारण वर्ा / Assessment Year: 2016-17 Dcit, Central Circle-2(2), Vs. M/S. Bilcare Limited, Pune. 601, Icc Trade Tower, Pune- 411016. Pan : Aabcb2242F Appellant Respondent आयकर अपीऱ सं. / Ita No.334/Pun/2021 निर्धारण वर्ा / Assessment Year: 2016-17 M/S. Bilcare Limited, Vs. Dcit, Central Circle- 6Th Floor, B Wing, Icc 2(2), Pune. Trade Tower, Senapati Bapat Road, Pune- 411006. Pan : Aabcb2242F Appellant Respondent

section 259 of the Companies Act of Singapore. The Hon‟ble High Court of Republic Singapore was pleased to grant the permission vide order dated 02.10.2015. Subsequently, the assessee company transferred the shares of 79,33,50,000 ordinary shares of BSPL held by the assessee company for total consideration of Singapore Dollar 1 to Bilcare Packaging Ltd., which