CAPGEMINI TECHNOLOGY SERVICES INDIA LIMITED ( SUCCESSOR OF ARICENT TECHNOLOGIES HOLDINGS LIMITED),PUNE vs. ASSISTANT COMMISSIONER OF INCOME TAX, CIRCLE 1(1), PUNE, PUNE

In the result, the appeal of the assessee is allowed

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

4 ITA No.1260/PUN/2025, AY 2020-21 notwithstanding any contained in subsection (6) of section 270A. In view of this specific carve out, the claim of the appellant is not acceptable and the ground is dismissed.‖ 5. The Ld. AR submitted that the assessee has already accepted the disallowance made by the Ld. AO on account of claim on health

SHRI MANOJ MADANLAL CHHAJED,PUNE vs. ASSISTANT COMMISSIONER OF INCOME TAX, CIRCLE -1(1)PUNE, PUNE

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

Bench: Shri Inturi Rama Rao & Shri S. S. Viswanethra Raviआयकर अपील सं. / It(Ss)A Nos.91 To 96/Pun/2022 िनधा"रण वष" / Assessment Years : 2012-13 To 2017-18 Shri Manoj Madanlal Vs. Acit, Central Circle- Chhajed, 1(1), Pune. 601, A-8 Building, Karishma Housing Society, Near Sangam Press, Kothrud, Pune- 411029. Pan : Aalpc4991M Appellant Respondent आयकर अपील सं. / It(Ss)A Nos.97 & 98/Pun/2022 िनधा"रण वष" / Assessment Years : 2012-13 & 2015-16 Acit, Circle-1(1), Pune. Vs. Shri Manoj Madanlal Chhajed, 601, A-8 Building, Karishma Housing Society, Near Sangam Press, Kothrud, Pune- 411029. Pan : Aalpc4991M Appellant Respondent आयकर अपील सं. / Ita No.725/Pun/2022 िनधा"रण वष" / Assessment Year: 2018-19 Shri Manoj Madanlal Vs. Acit, Circle-1(1), Pune. Chhajed, 601, A-8 Building, Karishma Housing Society, Near Sangam Press, Kothrud, Pune- 411029. Pan : Aalpc4991M Appellant Respondent

disallowances, the assessee had filed an appeal before the ld. CIT(A) contenting inter alia that the Assessing Officer ought not to have treated the unsecured loans of Rs.13,27,54,925/- as bogus loans, are merely accommodation entries since the interest was paid on such loans after deducting the TDS and the loans were accepted through the mode

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

41,897/- u/s 115JB including therein disallowance of Rs.33,20,874/- u/s 14A of the Act. 4. Aggrieved, the assessee carried the matter in appeal before the Ld. CIT(A). He deleted the disallowance made by the Ld. AO u/s 14A while computing the book profit for the purpose of section

JAYANTI S KUNDHADIYA, ASSISTANT COMMISSIONER OF INCOME TAX , CENTRAL CIRCLE-2(1), PUNE, PUNE vs. PATIL CONSTRUCTION AND INFRASTRUCTURE LIMITED, MUMBAI

In the result, all the three appeals filed by the Revenue are allowed for statistical purposes

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

disallowed the deduction claimed u/s 80IA(4) of the Act for all the three years mainly on two grounds i.e. (a) the projects undertaken by the assessee do not fall under the category of “new infrastructure facility” as envisaged in section 80IA(4) and (b) the assessee in respect of the impugned projects acted as contractor and not as developer

JAYANTI S KUNDHADIYA, ASSISTANT COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-2(1), PUNE, PUNE vs. PATIL CONSTRUCTION AND INFRASTRUCTURE LIMITED, MUMBAI

In the result, all the three appeals filed by the Revenue are allowed for statistical purposes

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

disallowed the deduction claimed u/s 80IA(4) of the Act for all the three years mainly on two grounds i.e. (a) the projects undertaken by the assessee do not fall under the category of “new infrastructure facility” as envisaged in section 80IA(4) and (b) the assessee in respect of the impugned projects acted as contractor and not as developer

ASSISTANT COMMISSIONER OF INCOME TAX CENTRAL CIRCLE 2(1), PUNE, PUNE vs. PATIL CONSTRUCTION AND INFRASTRUCTURE LIMITED, MUMBAI

In the result, all the three appeals filed by the Revenue are allowed for statistical purposes

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

disallowed the deduction claimed u/s 80IA(4) of the Act for all the three years mainly on two grounds i.e. (a) the projects undertaken by the assessee do not fall under the category of “new infrastructure facility” as envisaged in section 80IA(4) and (b) the assessee in respect of the impugned projects acted as contractor and not as developer

DESAI INFRA PROJECTS (I) PRIVATE LIMITED,PUNE vs. CIT(A), PUNE-11, PUNE

In the result, the appeal of the assessee stands

Bench: Shri Rama Kanta Panda & Ms. Astha Chandra

41,73,900/-, after claiming deduction of 2 ITA.No.1852/PUN./2024 Rs.3,42,22,700/- u/s.80IA(4)(i) of the Act. The CPC processed the return and passed an intimation u/s.143(1) determining the total income at Rs.9,83,96,600/-, by reducing the claim of deduction u/sec.80IA(4). 2.1. Before the learned CIT(A), it was argued that

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 14A read with Rule 8D should not be disallowed. The assessee explained that it has earned only Rs.2

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

4. In the light of the above, we note that now it is a settled position of law that the unabsorbed depreciation pertaining to A.Ys. 1997-98 to 2000- 01 could be carried forward and set off against the profits and gains of subsequent years without having 8 years of limit. Further, we note that the CIT(A) directed

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

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 :

41(1) of the outstanding creditors. Ld.DR relied on the order of CIT(A). Findings and Analysis : 4. We have heard both the parties and perused the records. ITA No.920/PUN/2025 [A] 4.1) In this case Assessee is having Proprietary Concern called M/s.H.H.Rupani and it is into business of Civil Contractor. In the Assessment Order the Assessing Officer(AO) made addition

M/S GIRIRAJ ENTERPRISES,PUNE vs. DCIT, CENTRAL CIRCLE 1(1), PUNE, PUNE

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

Bench: Shri R. K. Panda & Ms Astha Chandraassessment Year : 2015-16

4. All the payments towards sale consideration are received through account payee cheques and duly reflected in the bank account of the assessee and copies of corresponding bank statements are being filed and placed on record. 1. STT was duly charged by the fund which is reflected in the statement received and copies of the same are being submitted

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 :

4 raised by the Assessee are regarding the said disallowance of Rs.,1,41,38,625/-. During the hearing before this Tribunal, ld.AR has not made any specific submission, but stated that in the business of Civil Contractor 8% profit is an acceptable profit. Ld.AR submitted that after the disallowance of Rs.1,41,38,625/-, the net profit comes

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

KUMAR URBAN DEVELOPMENT PVT. LTD (SUCCESSOR KUMAR HOUSING CORPORATION PVT LTD),PUNE vs. DCIT CIRCLE 14, PUNE

disallowance u/s 36(1)(iii) and the\ndisallowance of depreciation of Rs.10,74,599/-. However, since the assessee is not\nin appeal before us on these two issues, we are not concerned with the same.\n9.\nSo far as the addition of trade advances from customers of Rs.26,90,56,640/-\nis concerned, the Ld. CIT(A) / NFAC gave part

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

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

section 40(a)(ia). He\nfurther submitted that from the books of account of the asssessee it was established\nthat these were actual expenses incurred during AY 2017-18 and not the\n\"provisions for expenses” on which TDS was not deducted. He submitted that the\nassessee failed to furnish any documentary evidence that TDS was deducted during\nthe assessment

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

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.

4. The Assessing Officer(AO) also noticed that assessee company had received dividend of Rs.2,86,27,085/- from subsidiary company and dividend from mutual funds on investment of Rs.123.78 crore and thus claimed exemption u/s.10 of the Act. In response to notice u/s.142(1) assessee furnished details of opening and closing balance of investments for year under consideration. Eventually