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 filed by order 2016-17 Assessee 26.12.2018 143(3) 2017-18 Assessee 25.12.2018 143(3) 2018-19 Assessee 20.04.2021 143(3) r.w.s.144B 2018-19 Revenue 02.10.2019 143(1) 2019-20 Revenue 17.05.2020 143(1) 2019-20 Assessee 17.05.2020 143(1) 2020-21 Revenue 20.12.2021 143(1) 2020-21 Assessee 20.12.2021 143(1) 2. We will first espouse the appeals

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 filed by order 2016-17 Assessee 26.12.2018 143(3) 2017-18 Assessee 25.12.2018 143(3) 2018-19 Assessee 20.04.2021 143(3) r.w.s.144B 2018-19 Revenue 02.10.2019 143(1) 2019-20 Revenue 17.05.2020 143(1) 2019-20 Assessee 17.05.2020 143(1) 2020-21 Revenue 20.12.2021 143(1) 2020-21 Assessee 20.12.2021 143(1) 2. We will first espouse the appeals

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 filed by order 2016-17 Assessee 26.12.2018 143(3) 2017-18 Assessee 25.12.2018 143(3) 2018-19 Assessee 20.04.2021 143(3) r.w.s.144B 2018-19 Revenue 02.10.2019 143(1) 2019-20 Revenue 17.05.2020 143(1) 2019-20 Assessee 17.05.2020 143(1) 2020-21 Revenue 20.12.2021 143(1) 2020-21 Assessee 20.12.2021 143(1) 2. We will first espouse the appeals

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

1) of section 43 of the Act has\nalready been taken into account the amount of subsidy for\ndetermination of the actual cost of assets for computing the\ndepreciation in the computation of income filed along with\nreturn of income of income for the assessment year under\nconsideration. However, ld. AO was not satisfied with these\narguments and submissions

SHRINIWAS ENGINEERING AUTO COMPONENTS PVT. LTD,PUNE vs. ITO WARD 6(1), PUNE

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

1) of section 43 of the Act has\nalready been taken into account the amount of subsidy for\ndetermination of the actual cost of assets for computing the\ndepreciation in the computation of income filed along with\nreturn of income of income for the assessment year under\nconsideration. However, ld. AO was not satisfied with these\narguments and submissions

ACIT, PUNE vs. SHRINIWAS ENGINEERING AUTO COMPONENTS PRIVATE LIMITED, PUNE

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

1) of section 43 of the Act has\nalready been taken into account the amount of subsidy for\ndetermination of the actual cost of assets for computing the\ndepreciation in the computation of income filed along with\nreturn of income of income for the assessment year under\nconsideration. However, ld. AO was not satisfied with these\narguments and submissions

DEPUTY COMMISSIONER OF INCOME-TAX CIRCLE -5, PUNE vs. SERUM INSTITUTE OF INDIA PVT LTD.,, PUNE

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

disallowed the same. 34 On appeal before the ld. CIT(A), the ld. CIT(A) following the decision of the Tribunal for the assessment year 2008-09 onwards allowed said expenditure is revenue expenditure u/s 35(1)(iv) of the Act. Being aggrieved by the decision of the ld. CIT(A), the Revenue is in appeal before

REXEL INDIA PRIVATE LIMITED,PUNE vs. DEPUTY COMMISSIONER OF INCOME TAX, PUNE

In the result, appeal of the assessee is partly allowed for statistical\npurposes

1) and Explanation-2 of Section 43(6) of the IT Act 1961\nestablishes that the depreciation on goodwill as a result of amalgamation is\nnot allowable.\nResultantly, the claims made by the appellant in support of this ground do\nnot have any merit. Therefore, the addition made by assessing officer on\naccount of disallowance

JOHN DEERE EQIPMENT P. LTD.,,PUNE vs. DEPUTY DIRECTOR OF INCOME-TAX,,

In the result, all the appeals of assessee are allowed

Bench: Ms. Sushma Chowla, Jm & Shri Anil Chaturvedi, Am आयकर अपीऱ सं. / Ita Nos.905 & 906/Pun/2015 यििाारण वषा / Assessment Years :2007-08 & 2008-09

43. Coming to the last issue of royalty on software, he pointed out that there was decision by the Hon’ble High Court of Delhi and there is decision by the Hon’ble High Court of Karnataka and both have different views. The learned Departmental Representative for the Revenue placed reliance on the decision of Hon’ble High Court

JOHN DEERE EQIPMENT P. LTD.,,PUNE vs. DEPUTY DIRECTOR OF INCOME-TAX,,

In the result, all the appeals of assessee are allowed

Bench: Ms. Sushma Chowla, Jm & Shri Anil Chaturvedi, Am आयकर अपीऱ सं. / Ita Nos.905 & 906/Pun/2015 यििाारण वषा / Assessment Years :2007-08 & 2008-09

43. Coming to the last issue of royalty on software, he pointed out that there was decision by the Hon’ble High Court of Delhi and there is decision by the Hon’ble High Court of Karnataka and both have different views. The learned Departmental Representative for the Revenue placed reliance on the decision of Hon’ble High Court

JOHN DEERE INDIA PVT. LTD.,,PUNE vs. DEPUTY DIRECTOR OF INCOME-TAX,,

In the result, all the appeals of assessee are allowed

Bench: Ms. Sushma Chowla, Jm & Shri Anil Chaturvedi, Am आयकर अपीऱ सं. / Ita Nos.905 & 906/Pun/2015 यििाारण वषा / Assessment Years :2007-08 & 2008-09

43. Coming to the last issue of royalty on software, he pointed out that there was decision by the Hon’ble High Court of Delhi and there is decision by the Hon’ble High Court of Karnataka and both have different views. The learned Departmental Representative for the Revenue placed reliance on the decision of Hon’ble High Court

JOHN DEERE INDIA PVT. LTD.,,PUNE vs. DEPUTY DIRECTOR OF INCOME-TAX,,

In the result, all the appeals of assessee are allowed

Bench: Ms. Sushma Chowla, Jm & Shri Anil Chaturvedi, Am आयकर अपीऱ सं. / Ita Nos.905 & 906/Pun/2015 यििाारण वषा / Assessment Years :2007-08 & 2008-09

43. Coming to the last issue of royalty on software, he pointed out that there was decision by the Hon’ble High Court of Delhi and there is decision by the Hon’ble High Court of Karnataka and both have different views. The learned Departmental Representative for the Revenue placed reliance on the decision of Hon’ble High Court

ASSISTANT COMMISSIONER OF INCOME-TAX vs. SINHAGAD TECHNICAL EDUCATION SOCIETY,, PUNE

Accordingly, additional ground No.3 by the assessee is allowed

Bench: Ms. Sushma Chowla, Jm & Shri Anil Chaturvedi, Am आयकर अपील सं. / Ita Nos. 2075 To 2077 & 2110/Pun/2014 "नधा"रण वष" / Assessment Years: 2007-08 To 2009-10 Sinhgad Technical Education Society, S. No. 44/1, Vadgaon ( Budruk), Off. Sinhagad Road, Pune-411 041. Pan : Aabts9900Q. …....अपीलाथ" / Appellant बनाम / V/S.

disallowance made u/s.40A(2)(b) on account of payment on rent in excess made to M.N. Navale (Bigger HUF), a related party. 2. On facts and in the circumstances of the case, the Ld. CIT(A) has erred in holding that the provision of section 13(1)(c) r.w.s.13(3) of the Income Tax Act, 1961 are not attracted

SINHGAD TECHNICAL EDUCATION SOCIETY,,PUNE vs. DEPUTY COMMISSIONER OF INCOME-TAX,,

Accordingly, additional ground No.3 by the assessee is allowed

Bench: Ms. Sushma Chowla, Jm & Shri Anil Chaturvedi, Am आयकर अपील सं. / Ita Nos. 2075 To 2077 & 2110/Pun/2014 "नधा"रण वष" / Assessment Years: 2007-08 To 2009-10 Sinhgad Technical Education Society, S. No. 44/1, Vadgaon ( Budruk), Off. Sinhagad Road, Pune-411 041. Pan : Aabts9900Q. …....अपीलाथ" / Appellant बनाम / V/S.

disallowance made u/s.40A(2)(b) on account of payment on rent in excess made to M.N. Navale (Bigger HUF), a related party. 2. On facts and in the circumstances of the case, the Ld. CIT(A) has erred in holding that the provision of section 13(1)(c) r.w.s.13(3) of the Income Tax Act, 1961 are not attracted

SINHGAD TECHNICAL EDUCATION SOCIETY,,PUNE vs. DEPUTY COMMISSIONER OF INCOME-TAX,,

Accordingly, additional ground No.3 by the assessee is allowed

Bench: Ms. Sushma Chowla, Jm & Shri Anil Chaturvedi, Am आयकर अपील सं. / Ita Nos. 2075 To 2077 & 2110/Pun/2014 "नधा"रण वष" / Assessment Years: 2007-08 To 2009-10 Sinhgad Technical Education Society, S. No. 44/1, Vadgaon ( Budruk), Off. Sinhagad Road, Pune-411 041. Pan : Aabts9900Q. …....अपीलाथ" / Appellant बनाम / V/S.

disallowance made u/s.40A(2)(b) on account of payment on rent in excess made to M.N. Navale (Bigger HUF), a related party. 2. On facts and in the circumstances of the case, the Ld. CIT(A) has erred in holding that the provision of section 13(1)(c) r.w.s.13(3) of the Income Tax Act, 1961 are not attracted

ASSISTANT COMMISSIONER OF INCOME-TAX vs. SINHAGAD TECHNICAL EDUCATION SOCIETY,, PUNE

Accordingly, additional ground No.3 by the assessee is allowed

Bench: Ms. Sushma Chowla, Jm & Shri Anil Chaturvedi, Am आयकर अपील सं. / Ita Nos. 2075 To 2077 & 2110/Pun/2014 "नधा"रण वष" / Assessment Years: 2007-08 To 2009-10 Sinhgad Technical Education Society, S. No. 44/1, Vadgaon ( Budruk), Off. Sinhagad Road, Pune-411 041. Pan : Aabts9900Q. …....अपीलाथ" / Appellant बनाम / V/S.

disallowance made u/s.40A(2)(b) on account of payment on rent in excess made to M.N. Navale (Bigger HUF), a related party. 2. On facts and in the circumstances of the case, the Ld. CIT(A) has erred in holding that the provision of section 13(1)(c) r.w.s.13(3) of the Income Tax Act, 1961 are not attracted

SINHGAD TECHNICAL EDUCATION SOCIETY,,PUNE vs. DEPUTY COMMISSIONER OF INCOME-TAX,,

Accordingly, additional ground No.3 by the assessee is allowed

Bench: Ms. Sushma Chowla, Jm & Shri Anil Chaturvedi, Am आयकर अपील सं. / Ita Nos. 2075 To 2077 & 2110/Pun/2014 "नधा"रण वष" / Assessment Years: 2007-08 To 2009-10 Sinhgad Technical Education Society, S. No. 44/1, Vadgaon ( Budruk), Off. Sinhagad Road, Pune-411 041. Pan : Aabts9900Q. …....अपीलाथ" / Appellant बनाम / V/S.

disallowance made u/s.40A(2)(b) on account of payment on rent in excess made to M.N. Navale (Bigger HUF), a related party. 2. On facts and in the circumstances of the case, the Ld. CIT(A) has erred in holding that the provision of section 13(1)(c) r.w.s.13(3) of the Income Tax Act, 1961 are not attracted

SINHGAD TECHNICAL EDUCATION SOCIETY,,PUNE vs. ASSISTANT COMMISSIONER OF INCOME-TAX,,

Accordingly, additional ground No.3 by the assessee is allowed

Bench: Ms. Sushma Chowla, Jm & Shri Anil Chaturvedi, Am आयकर अपील सं. / Ita Nos. 2075 To 2077 & 2110/Pun/2014 "नधा"रण वष" / Assessment Years: 2007-08 To 2009-10 Sinhgad Technical Education Society, S. No. 44/1, Vadgaon ( Budruk), Off. Sinhagad Road, Pune-411 041. Pan : Aabts9900Q. …....अपीलाथ" / Appellant बनाम / V/S.

disallowance made u/s.40A(2)(b) on account of payment on rent in excess made to M.N. Navale (Bigger HUF), a related party. 2. On facts and in the circumstances of the case, the Ld. CIT(A) has erred in holding that the provision of section 13(1)(c) r.w.s.13(3) of the Income Tax Act, 1961 are not attracted