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

disallowances of Rs.62,169/- and Rs.60,93,292/- made by the Assessing Officer on account of late payment of ESIC and PF beyond the period prescribed under the ESIC and PF Acts respectively. 2. The Ld. CIT(Appeals) has erred in dismissing the Ground No. 3 of the assessee in respect of the addition of Rs.43,20,39,280/- made

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

disallowances of Rs.62,169/- and Rs.60,93,292/- made by the Assessing Officer on account of late payment of ESIC and PF beyond the period prescribed under the ESIC and PF Acts respectively. 2. The Ld. CIT(Appeals) has erred in dismissing the Ground No. 3 of the assessee in respect of the addition of Rs.43,20,39,280/- made

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

disallowances of Rs.62,169/- and Rs.60,93,292/- made by the Assessing Officer on account of late payment of ESIC and PF beyond the period prescribed under the ESIC and PF Acts respectively. 2. The Ld. CIT(Appeals) has erred in dismissing the Ground No. 3 of the assessee in respect of the addition of Rs.43,20,39,280/- made

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

disallowances of Rs.62,169/- and Rs.60,93,292/- made by the Assessing Officer on account of late payment of ESIC and PF beyond the period prescribed under the ESIC and PF Acts respectively. 2. The Ld. CIT(Appeals) has erred in dismissing the Ground No. 3 of the assessee in respect of the addition of Rs.43,20,39,280/- made

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

disallowances of Rs.62,169/- and Rs.60,93,292/- made by the Assessing Officer on account of late payment of ESIC and PF beyond the period prescribed under the ESIC and PF Acts respectively. 2. The Ld. CIT(Appeals) has erred in dismissing the Ground No. 3 of the assessee in respect of the addition of Rs.43,20,39,280/- made

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

45,99,312/-.\nReturn processed u/s.143(1)(a) of the Act. Subsequently, case\nselected for Compulsory Manual Scrutiny followed by validly\nserving notices u/s.143(2) and 142(1) of the Act. So far as\nthe issue raised in the instant appeal is concerned, we note that\nld. AO had examined the issue of subsidy received by the\nassessee from

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

45,99,312/-.\nReturn processed u/s.143(1)(a) of the Act. Subsequently, case\nselected for Compulsory Manual Scrutiny followed by validly\nserving notices u/s.143(2) and 142(1) of the Act. So far as the\nissue raised in the instant appeal is concerned, we note that\nld. AO had examined the issue of subsidy received by the\nassessee from

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

45,99,312/-.\nReturn processed u/s.143(1)(a) of the Act. Subsequently, case\nselected for Compulsory Manual Scrutiny followed by validly\nserving notices u/s.143(2) and 142(1) of the Act. So far as the\nissue raised in the instant appeal is concerned, we note that\nld. AO had examined the issue of subsidy received by the\nassessee from

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

2 pertains to the newly inserted proviso to sub section 18 of section 155. The appellant states that even after timely filing of Form 69 the penalty has been levied. The proviso to Section 155(18) states that the benefit will be given to the assessee in a case where the assessee makes an application in the prescribed form, within

ASST. COMMISSIONER OF INCOME TAX, PANVEL CIRCLE PANVEL vs. OUTABOX MEDIA SOLUTIONS LLP, GHATKOPAR MUMBAI

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

Bench: Shri R. K. Panda & Ms Astha Chandraassessment Year : 2017-18

Section 142 (1). 2. In the present case, the facts did not warrant the order made by the High Court. At the same time, this Court notices that the High Court had granted liberty to the concerned authority to issue appropriate notice. 3. It is clarified, therefore, that the assessing officer is free to complete the assessment (in case

ITO, PUNE vs. THE GOVERNMENT SERVENTS MAHARASHTRA CO-OP CREDIT SOCIETY LIMITED PUNE, PUNE

In the result, both the appeals filed by the Revenue are\ndismissed

disallowed the entire claim of 80P deduction to the\nappellant.\n6.3 After giving finding in Para 45 for ascertaining the status of\nan entity as a co-operative society, in para 46 and 47, Hon'ble\nApex Court in Mavilayi judgment had distinguished the Kerala\nco-operative society Act vis-à-vis the Multipurpose co-operative\nsociety Act in Citizens

VIJAY SAHAKARI PAT SANSTHA LIMITED,ICHALKARANJI vs. ITO WARD-2, ICHALKARANJI, ICHALKARANJI

In the result, the appeal of the assessee is allowed

Bench: Shri Manish Borad & Ms. Astha Chandra

disallow the appellant's claim for a deduction of Rs. 8,81,745/- under Section 80P(2)(a)(i) of the Income Tax Act is in accordance with the provisions of the Act. Therefore, the appeal of the appellant is hereby dismissed.” 5. Dissatisfied, the assessee is in appeal before the Tribunal and all the grounds of appeal relate thereto

KOTHARI AGRITECH PVT. LTD,,SOLAPUR vs. THE DCIT, CIRCLE-1, SOLAPUR

In the result, the both appeals of the assessee in ITA Nos

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

45,612/- interalia disallowing the claim of deduction under section 80IA of the Act for the reason that Form 10CCB was not filed within the due date. The assessee being aggrieved by the said intimation order, filed an application for rectification u/s 154 of the Act before the Ld. Jurisdictional Assessing Officer (“JAO”). Subsequently, the case of the assessee

KOTHARI AGRITECH PRIVATE LIMITED,SOLAPUR vs. DCIT CIRCLE-1, SOLAPUR

In the result, the both appeals of the assessee in ITA Nos

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

45,612/- interalia disallowing the claim of deduction under section 80IA of the Act for the reason that Form 10CCB was not filed within the due date. The assessee being aggrieved by the said intimation order, filed an application for rectification u/s 154 of the Act before the Ld. Jurisdictional Assessing Officer (“JAO”). Subsequently, the case of the assessee

NASHIK DISTRICT PRIMARY TEACHERS CO-OP CREDIT SOCIETY LTD,NASHIK vs. ITO WARD 1(1), NASHIK

In the result, the appeal of the assessee in ITA No

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

45). d) It was also held that the loans given to nominal members would also qualify for the purpose of deduction u/s 80(P)(2)(a)(i) 6.5 This decision shows that deduction can be allowed on the profits attributable to the cooperative societies which are transacted with its members such as regular, associate and nominal members only, which

THE SANGLI SALARY EARNERS CO OP SOCIETY LTD,SANGLI vs. INCOME TAX OFFICER WARD 3 SANGLI, SANGLI

In the result, appeal of the assessee is allowed

Bench: Dr.Dipak P. Ripote & Shri Vinay Bhamoreआयकर अपऩल सं. / Ita No.2254/Pun/2025 निर्धारण वषा / Assessment Year: 2020-21 The Sangli Salary Earners Co V The Income Tax Officer, Op Society Ltd., S. Ward-3, Sangli. 1104 B, Harbhat Road, Main City, Sangli – 416416 Pan: Aaaat0980D Appellant/ Assessee Respondent / Revenue Assessee By Shri Amit Sudhir Shintre(Virtual) Revenue By Smt. Saumya Pandey Jain-Addl.Cit Date Of Hearing 17/11/2025 Date Of Pronouncement 17/11/2025 आदेश/ Order Per Dr. Dipak P. Ripote, Am: This Appeal Is Filed By The Assessee Against The Order Of Ld.Commissioner Of Income Tax(Appeals)[Nfac], Passed Under Section 250 Of The Income Tax Act, 1961 For A.Y.2020-21, Dated 27.08.2025 Emanating From Assessment Order U/S.143(3) Read With Section 143(3) R.W.S 144B Of The Income Tax Act, 1961 Dated 26.09.2022. The Assessee Has Raised Following Grounds Of Appeal : “1. Deduction U/S 80P(2)(A)(I) Relying On The Decision Of Totgars Co-

45,086/- earned from Sangli District Co-operative Bank Ltd. and 39,158/- earned from Primary Teachers Co-operative Bank, which are themselves registered co- operative societies. The authorities below have wrongly invoked Section 80P(4) The Appellant is not a co-operative bank within the meaning of Part V of the Banking Regulation Act, 1949, but a co-operative

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

45,58,297/-. Resultantly, no weighted deduction is admissible in respect of expenditure incurred outside India amounting to Rs.9,61,80,237/-. 16. At this juncture, it is pertinent to note the mandate of section 35 with the caption `Expenditure on scientific research’. Clause (iv) of section 35(1) provides for deduction of expenditure on scientific nature “in respect

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

45,58,297/-. Resultantly, no weighted deduction is admissible in respect of expenditure incurred outside India amounting to Rs.9,61,80,237/-. 16. At this juncture, it is pertinent to note the mandate of section 35 with the caption `Expenditure on scientific research’. Clause (iv) of section 35(1) provides for deduction of expenditure on scientific nature “in respect