M/S. CLASSIC CITI INVESTMENTS PRIVATE LIMITED,PUNE vs. THE INCOME TAX OFFICER, WARD-1(2), PUNE

In the result, the appeal for the A

Bench: Shri R.S. Syal & Shri Partha Sarathi Chaudhury

section 56(2)(viia) of the Act. 12. Ground No.4 of the assessee’s appeal is against the confirmation of disallowance

M/S. CLASSIC CITI INVESTMENTS PRIVATE LIMITED,PUNE vs. THE INCOME TAX OFFICER, WARD-1(2), PUNE

In the result, the appeal for the A

Bench: Shri R.S. Syal & Shri Partha Sarathi Chaudhury

section 56(2)(viia) of the Act. 12. Ground No.4 of the assessee’s appeal is against the confirmation of disallowance

WOCKHARDT LIMITED,,AURANGABAD vs. ASSISTAMT COMMISSIONER OF INCOME TAX, CIRCLE -3,, AURANGABAD

In the result, the appeal filed by Revenue is partly allowed, the appeal filed by assessee is partly allowed and the CO filed by assessee is dismissed as withdrawn

Bench: Shri Inturi Rama Rao & Shri S.S. Viswanethra Raviआयकर अपीऱ सं. / Ita No.775/Pun/2019 निर्धारण वषा / Assessment Year : 2013-14 Acit, Circle-3, Aurangabad .......अऩीऱाथी / Appellant बिधम / V/S. Wockhardt Ltd., R&D Centre, D-4, Midc, Chikalthana, Aurangabad. Pan: Aaacw2472M ……प्रत्यथी / Respondent आयकर अपीऱ सं. / Ita No.758/Pun/2019 निर्धारण वषा / Assessment Year : 2013-14 Wockhardt Ltd., R&D Centre, D-4, Midc, Chikalthana, Aurangabad. Pan: Aaacw2472M .......अऩीऱाथी / Appellant बिधम / V/S. Acit, Circle-3, Aurangabad ……प्रत्यथी / Respondent Co No.43/Pun/2019 निर्धारण वषा / Assessment Year : 2013-14 Wockhardt Ltd., R&D Centre, D-4, Midc, Chikalthana, Aurangabad. Pan: Aaacw2472M .......Cross Objector बिधम / V/S. Acit, Circle-3, Aurangabad ……प्रत्यथी / Respondent Co No.43/Pun/2019

section 35(2AB) of Rs.65,55,77,068/-, disallowance of Freebies to Doctors of Rs.1,19,82,100/-, disallowance u/s CO No.43/PUN/2019 14A of Rs.78,87,413/- and disallowance of Provision for BDDR of Rs.1,56

DEPUTY COMMISSIONER OF INCOME-TAX, CIR 1(1),, PUNE vs. M/S. CITY CORPORATION LTD.,(EARLIER KNOWN AS M/S AMANORA FUTURE TOWERS P LTD), PUNE

In the result, both the appeals are partly allowed

Bench: Shri R.S. Syal & Shri S.S. Viswanethra Raviआयकर अपील सं. / Ita No.619/Pun/2020 िनधा"रण वष" / Assessment Year : 2015-16 Vs. M/S. City Corporation Limited, Dcit, Circle-1(1), (Earlier Known As M/S. Amanora Pune Future Towers Pvt. Ltd.,), 917/9A, City Chambers, F.C. Road, Shivajinagar, Pune-411004 Pan : Aakca3074H Appellant Respondent आयकर अपील सं. / Ita No.45/Pun/2021 िनधा"रण वष" / Assessment Year : 2015-16

disallowance of Rs.9,18,700/- u/s.43CA of the Income-tax Act, 1961 (hereinafter also called `the Act’). 11. The facts concerning this issue are that the AO required the assessee to furnish a list of flat sales booked during the year under consideration along with the details of parties where the sale consideration was less than the stamp value

AMANORA FUTURE PVT. LTD,PUNE vs. DEPUTY COMMISSIONER OF INCOME-TAX, CIRCLE 1(1), PUNE

In the result, both the appeals are partly allowed

Bench: Shri R.S. Syal & Shri S.S. Viswanethra Raviआयकर अपील सं. / Ita No.619/Pun/2020 िनधा"रण वष" / Assessment Year : 2015-16 Vs. M/S. City Corporation Limited, Dcit, Circle-1(1), (Earlier Known As M/S. Amanora Pune Future Towers Pvt. Ltd.,), 917/9A, City Chambers, F.C. Road, Shivajinagar, Pune-411004 Pan : Aakca3074H Appellant Respondent आयकर अपील सं. / Ita No.45/Pun/2021 िनधा"रण वष" / Assessment Year : 2015-16

disallowance of Rs.9,18,700/- u/s.43CA of the Income-tax Act, 1961 (hereinafter also called `the Act’). 11. The facts concerning this issue are that the AO required the assessee to furnish a list of flat sales booked during the year under consideration along with the details of parties where the sale consideration was less than the stamp value

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

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

section 37 while computing income tax on Business\nIncome. Since these expenses were disallowed in earlier years it could not be held\nliable for tax in the year under consideration when they are reversed and credited\nto Profit & Loss Account. Accordingly, the assessee took the deduction of\nRs.2,02,56

R&DE (ENGRS) EMPLOYEES CO-OP. CREDIT SOCIETY,PUNE vs. ITO, WARD 7(3), PUNE, PUNE

In the result, the appeal of the assessee is allowed

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

56 of the Act and was not 100% deductible from the Gross Total Income under section 80P(2)(a)(i) of the Act, is not applicable to the present Assessment Years 2007-2008 to 2011-2012 involved in the present appeals and therefore, whether the Income-tax Appellate Tribunal as well as CIT (Appeals) were justified in holding that such

GORIBI ABDUL KARIM NADAF,PUNE vs. COMMISSIONER OF INCOME TAX (APPEALS), ADDL JCIT (A) 1 - AHMEDABAD, COMMISSIONER OF INCOME TAX (APPEALS), ADDL/JCIT (A) AHMEDABAD

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

Bench: Shri Inturi Rama Rao & Shri Vinay Bhamore

56, Addl. JCIT(A) 1, Survey No. 40, Subhash Ahmedabad Nagar, Vishrantwadi, Dhanori B.O.-411015 PAN : AEDPN4485P Appellant Respondent Assessee by : None Revenue by : Shri Manoj Tripathi Date of hearing : 29.04.2024 Date of pronouncement : 30.04.2024 आदेश / ORDER PER INTURI RAMA RAO, AM: These are the appeals filed by the assessee directed against the common order of ld. Commissioner of Income

GORIBI ABDUL KARIM NADAF,PUNE vs. COMMISSIONER INCOME TAX (APPEALS), ADDL JCIT (A) -1 AHMEDABAD, AHMEDABAD

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

Bench: Shri Inturi Rama Rao & Shri Vinay Bhamore

56, Addl. JCIT(A) 1, Survey No. 40, Subhash Ahmedabad Nagar, Vishrantwadi, Dhanori B.O.-411015 PAN : AEDPN4485P Appellant Respondent Assessee by : None Revenue by : Shri Manoj Tripathi Date of hearing : 29.04.2024 Date of pronouncement : 30.04.2024 आदेश / ORDER PER INTURI RAMA RAO, AM: These are the appeals filed by the assessee directed against the common order of ld. Commissioner of Income

POONAWALLA SHARES & SECURITIES PVT.LTD,PUNE vs. ASSISTANT COMMISSIONER OF WEALTH-TAX, CIRCLE-4, PUNE

Appeal is partly allowed in above terms

Bench: Shri S.S.Godara & Dr. Dipak P. Ripoteआयकर अपीलसं. / Ita No.380/Pun/2020 िनधा"रण वष" / Assessment Year : 2016-17 Poonawalla Shares & Securities The Assistant Pvt. Ltd., Vs Commissioner Of Income 16-B,/1, Sarosh Bhavan, Tax, Dr.Ambedkar Road, Circle-4, Pune. Pune – 411001 Pan: Aaacp 6087 H Appellant/ Assessee Respondent /Revenue Assessee By Shri Percy Pardiwala – Ar Revenue By Shri M.G.Jasnani – Dr Date Of Hearing 08/07/2022 Date Of Pronouncement 29/07/2022 आदेश/ Order Per S.S.Godara, Jm: This Assessee’S Appeal For Assessment Year 2016-17 Is Directed Against The Commissioner Of Income Tax(Appeals)-3, Pune’S Order Dated 11.12.2019 Passed In Case No.Pn/Cit(A)-3/Cir 4/193/2018-19/428, In Proceedings U/S.143(3) Of The Income Tax Act, 1961 [In Short “The Act”].

Disallowance under section 14A r, w. Rule 8D : On verification of the Balance Sheet for the year under consideration, it is found that assessee company has made investment in equity shares from which the assessee has earned exempt income. As per provision of section 14A of the Act for the purposes of computing the total income under this Chapter

DHAS KISHOR RAMCHANDRA, AURANGABAD vs. DWARKAPRASAD BHIKULAL SONI, JALNA

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

Bench: SHRI R. K. PANDA (Vice President), SHRI VINAY BHAMORE (Judicial Member)

section 56(2)(x) & 50CA in accordance with the Rule 11U & 11UA of Income Tax Rules, 1962. 3. Whether in the facts and circumstances of the case and in law, the Ld. CIT (A) erred in accepting the second valuation report furnished by assessee for the purpose of land situated at Survey No. 79, 82, 63 & 86 Village-Yerur valuing

BAJAJ ALLIANZ GENERAL INSURANCE COMPANY LTD.,,PUNE vs. DEPUTY COMMISSIONER OF INCOME-TAX,,

section 14A is held to be applicable, the disallowance in relation to non-taxable profits on sale! Redemption of investments and exempt dividend income should be restricted to Rs 11,56

DEPUTY COMMISSIONER OF INCOME-TAX vs. BAJAJ ALLIANZ GENERAL INSURANCE COMPANY LTD.,, PUNE

section 14A is held to be applicable, the disallowance in relation to non-taxable profits on sale! Redemption of investments and exempt dividend income should be restricted to Rs 11,56

MANSH PANNALAL BAGDIA,,JALNA vs. DEPUTY COMMISSIONER OF INCOME-TAX,, JALNA

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

Bench: Shri Anil Chaturvedi, Am & Shri Partha Sarathi Chaudhury, Jm आयकर अपीऱ सं. / Ita No.1210/Pun/2017 नििाारण वषा / Assessment Year : 2012-13 Manish Pannalal Bagdia, Bagadia Palace, Rajendra Prasad Road, Jalna-431203 Pan :Ahopb0111E .......अऩीऱाथी / Appellant बिाम / V/S.

disallowance of interest of Rs.5,56,842/- under section 14A of the Act against exempt agricultural income. 3. Any other

VEERACHARYA BABASAHEB KUCHNURE ZILLA NAGARI SAHAKARI PAT SANSTHA LTD.,SANGLI vs. INCOME TAX OFFICER 1(1), SANGLI

In the result, the appeal of the assessee is allowed

Bench: Shri Manish Borad & Ms. Astha Chandra

section 56 and disallowed the corresponding claim under section 80P. On the facts and in law, the addition made by the Assessing

VEERACHARYA BABASAHEB KUCHNURE ZILLA NAGARI SAHAKARI PAT SANSTHA LIMITED,SANGLI vs. INCOME TAX OFFICER 1(1), SANGLI

In the result, the appeal of the assessee is allowed

Bench: Shri Manish Borad & Ms. Astha Chandra

section 56 and disallowed the corresponding claim under section 80P. On the facts and in law, the addition made by the Assessing

DHANLAXMI MAHILA GRAMIN BIGARSHETI SAHAKARI PATSANSTHA LIMITED,PUNE vs. PCIT-1, PUNE

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

Bench: Shri Rama Kanta Panda, Vice- & Ms. Astha Chandra

disallowance of corresponding interest is warranted b) Assessee has shown high liabilities in balance sheet as compared to low income/receipt declared in ITR Genuineness of liabilities declared may be verified c) The assessee has claimed large deduction under chapter VI-A (excluding deduction claimed u/s 80-IA/ 80-IAB/80-IAC/80-IB/80-IBA/80-IC/80-IE/80-ID. Here whether the assessee has claimed deduction u/c VIA correctly

KIMBERLY CLARK LEVER P.LTD.,PUNE vs. ACIT, PUNE

In the result, the appeal of the assessee stands allowed

Bench: Shri Inturi Rama Rao, Am & Shri Partha Sarathi Chaudhury, Jm आयकर अपील सं. / Ita No.2481/Pun/2012 िनधा"रण वष" / Assessment Year : 2008-09 Kimberly Clark Lever P. Ltd., Gat No.934 To 937, Village Sanaswadi Off Nagar Road, Ta- Shirur, Pune-412208. .......अपीलाथ" / Appellant Pan : Aaack4647E बनाम / V/S. Acit, Circle-Xi(I), ……""यथ" / Respondent Pune. Assessee By : Shri Percy Pardiwalla Revenue By : Shri Sandeep Garg सुनवाई क" तारीख / Date Of Hearing : 08.02.2021 घोषणा क" तारीख / Date Of Pronouncement : 22.02.2021 आदेश / Order Per Inturi Rama Rao, Am: This Is An Appeal Filed By The Assessee Directed Against The Final Assessment Order U/S 143(3) R.W.S. 144C Of The Income Tax Act, 1961 (‘The Act’ For Short) Of The Asstt. Commissioner Of Income Tax, Circle-11(1), Pune (‘The Assessing Officer’ For Short) Dated 29.10.2012 For The Assessment Year 2008-09. 2. The Appellant Raised The Following Grounds Of Appeal :- “The Appellant Objects To The Order Dated 29 October 2012 Passed Under Section 143(3) R.W.S. 144(C) Of The Income-Tax Act, 1961 (‘The Act’) By The Assistant Commissioner Of Income Tax, Circle 11(1), Pune [‘Acit’ Or ‘Ao’] Following The Directions Issued By The Dispute Resolution Panel (‘Drp’) In Respect Of The Aforesaid Assessment Year On The Following Among Other Grounds:

56. Thus, under Section 92B(1) an 'international transaction' means- (a) a transaction between two or more AEs, either or both of whom are non-resident (b) the transaction is in the nature of purchase, sale or lease of tangible or intangible property or provision of service or lending or borrowing money or any other transaction having a bearing