M/S. L.B. KUNJIR,PUNE vs. DEPUTY COMMISSIONER OF INCOME TAX, CIRCLE 7, PUNE, PUNE

In the result, the two appeals filed by the assessee are allowed and the three appeals filed by Revenue are dismissed

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

69 to 69D of the Act. Therefore, the CBDT issued circular holding that the set off of losses is prohibited from assessment year 2017- 18 onwards. He submitted that as per the circular, what is prohibited under sub- section (2) is set off of any expenditure or allowance or loss against the deemed income. Since the assessee in the instant

M/S. L.B. KUNJIR,PUNE vs. DEPUTY COMMISSIONER OF INCOME TAX, CIRCLE 7, PUNE, PUNE

In the result, the two appeals filed by the assessee are allowed and the three appeals filed by Revenue are dismissed

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

69 to 69D of the Act. Therefore, the CBDT issued circular holding that the set off of losses is prohibited from assessment year 2017- 18 onwards. He submitted that as per the circular, what is prohibited under sub- section (2) is set off of any expenditure or allowance or loss against the deemed income. Since the assessee in the instant

DEPUTY COMMISSIONER OF INCOME TAX, CIRCLE-7, PUNE vs. LB KUNJIR, PUNE

In the result, the two appeals filed by the assessee are allowed and the three appeals filed by Revenue are dismissed

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

69 to 69D of the Act. Therefore, the CBDT issued circular holding that the set off of losses is prohibited from assessment year 2017- 18 onwards. He submitted that as per the circular, what is prohibited under sub- section (2) is set off of any expenditure or allowance or loss against the deemed income. Since the assessee in the instant

DCIT CIRCLE 7, BODHI TOWER SALISBURY PARK vs. L B KUNJIR, PUNE

In the result, the two appeals filed by the assessee are allowed and the three appeals filed by Revenue are dismissed

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

69 to 69D of the Act. Therefore, the CBDT issued circular holding that the set off of losses is prohibited from assessment year 2017- 18 onwards. He submitted that as per the circular, what is prohibited under sub- section (2) is set off of any expenditure or allowance or loss against the deemed income. Since the assessee in the instant

DCIT, PUNE vs. L B KUNJIR, PUNE

In the result, the two appeals filed by the assessee are allowed and the three appeals filed by Revenue are dismissed

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

69 to 69D of the Act. Therefore, the CBDT issued circular holding that the set off of losses is prohibited from assessment year 2017- 18 onwards. He submitted that as per the circular, what is prohibited under sub- section (2) is set off of any expenditure or allowance or loss against the deemed income. Since the assessee in the instant

NILESH POPATLAL GADA,PUNE vs. INCOME TAX OFFICER WARD 2(4) , PUNE

In the result, appeal of the assessee is Partly Allowed

Bench: DR.DIPAK P. RIPOTE (Accountant Member), SHRI VINAY BHAMORE (Judicial Member)

disallowance of claim of agriculture income of Rs 5,52,310/- and addition u/s 68 of the Act treating the same as unexplained cash credit is unwarranted, unjustified and contrary to the provisions of the Act and facts prevailing in the case. It further be held that no addition is warranted in the case of the Appellant. The addition

DY.COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-1, AURANGABAD, AURANGABAD vs. SHRI. BALAJI RAMCHANDRA ANDE, LATUR

In the result, appeal of the Revenue dismissed

Bench: Shri Rama Kanta Panda & Ms. Astha Chandra

sections 68, 69, 69A to 69D and levy of higher rate of tax u/s 115BBE, following factors are required to be considered – • Whether nature of income is clearly explained during the survey or during assessment proceedings. • Whether income can be classified under a particular head of income based on nature so as to demonstrate that it is flowing from

WILDERNEST BETTER LIVING & MAINTENANCE CO-OPERATIVE SOCIETY LIMITED,PUNE vs. INCOME TAX OFFICER, WARD 6(1), PUNE, PUNE

In the result, the appeal of the assessee is allowed

Bench: Dr.Dipak P. Ripote & Shri Vinay Bhamoreआयकर अपील सं. / Ita No.856/Pun/2025 िनधा"रण वष" / Assessment Year: 2020-21 Wildernest Better Living V The Income Tax Officer, Maintenance Co-Operative S Ward-6(1), Pune. Society Limited, Plot No.58, 59 & 60, Woldernest Society, Khadakwasla, Taluka Haveli, Pune – 411024. Maharashtra. Pan: Appellant/ Assessee Respondent / Revenue Assessee By Shri Arpit Dnyandeo Dambhare & Shri Deepak Sasar – Ca’S Revenue By Shri Madhan Thirmanpalli – Addl.Cit(Dr) Date Of Hearing 15/05/2025 Date Of Pronouncement 23/05/2025 आदेश/ Order Per Dr. Dipak P. Ripote, Am: This Appeal Filed By The Assessee Directed Against The Order Of Ld.Addl./Joint Commissioner Of Income Tax(Appeal), Panaji Under Section 250 Of The Income Tax Act, 1961 For The A.Y.2021-22 Dated

section 139; (iv) disallowance of expenditure 68[or increase in income] indicated in the audit report but not taken into account in computing the total income in the return; (v) disallowance of deduction claimed under 69

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

69,52,691/- and consequent short levy of tax. 08. In view of the above, the order dt. 26/02/2022 passed by the Faceless Assessing Officer, NeAC, Delhi under section 143(3) r.w.s. 144C(13) r.w.s. 144B of the Income-tax Act, 1961 for the A.Y 2017-18 is erroneous and prejudicial to the interest of revenue within the meaning

SHAHU SHIKSHAN PRASARAK MANDAL, LATUR,LATUR vs. ACIT (EXMP.) CIRCLE, AURANGABAD, AURANGABAD

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

69,44,047/- claimed by the\nassessee under the provisions of section 10(23C)(iiiab) of the Act should be\nallowed to the assessee declaring taxable income of the trust at Rs. Nil.\n6.4 He further submitted that both the Ld. AO and the Ld. CIT(A) has\nerred in disallowing

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

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

69,81,530/- and Rs.8,76,65,984/- on account of liquidated\ndamages in assessments years 2017-18 and 2015-16 respectively. These damages\nwere disallowed under section

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

disallowance of health and education cess and also filed Form 69 as per requirement of section 155(18) of the Act. The assessee

SHREE RAM CARGO PRIVATE LIMITED,PUNE vs. INCOME TAX OFFICER, WARD 6(5), PUNE, PMT BUILDING, SHANKAR SHET ROAD, PUNE

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

Bench: Dr.Manish Borad & Shri Vinay Bhamoreआयकर अपील सं. / Ita No.1568/Pun/2024 "नधा"रण वष" / Assessment Year : 2015-16 Shree Ram Cargo Private Limited, Vs. Ito, Ward-6(5), 3-A & B, Archies Court, Pune Shankar Shet Road, Pune 411 037 Maharashtra Pan : Aalcs3844A Appellant Respondent

Section 40A(3) for 78,45,580/- and disallowed @20% thereon 15,69,116/-. It is also made clear that

SUBHADRA TANAJI CHAVAN,SATARA vs. INCOME TAX OFFICER WARD 2, SATARA

In the result, the appeal of the assessee is allowed

Bench: Ms.Astha Chandra & Dr.Dipak P. Ripoteआयकर अपील सं. / Ita No.1389/Pun/2025 िनधा"रण वष" / Assessment Year: 2021-22 Subhadra Tanaji Chavan, V The Income Tax Officer, Plot No.31, Suparna Niwas S Ward-2, Satara. Pawar Colony, Shahupuri, Satara – 415002. Maharashtra. Pan: Bgspc7420D Appellant/ Assessee Respondent / Revenue Assessee By Shri Pramod S Shingte – Ar Revenue By Shri Akhilesh Srivastva–Addl.Cit(Dr) Date Of Hearing 10/07/2025 Date Of Pronouncement 29/07/2025 आदेश/ Order Per Dr. Dipak P. Ripote, Am: This Is An Appeal Filed By Assessee Against The Order Of Ld.Commissioner Of Income Tax(Appeal)[Nfac], Passed Under Section 250 Of The Income Tax Act, 1961 For The A.Y.2021-22Dated 30.03.2025, Emanating From Order U/S.143(1)Of The Income Tax Act, 1961, Dated 28.12.2022. The Assessee Has Raised Following Grounds Of Appeal :

section 139, (iv) disallowance of expenditure 68/or increase in income) indicated in the audit report but not taken into account in computing the total income in the return; (v) disallowance of deduction claimed under 69

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

section 143(3), the learned AO had taken income as per revised return as against income as per revised computation submitted on 21 October 2016 as the starting point for assessing total income. In a nutshell, the aforesaid stand of learned AO has resulted into disallowance of Rs 1,64,69

KUDALE AGRO FOODS,PUNE vs. INCOME TAX OFFICER, CIRCLE-14, PUNE, PUNE

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

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

69,050/- vide order dated 19.12.2019 passed u/s 143(3) of the Act. 3. Aggrieved, the assessee challenged the order of the Ld. AO before the Ld. CIT(A) contending that the Ld. AO erred in making disallowance of Rs.3,92,050/- being (30% of interest expenses of Rs.13,06,800/-) u/s 40(a)(ia) of the Act on account

SHAARP ALUMINUM,PUNE vs. THE ASSISTANT COMMISSIONER OF INCOME TAX, CIRCLE-2, PUNE

The appeal of the assessee is allowed for statistical purposes

Bench: Hon’Ble Shri Partha Sarathi Choudhury & Shri G. D. Padmahshaliआयकर अपऩल सं. / Ita No.957/Pun/2023 निर्धारण वषा / Assessment Year : 2019-20 M/S Sharp Aluminium F-41, S.No. 28/29 Shrushti, Guruganesh Nagar, Kothrud Pune-411038. Pan: Aczfs2580G . . . . . . .अपऩलधर्थी / Appellant

69,63,968/- u/s 43B of the Act for assessee’s failure to discharge statutory dues by actual payment within the due date of filing as prescribed u/s 139(1) of the Act and processed its ITR determining total income at ₹3,60,79,078/-.. 2.2 Aggrieved assessee instituted appeal before first appellate authority, wherein Ld. NFAC, after considering appellant

COOPER CORPORATION PRIVATE LIMITED,SATARA vs. NATIONAL EASSESSMENT CENTRE, NOT KNOWN

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

Bench: Shri R. K. Panda & Ms. Astha Chandraassessment Year : 2020-21 Cooper Corporation Pvt. Ltd. Dcit, Satara Circle, Satara M60-1, Nariman House, Additional Vs. Midc, Vijay Nagar, Gojegaon B.O., Satara – 415004 Pan: Aaacc9687J (Appellant) (Respondent) Assessee By : Shri Krishna V Gujarathi Department By : Shri Amol Khairnar Cit-Dr Date Of Hearing : 14-05-2025 Date Of Pronouncement : 22-05-2025 O R D E R

69,17,337/- made by the Assessing Officer by observing as under: 1. Ground no.1 to 3 objects to disallowance of deduction claimed u/s. 35(2AB) for not fulfilling all the conditions prescribed under section

CARRARO INDIA PVT. LTD.,PUNE vs. PRINCIPAL COMMISSIONER OF INCOME-TAX-1, PUNE

In the result, appeal of the assessee is allowed

Bench: Shri S.S.Godara & Dr. Dipak P. Ripoteआयकर अपील सं. / Ita No.814/Pun/2022 िनधा"रण वष" / Assessment Years : 2017-18 Carraro India Private Limited, The Principal B 2/2, Midc, Ranjangaon V Commissioner Income Karegaon, Pune – 412220. S Tax-1, Pune. Pan: Aaacc 5292 M Appellant/ Assessee Respondent /Revenue Assessee By Shri Nikhil Mutha – Ar Revenue By Shri Ganesh Bare - Cit Date Of Hearing 26/06/2023 Date Of Pronouncement 25/07/2023 आदेश/ Order Per Dr. Dipak P. Ripote, Am: This Appeal Filed By Assessee Is Directed Against The Order Of Ld.Principal Commissioner Of Income Tax, Pune-1 Dated 15.09.2022 For A.Y. 2017-18 Under Section 263 Of The Income Tax Act, 1961. The Assessee Has Raised The Following Grounds Of Appeal: “Appeal Against Order Passed By Pr. Cit U/S 263 Of The Act Ay 2017-18

section 263 of the Act, by setting aside with a direction to AO to re-examine the Appellant’s claim of deduction in respect of Royalty expenses of Rs.16,69,36,844 and Legal and Professional Fees of Rs.17,18,57,600; 3. Erred in holding that the Ld. AO ought to have made the disallowance