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

section 143(3) and 154 of the Income Tax Act, 1961 (“the Act”). Since the issues involved in both the appeal are correlated therefore both the appeals were heard together and are being disposed of by this common order. 2. Briefly stated the facts are that the assessee is a company engaged in the manufacturer of a wide array

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

73,55,850/-. The return was processed u/s 143(1) of the Income Tax Act, 1961 (hereinafter referred to as ‘the Act’) at total income of Rs.36,85,60,000/-. Subsequently the return was selected for complete scrutiny assessment under CASS. Accordingly statutory notices u/s 143(2) and 142(1) of the Act were issued and served on the assessee

FCA INDIA AUTOMOBILES PRIVATE LIMITED (SURVIVING ENTITY AFTER THE MERGER OF PCA MOTORS PVT LTD),PUNE vs. ASSESSMENT UNIT, INCOME TAX DEPARTMENT, NATIONAL FACELESS ASSESSMENT CENTRE

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

Bench: SHRI MANISH BORAD (Accountant Member), SHRI VINAY BHAMORE (Judicial Member)

disallowance in its return of income. 3. Restriction of deduction under section 10AA of the Act to INR 73,822,670. 3.1 On the facts

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.2,02,56,631/- in the relevant year under any other amount allowable

SURIA STEELTECH PRIVATE LIMITED (PREVIOUSLY KNOWN AS TMS ENGINEERS PRIVATE LIMITED),PUNE vs. ASSESSING OFFICER, WARD-9(4), PUNE, PUNE

Appeal is dismissed in above terms

Bench: Shri Satbeer Singh Godara & Dr. Dipak P. Ripote

Disallowing the employees Contribution towards provident fund to tune of RS 71,73,633/- and Employees State Corporation of RS 49,75,899/- being paid after the Stipulated date as Mentioned in the respective act, Whereas paid before the due date of filling of return of income as per Section

CTR MANUFACTURING INDUSTRIES PRIVATE LIMITED,PUNE vs. THE DEPUTY COMMISSIONER OF INCOME TAX, CIRCLE 1(1), PUNE, PUNE

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

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

73,07,240/- including therein the above disallowances and addition of Rs.1,47,782/- being excess claim offered to tax by the assessee in provision for superannuation fund. 5. Before the Ld. CIT(A)/NFAC, the assessee challenged the disallowances made by the Ld. AO u/s 14A and section

SUN INFRASTRUCTURES PRIVATE LIMITED,NASHIK vs. INCOME TAX OFFICER, WARD-2(1), NASHIK, NASHIK

In the result, the appeal of the assessee is dismissed

Bench: Shri Inturi Rama Rao & Shri S.S. Viswanethra Ravi

disallowed the same by holding as under- "It would be pertinent to mention here that the above assessed loss of Rs.73,24,3051- is inclusive of Depreciation loss of Rs. 12,69,0741-. Further, under the circumstances that the return of income was not filed within the stipulated time limit as detailed in section 139(1) of the Act, only

ASSISTANT COMMISSIONER OF INCOME-TAX, CENTRAL CIRCLE - 1,, AURANGABAD vs. M/S. M.B. PATIL CONSTRUCTION LTD,, AURANGABAD

In the result, the cross appeal filed by the Revenue in ITA

Bench: SHRI MANISH BORAD (Accountant Member), SHRI VINAY BHAMORE (Judicial Member)

disallowance of assessee's claim of a deduction of Rs.2,73,36,424/- under section 801A of the I.T. Act, 1961, made

M/S. M.B.PATIL CONSTRUCTIONS LTD,,AURANGABAD vs. DEPUTY COMMISSIONER OF INCOME-TAX, CENTRAL CIRCLE - 1,, AURANGABAD

In the result, the cross appeal filed by the Revenue in ITA

Bench: SHRI MANISH BORAD (Accountant Member), SHRI VINAY BHAMORE (Judicial Member)

disallowance of assessee's claim of a deduction of Rs.2,73,36,424/- under section 801A of the I.T. Act, 1961, made

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

disallowance under section 36(1)(va) of the Act 13 The Ld. AO erred in initiating penalty proceedings under Section 270A of the Act on arbitrary premise that there is under-reporting of income done by the Appellant The above grounds are without prejudice to each other The appellant craves leave to alter, amend or withdraw

ASSISTANT COMMISSIONER OF INCOME TAX, AAYKAR BHAWAN, KOLHAPUR, MAHARASHTRA vs. KOLHAPUR ZILLA SAHAKARI DUDH UTPADAK SANGH LIMITED, KOLHAPUR

In the result, appeal of the Revenue is partly allowed

Bench: Shri S.S.Godara & Dr. Dipak P. Ripoteआयकर अपील सं. / Ita No.1236/Pun/2023 िनधा"रण वष" / Assessment Year : 2017-18 The Assistant Kolhapur Zilla Sahakari Commissioner Of Income V Dudhutpadak Sangh Limited, Tax, S B-1, Midc, Gokul Shirgaon, Kolhapur. Kolhapur – 416234. Pan: Aaaak0230D Appellant / Revenue Respondent /Assessee Assessee By None. Revenue By Shri Sandeep P. Sathe – Dr Date Of Hearing 10/04/2024 Date Of Pronouncement 25/04/2024 आदेश/ Order Per Dr. Dipak P. Ripote, Am: This Is An Appeal Filed By The Revenue Against The Order Of Ld.Commissioner Of Income Tax(Appeal)[Nfac], Delhi Under Section 250 Of The Income Tax Act, 1961, Emanating From The Order Under Section 143(3) Of The Act, Dated 30.12.2019.The Revenue Has Raised The Following Grounds Of Appeal : “1. The Cit(A) Erred In Allowing Rs.5,62,220/- On Account Of Fixed Assets On Which Project Subsidy Was Received From National Dairy Development Board As The Department Has Contested The Issue Before The Supreme Court. Kolhapur Zilla Sahakari Dudh Utpadak Sangh Limited [R]

73,998. 4 Kolhapur Zilla Sahakari Dudh Utpadak Sangh Limited [R] The AO was of the view that the provisions of section 32(1)(iia) are effective from 01/04/2016. He therefore, disallowed

DY. COMMISSIONER OF INCOME TAX, CIRCLE PUNE vs. APOORVA ASHOKKUMAR PATNI, PUNE

In the result, the appeal of the Revenue is dismissed

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

73,06,926/- u/s 14A r.w. Rule 8D. The Ld. AO has discussed this issue in para 6.1 of the assessment order. Before the Ld. AO the assessee submitted that the issue of disallowance does not arise in the case of the assessee. Rejecting the assessee’s contention and observing that section

GOVERNMENT PRINTING PRESS EMPLOYEE CREDIT CO-OPERATIVE SOCIETY LTD,PUNE vs. ITO, WARD 7(1), PUNE, PUNE

In the result, appeal of the Assessee is allowed

Bench: Ms.Astha Chandra & Dr.Dipak P. Ripoteआयकर अपऩल सं. / Ita No.793/Pun/2025 निर्धारण वषा / Assessment Year: 2019-20 Government Printing Press V The Income Tax Officer, Employee Credit Co-Operative S Ward-7(1), Pune. Society Limited, Yerawadakaragruh, Airport Road, Yerawada, Pune – 411006. Pan: Aabag2986P Appellant/ Assessee Respondent / Revenue Assessee By Mr.Sarvesh Khandelwal Revenue By Shri Ramnath P Murkunde Date Of Hearing 16/09/2025 Date Of Pronouncement 30/09/2025 आदेश/ Order Per Dr. Dipak P. Ripote, Am: This Is An Appeal Filed By The Assessee Against The Order Of Ld.Additional/Joint Commissioner Of Income Tax(Appeal)-2, Visakhapatnamunder Section 250 Of The Income Tax Act, 1961 Dated 30.01.2025 Emanating From The Assessment Order Passed Under Section 143(1) Of The Act, Dated 02.12.2020 For Ay 2019-20.The Assessee Has Raised The Following Grounds Of Appeal :

disallowance of deduction claimed u/s 80P(2)(a)(i) of Rs.1,30,92,363/-, 80P(2)(c) of Rs.28,171/- and u/s 80P(2)(d) of Rs.13,08,573/- while processing the return u/s 143(1) of the Income Tax Act, 1961 is not covered by scope of the said section. It is held that intimation order is not passed

DCIT, PUNE vs. JOHN DEERE INDIA PRIVATE LIMITED, PUNE

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

Bench: Shri R. K. Panda & Ms Astha Chandraassessment Year : 2016-17

section 14A read with rule 8D. The Assessing Officer therefore, issued a show cause notice asking the assessee to explain as to why the disallowance u/s 14A read with rule 8D should not be made. Not being satisfied with the reply of the assessee, the Assessing Officer disallowed an amount of Rs.3,73

DIMPLE ALNESH SOMJI,PUNE vs. ACIT, CENTRAL CIRCLE 1(3), PUNE, PUNE

In the result, appeal of the assessee is partly allowed

Bench: Shri Rama Kanta Panda & Ms. Astha Chandra

disallowance of business expenditure of Rs.1,25,870/- is concerned, Learned Counsel for the Assessee, drew the attention of the Bench to pages-25 to 29 of the paper book with regard to the details of expenditure such as professional fees of Rs.30,000/; salary Rs.42,850/-; 8 ITA.No.973/PUN./2024 travelling and conveyance Rs.30,593/-; Bank charges Rs.944

VIDYA VIKAS PRATISHTAN,SOLAPUR vs. DCIT, EXEMPTION CIRCLE, PUNE

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

Bench: Shri Manish Borad & Shri Vinay Bhamoreआयकर अपील सं. / Ita No.902/Pun/2025 िनधा"रण वष" / Assessment Year : 2022-23 Vidya Vikas Pratishtan, Vs. Assessment Unit, 72/2B, Pratap Nagar, Income Tax Department. Soregaon, Solapur- 413004. Pan : Aaatv8537F Appellant Respondent Assessee By : Shri Piyush Bafna Revenue By : Shri Amit Bobde Date Of Hearing : 18.08.2025 Date Of Pronouncement : 29.10.2025 आदेश / Order Per Vinay Bhamore, Jm: This Appeal Filed By The Assessee Is Directed Against The Order Dated 19.12.2024 Passed By Ld. Cit(A)/Nfac For The Assessment Year 2022-23. 2. There Is Delay In Filing Of The Present Appeal. We Are Satisfied With The Reasons Mentioned In The Application For Condonation Of Delay Duly Supported By An Affidavit That The Applicant Was Prevented By Sufficient Cause For Not Filing The Appeal Within The Prescribed Time Limit. After Hearing Ld. Dr, We Condone The Delay & Proceed To Adjudicate The Appeal.

section 250(6) of the Act and therefore, the impugned order, being non-speaking and devoid of proper reasoning, is bad in law and deserves to be quashed. 2. On the facts and in the circumstances of the case and without prejudice to any other grounds, the learned CIT(A) has erred in confirming the disallowance of Rs 1,73

AMJ LAND HOLDINGS LTD.,PUNE vs. ASSTT. DIRECTOR OF INCOME TAX, CPC, BENGALURU

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

Bench: Shri R. K. Panda & Ms. Astha Chandraassessment Year : 2021-22 Amj Land Holdings Limited Asst. Director Of Income Tax, Vs. Thergaon, Pune – 411033 Cpc, Bengaluru Pan: Aabcp0310Q (Appellant) (Respondent) Assessee By : Shri Nikhil S Pathak Department By : Shri Ramnath P Murkunde Date Of Hearing : 05-05-2025 Date Of Pronouncement : 07-05-2025 O R D E R

73,924/- with a tax payable thereon at Rs.1,12,62,748/-. While processing the return, the CPC disallowed an amount of Rs.64,469/- out of Rs.2,28,590/- against the payment of employees’ contribution towards provident fund. Similarly, 2 the CPC disallowed an amount of Rs.1,64,120/- out of Rs.2,28,590/- against the payment of employees contribution

ASSTT.COMMISSIONER OF INCOME TAX, PUNE vs. NITIN DWARKADAS NYATI, PUNE

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

Bench: Shri R. K. Panda & Ms. Astha Chandraassessment Year : 2020-21 Acit, Central Circle 2(3), Nitin Dwarkadas Nyati Pune Sr. No.103/129, Nyati Unitree, Vs. Yerwada, Nagar Road, Pune – 411006 Pan: Aabpn2601F (Appellant) (Respondent) Assessee By : Shri Krishna V Gujarathi Department By : Shri Vidya Ratan Kishore Date Of Hearing : 15-12-2025 Date Of Pronouncement : 19-12-2025 O R D E R

73,55,850/-. The return was processed u/s 143(1) of the Income Tax Act, 1961 (hereinafter referred to as ‘the Act’) at total income of Rs.36,85,60,000/-. Subsequently the return was selected for complete scrutiny assessment under CASS. Accordingly statutory notices u/s 143(2) and 142(1) of the Act were issued and served on the assessee

YARDI SOFTWARE INDIA PRIVATE LIMITED,PUNE vs. ASSESSING OFFICER, JURISDICTION CIRCLE 12, PUNE, INCOME TAX DEPARTMENT, PUNE

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

Bench: Shri R. K. Panda & Shri Vinay Bhamoreआयकर अपील सं. / Ita No.549/Pun/2025 िनधा"रण वष" / Assessment Year : 2022-23 Yardi Software India Private Vs. Acit, Circle-12, Pune. Limited, Second Floor, Sigma House, Senapati Bapat Road, Pune City, Pune, Shivaji Housing Society S.O.- 411016. Pan : Aaccr8107N Appellant Respondent

disallowance of Rs.38,80,972/-made under Section 36(1)(va) of the Act, on account of delayed payment of Employees Contribution to PF/ESI u/s 143(1) is confirmed. The grounds of appeal are dismissed. 4 3.2. It is this order against which the assessee is in appeal before the Tribunal. 4. Learned AR appearing from the side