DEPUTY COMMISSIONER OF INCOME-TAX vs. M/S. HONEYWELL AUTOMATION INDIA LTD.,, PUNE

In the result, the appeal of Revenue is dismissed

Bench: Shri R.S. Syal & Shri S.S. Viswanethra Ravi

disallow by restricting the deduction to ordinary profit. The contention of assessee is that the AO did not make any addition in terms of sub-section (7) of section 10A of the Act and enhancement proposed by the CIT(A) is not warranted u/s. 251(2) of the Act. The case of CIT(A) is that the deduction

M/S. HONEWELL AUTOMATION INDIA LTD.,,PUNE vs. DEPUTY COMMISSIONER OF INCOME-TAX,,

In the result, the appeal of Revenue is dismissed

Bench: Shri R.S. Syal & Shri S.S. Viswanethra Ravi

disallow by restricting the deduction to ordinary profit. The contention of assessee is that the AO did not make any addition in terms of sub-section (7) of section 10A of the Act and enhancement proposed by the CIT(A) is not warranted u/s. 251(2) of the Act. The case of CIT(A) is that the deduction

M/S PERSISTENT SYSTEMS LIMITED,PUNE vs. ASSESSMENT UNIT, INCOME-TAX DEPARTMENT, PUNE

In the result, appeal of the Assessee is Partly Allowed

Bench: Shri S.S.Godara & Dr. Dipak P. Ripoteआयकरअपीलसं. / Ita No.692/Pun/2022 िनधा"रणवष" / Assessment Year : 2018-19 M/S.Persistent Systems Assessment Unit, Income Limited, V Tax Department. “Bhageerath” 402, Senapati S Bapat Road, Pune – 411016. Pan: Aabcp 1209 Q Appellant/ Assessee Respondent /Revenue Assessee By Shri Dhanesh Bafna& Shriaditya Vaidya– Ar’S Revenue By Shri Suhas Kulkarni - Irs Addl Commissioner Of Income Tax Date Of Hearing 26/09/2023 Date Of Pronouncement 02/11/2023 आदेश/ Order Per Dr. Dipak P. Ripote, Am: This Appeal Filed By The Assessee Is Directed Against The Assessment Order, Dated 20.07.2022 Under Section 143(3) R.W.S. 144C(13) Read With Section 144B Of The Income Tax Act, 1961 For A.Y.2018-19. The Assessee Has Raised The Following Grounds Of Appeal: “Ground 1: Order Is Invalid / Non Est  On The Facts & In The Circumstances Of The Case & In Law, The Assessment Unit (‘Au’) Has Erred In Passing The Draft Assessment M/S.Persistent Systems Limited [A]

disallowance of INR 4,50,70,798 under u/s 14A of the Act r.w rule 8D(2)(ii) be deleted. Ground 10: Additional relief under section 90 On the facts and circumstances of the case, and in law, the AU based on the directions of Ld. DRP erred in disregarding Appellant’s claim for additional relief under section

DEPUTY COMMISSIONER OF INCOME-TAX, CENTRAL CIRCLE-2(1),, PUNE vs. M/S. VASCON ENGINEERS LIMITED,, PUNE

Appeal is dismissed in above terms

Bench: Shri S.S.Godara, Jm & Shri G.D. Padmahshali, Am

section 14A r.w. Rule 8D disallowance of Rs.1,94,85,303/- in his assessment order dated 01.12.2017, it emerges at the outset that the former’s lower appellate discussion to this effect reads as follows. “5.1 I have considered the materials placed before me. During the appellate proceeding the appellant submitted that the Hon’ble Jurisdictional ITAT, Pune in appellant

MULAY CONSTRUCTION PRIVATE LIMITED,,AURANGABAD vs. ASSISTANT COMMISSIONER OF INCOME TAX,, AURANGABAD

In the result, the appeal is partly allowed for statistical

Bench: Shri R.S. Syal & Shri S.S. Viswanethra Ravi"नधा"रण वष" / Assessment Year : 2013-14 Mulay Construction Private Limited, Vs. Acit, Ist Floor, Tapadiya Teraces, Central Circle-1, Adalat Road, Aurangabad – 431 001 Aurangabad Pan : Aadcm1853B Appellant Respondent

section 14A of the Act. No proposition for not making disallowance at 0.5% of the average value of investments, which is otherwise in accordance with rule 8D(2)(iii) of the Rules, has been laid 4 down in the case. We, therefore, uphold the impugned order on this score. 5. The only other ground raised in this appeal is against

DCIT, SWARGATE PUNE vs. CUMMINS INDIA LTD , PUNE

In the result, appeal of the assessee bearing ITA No

disallowance of deduction claimed under\nsections 10AA, 80-IA, 80-IAB, 80-IB, 80-IC, 80-ID\nor section 80-IE, if the return is furnished beyond\nthe due date specified under sub-section (1) of\nsection 139\"\n6. Given that there is no specific requirement in section 10AA\nto file the return of income within the due date

BYK ASIA PACIFIC PTE LIMITED,PUNE vs. ACIT(IT), CIRCLE-1, PUNE

In the result, the appeal is partly allowed

Bench: Shri R.S. Syal & Shri Partha Sarathi Chaudhuryआयकर अपील सं. / Ita No.2110/Pun/2019 िनधा"रण वष" / Assessment Year : 2016-17

disallowance of Rs.1,22,43,873/- u/s.40(a)(i) of the Act for non-deduction of tax at source on the following payments made by the Indian BO to the Singapore HO: i. Seminar expenses – Rs.83,85,562.72 ii. IT expenses – Rs.36,44,507.64 iii. Training expenses – Rs.1,45,779.75 iv. Printing expenses – Rs.46,682.32 4 BYK Asia Pacific

RENU ELECTRONICS PVT. LTD.,PUNE vs. ACIT, CIRCLE 5, PUNE, PUNE

In the result, appeal filed by the assessee is allowed

Bench: Shri R. K. Panda & Shri Vinay Bhamoreआयकर अपील सं. / Ita No.132/Pun/2024 िनधा"रण वष" / Assessment Year: 2017-18 Renu Electronics Pvt. Ltd., Vs. Acit, Circle-5, Pune. S.No.2/6, Near Baner Telephone Exchange, Baner, Pune- 411045. Pan : Aaacr8741G Appellant Respondent Assessee By : Shri Nikhil S. Pathak Revenue By : Shri Ajay Kumar Keshari Date Of Hearing : 25.06.2024 Date Of Pronouncement : 20.09.2024 आदेश / Order Per Vinay Bhamore, Jm: This Appeal Filed By The Assessee Is Directed Against The Order Dated 29.12.2023 Passed By Ld Cit(A)/Nfac For The Assessment Year 2017-18. 2. The Appellant Has Raised The Following Grounds Of Appeal :- “1] The Learned Cit(A) Erred In Confirming The Disallowance Of Weighted Deduction Amounting To Rs.9,25,79,494/- U/S 35(2Ab) Of The Act. 2] The Learned Cit(A) Erred In Holding That The Assessee Company Was Not Entitled To Claim Weighted Deduction U/S 35(2Ab) Since Form No. 3Cla Was Filed By The Assessee Beyond The Due Date Specified U/S 139(1) Of The Act.

747/- = Rs.52,31,494/- Therefore, an amount of Rs.52,31,494/- is being added back to the total income of the assessee company for the A.Y. 2017-18.” 5. It was further found by the Assessing Officer that the Form 3CLA for the claim of deduction u/s 35(2AB) by the assessee company was filed on 23.02.2018. Although, the assessee

MARATHA SEVA SANGH SANCHLIT DHULE DIST NAGARI SAHAKARI PATSANSTHA LTD,DHULE vs. ASSESSMENT UNIT, ITD, DELHI

In the result, appeal of the assessee is allowed

Bench: Ms.Astha Chandra & Dr.Dipak P. Ripoteआयकर अपऩल सं. / Ita No.2183/Pun/2025 निर्धारण वषा / Assessment Year: 2015-16 Maratha Seva Sangh Sanchlit V Assessment Unit, Dhule Dist Nagari Sahakari S Itd. Patsanstha Ltd., Plot No.148, Chudamani, Jay Hind Colony, Deopur Dhule, Dhule – 424002. Pan: Aactm4087D Appellant/ Assessee Respondent / Revenue Assessee By Shri Sharad A Shah Revenue By Shri Pawan Bharti (Virtual Hearing) Date Of Hearing 13/11/2025 Date Of Pronouncement 14/11/2025 आदेश/ Order Per Dr. Dipak P. Ripote, Am: This Is An Appeal Filed By The 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.2015-16 Dated 23.07.2025 Emanating From The Assessment Order Passed Under Section 147 R.W.S 144B Of The Act, Dated 21.02.2024. The Assessee Has Raised The Following Grounds Of Appeal :

747/-. GROUND NO.5: In the facts, circumstances and position of law learned CIT (A), NFAC, erred in confirming the disallowance of deduction u/s.80P(2)(a)(i) in respect of interest on fixed deposits kept with State Bank of India which is at Rs.7,426/-. GROUND NO.6: Appellant craves leave to add, alter, amend or substitute to the above grounds

SANKET FOOD PRODUCTS PRIVATE LTD,,AURANGABAD vs. INCOME-TAX OFFICER, WARD - 1(3),, JALNA

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

Bench: Shri S.S.Viswanethra Ravi & Shri Dr. Dipak P. Ripoteआयकर अपील सं. / Ita No.1956/Pun/2017 िनधा"रण वष" / Assessment Year : 2012-13 Sanket Food Products Private Limited, Vs. Ito, Ward 1(3), Jalna Flat No.101, Bhoomi Apartment, 1St Floor, Nutan Laxmi Chs, Plot No.9, Jvpd Scheme, Ville Parle (W), N.S. Road, No.8, Mumbai – 400056 Pan: Aaecs0131P Appellant Respondent Assessee By None Revenue By Shri S.P. Walimbe Date Of Hearing 08-02-2022 Date Of Pronouncement 11-02-2022 आदेश / Order Per Dr. Dipak P. Ripote, Am : This Appeal Is Against Commissioner Of Income Tax (Appeals)-1, Aurangabad’S Order Dated 24.03.2017 For Assessment Year 2012-13. 2. The History Of Notices By Itat Issued For Hearing In This Case Is As Under: Date Of Hearing Present / Absent 03.07.2020 Ld. Ar Present & Sought Adjournment 04.08.2020 Ld. Ar Present & Sought Adjournment 09.09.2020 None Present On Behalf Of Appellant 09.10.2020 None Present On Behalf Of Appellant 10.11.2020 None Present On Behalf Of Appellant 08.01.2021 None Present On Behalf Of Appellant 30.04.2021 None Present On Behalf Of Appellant 16.09.2021 None Present On Behalf Of Appellant 08.11.2021 None Present On Behalf Of Appellant 15.12.2021 None Present On Behalf Of Appellant 08.02.2022 None Present On Behalf Of Appellant 3. Even On 08.02.2022, No One Has Appeared On Behalf Of The Appellant. From The History Of Hearings Mentioned Above, It Can Be Seen That Sufficient Opportunity Has Already

Disallowance of Interest on Excise Duty of Rs.29,89,381/- 15. The CIT(A) has allowed interest of Rs.1,29,45,747/- on Excise duty. However, interest of Rs.29,89,381/- was not allowed as the same was shown by the appellant as payable as on 31.03.2012 due to changes in Union Budget. Therefore, the CIT(A) concluded that

DEPUTY COMMISSIONER OF INCOME TAX, CIRCLE-1, AURANGABAD, AURANGABAD vs. ENDURANCE TECHNOLIGIES LIMITED, AURANGABAD

In the result, all the appeals filed by the Revenue are dismissed

Bench: Shri R. K. Panda & Ms. Astha Chandrasr No 1

747/- and Rs.4,59,13,562/- is not allowable to the assessee for weighted deduction u/s 35(2AB) and the then Assessing officer was correct in disallowing the excess claim. 49. The Ld. Counsel for the assessee while supporting the order of the Ld. CIT(A) / NFAC submitted that since the order of Ld. CIT(A) / NFAC is in accordance

DEPUTY COMMISSIONER OF INCOME TAX, CIRCLE-1, AURANGABAD, AURANGABAD vs. ENDURANCE TECHNOLOGIES LIMITED, AURANGABAD

In the result, all the appeals filed by the Revenue are dismissed

Bench: Shri R. K. Panda & Ms. Astha Chandrasr No 1

747/- and Rs.4,59,13,562/- is not allowable to the assessee for weighted deduction u/s 35(2AB) and the then Assessing officer was correct in disallowing the excess claim. 49. The Ld. Counsel for the assessee while supporting the order of the Ld. CIT(A) / NFAC submitted that since the order of Ld. CIT(A) / NFAC is in accordance

M/S. ROHAN DEVELOPERS,PUNE vs. PR. COMMISSIONER OF INCOME-TAX -2, PUNE

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

Bench: Shri Inturi Rama Rao, Am & Shri S. S. Viswanethra Ravi, Jm आयकर अपील सं. / Ita No.459/Pun/2020 िनधा"रण वष" / Assessment Year : 2015-16 M/S. Rohan Developers, 1, Modibaug Commercial Building, Ganeshkhind Road, Shivajinagar, Pune-411016. .......अपीलाथ" / Appellant Pan : Aaffr5298C बनाम / V/S. Pr. Cit-2, ……""यथ" / Respondent Pune. Assessee By : None Revenue By : Shri Deepak Garg सुनवाई क" तारीख / Date Of Hearing : 14.12.2020 घोषणा क" तारीख / Date Of Pronouncement : 14.12.2020 आदेश / Order Per Inturi Rama Rao, Am: This Is An Appeal Filed By The Assessee Directed Against The Order Of The Ld. Pr. Commissioner Of Income Tax-2, Pune Dated 30.03.2020 Passed U/S 263 Of The Income Tax Act, 1961 (For Short “The Act”) For The Assessment Year 2015-16. 2. Briefly, The Facts Of The Case Are That The Appellant Is A Partnership Firm & Is Engaged In The Business Of Builders & Land Developers. The Return Of Income For The Assessment Year 2015-16 Was Filed On 27.09.2015 Through Electronic Mode Disclosing A Total Income Of Rs.3,32,39,320/-. Against The Said Return Of Income, The Assessment Was Completed By The Income Tax

747 (Gauhati); (ii) CIT vs. Sakthi Charities, 244 ITR 226; and, (iii) Rayon Silk Mills vs. CIT, 221 ITR 155. 8. In the present case on mere perusal of the impugned order, we find that there is no material or reference to any material on record suggesting that the provision for expenses of Rs.50,00,000/- is disallowable

L/H OF LATE SHRI TAJUDDIN M. SOMJEE, MRS. SHAHNAZ ALI MOHAMMAD SOMJEE,,PUNE vs. DEPUTY COMMISSIONER OF INCOME-TAX, CIRCLE - 2,, PUNE

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

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

section 54EC of the Act. Against that order, an appeal was preferred before the CIT(A), who had confirmed the action of AO and even on further appeal before the Tribunal, the orders of the lower authorities was confirmed. 3. While the matter stood thus, a notice u/s 274 r.w.s. 271(1)(c) of the Act dated 16.03.2012 was issued

DEPUTY COMMISSIONER OF INCOME-TAX vs. M/S. FINOLEX PLASSON INDUSTRIES PVT. LTD.,, PUNE

The appeals of the Revenue are dismissed

Bench: Shri D. Karunakara Rao, Am & Shri Vikas Awasthy, Jm

section 234C of the Act the interest is to be charged on the returned income. We find from the facts of the case that there is no tax due on the returned income and hence, no interest can be levied u/s 234C of the Act in the present case before us. We direct the AO to delete the levy

DEPUTY COMMISSIONER OF INCOME-TAX vs. M/S. FINOLEX PLASSON INDUSTRIES PVT. LTD.,, PUNE

The appeals of the Revenue are dismissed

Bench: Shri D. Karunakara Rao, Am & Shri Vikas Awasthy, Jm

section 234C of the Act the interest is to be charged on the returned income. We find from the facts of the case that there is no tax due on the returned income and hence, no interest can be levied u/s 234C of the Act in the present case before us. We direct the AO to delete the levy

FINOLEX PLASSON INDUSTRIES PVT. LTD.,,PUNE vs. DEPUTY COMMISSIONER OF INCOME-TAX,,

The appeals of the Revenue are dismissed

Bench: Shri D. Karunakara Rao, Am & Shri Vikas Awasthy, Jm

section 234C of the Act the interest is to be charged on the returned income. We find from the facts of the case that there is no tax due on the returned income and hence, no interest can be levied u/s 234C of the Act in the present case before us. We direct the AO to delete the levy

FINOLEX PLASSON INDUSTRIES PVT. LTD.,,PUNE vs. DEPUTY COMMISSIONER OF INCOME-TAX,,

The appeals of the Revenue are dismissed

Bench: Shri D. Karunakara Rao, Am & Shri Vikas Awasthy, Jm

section 234C of the Act the interest is to be charged on the returned income. We find from the facts of the case that there is no tax due on the returned income and hence, no interest can be levied u/s 234C of the Act in the present case before us. We direct the AO to delete the levy