CAPGEMINI TECHNOLOGY SERVICES INDIA LIMITED,PUNE vs. ASSISTANT COMMISSIONER OF INCOME TAX, PUNE

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

disallowed CSR expenditure of INR 22,81,29,964/-debited to the statement of profit and loss under section 37 of the Act. DRP rejected the claim of the assessee by saying that the donation is pursuant to the CSR policy of the company and lacks the test of voluntariness as required under section 80G

NYATI BUILDERS PRIVATE LIMITED,PUNE vs. ASSISSTANT COMMISSIONER OF INCOME TAX, PUNE

In the result, the appeal of the assessee is allowed

disallowed\nthe same u/s 37 while computing the income from business. However, the\nassessee claimed deduction of Rs.56,68,900/- u/s 80G of the Act in\nrespect of CSR expenditure of Rs.1,13,37,800/-, the details of which is\nprovided by the Ld. AO in para 2.3 of the assessment order. After\nanalyzing the provisions of section

ADVIK HI TECH PVT LTD,PUNE vs. DY.COMM.OF INCOME TAX, CIRCLE 8, PUNE, AKURDI PUNE

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

Bench: Shri R. K. Panda & Shri Vinay Bhamoreआयकर अपील सं. / Ita No.1158/Pun/2023 िनधा"रण वष" / Assessment Year : 2020-21 Advik Hi Tech Pvt. Ltd., Vs. Dcit, Circle-8, Pune. Gat No.357, Plot No.99, Village- Kharabwadi, Tal.- Khed, Chakan- 410501. Pan : Aacca3106E Appellant Respondent आयकर अपील सं. / Ita No.1330/Pun/2023 िनधा"रण वष" / Assessment Year : 2020-21 Dcit, Circle-8, Pune. Vs. Advik Hi Tech Pvt. Ltd., Gat No.357, Plot No.99, Village- Kharabwadi, Tal.- Khed, Chakan- 410501. Pan : Aacca3106E Appellant Respondent Assessee By : Shri Sharad A. Shah & Shri Rohit S. Tapadiya Revenue By : Shri Amol Khairnar Date Of Hearing : 21.11.2024 Date Of Pronouncement : 18.02.2025 आदेश / Order Per Vinay Bhamore, Jm: These Cross Appeals Filed By The Assessee As Well As By The Revenue Are Directed Against The Order Dated 16.10.2023 Passed By Ld.Cit(A)/Nfac For The Assessment Year 2020-21 Respectively.

disallowing an amount of INR 67,87,728/- claimed as deduction under section 80G of the Act, holding that the contributions

DANA ANAND INDIA PRIVATE LIMITED,PUNE vs. DCIT, AKURDI,PUNE

Bench: Shri R. K. Panda & Shri Vinay Bhamore

80G of the Act 1. The learned AO erred in disallowing deduction claimed under section 80G amounting to Rs.1,57,55,750/- in respect

DY. COMMISSIONER OF INCOME TAX, CIRCLE-1(1), PUNE, PUNE vs. CREDIT SUISSE SERVICES (INDIA) PRIVATE LIMITED , PUNE

Appeal is dismissed in above terms

Bench: Shri Rama Kanta Panda & Shri Satbeer Singh Godara

section 80G forms part of CSR payments ( keeping in mind ineligible deduction expressly provided u/s.80G), the same would already stand excluded while computing, Income under the head, “Income form Business and Profession". The effect of such disallowance

DEPUTY COMMISSIONER OF INCOME TAX, CIRCLE-8, PUNE, PUNE vs. ADVIK HI-TECH PVT. LTD., PUNE

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

section 80G forms part of CSR\npayments (keeping in mind ineligible deduction expressly\nprovided u/s.80G), the same would already stand excluded\nwhile computing, Income under the head, “Income form\nBusiness and Profession\". The effect of such disallowance

THE LIFE ETERNAL TRUST,PUNE vs. COMMISSIONER OF INCOME TAX (EXEMPTION),PUNE, 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.447/Pun/2025 The Life Eternal Trust, Vs. Cit, Exemption, Pune. Plot No.79, Sr. No.98, Right Bhusari Colony, Behind Lohiya Jain It Park, Kothrud, Pune- 411028. Pan : Aactt4211E Appellant Respondent Assessee By : Shri Sharad A. Shah Revenue By : Shri Amit Bobde Date Of Hearing : 17.09.2025 Date Of Pronouncement : 26.09.2025 आदेश / Order Per Vinay Bhamore, Jm: This Appeal Filed By The Assessee Is Directed Against The Order Dated 21.12.2024 Passed By Ld. Cit, Exemption, Pune Rejecting The Application For Registration U/S 80G(5) Of The It Act. 2. Facts Of The Case, In Brief, Are, That The Assessee Filed Its Application For Registration In Form No.10Ab Under Clause (Iii) Of First Proviso To Sub-Section (5) Of Section 80G Of The It Act On 29.06.2024. With A View To Verify The Genuineness Of Activities Of The Assessee & Fulfillment Of Conditions Laid Down In Clauses (I) To (V) Of Section 80G(5) Of The It Act, A Notice Was Issued Through

section 80G(58) of the Income-tax Act, 1961, which explicitly disallows deductions under section 80G for any trust or institution

SAI SERVICE PRIVATE LIMITED,PUNE vs. THE DEPUTY COMMISSIONER OF INCOME TAX, CIRCLE-10, PUNE

In the result, appeal of the assessee is partly allowed

Bench: Shri S.S.Godara & Dr. Dipak P. Ripoteआयकर अपील सं. / Ita Nos.1074 & 1075/Pun/2023 िनधा"रण वष" / Assessment Years : 2017-18 & 2018-19 Sai Service Private Limited, Dcit, Circle-10, Mumbai Pune Road, Vs Pune Phugewadi, Pune 411 012 Maharashtra Pan : Aabcs4998M Appellant/ Assessee Respondent /Revenue Assessee By Smt. Deepa Khare– Ar Revenue By Shri Sourabh Nayak- Dr Date Of Hearing 22/02/2024 Date Of Pronouncement 16/04/2024 आदेश/ Order Per Dr. Dipak P. Ripote, Am: These Two Appeals Filed By Assessee Are Against The Separate Orders Of Commissioner Of Income-Tax (Appeals) In The National Faceless Appeal Centre, Delhi Passed U/S.250 Of The Income-Tax Act, 1961 (Hereinafter Referred To As ‘The Act’) On 04.09.2023 & 18.09.2023 Respectively For Assessment Years 2017-18 & 2018-19. Since Some Grounds Of Appeal Are Common In All These Appeals, We Proceed To Dispose Of These Appeals By This Consolidated Order For The Sake Of Convenience. We Are Discussing A.Y.2017-18 Hereonwards.

80G during the course of assessment be allowed. 4. The appellant craves leave to add, amend, alter, delete or substitute all or any of the above grounds of appeal. 5. Such order and such other orders be passed as deem fit and proper.” 16. The Ground No.2 is regarding disallowance under section

SAI SERVICE PRIVATE LIMITED ,PUNE vs. THE DEPUTY COMMISSIONER OF INCOME TAX, CIRCLE-10, PUNE

In the result, appeal of the assessee is partly allowed

Bench: Shri S.S.Godara & Dr. Dipak P. Ripoteआयकर अपील सं. / Ita Nos.1074 & 1075/Pun/2023 िनधा"रण वष" / Assessment Years : 2017-18 & 2018-19 Sai Service Private Limited, Dcit, Circle-10, Mumbai Pune Road, Vs Pune Phugewadi, Pune 411 012 Maharashtra Pan : Aabcs4998M Appellant/ Assessee Respondent /Revenue Assessee By Smt. Deepa Khare– Ar Revenue By Shri Sourabh Nayak- Dr Date Of Hearing 22/02/2024 Date Of Pronouncement 16/04/2024 आदेश/ Order Per Dr. Dipak P. Ripote, Am: These Two Appeals Filed By Assessee Are Against The Separate Orders Of Commissioner Of Income-Tax (Appeals) In The National Faceless Appeal Centre, Delhi Passed U/S.250 Of The Income-Tax Act, 1961 (Hereinafter Referred To As ‘The Act’) On 04.09.2023 & 18.09.2023 Respectively For Assessment Years 2017-18 & 2018-19. Since Some Grounds Of Appeal Are Common In All These Appeals, We Proceed To Dispose Of These Appeals By This Consolidated Order For The Sake Of Convenience. We Are Discussing A.Y.2017-18 Hereonwards.

80G during the course of assessment be allowed. 4. The appellant craves leave to add, amend, alter, delete or substitute all or any of the above grounds of appeal. 5. Such order and such other orders be passed as deem fit and proper.” 16. The Ground No.2 is regarding disallowance under section

SAI SERVICE AGENCY(B0MBAY) P LTD,PUNE vs. DEPUTY COMMISSIONER OF INCOME-TAX, CIRCLE -8,, PUNE

Appeal is partly allowed in above terms

Bench: Shri S.S.Godara & Shri G.D.Padmashaliआयकर अपीलसं. / Ita No.490/Pun/2021 िनधा"रणवष" / Assessment Year : 2017-18 Sai Service Agency (Bombay) The Dcit, Circle-8, Pune. Pvt. Ltd., Vs Mumbai Pune Road, . Phugewadi, Pune – 411012. Pan: Aaccs 5991 F Appellant/ Assessee Respondent /Revenue Assessee By Shri Deepa Khare – Adv. Revenue By Shri Arvind Desai – Dr Date Of Hearing 17/08/2022 Date Of Pronouncement 30/08/2022 आदेश/ Order Per S.S.Godara, Jm: This Assessee’S Appeal For Assessment Year 2010-11 Is Directed Against The Commissioner Of Income Tax(Appeals), Pune- 8’S Order Dated 05.08.2019 Passed In Case No.Pn/Cit(A)-8/Dcitc Cir-1(2)/202/18-19/188, In Proceedings U/S.143(3) R.W.S. 147 Of The Income Tax Act, 1961 [In Short “The Act”].

disallowance of Rs.51,356/- keeping in mind smallness thereof. Rejected accordingly. 7. Next comes section 80G disallowance of Rs.11 lakhs

ASSISTANT COMMISSIONER OF INCOMETAX, EXEMPTIONS, CIRCLE,PUNE, PUNE vs. SHREE WARANA VIBHAG SHIKSHAN MANDAL , WARNANAGAR

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

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

section 12A and 80G registration certificate, return of income, balance sheet etc. were all available on the records of the Department (Kolhapur AO) and therefore the Ld. AO was completely unjustified in making an ad hoc disallowance

KARMYOGI SHANKARRAOJI PATIL SSK LTD.,PUNE vs. THE DEPUTY COMMISSIONER OF INCOME TAX, CIRCLE-7, PUNE

Bench: Shri Partha Sarathi Chaudhury & Shri G. D. Padmahshaliआयकर अपऩल सं. / Ita No. 411 & 412/Pun/2023 निर्धारण वर्ा / Assessment Year : 2009-10 & 2012-13 Karmyogi Shankarraoji Patil Ssk Ltd., A/P. Mahatmaphulenagar, Bijwadi, Tal. Indapur, Dist. - Pune Pin – 413106 Pan: Aaaai0225N . . . . . . . अपीलार्थी / Appellant

Disallowance of contribution to Chief Minister Relief Fund : 32. Now, coming to the next issue of contribution to Chief Minister’s Fund, wherein though the addition needs to be confirmed in the hands of assessee, but the matter is set aside to the file of Assessing Officer to allow the consequent deduction under section 80G

KARMYOGI SHANKARRAOJI PATIL SSK LTD.,PUNE vs. THE DEPUTY COMMISSIONER OF INCOME TAX, CIRCLE-7, PUNE

Bench: Shri Partha Sarathi Chaudhury & Shri G. D. Padmahshaliआयकर अपऩल सं. / Ita No. 411 & 412/Pun/2023 निर्धारण वर्ा / Assessment Year : 2009-10 & 2012-13 Karmyogi Shankarraoji Patil Ssk Ltd., A/P. Mahatmaphulenagar, Bijwadi, Tal. Indapur, Dist. - Pune Pin – 413106 Pan: Aaaai0225N . . . . . . . अपीलार्थी / Appellant

Disallowance of contribution to Chief Minister Relief Fund : 32. Now, coming to the next issue of contribution to Chief Minister’s Fund, wherein though the addition needs to be confirmed in the hands of assessee, but the matter is set aside to the file of Assessing Officer to allow the consequent deduction under section 80G

DY.CIT, CIR.-3(1), DHULE, DHULE vs. SHIRPUR SHETKARI SAHAKARI SAKHAR KARKHANA LTD.,, DAHIWAD

In the result, all the appeals of assessee and Revenue are allowed as indicated above

Bench: Ms. Sushma Chowla, Jm & Shri Anil Chaturvedi, Am

disallow the claim made as business expenditure, but allow the claim of deduction under section 80G of the Act, on verification

SHRI DUDHGANGA VEDGANGA SAH: SAKHAR KARKHANA LTD,KOLHAPUR vs. ACIT, KOLHAPUR

In the result, all the appeals of assessee and Revenue are allowed as indicated above

Bench: Ms. Sushma Chowla, Jm & Shri Anil Chaturvedi, Am

disallow the claim made as business expenditure, but allow the claim of deduction under section 80G of the Act, on verification

SIDHESHWAR SAH. SAKHAR KARKHANA LTD.,AURANGABAD vs. DCIT, S.R.-2,, AURANGABAD

In the result, all the appeals of assessee and Revenue are allowed as indicated above

Bench: Ms. Sushma Chowla, Jm & Shri Anil Chaturvedi, Am

disallow the claim made as business expenditure, but allow the claim of deduction under section 80G of the Act, on verification

SHRI CHH SAHU SAHAKARI SAKHAR KARKHANA LTD,KOLHAPUR vs. DCIT, KOLHAPUR

In the result, all the appeals of assessee and Revenue are allowed as indicated above

Bench: Ms. Sushma Chowla, Jm & Shri Anil Chaturvedi, Am

disallow the claim made as business expenditure, but allow the claim of deduction under section 80G of the Act, on verification

VITHAL RAO SHINDE SSK LTD,SOLAPUR vs. ACIT, SOLAPUR

In the result, all the appeals of assessee and Revenue are allowed as indicated above

Bench: Ms. Sushma Chowla, Jm & Shri Anil Chaturvedi, Am

disallow the claim made as business expenditure, but allow the claim of deduction under section 80G of the Act, on verification