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

sections": [ "263", "143(3)", "135", "37(1)", "142(1)", "80G", "80G(5)", "80G(1)", "37", "30", "36", "144C(13)", "143(2)", "115JB", "115JJB" ], "issues": "Whether CSR expenditure, even if disallowed

DY. COMMISSIONER OF INCOME TAX, CIRCLE-1(1), PUNE, PUNE vs. HONEYWELL AUTOMATION INDIA LIMITED, PUNE

In the result, the appeal of the Revenue is dismissed

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

disallowance, which is not the intention of Legislature. 19. On the basis of above discussion, in our view, authorities below have erred in denying claim of assessee under section 80G of the Act. We also note that authorities below have not verified nature of payments qualifying exemption under section 80G of the Act and quantum of eligibility as per section

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

In the result, the appeal of the assessee is allowed

disallowing the\nclaim of deduction u/s 80G of the Act by observing as under :\n“5.5 I have considered the submissions of the appellant, assessment order\nand facts of the case. Following aspects are noted in respect of issue of non-\nallowability of section 80G deduction on CSR spends:\n(i) CSR outlay is NOT a Donation:\nSection 80G deduction

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.

disallowance, which is not the intention of Legislature. 19. On the basis of above discussion, in our view, authorities below have erred in denying claim of assessee under section 80G of the Act. We also note that authorities below have not verified nature of payments qualifying exemption under section 80G of the Act and quantum of eligibility as per section

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

disallows deductions under section 80G for any trust or institution that spends more than 5% of its total income on religious

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

5. Decision\nI have carefully perused grounds of appeal, facts of the case, submissions\nmade by the Appellant, assessment order and other evidences on records.\n5. 1. Ground 1\nVide this Ground, the Appellant has challenged action of the AO in making\nthe disallowance of Rs.4,55,13,521/- u/s 80G with respect to the donations\nforming part of Corporate

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

disallowance, which is not the intention of Legislature. 19. On the basis of above discussion, in our view, authorities below have erred in denying claim of assessee under section 80G of the Act. We also note that authorities below have not verified nature of payments qualifying exemption under section 80G of the Act and 8 ITA.No.44/PUN./2024 quantum

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

5. Decision\nI have carefully perused grounds of appeal, facts of the case,\nsubmissions made by the Appellant, assessment order and other\nevidences on records.\n\n5. 1. Ground 1\nVide this Ground, the Appellant has challenged action of the\nAO in making the disallowance of Rs.4,55,13,521/- u/s 80G\nwith respect to the donations forming part

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

SHRI GANADHIPATI GANDHARACHARYA KUNTIUSAGAR VIDYA SODH SONSTHA,KOLHAPUR vs. ITO, EXEMPTION, PUNE, KOLHAPUR

Bench: Shri Manish Borad & Ms. Astha Chandra

5. The delay was neither intentional nor deliberate. It occurred due to reasons beyond our control, as explained below: 4.1 That as mentioned above I was deputed to look after tax and accounts matters of the trust since many years. 4.2 That, during the relevant period I was suffering from prolonged back pain, kidney-related problems and Umbilical hernia which

SHRI GANADHIPATI GANDHARACHARYA KUNTIUSAGAR VIDYA SODH SONSTHA,PUNE vs. ITO, EXEMPTION, PUNE, PUNE

Bench: Shri Manish Borad & Ms. Astha Chandra

5. The delay was neither intentional nor deliberate. It occurred due to reasons beyond our control, as explained below: 4.1 That as mentioned above I was deputed to look after tax and accounts matters of the trust since many years. 4.2 That, during the relevant period I was suffering from prolonged back pain, kidney-related problems and Umbilical hernia which

SHRI GANADHIPATI GANDHARACHARYA KUNTIUSAGAR VIDYA SODH SONSTHA,KOLHAPUR vs. ITO, EXEMPTION, PUNE, KOLHAPUR

Bench: Shri Manish Borad & Ms. Astha Chandra

5. The delay was neither intentional nor deliberate. It occurred due to reasons beyond our control, as explained below: 4.1 That as mentioned above I was deputed to look after tax and accounts matters of the trust since many years. 4.2 That, during the relevant period I was suffering from prolonged back pain, kidney-related problems and Umbilical hernia which

SHRI GANADHIPATI GANDHARACHARYA KUNTIUSAGAR VIDYA SODH SONSTHA,KOLHAPUR vs. ITO, EXEMPTION, PUNE, KOLHAPUR

Bench: Shri Manish Borad & Ms. Astha Chandra

5. The delay was neither intentional nor deliberate. It occurred due to reasons beyond our control, as explained below: 4.1 That as mentioned above I was deputed to look after tax and accounts matters of the trust since many years. 4.2 That, during the relevant period I was suffering from prolonged back pain, kidney-related problems and Umbilical hernia which

AGRA OBSTETRICAL AND GYNAECOLOGICAL SOCIETY,AGRA vs. PCIT, CENTRAL, PUNE

disallowance u/s 37(1) of the Act, the pharmaceutical company i.e\nEmcure Pharmaceuticals Ltd. has routed the expense of providing of\nfreebies through the assessee trust as it enables the Emcure\nPharmaceuticals Ltd. to claim an otherwise inadmissible expense as\ndeduction. Such act of the assessee trust of carrying the activity of\nproviding freebies at the behest of the pharmaceutical

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 144 cannot be arbitrary. It has to be reasonable and wellinformed. An adhoc disallowance of expenses is not justified even 5 ITA No.987/PUN/2024, AY 2017-18 under a best judgment assessment. Such a disallowance is a spiteful act and not a fair assessment of income. Therefore disallowance of Rs.8,74,57,590, being 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

disallow the claim made as business expenditure, but allow the claim of deduction under section 80G of the Act, on verification.(Emphasis supplied) 5

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

disallow the claim made as business expenditure, but allow the claim of deduction under section 80G of the Act, on verification.(Emphasis supplied) 5

INCOME TAX OFFICER (EXEMPTIONS) WARD, KOLHAPUR , KOLHAPUR vs. THE NEW MIRAJ EDUCATION SOCIETY, MIRAJ, DIST. SANGLI

In the result, the appeal of Revenue is dismissed

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

80G of the Income Tax Act, 1961 (“Act”). For A.Y. 2021-22, assessee filed its return of income on 30/12/2021 declaring total income of ₹36,460/- after 2 ITA.No.928/PUN/2025 (The New Miraj Education Society) claiming exemption u/s. 11 of the Act. The audit report in Form 10B was filed on 23/09/2022 with a delay of 268 days from