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

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 of failure to deduct TDS thereon contending that the case of the assessee is covered under proviso to section

PUNE ZILHA MADHYAWATI SAKAKAK PUNE,PUNE vs. ITO, WARD 6(3), PUNE

In the result, appeal of the assessee is allowed

Bench: Dr.Dipak P. Ripote & Shri Vinay Bhamoreआयकर अपील सं. / Ita No.322/Pun/2025 िनधा"रण वष" / Assessment Year: 2019-20 Pune Zilla Madhyawati V The Income Tax Officer, Sakakak, S Ward-6(3), Pune. 92 Ranjan Co-Op Society, Shukrawar Peth, Shukrawar Peth S.O., Pune – 411002. Maharashtra. Pan: Aaatp6962E Appellant/ Assessee Respondent / Revenue

92 Ranjan Co-op Society, Shukrawar Peth, Shukrawar Peth S.O., Pune – 411002. Maharashtra. PAN: AAATP6962E Appellant/ Assessee Respondent / Revenue Assessee by CA-Sarang Gudhate and Ashwini V. Shendye – Advocate – AR’s Revenue by Shri Ratnakar Shelake – Addl.JCIT(DR) Date of hearing 30/04/2025 Date of pronouncement /04/2025 आदेश/ ORDER PER DR. DIPAK P. RIPOTE, AM: This is an appeal filed

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

section 36(1)(va) of the Act and withdrawal of deduction claimed towards Health & Education Cess amounting to INR 24,70,183. 10. The Ld DRP and the Ld. AO have grossly erred in considering the income u/s 143(1)(a) of the Act and consequently disallowing PF contribution received from employees of INR 53,92

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

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

92,709\nservices\n40(a)(i): Sum payable outside India or to a Non-\n49,93,112\n49,93,112\nresident\nTotal\n1,78,75,505\n4,79,34,420\n1.2\nAbove mentioned amounts referred to the provisions amounts / accrued\nexpenses, hence disallowed under section

DCIT-CIRCLE 7 PUNE, BODHI TOWER SALISBURY PARK PUNE vs. TRIO CHEMSUCROTECH ENG. PROJECTS PVT. LTD, PUNE

92,146/-and provision for expenses of Rs.2,31,13,761/- making together total disallowance of Rs.26,55,05,907/-. It is an undisputed fact that the Appellant Company had debited its account by bogus expenditure of Rs.26,55,05,907/-. At the time of survey, in the statement recorded of Mr. Nitin Deshpande, Managing Director of the appellant company

UTTAM ENERGY LIMITED,PUNE vs. ACIT CIRCLE-12, PUNE

Appeal of the Assessee is partly allowed

Bench: Dr.Dipak P. Ripote & Shri Vinay Bhamoreआयकर अपील सं. / Ita No.2033/Pun/2019 िनधा"रण वष" / Assessment Year: 2015-16 Uttam Energy Limited, The Acit, Circle-12, Mahendra Chamber, Mayfair V Pune. Co-Op Housing Society, S A-4, Dhole Patil Road, Pune – 411001. Pan: Aabcu4100H Appellant/ Revenue Respondent /Assessee Assessee By Shri Ch Naniwadekar & Kiran Sanmane – Ar;S Revenue By Shri Deepak Garg – Cit Date Of Hearing 16/05/2024 Date Of Pronouncement 30/05/2024 आदेश/ Order Per Dr. Dipak P. Ripote, Am: This Appeal Has Been Filed By The Assessee Against The Final Assessment Order Of The Learned Acit, Circle-12, Pune Passed U/Sec. 143(3) R.W.S. 144C(13) Of The Of The Income Tax Act, 1961 (In Short "The Act") After Giving Effect To The Learned Drp’S Order Dated 24.09.2019. 1.1 The Assessee Has Raised The Following Grounds Of Appeal :

92, 92C, 92D and 92E, "specified domestic transaction" in case of an assessee means any of the following transactions, not being an international transaction, namely:— (i) 38[***] (ii) any transaction referred to in section 80A; (iii) any transfer of goods or services referred to in sub-section (8) of section 80-IA; (iv) any business transacted between the assessee

PRAJ INDUSTRIES LIMITED,PUNE vs. DCIT, CENTRAL CIRCLE 1(1), PUNE, PUNE

In the result, the appeal of assessee is allowed

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

section 14A of the Act. Accordingly, the submission of the Ld. DR in this regard is rejected. 8.2 We also do not find any substance in the contention of the Ld. DR that the details of employees handling the investments of the company were not furnished. We notice that in its note (copy at page 92 of the paper book

NELSON GLOBAL PRODUCTS INDIA PRIVATE LIMITED,PUNE, MAHARAHSTRA vs. DEPUTY COMMISSIONER OF INCOME TAX, PUNE

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

Bench: Dr.Manish Borad

section 37 of the Act: Erred on the facts and in circumstances of the case and in law by confirming the disallowance for the warranty expenses amounting to Rs.12,32,732 without appreciating the fact that these are actual settlement of warranty expenses with the customers of the Appellant. Erred on the facts in circumstances of the case

SWAROOP AGROCHEMICAL INDUSTRIES,NASHIK vs. ACIT, CIRCLE-1, NASHIK

In the result, appeal of the Assessee is allowed

disallowance\nof prior period of expenses of Rs.7,92,413/- is also deleted.\nGround Nos.6 raised by the assessee is also allowed. Ground\nNo.7 is general in nature, needs no adjudication since the\nsame is against the application of provisions of 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

DHAS KISHOR RAMCHANDRA, AURANGABAD vs. DWARKAPRASAD BHIKULAL SONI, JALNA

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

Bench: SHRI R. K. PANDA (Vice President), SHRI VINAY BHAMORE (Judicial Member)

92,000- under section 50CA of the Income Tax Act, 1961 without appreciating the fact that the 2 valuation for the purpose of section 56(2)(x) and 50CA is the Fair Market Value [FMV] which is derived as prescribed method of valuation in accordance with the Rule 11U & 11UA of Income Tax Rule, 1962 with respect to the unquoted

DESAI INFRA PROJECTS(I) PRIVATE LIMITED,PUNE vs. PCIT, CENTRAL PUNE, PUNE

In the result, appeal of the assessee is allowed

Bench: Dr. Manish Borad & Ms. Astha Chandra

92,277/- The fact that the assessee has received exempt income of Rs. 1,44,42,319/- from AOP/BOI and no disallowance has been made by the assessee u/s 14A of the Act as seen from the computation of income. As the assessee has not disallowed u/s 14A voluntarily, provisions of sub-section

DCIT CIRCLE-1, NASHIK vs. JYOTI PAPER UDYOG LIMITED, NASHIK

In the result, appeal of the Revenue is dismissed

92 BA in the Income-tax Act, 1961 by Finance Act, 2012 and the reason for its omission and the effective dates of operation of such amendments have not been considered at all.”\n3. At the outset of hearing, no one attended on behalf of the Assessee for hearing. This was the fifth hearing when no one appeared on behalf

DEPUTY COMMISSIONER OF INCOME-TAX, CIRCLE - 8,, PUNE vs. M/S. FINOLEX CABLES LTD,, PUNE

In the result, appeal of the Revenue is partly allowed

Bench: Shri R.S. Syal, Hon. Vice-& Shri Partha Sarathi Chaudhury, Hon.Dcit, Circle-8, Vs M/S. Finolex Cables Ltd., Pune. 26/27, Mumbai Pune Road, Pimpri, Pune. Pan: Aaacf 2637 D Appellant/Revenue Respondent /Assessee Assessee By : Shrij.G. Pendse, Ar Revenue By : Shrim.M. Chate, Cit Dr Date Of Hearing : 24/05/2023 Date Of Pronouncement : 26/05/2023 Order Perpartha Sarathi Chaudhury, Jm: This Appeal Preferred By The Revenue Emanates From The Order Of Commissioner Of Income Tax (Appeals)-13, Pune, Dated 19.05.2022For A.Y.2013-14 As Per The Following Revised Grounds Of Appeal:- “1(A) Whether On The Facts & Circumstances Of The Case & In Law, The Ld. Cit(A) Has Erred In Allowing The Claim Of The Assessee U/S 80Ic On Income Earned From Sale Of Scrap Without Appreciating The Fact That Assesses Itself Categorized Income Earned From Sale Of Scrap As Other Income In The Profit & Loss Statement Of Roorkee Unit Undertaking & The Same Is Not Derived From The Activities Of The Eligible Business. 1(B) Whether On The Facts & Circumstances Of The Case & In Law, The Ld.Cit(A)Has Erred In Ignoring The Decision Of Hon'Ble Supreme Court In The Case Of Liberty India Vs. Cit (2009) 317 Itr 218 (Sc) Wherein The Words "Derived From' Is Explained? 1(C) Whether On The Facts & Circumstances Of The Case & In Law, The Ld. Cit(A) Was Justified In Allowing The Claim Of The Assessee U/S 80Ic On Sale Of Scrap, Relying On The Decision Of The Hon'Ble Madras High Court In The Case Of M/S Fenner India Ltd. (241 Itr 803) Without Appreciating The Facts That The Same Has Been M/S. Finolex Cables Ltd.

section 92(2) of the Act? 3(b) Whether on the facts and in circumstances of the case, Ld. CIT(A) was justified in placing reliance on the transfer pricing orders for the subsequent assessment years 2016-17 and 2017- 18 for allowing the appeal of the assessee for assessment year 2013-14 without appreciating that the principle

DCIT, PUNE vs. BAJAJ ALLIANZ LIFE INSURANCE COMPANY LIMITED, PUNE

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

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

section 14A read with rule 8D. Rejecting the various explanations given by the assessee and observing that the decision of the Tribunal in assessee’s own case has not attained finality, the Assessing Officer worked out the disallowance u/s 14A read with rule 8D at Rs.12,53,92

DCIT, PUNE vs. BAJAJ ALLIANZ LIFE INSURANCE COMPANY LIMITED, PUNE

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

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

section 14A read with rule 8D. Rejecting the various explanations given by the assessee and observing that the decision of the Tribunal in assessee’s own case has not attained finality, the Assessing Officer worked out the disallowance u/s 14A read with rule 8D at Rs.12,53,92

ASSTT. COMMISSIONER OF INCOME TAX, CIRCLE -1, KOLHAPUR, KOLHAPUR vs. MAHALAXMI INFRA PROJECTS PRIVATE LIMITED, KOLHAPUR, MAHARASHTRA

In the result, the appeal filed by the Revenue is partly allowed for

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

section 14A r.w. Rule 8D made the disallowance of Rs.6,65,484/- on the ground that assessee has made investment of Rs.6,89,03,906/- and has incurred interest expenditure on borrowed funds to the tune of Rs.2,93,08,592/-. We find the ld. CIT(A) deleted the addition, the reasons of which have already been reproduced in preceding

SEMPERTRANS INDIA PRIVATE LIMITED,ROHA vs. INCOME-TAX OFFICER, PANVEL

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

92(c) (1) (f) of the\nAct. The impugned order of the Tribunal holds that the method adopted by the Revenue to\ndetermine the ALP was alien to the methods prescribed under Section 92C of the Act. In the\nabove circumstances, the Tribunal declined to restore the issue to the Assessing Officer for re-\ndetermining the ALP by adopting