JOHN DEERE EQIPMENT P. LTD.,,PUNE vs. DEPUTY DIRECTOR OF INCOME-TAX,,

In the result, all the appeals of assessee are allowed

Bench: Ms. Sushma Chowla, Jm & Shri Anil Chaturvedi, Am आयकर अपीऱ सं. / Ita Nos.905 & 906/Pun/2015 यििाारण वषा / Assessment Years :2007-08 & 2008-09

199 (Bangalore – Trib.) and in the case of Secondment of skilled personnel for rendering services, amount received was taxable in the hands of overseas company and he stated that in such scenario, the assessee was liable to deduct tax at source. When the hearing was commenced on the next day, the learned Departmental Representative for the Revenue stressed that

JOHN DEERE INDIA PVT. LTD.,,PUNE vs. DEPUTY DIRECTOR OF INCOME-TAX,,

In the result, all the appeals of assessee are allowed

Bench: Ms. Sushma Chowla, Jm & Shri Anil Chaturvedi, Am आयकर अपीऱ सं. / Ita Nos.905 & 906/Pun/2015 यििाारण वषा / Assessment Years :2007-08 & 2008-09

199 (Bangalore – Trib.) and in the case of Secondment of skilled personnel for rendering services, amount received was taxable in the hands of overseas company and he stated that in such scenario, the assessee was liable to deduct tax at source. When the hearing was commenced on the next day, the learned Departmental Representative for the Revenue stressed that

M/S. GREAT FORTUNE INVESTMENTS AND INFRASTRUCTURE PVT.LTD,,NASHIK vs. ASSISTANT COMMISSIONER OF INCOME-TAX, CIRCLE - 1,, NASHIK

The appeal of the assessee is allowed

Bench: Shri S.S.Viswanethra Ravi, Hon’Ble Jm & Dr. Dipak P. Ripote, Hon’Ble Am आयकरअपीलसं. / Ita No.2325/Pun/2017 निर्ाारण वषा / Assessment Year : 2014-15 Great Fortune Investments & The Assistant Commissioner Of Infrastructure Pvt. Ltd., Vs Income Tax, Shop No.6, Rushiraj Heights, Near Cirlce-1, Nashik. Nmc Water Tank, Parijat Nagar, Mahatma Nagar, Nahik. Pan: Aaccg 6406 F Appellant/ Assessee Respondent /Revenue Assessee By Shri Sanket M Joshi – Ar Revenue By Shri S.P.Walimbe - Dr Date Of Hearing 10/02/2022 Date Of Pronouncement 08/04/2022

house property. However, it is the decision of the co-ordinate Bench in the case of Makrupa Chemicals (P) Ltd. (2007) 108 ITD 95/12 SOT 68 (Mum) that the standard rent is the upper limit for determining the annual value. The above synopsis goes well with the decisions of the Apex Court in the case of Dewan Daulat Rai Kapoor

DCIT, SWARGATE PUNE vs. GRIHUM HOUSING FINANCE LIMITED, PUNE

In the result, the Cross Objection filed by the assessee is allowed and the appeal filed by the Revenue is dismissed

Bench: Shri R. K. Panda & Ms Astha Chandraassessment Year : 2019-20

Housing Finance Limited ITO, Ward 1, Ahmednagar 602, 6th Floor, Zero One IT Park, Vs. Mundhva Road, Ghorpadi, Pune – 411036 PAN: AACCG2265N (Cross Objector) (Respondent) Assessee by : S/Shri Nikhil Mutha and Abhilash Hiran Department by : Shri Ramnath P Murkunde Date of hearing : 08-05-2025 Date of pronouncement : 12-06-2025 O R D E R PER R.K. PANDA

M.M. PATEL PUBLIC CHARITABLE TRUST,SOLAPUR vs. PCIT- CENTRAL, PUNE, PUNE

In the result, the appeal of the assessee is partly allowed

199 and Allahabad High Court in the case of Oxford Academy for\nCareer Development v. Chief CIT [20091.315 ITR 382\n29. All the three High Courts after examining the issue, in the light of the\nobject of Section 12A of the Act and Section 21 of the General Clauses Act\nheld that the order of the CIT passed under Section

AIDS SOCIETY OF INDIA,MUMBAI vs. THE PRINCIPAL COMMISSIONER OF INCOME TAX (CENTRAL), PUNE

House, Tilak Road, Shukrawar Peth, Pune 411 002, Maharashtra PAN : AAATP1435C Vs. Pr.CIT (Central), Pune\nAppellant Respondent\nआयकर अपील सं. / ITA No.522/PUN/2023\n2. The Mumbai Obstetrics and Gynaecological Society, C-114, Ist Floor, D-wing Entrance, Trade World, Kamala City, Senapati Bapat Marg, Low Parel (W), Mumbai-400 013 Maharashtra PAN : AAATT4562C Vs. Pr.CIT (Central), Pune\nAppellant Respondent\nआयकर अपील

PRITESH RATANSHI VED,PUNE vs. INCOME TAX OFFICER, WARD 1(2), JALGAON

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

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

199, Navipeth, M. G. Road, Natwar Talkies, Jalgaon- 425001. PAN : ADOPV6298A Appellant Respondent Assessee by : Shri Nikhil S. Pathak Revenue by : Shri Shashank Ojha Date of hearing : 21.08.2025 Date of pronouncement : 17.11.2025 आदेश / ORDER PER VINAY BHAMORE, JM: This appeal filed by the assessee is directed against the order dated 12.06.2025 passed by Ld. CIT(A)/NFAC for the assessment

BHARAT KESHAVLAL SHAH,,PUNE vs. PR. COMMISSIONER OF INCOME-TAX -3,, PUNE

Appeal is partly allowed in above terms

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

199 (1) of the Act. The issue thus raised be deleted and proper relief be granted to the assessee. 3 ITA.No.855/PUN/2019 Shri Bharat Keshavlal Shah, Pune. 7. Issue no 11 raised on account of deemed rent not included in stock in trade is not as per provisions stated under section 23 of the Act. The issue hence raised should

M/S. FIS SOLUTIONS (INDIA) PVT.LTD, (FROMERLY KNOWN AS SUNGARD SOLUTIONS INDIA PVT.LTD,),PUNE vs. DEPUTY COMMISSIONER OF INCOME-TAX, CIRCLE - 1(2),, PUNE

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

Bench: Shri R.S.Syal, Vp & Shri Partha Sarathi Chaudhury, Jm आयकर अपीऱ सं. / Ita No. 1695/Pun/2018 नििाारण वषा / Assessment Year : 2014-15 M/S. Fis Solutions (India) Private Limited. Formerly Known As Sungard Solutions (India) Private Limited. Westend Centre One, Survey No. 169/1, Sector Ii, Aundh, Pune-411 007. Pan : Aaace7476K .......अऩीऱाथी / Appellant बिाम / V/S. The Deputy Commissioner Of Income Tax, Circle 1(2), Pune. ……प्रत्यथी / Respondent

property led solutions and end-to end solutions, strategic acquisitions and financial year 2010-11 is an exceptional year of operation of Persistent Systems. We find support from the decision of 3DPLM Software Solutions Ltd. (supra) at para 17 Page 13 of the paper book as under: “17. Persistent Systems Ltd. 17.1.1 This company was selected

BANSILAL RAMNATH AGARWAL CHARITABLE TRUST,PUNE vs. CIT (EXEMPTION), PUNE

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

Bench: Shri R. K. Panda & Ms. Astha Chandraassessment Year : 2020-21 Bansilal Ramnath Agarwal Charitable Trust Cit (Exemption), 251, Budhwar Peth, City Post Chowk, Vs. Pune Pune – 411002 Pan: Aaatb4383K (Appellant) (Respondent) Assessee By : Shri Kishor B Phadke Department By : Shri Amol Khairnar, Cit-Dr Date Of Hearing : 11-12-2025 Date Of Pronouncement : 28-01-2026 O R D E R Per R.K. Panda, V.P:

1) to show that before passing the final order under that section, the Commissioner must necessarily and in all cases record final conclusions above the points in controversy before him. As already noted by us above, we would have expected him to record final 41 conclusions, which he thought proper if he was to settle the assessment finally but since

CHANDRAKANT GULABRAO BORDE,,PUNE vs. INCOME-TAX OFFICER, WARD - 13(1),, PUNE

In the result, appeal of the assessee is allowed

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

199 ITR 351. 11. On going through the facts of the case narrated above, we are of the opinion that the additional ground raised by the assessee is required to be admitted for adjudication by virtue of binding decisions on the same. 12. We heard both the parties on this limited issue of validity of reassessment proceedings and perused

KALU NAMDEO NANDGUDE,,PUNE vs. INCOME-TAX OFFICER,,

In the result, appeal of assessee is partly allowed

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

199 has held that where the agreement to sell has been executed and the registered sale deed is executed at later date, the date of agreement to sell has to be considered for computing Long Term Capital Gain. 4. On the other hand Shri Sanjeev Ghei representing the Department vehemently defended the order of Commissioner of Income Tax (Appeals

INCOME TAX OFFICER, WARD-6(3), INCOME TAX DEPARTMENT, PUNE vs. KALAWATI VIJAYKUMAR AGARWAL, PUNE

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

Bench: Shri R. K. Panda & Ms Astha Chandraassessment Year : 2021-22

199, Ganesh Peth, Pune – 411002 PAN: AAQPA9323E (Appellant) (Respondent) Assessee by : Shri Krishna V Gujarathi Department by : Shri Ramnath P Murkunde Date of hearing : 03-07-2024 Date of pronouncement : 13-09-2024 O R D E R PER ASTHA CHANDRA, JM : This appeal filed by the Revenue is directed against the order dated 11.07.2023 of the CIT(A) / NFAC

KEDAR ARVIND SARASWATE,,PUNE vs. INCOME-TAX OFFICER,,

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

Bench: Shri R.S.Syal, Vp & Shri Partha Sarathi Chaudhury, Jm

house property and capital gain and other sources. During the year under consideration, the assessee has declared income from capital gains, on which he claimed the deduction u/s.54B of the Income Tax Act, 1961 (hereinafter referred to as ‘the Act’) by investing the amount of capital gain by purchasing agricultural land. The Assessing Officer in the order passed u/s.143

INCOME-TAX OFFICER WARD 2(3),, SOLAPUR vs. KAPURBA AND COMPANY, BARSHI, SOLAPUR

In the result, the cross objection filed by the assessee is dismissed

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

section 2(47) of the Act. 6. We note that the assessee is a firm, engaged in the business of purchase and sale of land. The assessee conducts its business under the name and style as “Kapurba and Company”. The assessee filed its return of income declaring a total income of Rs.10,16,327/- which was processed u/s. 143(1

DEPUTY COMMISSIONER OF INCOME-TAX vs. SHRI MUKUND JAISHANKAR DHARIYA,, PUNE

In the result, appeal of the Revenue is allowed for statistical

Bench: Shri D.Karunakara Rao, Am & Shri Vikas Awasthy, Jm आयकर आयकर अपील आयकर आयकर अपील अपील संसंसंसं. / Ita No.330/Pun/2015 अपील िनधा"रण िनधा"रण वष" िनधा"रण िनधा"रण वष" वष" / Assessment Year : 2010-11 वष"

Housing Society, Shivajinagar, Pune – 411 015 …. ""यथ" / Respondent PAN : AAPPD8665F Assessee by : Shri C.V. Chitale Revenue by : Shri Achal Sharma सुनवाई क" तारीख / घोषणा क" तारीख / Date of Hearing : 09.04.2018 Date of Pronouncement: 11 .04.2018 आदेश आदेश / ORDER आदेश आदेश PER D. KARUNAKARA RAO, AM : These are the cross appeals filed against the order of CIT(A)-3, Pune, dated

MUKUND DHARIYA,,PUNE vs. DEPUTY COMMISSIONER OF INCOME-TAX,,

In the result, appeal of the Revenue is allowed for statistical

Bench: Shri D.Karunakara Rao, Am & Shri Vikas Awasthy, Jm आयकर आयकर अपील आयकर आयकर अपील अपील संसंसंसं. / Ita No.330/Pun/2015 अपील िनधा"रण िनधा"रण वष" िनधा"रण िनधा"रण वष" वष" / Assessment Year : 2010-11 वष"

Housing Society, Shivajinagar, Pune – 411 015 …. ""यथ" / Respondent PAN : AAPPD8665F Assessee by : Shri C.V. Chitale Revenue by : Shri Achal Sharma सुनवाई क" तारीख / घोषणा क" तारीख / Date of Hearing : 09.04.2018 Date of Pronouncement: 11 .04.2018 आदेश आदेश / ORDER आदेश आदेश PER D. KARUNAKARA RAO, AM : These are the cross appeals filed against the order of CIT(A)-3, Pune, dated