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

property or proprietary right in the software or the documentation. It is specifically provided that ‘Dakota’ retains sole and exclusive title to all portions of software and documentation and any copies thereof. 62. Now, coming to the second agreement which has been referred to by both the learned authorized representatives, which is placed at pages 14 to 17 of Paper

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

property or proprietary right in the software or the documentation. It is specifically provided that ‘Dakota’ retains sole and exclusive title to all portions of software and documentation and any copies thereof. 62. Now, coming to the second agreement which has been referred to by both the learned authorized representatives, which is placed at pages 14 to 17 of Paper

ALNESH AKIL SOMJI,PUNE vs. ASSISTANT COMMISSIONER OF INCOME TAX, PUNE

In the result, both the appeals filed by the assessee are partly allowed for statistical purposes

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

section 57(iii) of the IT Act, deduction of interest paid shall be allowed as deduction only if it is laid out wholly and exclusively for the purpose of making or earning such income. As is evident from the above table, the assessee has received interest @21% on the amount of loans given to M/s Gagan I Land Township

ALNESH MOHAMADAKIL SOMJI,PUNE vs. ASSISTANT COMMISSIONER OF INCOME TAX, PUNE

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

section 57(iii) of the IT Act, deduction of interest paid shall be allowed as deduction only if it is laid out wholly and exclusively for the purpose of making or earning such income. As is evident from the above table, the assessee has received interest @21% on the amount of loans given to M/s Gagan I Land Township

INCOME-TAX OFFICER, WARD - 2(3),, SOLAPUR vs. SHRI. ULHAS MALLIKARJUN PATIL,, SOLAPUR

Appeal is partly allowed for statistical purpose in above terms

Bench: Shri S.S.Godara & Shri Inturi Rama Raoआयकर अपीलसं. / Ita No.1751/Pun/2018 िनधा"रणवष" / Assessment Year : 2013-14 The Income Tax Officer, Shri Ulhas Mallikarjun Patil, Ward-2(3), Solapur, Vs Block No.3, Sunandan . Complex, Near Dayanand College, Ravivar Peth, Solapur – 413004. Pan: Akepp 1943 P Appellant/ Assessee Respondent /Revenue Assessee By Shri Krishna V Gujarathi – Ar Revenue By Shri Ramnath P Murkunde – Dr Date Of Hearing 05/09/2022 Date Of Pronouncement 06/09/2022 आदेश/ Order Per S.S.Godara, Jm: This Revenue’S Appeal For Assessment Year 2013-14 Is Directed Against The Commissioner Of Income Tax(Appeals)-7, Pune’S Order Dated 31.08.2018 Passed In Case No.Pn/Cit(A)-7/Wd- 2(3)/10434/2016-147, In Proceedings U/S.143(3) Of The Income Tax Act, 1961 [In Short “The Act”].

house property would be Rs. 4,87,892/- whereas the appellant has shown income from business at Rs. 2,40,450/- as per income & expenditure account. The income & expenditure account depicts that there is receipt of rent, salary and dividend. Apparently, there are no other receipts which would depicts complex nature of letting out to treat rental receipt as business

M/S. VIKRAM DEVELOPERS & PROMOTERS,,PUNE vs. DEPUTY COMMISSIONER OF INCOME TAX,,

In the result, the appeal of the assessee in ITA No

Bench: Shri D. Karunakara Rao, Am & Shri Partha Sarathi Chaudhury, Jm आयकर अपील सं. / Ita Nos.2795 & 2796/Pun/2016 िनधा"रण वष" / Assessment Years : 2012-13 & 2013-14 M/S. Vikram Developers & Promoters, 19, Shrikrishna Heights, Ganeshkhind Road, Shivaji Nagar, Pune-411005. .......अपीलाथ" / Appellant Pan : Aagfv4298R बनाम / V/S. Dcit, Central Circle-2(1), ……""यथ" / Respondent Pune. Assessee By : Shri Kishor Phadke Revenue By : Shri Milind Chahure सुनवाई क" तारीख / Date Of Hearing : 17.10.2019 घोषणा क" तारीख / Date Of Pronouncement : 14.11.2019 आदेश / Order Per D. Karunakara Rao, Am: There Are Two Appeals Under Consideration Filed By The Assessee Against The Common Orders Of The Cit(A)-12, Pune Dated 08.09.2016 For The Assessment Years 2012-13 & 2013-14 Respectively. Preliminary Issue - Condonation Of Delay – Both Appeals 2. Before Us, At The Outset, Ld. Counsel For The Assessee Submitted That The Both The Appeals Could Not Be Filed In Time & The Said Appeals Were Filed With The Delay Of 01 Day. In This Regard, Ld. Counsel For The Assessee Submitted That The Delay Is Unintentional & Prayed For Condoning The Same. 3. After Hearing Both The Sides & Considering The Smallness Of Delay In Filing Of Both The Appeals, We Condone The Delay & Proceed To Adjudicate The Appeals Of The Assessee In The Following Paragraphs. 4. The Facts & Grounds Are Common In Both The Appeals, Therefore, Both The Appeals Were Heard Together & Are Being Disposed Of By This Composite Order. Accordingly, The Appeal-Wise Adjudication Is Taken Up In The Following Paragraphs.

201 and 308 of 2012, where this very aspect is answered in the following manner: “36. There is yet another reason for coming to the aforesaid conclusion. Take a scenario where an Assessee, following the project completion method of accounting, has completed the housing project approved by the local authority complying with all the conditions as set out in section

VIKRAM DEVELOPERS & PROMOTERS,,PUNE vs. DEPUTY COMMISSIONER OF INCOME TAX,,

In the result, the appeal of the assessee in ITA No

Bench: Shri D. Karunakara Rao, Am & Shri Partha Sarathi Chaudhury, Jm आयकर अपील सं. / Ita Nos.2795 & 2796/Pun/2016 िनधा"रण वष" / Assessment Years : 2012-13 & 2013-14 M/S. Vikram Developers & Promoters, 19, Shrikrishna Heights, Ganeshkhind Road, Shivaji Nagar, Pune-411005. .......अपीलाथ" / Appellant Pan : Aagfv4298R बनाम / V/S. Dcit, Central Circle-2(1), ……""यथ" / Respondent Pune. Assessee By : Shri Kishor Phadke Revenue By : Shri Milind Chahure सुनवाई क" तारीख / Date Of Hearing : 17.10.2019 घोषणा क" तारीख / Date Of Pronouncement : 14.11.2019 आदेश / Order Per D. Karunakara Rao, Am: There Are Two Appeals Under Consideration Filed By The Assessee Against The Common Orders Of The Cit(A)-12, Pune Dated 08.09.2016 For The Assessment Years 2012-13 & 2013-14 Respectively. Preliminary Issue - Condonation Of Delay – Both Appeals 2. Before Us, At The Outset, Ld. Counsel For The Assessee Submitted That The Both The Appeals Could Not Be Filed In Time & The Said Appeals Were Filed With The Delay Of 01 Day. In This Regard, Ld. Counsel For The Assessee Submitted That The Delay Is Unintentional & Prayed For Condoning The Same. 3. After Hearing Both The Sides & Considering The Smallness Of Delay In Filing Of Both The Appeals, We Condone The Delay & Proceed To Adjudicate The Appeals Of The Assessee In The Following Paragraphs. 4. The Facts & Grounds Are Common In Both The Appeals, Therefore, Both The Appeals Were Heard Together & Are Being Disposed Of By This Composite Order. Accordingly, The Appeal-Wise Adjudication Is Taken Up In The Following Paragraphs.

201 and 308 of 2012, where this very aspect is answered in the following manner: “36. There is yet another reason for coming to the aforesaid conclusion. Take a scenario where an Assessee, following the project completion method of accounting, has completed the housing project approved by the local authority complying with all the conditions as set out in section

ASSISTANT COMMISSIONER OF INCOME-TAX vs. SINHAGAD TECHNICAL EDUCATION SOCIETY,, PUNE

Accordingly, additional ground No.3 by the assessee is allowed

Bench: Ms. Sushma Chowla, Jm & Shri Anil Chaturvedi, Am आयकर अपील सं. / Ita Nos. 2075 To 2077 & 2110/Pun/2014 "नधा"रण वष" / Assessment Years: 2007-08 To 2009-10 Sinhgad Technical Education Society, S. No. 44/1, Vadgaon ( Budruk), Off. Sinhagad Road, Pune-411 041. Pan : Aabts9900Q. …....अपीलाथ" / Appellant बनाम / V/S.

house at Warje and the flats at Sion, Mumbai, which are among the properties in respect of which excess rent is stated to have been paid to the Managing Trustee, Shri M. N.Navale in fact belonged not to M.N.Navale (Individual) but to the M.N.Navale (Bigger HUF) Which Was not one of the persons specified in S 13(3). The appellant

SINHGAD TECHNICAL EDUCATION SOCIETY,,PUNE vs. ASSISTANT COMMISSIONER OF INCOME-TAX,,

Accordingly, additional ground No.3 by the assessee is allowed

Bench: Ms. Sushma Chowla, Jm & Shri Anil Chaturvedi, Am आयकर अपील सं. / Ita Nos. 2075 To 2077 & 2110/Pun/2014 "नधा"रण वष" / Assessment Years: 2007-08 To 2009-10 Sinhgad Technical Education Society, S. No. 44/1, Vadgaon ( Budruk), Off. Sinhagad Road, Pune-411 041. Pan : Aabts9900Q. …....अपीलाथ" / Appellant बनाम / V/S.

house at Warje and the flats at Sion, Mumbai, which are among the properties in respect of which excess rent is stated to have been paid to the Managing Trustee, Shri M. N.Navale in fact belonged not to M.N.Navale (Individual) but to the M.N.Navale (Bigger HUF) Which Was not one of the persons specified in S 13(3). The appellant

SINHGAD TECHNICAL EDUCATION SOCIETY,,PUNE vs. DEPUTY COMMISSIONER OF INCOME-TAX,,

Accordingly, additional ground No.3 by the assessee is allowed

Bench: Ms. Sushma Chowla, Jm & Shri Anil Chaturvedi, Am आयकर अपील सं. / Ita Nos. 2075 To 2077 & 2110/Pun/2014 "नधा"रण वष" / Assessment Years: 2007-08 To 2009-10 Sinhgad Technical Education Society, S. No. 44/1, Vadgaon ( Budruk), Off. Sinhagad Road, Pune-411 041. Pan : Aabts9900Q. …....अपीलाथ" / Appellant बनाम / V/S.

house at Warje and the flats at Sion, Mumbai, which are among the properties in respect of which excess rent is stated to have been paid to the Managing Trustee, Shri M. N.Navale in fact belonged not to M.N.Navale (Individual) but to the M.N.Navale (Bigger HUF) Which Was not one of the persons specified in S 13(3). The appellant

ASSISTANT COMMISSIONER OF INCOME-TAX vs. SINHAGAD TECHNICAL EDUCATION SOCIETY,, PUNE

Accordingly, additional ground No.3 by the assessee is allowed

Bench: Ms. Sushma Chowla, Jm & Shri Anil Chaturvedi, Am आयकर अपील सं. / Ita Nos. 2075 To 2077 & 2110/Pun/2014 "नधा"रण वष" / Assessment Years: 2007-08 To 2009-10 Sinhgad Technical Education Society, S. No. 44/1, Vadgaon ( Budruk), Off. Sinhagad Road, Pune-411 041. Pan : Aabts9900Q. …....अपीलाथ" / Appellant बनाम / V/S.

house at Warje and the flats at Sion, Mumbai, which are among the properties in respect of which excess rent is stated to have been paid to the Managing Trustee, Shri M. N.Navale in fact belonged not to M.N.Navale (Individual) but to the M.N.Navale (Bigger HUF) Which Was not one of the persons specified in S 13(3). The appellant

SINHGAD TECHNICAL EDUCATION SOCIETY,,PUNE vs. DEPUTY COMMISSIONER OF INCOME-TAX,,

Accordingly, additional ground No.3 by the assessee is allowed

Bench: Ms. Sushma Chowla, Jm & Shri Anil Chaturvedi, Am आयकर अपील सं. / Ita Nos. 2075 To 2077 & 2110/Pun/2014 "नधा"रण वष" / Assessment Years: 2007-08 To 2009-10 Sinhgad Technical Education Society, S. No. 44/1, Vadgaon ( Budruk), Off. Sinhagad Road, Pune-411 041. Pan : Aabts9900Q. …....अपीलाथ" / Appellant बनाम / V/S.

house at Warje and the flats at Sion, Mumbai, which are among the properties in respect of which excess rent is stated to have been paid to the Managing Trustee, Shri M. N.Navale in fact belonged not to M.N.Navale (Individual) but to the M.N.Navale (Bigger HUF) Which Was not one of the persons specified in S 13(3). The appellant

SINHGAD TECHNICAL EDUCATION SOCIETY,,PUNE vs. DEPUTY COMMISSIONER OF INCOME-TAX,,

Accordingly, additional ground No.3 by the assessee is allowed

Bench: Ms. Sushma Chowla, Jm & Shri Anil Chaturvedi, Am आयकर अपील सं. / Ita Nos. 2075 To 2077 & 2110/Pun/2014 "नधा"रण वष" / Assessment Years: 2007-08 To 2009-10 Sinhgad Technical Education Society, S. No. 44/1, Vadgaon ( Budruk), Off. Sinhagad Road, Pune-411 041. Pan : Aabts9900Q. …....अपीलाथ" / Appellant बनाम / V/S.

house at Warje and the flats at Sion, Mumbai, which are among the properties in respect of which excess rent is stated to have been paid to the Managing Trustee, Shri M. N.Navale in fact belonged not to M.N.Navale (Individual) but to the M.N.Navale (Bigger HUF) Which Was not one of the persons specified in S 13(3). The appellant

RAJESH MOHANLAL BORA,,NASHIK vs. INCOME-TAX OFFICER, WARD - 1 (1),, NASHIK

Bench: Hon’Ble Shri S. S. Godara & Shri G. D. Padmahshaliआयकर अपऩल सं. / Ita No.1609/Pun/2019 निर्धारण वर्ा / Assessment Year : 2014-15 Rajesh Mohanlal Bora, 401, Rushiraj House, Thatte Nagar, College Road, Nashik – 422 005 Pan : Abcpb5526F . . . . . . . अपऩलधथी / Appellant बनाम / V/S. Ito Ward- 1(1) Nashik . . . . . . . प्रत्यथी / Respondent द्वारा/ Appearances Assessee By : Shri Pramod Shingte Revenue By : Shri M. G. Jasnani सपिवधई की तधरऩख / Date Of Conclusive Hearing : 03/10/2022 घोर्णध की तधरऩख / Date Of Pronouncement : 20/12/2022 आदेश / Order Per G. D. Padmahshali, Am; The Present Appeal Of The Assessee Is Assailed Against The Order Of Commissioner Of Income Tax (Appeals)-1, Nashik [For Short “Cit(A)”] Dt. 23/08/2019 Passed U/S 250 Of The Income-Tax Act, 1961 [For Short “The Act”] Which Dove Out Of Order Of Assessment Dt. 29/12/2016 Passed U/S 143(3) Of The Act By Income Tax Officer 1(1), Nashik [For Short “Ao”] For The Assessment Year [For Short “Ay”] 2014-15. Itat-Pune Page 1 Of 8

House, Thatte Nagar, College Road, Nashik – 422 005 PAN : ABCPB5526F . . . . . . . अपऩलधथी / Appellant बनाम / V/s. ITO Ward- 1(1) Nashik . . . . . . . प्रत्यथी / Respondent द्वारा/ Appearances Assessee by : Shri Pramod Shingte Revenue by : Shri M. G. Jasnani सपिवधई की तधरऩख / Date of conclusive Hearing : 03/10/2022 घोर्णध की तधरऩख / Date of Pronouncement : 20/12/2022 आदेश / ORDER PER G. D. PADMAHSHALI, AM; The present appeal

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

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

201 (Allahabad)\n3. Commissioner of Income-tax Vs. MAC Public Charitable Trust (2022)\n144 taxmann.com 54 (Madras)\n4. Nayyar Patel Vs. Assistant Commissioner of Income-tax (2022) 137\ntaxmann.com 149 (Kerala)\n5. Bannalal Jat Constructions (P) Ltd. Vs. Assistant Commissioner of\nIncome-tax (2019) 106 taxтапп.com 128 (SC)\n6. Sri Vidyaranya Seva Sangha Vs. Commissioner of Income

SHAMKANT KESHAV KOTKAR (PROP. NANDAN BUILDERS),PUNE vs. PR. COMMISSIONER OF INCOME TAX (CENTRAL), PUNE

In the result, appeal of the assessee is allowed

Bench: SHRI VINAY BHAMORE (Judicial Member)

201 pages. ITA No.1358/PUN/2025 [A] 2.1 The ld.AR Mr.Kishor Phadke submitted that in this case, original assessment order was passed on 12.12.2019 for A.Y.2017- 18 under section 143(3) of the Act, accepting returned income at Rs.2,18,66,125/-. In this case, Assessee had e-filed return of income on 07.11.2017 declaring total income at Rs.2

NILESH POPATLAL GADA,PUNE vs. INCOME TAX OFFICER WARD 2(4) , PUNE

In the result, appeal of the assessee is Partly Allowed

Bench: DR.DIPAK P. RIPOTE (Accountant Member), SHRI VINAY BHAMORE (Judicial Member)

201, Sai Siddhi Congress s Ward-2(4), Pune. Bhavan, Shivaji Nagar, Pune – 411005. PAN: AHOPS1114Q Appellant/ Assessee Respondent / Revenue Assessee by Shri Neelesh Khandelwal – AR Revenue by Shri A.D.Kulkarni – Addl.CIT(DR) Date of hearing 18/11/2024 Date of pronouncement 20/12/2024 आदेश/ ORDER PER DR. DIPAK P. RIPOTE, AM: This is an appeal filed by the assessee against the order

INDIAN MEDICAL ASSOCIATION PUNE BRANCH,SHUKRAWAR PETH vs. DCIT EXEMPTION CIRCLE, PUNE, SWARGATE

In the result, all the 5 appeals filed by the assessee are allowed

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

House, Tilak Road, Pune – 411002 PAN : AAATI2653M (Appellant) (Respondent) Assessee by : Shri Nikhil S Pathak Department by : Shri Ramnath P Murkunde Date of hearing : 14-07-2025 Date of pronouncement : 31-07-2025 O R D E R PER R.K. PANDA, V.P: The above batch of 5 appeals filed by the assessee are directed against the separate orders dated