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

1), End User License was granted by Dakota Software Corporation under and subject to Master Agreement, as referred in the paras above and statement of work between Dakota Software Corporation and any other legal entity which was licensing access and use of software and instruction to access or use software. Then under clause 2.1 it is provided the access

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

1), End User License was granted by Dakota Software Corporation under and subject to Master Agreement, as referred in the paras above and statement of work between Dakota Software Corporation and any other legal entity which was licensing access and use of software and instruction to access or use software. Then under clause 2.1 it is provided the access

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

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

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

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

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

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.

1)(c) will not attracted vis-à-vis these properties. 6.9. The next contention of the appellant is that even if excess rent was paid to the trustee, the only effect of this would be that the trust would be denied the benefit of Section 11. But no addition can be made to the total income of the trust

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.

1)(c) will not attracted vis-à-vis these properties. 6.9. The next contention of the appellant is that even if excess rent was paid to the trustee, the only effect of this would be that the trust would be denied the benefit of Section 11. But no addition can be made to the total income of the trust

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.

1)(c) will not attracted vis-à-vis these properties. 6.9. The next contention of the appellant is that even if excess rent was paid to the trustee, the only effect of this would be that the trust would be denied the benefit of Section 11. But no addition can be made to the total income of the trust

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.

1)(c) will not attracted vis-à-vis these properties. 6.9. The next contention of the appellant is that even if excess rent was paid to the trustee, the only effect of this would be that the trust would be denied the benefit of Section 11. But no addition can be made to the total income of the trust

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.

1)(c) will not attracted vis-à-vis these properties. 6.9. The next contention of the appellant is that even if excess rent was paid to the trustee, the only effect of this would be that the trust would be denied the benefit of Section 11. But no addition can be made to the total income of the trust

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.

1)(c) will not attracted vis-à-vis these properties. 6.9. The next contention of the appellant is that even if excess rent was paid to the trustee, the only effect of this would be that the trust would be denied the benefit of Section 11. But no addition can be made to the total income of the trust

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

1. On the facts and circumstances of the case the learned Commissioner of Income Tax (Appeals) has erred in denying the appellant the carry forward of House Property loss amounting to Rs.2,00,000/- without appreciating the facts of the case in the proper perspectives. Therefore, the appellant requests your honour to allow the loss under House Property

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

In the result, appeal of the assessee is allowed

Bench: Dr.Manish Borad

House, Tilak Road, Maharashtra PAN : AAATI2653M Appellant Respondent Assessee by : Shri Nikhil S. Pathak Shri Dayanand Jawalikar Revenue by : Date of hearing : 10.06.2025 Date of pronouncement : 16.06.2025 आदेश / ORDER PER DR. MANISH BORAD, ACCOUNTANT MEMBER : This appeal filed by the assessee pertaining to the assessment year 2021-22 is directed against the order dated 28.02.2025 of Addl/JCIT(A)-5, Delhi

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

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.

1) of the Act and subsequently, the assessment was completed under section.143(3) of the Act vide order dated 30.3.2016 by accepting the returned income except making of disallowance of non payment of MVAT and service tax under section.43B of the Act. The deduction claimed under Chapter VIA under section 80IB(10) in respect of housing project namely; KIrishna Regency

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.

1) of the Act and subsequently, the assessment was completed under section.143(3) of the Act vide order dated 30.3.2016 by accepting the returned income except making of disallowance of non payment of MVAT and service tax under section.43B of the Act. The deduction claimed under Chapter VIA under section 80IB(10) in respect of housing project namely; KIrishna Regency