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 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

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

INCOME-TAX OFFICER, WARD - 2,, PANVEL vs. PRAMOD ARJUN THAKUR,, RAIGAD

Appeal is allowed in above terms

Bench: Shri S.S.Godara, Jm & Shri Dr. Dipak P. Ripote, Am आयकर अपीऱ सं. / Ita No.860/Pun/2019 ननधधारण वषा / Assessment Year : 2015-16

1. The respondent is an individual having income from house property, capital gains and other sources. The return of income for the year under appeal was filed by the appellant on 31.03.2017, declaring therein total income of Rs.7,78,000/-. Addition of Rs.6,54,61,100/- was made by the Id AO by relying upon the provisions of section 56

KISHOR NAMDEVRAO KACHI,,PUNE vs. INCOME-TAX OFFICER, WARD - 5(2),, PUNE

Appeal is allowed in above terms

Bench: Shri S.S.Godara, Jm & Shri Dr. Dipak P. Ripote, Am आयकर अपील सं./ Ita No.63/Pun/2018 धनधाारण वषा / Assessment Year : 2010-11

section 56(1)(vii)(b)(i) addition of Rs.1.20 crores in the course of assessment herein dated 27.02.2014; as upheld in the CIT(A)’s order. We deem it appropriate to extract the CIT(A)’s detail discussion in issue as follows :- “6.3 DECISION: I have perused the assessment order and the submission made by the appellant as above carefully

ACIT, CENTRAL CIRCLE-1, NASHIK, NASHIK vs. RAJENDRA RASIKLAL SHAH, NASHIK

Bench: Dr. Manish Borad & Ms. Astha Chandraआयकर अपील सं. / Ita No.1016/Pun/2024

1) of the Act, the assessee claimed that on 12.08.1997 unregistered agreement was entered into with the seller of the property and part consideration was paid through banking channel but the balance amount was payable since some contractual obligations on part of the seller regarding updation of land revenue records with names of original owners and obtaining relevant permissions were

SHRI MUKUND BHAVAN TRUST,PUNE vs. CIT(E), PUNE

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

Bench: Shri R. K. Panda & Ms. Astha Chandrashri Mukund Bhavan Trust Cit (Exemption), Pune 1105, Raviwar Peth, Mukund Vs. Bhavan, Pune – 411002 Pan: Aaats5170R (Appellant) (Respondent) Assessee By : Shri V.L. Jain Department By : Shri Mallikarjun Utture, Cit Date Of Hearing : 05-02-2025 Date Of Pronouncement : 29-04-2025 O R D E R

house hold activities), and Sannyasashram (renouncing material world), which is a materialistic arrangement for one social group to dominate another, and by reinforcing identity based on bodily categories. Thus, the entire concept itself is against the social development and not for any charity of the people at large at all. 2 Further verification shows that the Trust Deed contains

AKASH ,NOIDA vs. INCOME TAX OFFICER (IT), WARD-1, PUNE

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

Bench: SHRI SATBEER SINGH GODARA, JUDICIAL MEMBER AND DR.DIPAK P. RIPOTE (Accountant Member)

House No.1140, Sector-29, Officer(IT), Noida – 201303. Ward-1, Pune. Uttar Pradesh. PAN: AFIPA4977M Appellant/ Assessee Respondent / Revenue Assessee by None. Revenue by Ms. Neha Thakur – Addl.CIT(DR) Date of hearing 28/08/2024 Date of pronouncement 30/08/2024 आदेश/ ORDER PER DR. DIPAK P. RIPOTE, AM: Brief facts of the case : As per the assessment order, in this case, the assessee

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

house property and gains from business or profession and capital gains is to be assessed under the head 'income from other sources'. However, for applicability of Section 14 and thereafter Section 56, what is required is the receipt in the nature of income. In Circular No.447, it has been clearly stated "In view of this, it is clarified that such

DY. COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-1, AURANGABAD., AURANGABAD. vs. TAPADIYA CONSTRUCTION LTD, AURANGABAD

In the result, appeal of the Revenue is dismissed

Bench: Dr. Manish Borad & Shri Vinay Bhamore

vii) of sub-section (2) of section 56. 23 ITA.No.1375/PUN./2024 (Tapadiya Construction Ltd.) 14. We note that the seized diary based on which the amount of Rs. 1,37,73,000/- has been arrived by the search team, the Ld.CIT(A) has made a detailed discussion in para 5.4 of the impugned order wherein the Ld.CIT

M/S KIRAN SANRAN ASSOCIATES,PUNE vs. PRINCIPAL COMMISSIONER OF INCOME TAX (CENTRAL), PUNE, PUNE

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

Bench: Shri R. K. Panda & Ms Astha Chandraassessment Year : 2018-19

56,225/- 27,41,121/- 3.1 Further, on perusal of assessment records, it is found that there is substantial variation between consideration received or accrued and value adopted or assessed or assessable. The same difference is corroborated by the Index-II submitted with respect to the concerned sales. However, during the course of assessment proceedings, the assessee had relied

DCIT CIRCLE 1 NASHIK, NASHIK vs. SHREE SAI PROPERTIES, NASHIK

In the result, appeal of the Revenue is dismissed

Bench: Dr. Manish Borad & Shri Vinay Bhamore

1,2 and 4 against the deletion of addition of Rs.86,63,700/- and Rs.7,93,62,371/- made by the 35 ITA.No.987/PUN./2025 (M/s. Shree Sai Properties) Assessing Officer. We observe that the information contained in the alleged seized material is only having a reference of the words “367 Makhmalabad” and that referring to sale consideration received through

BRAHM PRECISION MATERIALS PVT LTD,AURANGABAD vs. CIT(A), NATIONAL FACELESS APPEAL CENTRE (NFAC) DELHI

In the result, appeal of the assessee for A

Section 36\n(1) (vii) of the Income-tax Act, and further in view of the interpretation\nas stated here-in-above. Therefore, the Tribunal has rightly allowed\nthe appeal of the assessee.\n10. The Apex Court in the case of Kerala State Industrial Development\nCorpn. Lid. v. CIT [2012] 349 ITR 365/25 taxmann.com 564, while\ndealing with the State

SANDVIK MACHINING SOLUTION AB, (FORMERLY KNOWN AS) SANDVIK TOLLING SEVERIGE AB),,PUNE vs. ASSISTANT COMMISSIONER OF INCOME-TAX, (IT), CIRCLE -2,, PUNE

In the result, the appeal of the assessee is allowed

Bench: Shri Anil Chaturvedi, Am & Shri S.S. Viswanethra Ravi, Jm

house developed production systems such as GSS and related applications. Apart from the aforesaid receipts, assessee had also received licence fee, and technical fee which were offered to tax at 10% including receipts of exports and raw-materials. The assessee was thereafter asked to show cause as to why the total receipts should not be considered as taxable income

BRAHM PRECISION MATERIALS PVT. LTD.,AURANGABAD vs. COMMISSIONER OF INCOME TAX (APPEALS), NATIONAL FACELESS APPEAL CENTRE, NEW DELHI

In the result, appeal of the assessee for A

Section 36\n(1) (vii) of the Income-tax Act, and further in view of the interpretation\nas stated here-in-above. Therefore, the Tribunal has rightly allowed\nthe appeal of the assessee.\n\n10. The Apex Court in the case of Kerala State Industrial Development\nCorpn. Lid. v. CIT [2012] 349 ITR 365/25 taxmann.com 564, while\ndealing with

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

house property u/s. 23 of the Act. The assessee’s arguments to this effect are rejected accordingly. 9. Lastly comes the issue of section 56(2)(vii) made applicable in assessee’s case on account of alleged difference between stamp valuation and actual purchase consideration qua the sale deed executed in the relevant previous year. 6 ITA.No.855/PUN/2019 Shri Bharat

SHRI MANOJ MADANLAL CHHAJED,PUNE vs. ASSISTANT COMMISSIONER OF INCOME TAX, CIRCLE -1(1)PUNE, PUNE

In the result, the appeal filed by the assessee in ITA

Bench: Shri Inturi Rama Rao & Shri S. S. Viswanethra Raviआयकर अपील सं. / It(Ss)A Nos.91 To 96/Pun/2022 िनधा"रण वष" / Assessment Years : 2012-13 To 2017-18 Shri Manoj Madanlal Vs. Acit, Central Circle- Chhajed, 1(1), Pune. 601, A-8 Building, Karishma Housing Society, Near Sangam Press, Kothrud, Pune- 411029. Pan : Aalpc4991M Appellant Respondent आयकर अपील सं. / It(Ss)A Nos.97 & 98/Pun/2022 िनधा"रण वष" / Assessment Years : 2012-13 & 2015-16 Acit, Circle-1(1), Pune. Vs. Shri Manoj Madanlal Chhajed, 601, A-8 Building, Karishma Housing Society, Near Sangam Press, Kothrud, Pune- 411029. Pan : Aalpc4991M Appellant Respondent आयकर अपील सं. / Ita No.725/Pun/2022 िनधा"रण वष" / Assessment Year: 2018-19 Shri Manoj Madanlal Vs. Acit, Circle-1(1), Pune. Chhajed, 601, A-8 Building, Karishma Housing Society, Near Sangam Press, Kothrud, Pune- 411029. Pan : Aalpc4991M Appellant Respondent

56,72,950 NIL 2013-14 24/01/2019 1,33,93,090 1,00,00,000 2014-15 24/01/2019 1,78,36,710 1,00,00,000 2015-16 24/01/2019 22,27,420 NIL 2016-17 24/01/2019 1,46,95,030 1,00,00,000 2017-18 24/01/2019 1,75,91,360 1,00,00,000 6 IT(SS)A Nos.91

BHUJPAL BROTHERS CONSTRUCTION COMPANY,PUNE vs. ITO WARD 3(5), PUNE

Appeal is allowed for statistical purpose in above terms

Bench: Shri S.S.Godara & Dr. Dipak P. Ripoteआयकरअपीलसं. / Ita No.21/Pun/2021 िनधा"रणवष" / Assessment Year : 2015-16 Bhujbal Brothers Construction The Income Tax Officer, Company, Vs Ward-3(5), Pune. Bhujbal House, S.No.28 , Karve Nagar, Pune – 411052. Pan: Aagfb 7974 A Appellant/ Assessee Respondent /Revenue Assessee By None. Revenue By Shri S P Walimbe – Dr Date Of Hearing 24/06/2022 Date Of Pronouncement 07/07/2022 आदेश/ Order Per S.S.Godara, Jm: This Assessee’S Appeal For Assessment Year 2015-16 Is Directed Against The Commissioner Of Income Tax(Appeals)-3, Pune’S Order Dated 04.11.2019 Passed In Case No.Pn/Cit(A)-3Ito Wd. 3(5)/388/2018-19 In Proceedings U/S.143(3) Of The Income Tax Act, 1961 [In Short “The Act”].

House, S.No.28 , Karve Nagar, Pune – 411052. PAN: AAGFB 7974 A Appellant/ Assessee Respondent /Revenue Assessee by None. Revenue by Shri S P Walimbe – DR Date of hearing 24/06/2022 Date of pronouncement 07/07/2022 आदेश/ ORDER Per S.S.Godara, JM: This Assessee’s appeal for Assessment Year 2015-16 is directed against the Commissioner of Income Tax(Appeals)-3, Pune’s order