REHAU POLYMERS PVT.LTD,,PUNE vs. ASSISTANT COMMISSIONER OF INCOME-TAX, CIRCLE - 8,, PUNE

Bench: Shri R. K. Panda & Shri Vinay Bhamore

house. It was submitted that these services pertained to the internal systems and processes of the Rehau Group. It was submitted that the assessee has received various benefits by receipt of these services as without receiving such services, the assessee could not have carried out its business operations successfully in India, since Rehau India depends solely on technical support

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

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

92C(1) of the Act. Ld. Counsel for\nthe assessee made reference to various documents filed in the\npaper book in support of its contention that genuine claim of\nIntra Group Services expenditure has been made and there\nare various areas for which the costs are incurred by AE at\nthe Head office level by appointing an expert team

M/S. EATON TECHNOLOGIES PRIVATE LTD.,,PUNE vs. ASSISTANT COMMISSIONER OF INCOME-TAX,,

Appeal of the assessee is partly allowed for statistical purposes

Bench: Shri R.S.Syal, Vp & Shri Partha Sarathi Chaudhury, Jm आयकर अपील सं. / Ita No. 519/Pun/2015 धनधाारण वषा / Assessment Year : 2010-11

section 92C(2) of the Act. 14. That on the facts and circumstances of the case and in law, the AO has erred in not giving full credit for advance tax amounting to Rs.88,53,478 and self-assessment tax amounting to Rs.1,88,55,880 while determining the total tax liability of the Appellant. Each of the above grounds

DEPUTY COMMISSIONER OF INCOME-TAX, CIRCLE- 1(1), PUNE vs. M/S. BHAIRAVNATH SUGAR WORKS LTD., PUNE

In the result, the appeal is dismissed

Bench: Shri R.S. Syal & Shri S.S. Viswanethra Raviनिर्धारण वषा / Assessment Year : 2013-14 Dcit, Circle 1(1), Vs. M/S. Bhairavanath Sugar Works Ltd., Pune S.No. 21/2, Sawant Corner, Pune-Mumbai Bypass Road, Katraj, Pune. Pan: Aadcb0529M Appellant Respondent Assessee By Shri B.C. Malakar Revenue By Smt. Divya Bhajpai Date Of Hearing 10-06-2021 Date Of Pronouncement 11-06-2021 आदेश / Order Per R.S.Syal, Vp : This Appeal By The Revenue Is Directed Against The Order Dated 23.12.2019 Passed By The Ld. Cit(A) U/S.143(3) Read With Section 144C(3) Of The Income-Tax Act, 1961 (Hereinafter Also Called „The Act‟) In Relation To The Assessment Year 2013- 14. 2. This Appeal Was Filed Belatedly By 68 Days. The Ld. Dr Explained The Lockdown Due To Covid-19 As The Reason For The Late Filing Of The Appeal. The Ld. Ar Did Not Object

section 92C, the other method for determination of the arm's length price in relation to an international transaction or a specified domestic transaction shall be any method which takes into account the price which has been charged or paid, or would have been charged or paid, for the same or similar uncontrolled transaction, with or between non-associated enterprises

M/S. SAVA MEDICA LTD,,PUNE vs. ASSISTANT COMMISSIONER OF INCOME TAX,, PUNE

In the result, the appeal for the A

Bench: Shri R.S. Syal & Shri S.S. Viswanethra Raviआयकर अपील सं. / Ita Nos.738, 739 & 740/Pun/2017 िनधा"रण वष" / Assessment Years : 2011-12, 2012-13 & 2013-14

House, 3rd Floor, 2(1), Pune Lawani Plaza, B-Wing, Plot No.57/58, Sakorenagar, Viman Nagar, Pune – 411007 PAN: AANCS8819F Appellant Respondent Assessee by : Shri Kishor Phadke Revenue by : Shri Sangram Gaikwad Date of hearing : 25-08-2021 Date of pronouncement : 30-08-2021 आदेश / ORDER PER R.S.SYAL, VP : These three appeals by the assessee are directed against the separate final

M/S. SAVA MEDICA LTD,,PUNE vs. ASSISTANT COMMISSIONER OF INCOME TAX,, PUNE

In the result, the appeal for the A

Bench: Shri R.S. Syal & Shri S.S. Viswanethra Raviआयकर अपील सं. / Ita Nos.738, 739 & 740/Pun/2017 िनधा"रण वष" / Assessment Years : 2011-12, 2012-13 & 2013-14

House, 3rd Floor, 2(1), Pune Lawani Plaza, B-Wing, Plot No.57/58, Sakorenagar, Viman Nagar, Pune – 411007 PAN: AANCS8819F Appellant Respondent Assessee by : Shri Kishor Phadke Revenue by : Shri Sangram Gaikwad Date of hearing : 25-08-2021 Date of pronouncement : 30-08-2021 आदेश / ORDER PER R.S.SYAL, VP : These three appeals by the assessee are directed against the separate final

M/S. SAVA MEDICA LTD,,PUNE vs. ASSISTANT COMMISSIONER OF INCOME TAX,, PUNE

In the result, the appeal for the A

Bench: Shri R.S. Syal & Shri S.S. Viswanethra Raviआयकर अपील सं. / Ita Nos.738, 739 & 740/Pun/2017 िनधा"रण वष" / Assessment Years : 2011-12, 2012-13 & 2013-14

House, 3rd Floor, 2(1), Pune Lawani Plaza, B-Wing, Plot No.57/58, Sakorenagar, Viman Nagar, Pune – 411007 PAN: AANCS8819F Appellant Respondent Assessee by : Shri Kishor Phadke Revenue by : Shri Sangram Gaikwad Date of hearing : 25-08-2021 Date of pronouncement : 30-08-2021 आदेश / ORDER PER R.S.SYAL, VP : These three appeals by the assessee are directed against the separate final

VISTEON ENGINEERING CENTER (INDIA) PRIVATE LTD.,,PUNE vs. ASSISTANT COMMISSIONER OF INCOME-TAX,,

Accordingly, the appeal of Revenue is dismissed

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

92C (2) of the Act. 11. Initiation of penalty proceedings The learned ACIT erred on the facts and in law In initiating penalty proceedings section 271 (1) (c) of the Act. 12. Levy of interest obligation on account of transfer pricing adjustment The learned ACIT has erred on the facts and in law while levying interest under section 234B

ASSISTANT COMMISSIONER OF INCOME-TAX vs. VISTEON ENGG. CENTER (I) PVT. LTD.,, PUNE

Accordingly, the appeal of Revenue is dismissed

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

92C (2) of the Act. 11. Initiation of penalty proceedings The learned ACIT erred on the facts and in law In initiating penalty proceedings section 271 (1) (c) of the Act. 12. Levy of interest obligation on account of transfer pricing adjustment The learned ACIT has erred on the facts and in law while levying interest under section 234B

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