INCOME TAX OFFICER , JALNA vs. VIKRAM TEA PROCESSOR PRIVATE LIMITED , JALNA

In the result, both the appeals filed by the Revenue are dismissed

Bench: Shri R. K. Panda & Ms Astha Chandraassessment Year : 2013-14

u/s 92CA of the Act. We appropriate method and proposed an upward adjustment of Rs.4,73,46,877/-. We find the Ld. CIT(A) deleted the addition made by the Assessing Officer on the ground that clause (i) of section 92BA of the Act has been omitted by the Finance Act, 2017 w.e.f. 01.04.2017. The reasons given

INCOME TAX OFFICER WARD 1 JALNA, JALNA vs. VIKRAM TEA PROCESSOR PRIVATE LIMITED, JALNA

In the result, both the appeals filed by the Revenue are dismissed

Bench: Shri R. K. Panda & Ms Astha Chandraassessment Year : 2013-14

u/s 92CA of the Act. We appropriate method and proposed an upward adjustment of Rs.4,73,46,877/-. We find the Ld. CIT(A) deleted the addition made by the Assessing Officer on the ground that clause (i) of section 92BA of the Act has been omitted by the Finance Act, 2017 w.e.f. 01.04.2017. The reasons given

LEAR AUTOMOTIVE INDIA P. LTD. ,PUNE vs. ASSISTANT COMMISSIONER OF INCOME TAX, CIRCLE-8, PUNE, PUNE

271(1)(c) of\nthe Act.\nPrayer\nThe Appellant prays that the initiation of penalty proceedings u/ 274 r.w.s.\n271(1)(c) of the Act by the Ld. AO is not warranted and hence the Ld. AO\nshould be directed to drop the penalty proceedings.\nThe above grounds are independent of and without prejudice to each other.\nThe Appellant craves

RENISHAW METROLOGY SYSTEMS LTD,,PUNE vs. DEPUTY COMMISSIONER OF INCOME-TAX, CIRCLE - 5,, PUNE

In the result, appeal of the assessee is dismissed

Bench: Shri Satbeer Singh Godara & Dr. Dipak P. Ripoteआयकर अपीलसं. / Ita No.619/Pun/2021 िनधा"रण वष" / Assessment Year : 2013-14 Renishaw Metrology Systems The Dy.Commissioner Limited, V Of Income Tax, Circle- S.No.283, Hissa No.2, S.No.284, S 5, Pune. Hissa No.2 & 3A, Raisoni Estate, Taluk – Mulshi, Dist-Pune. Pan: Aabcr6361F Appellant/ Assessee Respondent /Revenue Assessee By Shri Ajit Jain & Shri Siddesh Chaugule – Ar’S Revenue By Shri Suhas Kulkarni – Addl. Cit(Dr) Date Of Hearing 04/01/2024 Date Of Pronouncement 24/01/2024

10B of the Rules; 3.3 rejecting the use of multiple year data i.e. contemporaneous data in the transfer pricing study report maintained as per Section 92D of the Act read with Rule 1OD of the Rules used for determining the arm’s length price of the international transaction of the Appellant; 3.4 violating the principle of “Rule of Consistency” while

M/S PERSISTENT SYSTEMS LIMITED,PUNE vs. ASSESSMENT UNIT, INCOME-TAX DEPARTMENT, PUNE

In the result, appeal of the Assessee is Partly Allowed

Bench: Shri S.S.Godara & Dr. Dipak P. Ripoteआयकरअपीलसं. / Ita No.692/Pun/2022 िनधा"रणवष" / Assessment Year : 2018-19 M/S.Persistent Systems Assessment Unit, Income Limited, V Tax Department. “Bhageerath” 402, Senapati S Bapat Road, Pune – 411016. Pan: Aabcp 1209 Q Appellant/ Assessee Respondent /Revenue Assessee By Shri Dhanesh Bafna& Shriaditya Vaidya– Ar’S Revenue By Shri Suhas Kulkarni - Irs Addl Commissioner Of Income Tax Date Of Hearing 26/09/2023 Date Of Pronouncement 02/11/2023 आदेश/ Order Per Dr. Dipak P. Ripote, Am: This Appeal Filed By The Assessee Is Directed Against The Assessment Order, Dated 20.07.2022 Under Section 143(3) R.W.S. 144C(13) Read With Section 144B Of The Income Tax Act, 1961 For A.Y.2018-19. The Assessee Has Raised The Following Grounds Of Appeal: “Ground 1: Order Is Invalid / Non Est  On The Facts & In The Circumstances Of The Case & In Law, The Assessment Unit (‘Au’) Has Erred In Passing The Draft Assessment M/S.Persistent Systems Limited [A]

penalty proceedings under Section 274 r.w.s 270A of the Act.” 6 M/s.Persistent Systems Limited [A] Brief facts of the case : 2. The Assessee is a Public Limited Company which is listed on Bombay Stock exchange and National Stock Exchange. It is engaged in the business of Software development, and related services. It operates from various locations in India and also