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

penalty proceedings u/s 274 r.w.s. 271(1)(c) of\nthe Act is pre-mature.\n17.\nIn the result, the appeal of the assessee is allowed.\nOrder pronounced in the open court on 10th October, 2025.\nSd/-\n(R.K. Panda)\nVICE PRESIDENT\nSd/-\n(Astha Chandra)\nJUDICIAL MEMBER\nपुणे / Pune; दिनांक / Dated : 10th October, 2025.\nरवि\nआदेश की प्रतिलिपि अग्रेषित / Copy

BNY MELLON INTERNATIONAL OPERATIONS (INDIA) PVT. LTD.,,PUNE vs. ASSESSING OFFICER, NATIONAL E-ASSESSMENT CENTRE,, DELHI

The appeal of the assessee is PARTLY ALLOWED

Bench: Shri Satbeer Singh Godara & Shri G. D. Padmahshaliआयकर अपील सं. / Ita No. 699/Pun/2021 धििाारण वर्ा / Assessment Year : 2017-18 Bny Mellon International Operations (India) Pvt. Ltd., Tower S3, Level 1, Cybercity, Magarpatta City, Hadapsar, Pune-411013 Pan: Aadcm 9640 E . . . . . . . अपीलाथी / Appellant बिाम / V/S National E-Assessment Centre, Delhi . . . . . . .प्रत्यथी / Respondent द्वारा / Appearances Assessee By : Shri Nitesh Joshi Revenue By : Shri Rakesh Jha सुनवाई की तारीख / Date Of Conclusive Hearing : 03/08/2023 घोषणा की तारीख / Date Of Pronouncement : 08/08/2023 आदेश / Order Per G. D. Padmahshali, Am; This Appeal Is Directed Against The Order Of The National Faceless Assessment Centre, Delhi, [‘Ao’ Hereinafter] Dt. 29/10/2021 Passed U/S 143(3) R.W.S. 144C(13) R.W.S. 144B Of The Income-Tax Act, 1961 [‘The Act’ Hereinafter] For The Ay 2017-18. Itat-Pune Page 1 Of 16

u/s 253(1) of the Act; “The Appellant appeals against the impugned Order dated 29.10.2021 passed by the Assessing Officer, National Faceless Assessment Centre (the AO) under section 143 read with section 144C(13) & 144B of the Income-tax Act, 1961 (the Act), in accordance with section 253(1)(d) of the said Act, on the following amongst other grounds

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]

144C(6)(C) of the Act. The grounds of appeal mentioned below are without prejudice to the above ground. Transfer Pricing related grounds Ground No. 2: General Ground On the facts and in the circumstances of the case, and in law, the AU pursuant to the directions of the Ld. DRP, erred in making a TP 2 M/s.Persistent Systems Limited

M/S. FIAT INDIA AUTOMOBILES PRIVATE LIMITED,PUNE vs. ACIT CIRCLE 1(1), PUNE

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

Bench: SHRI MANISH BORAD (Accountant Member), SHRI VINAY BHAMORE (Judicial Member)

271(1)(c) of the Act. The Appellant prays that the penalty proceedings be quashed. The Appellant craves leave to add, alter, amend, substitute or withdraw all or any of the Grounds of appeal herein and to submit such statements, documents and papers as may be considered necessary either at or before the appeal hearing so as to enable

DY. COMMISSIONER OF INCOME TAX CIRCLE-1(1) , PUNE vs. FIAT INDIA AUTOMOBILES PRIVATE LIMITED, PUNE

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

Bench: SHRI MANISH BORAD (Accountant Member), SHRI VINAY BHAMORE (Judicial Member)

271(1)(c) of the Act. The Appellant prays that the penalty proceedings be quashed. The Appellant craves leave to add, alter, amend, substitute or withdraw all or any of the Grounds of appeal herein and to submit such statements, documents and papers as may be considered necessary either at or before the appeal hearing so as to enable

UTTAM ENERGY LIMITED,PUNE vs. ACIT CIRCLE-12, PUNE

Appeal of the Assessee is partly allowed

Bench: Dr.Dipak P. Ripote & Shri Vinay Bhamoreआयकर अपील सं. / Ita No.2033/Pun/2019 िनधा"रण वष" / Assessment Year: 2015-16 Uttam Energy Limited, The Acit, Circle-12, Mahendra Chamber, Mayfair V Pune. Co-Op Housing Society, S A-4, Dhole Patil Road, Pune – 411001. Pan: Aabcu4100H Appellant/ Revenue Respondent /Assessee Assessee By Shri Ch Naniwadekar & Kiran Sanmane – Ar;S Revenue By Shri Deepak Garg – Cit Date Of Hearing 16/05/2024 Date Of Pronouncement 30/05/2024 आदेश/ Order Per Dr. Dipak P. Ripote, Am: This Appeal Has Been Filed By The Assessee Against The Final Assessment Order Of The Learned Acit, Circle-12, Pune Passed U/Sec. 143(3) R.W.S. 144C(13) Of The Of The Income Tax Act, 1961 (In Short "The Act") After Giving Effect To The Learned Drp’S Order Dated 24.09.2019. 1.1 The Assessee Has Raised The Following Grounds Of Appeal :

144C(13) of the of the Income Tax Act, 1961 (in short "the Act") after giving effect to the learned DRP’s order dated 24.09.2019. 1.1 The assessee has raised the following grounds of appeal : ITA No.2033/PUN/2019 / Uttam Energy Limited [A] “1. The learned Assessing Officer acting under directions of leaned Dispute Resolution Panel erred both on facts