DEPUTY COMMSSIONER OF INCOME TAX CIRCLE-1(1), PUNE vs. FERRERO INDIA PVT.LTD, PUNE

penalty proceedings under section 271 (1 )(c) of the Act. 6. The AO passed the assessment order uls 143(3) r.w.s. 144C of the Act on 17.04.2015 (Received by assessee on 07.05.2015). Aggrieved by the assessment order passed by the AO, the Assessee has filed the appeal before the CIT(A) on 03.06.2015. In respect of transfer pricing adjustment

RBL BANK LTD.,,KOLHAPUR vs. ASSISTANT COMMISSIONER OF INCOME-TAX,,

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

Bench: Shri D. Karunakara Rao, Am & Shri Vikas Awasthy, Jm आयकर अपील सं आयकर अपील सं. / Ita No.650/Pun/2016 आयकर अपील सं आयकर अपील सं िनधा"रण वष" / Assessment Year : 2012-13 िनधा"रण वष" िनधा"रण वष" िनधा"रण वष"

194(A)(3)(iii)(a) whereby no tax is required to be deducted at source in respect of any interest credited or paid to any banking company to which the Banking Regulation Act, 1949 (10 of 1949) applies or any co-operative society engaged in carrying on the business of banking (including a co-operative land mortgage bank

SARIKA AMIT SANAP,,AURANGABAD vs. ASSISTANT COMMISSIONER OF INCOME-TAX, CIRCLE - 3,, AURANGABAD

In the result, assessee‟s appeal is dismissed

section 68 would indicate that when any money is found to be credited in the books of the assessee it is for the assessee to prove the identity of the creditor, genuineness of the transaction and the creditworthiness. 16.3 The detailed analysis of evidences available on record clears any iota of doubt about the spurious nature of such transactions

ASSISTANT COMMISSIONER OF INCOME-TAX, CIRCLE - 6,, PUNE vs. M/S. SAS RESEARCH & DEVELOPMENT (I) PVT.LTD,, PUNE

In the result, the appeal of Revenue in ITA No

Bench: Shri R.S. Syal & Shri S.S. Viswanethra Ravi

194 of the paper book wherein the conditions of services provided by the consultant is reflected. On an examination of said agreement we note that the assessee in the capacity of consultant provide professional services in support of the Institute‟s R&D department with a condition that the consultant shall not subcontract any of consultant‟s obligations. The Institute

SAS RESEARCH AND DEVELOPMENT (INDIA) PVT.LTD,,PUNE vs. DEPUTY COMMISSIONER OF INCOME-TAX, CIRCLE - 6,, PUNE

In the result, the appeal of Revenue in ITA No

Bench: Shri R.S. Syal & Shri S.S. Viswanethra Ravi

194 of the paper book wherein the conditions of services provided by the consultant is reflected. On an examination of said agreement we note that the assessee in the capacity of consultant provide professional services in support of the Institute‟s R&D department with a condition that the consultant shall not subcontract any of consultant‟s obligations. The Institute

AYOKI FABRICON PVT. LTD.,,PUNE vs. DEPUTY COMMISSIONER OF INCOME-TAX,,

In the result, the appeal of the assessee is allowed

Bench: Shri D. Karunakara Rao, Am & Shri Vikas Awasthy, Jm आयकर अपील सं. / Ita No.2155/Pun/2016 िनधा"रण वष" / Assessment Year : 2009-10 Ayoki Fabricon Pvt. Ltd., 137 To 139, Akshay Complex, Dhole Patil Road, Pune. Pan : Aabca5780F .......अपीलाथ" / Appellant बनाम / V/S. Dcit, Circle- 1(1), ……""यथ" / Respondent Pune. Assessee By : Shri Nikhil Pathak & Shri Nimit Gujarathi Revenue By : Shri Yogesh Kamat, Addl.Cit सुनवाई क" तारीख / Date Of Hearing : 20.12.2018 घोषणा क" तारीख / Date Of Pronouncement : 31.12.2019 आदेश / Order Per D. Karunakara Rao, Am : This Appeal Is Filed By The Assessee Against The Order Of Cit(A)-1, Pune Dated 14.06.2016 For The Assessment Year 2009-10. 2. The Grounds Raised By The Assessee Are As Under :- “1. The Learned Cit(A) Erred In Confirming The Disallowance Of Additional Depreciation Of Rs.1,10,53,748/- U/S 32(1)(Iia) On New Plant & Machinery On The Ground That The Assessee Was Not Engaged In The Business Of Manufacture Or Production Of Any Article Or Thing. 2. The Learned Cit(A) Erred In Ignoring The Fact That – I) The Details Furnished To The Assessing Officer By The Assessee During The Assessment Proceedings U/S 143(3) R.W.S. 147 Were Same As Were Furnished During The Assessment Proceedings U/S 143(3) & Therefore.

penalty proceedings u/s 271(1)(c) of the I.T. Act, 1961 are being initiated.” 4. Aggrieved with the said reassessment order of the Assessing Officer, the assessee filed an appeal before the CIT(A) raising the legal objection in ground no.1 and questioning the validity of the reassessment proceedings and also the ground on change of opinion