DEPUTY DIRECTOR OF INCOME-TAX,, PUNE vs. SANDVIK A B.,, PUNE

Bench: Ms. Sushma Chowla, Jm & Shri D. Karunakara Rao, Am आयकर अपीऱ सं. / Ita No.608/Pun/2014 यििाारण वषा / Assessment Year :2006-07

permanent establishment of STSA in India, such payments are not considered as taxable in India.” 9. The Auditor in the audit report in Form No.3CEB had also reported in respect of said receipts which is placed at page 14 of Compilation No.I, which read as under:- CO Nos.20 & 28/PUN/2015 Sr. Name and address of Description of Amount paid/received or Method

M/S. KASTURI RASHI DEVELOPERS,,PUNE vs. INCOME-TAX OFFICER, WARD - 5(3), , PUNE

In the result, the appeal is dismissed

Bench: Shri R.S. Syal

permanent establishment in India, etc., are matters of merits which are to be decided in the assessment proceedings.” Similar view has been taken by the Hon’ble Delhi High Court in Rolls Royce PLC vs. DIT (International Taxation) (2011) 339 ITR 147 (Del) upholding the view of the Tribunal in Rolls Royce PLC vs. DIT 2007-TII-32-ITAT

DEPUTY COMMISSIONER OF INCOME-TAX,, PUNE vs. M/S. SECO TOOLS INDIA PVT. LTD.,, PUNE

In the result, the Cross Objections of assessee are allowed and appeals of Revenue are dismissed

Bench: Ms. Sushma Chowla, Jm & Shri Anil Chaturvedi, Am आयकर अपीऱ सं. / Ita Nos.812 & 813/Pun/2017 यििाारण वषा / Assessment Years : 2002-03 & 2003-04

permanent establishment of STSA in India, such payments are not considered as taxable in India.” ITA Nos.812 & 813/PUN/2017 9 CO Nos.30 & 31/PUN/2018 M/s. Seco Tools India Pvt. Ltd. 9. The Auditor in the audit report in Form No.3CEB had also reported in respect of said receipts which is placed at page 14 of Compilation No.I, which read as under

KIRLOSKAR BROTHERS LIMITED,,PUNE vs. DCIT, RANGE 11(1),, PUNE

In the result, the appeal of the assessee for A

Bench: Shri D. Karunakara Rao, Am & Shri Vikas Awasthy, Jm आयकर अपील सं आयकर अपील सं. / Ita Nos. 2611 & 2612/Pun/2012 आयकर अपील सं आयकर अपील सं िनधा"रण वष" िनधा"रण वष" / Assessment Years : 2002-03 & 2003-04 िनधा"रण वष" िनधा"रण वष"

reassessment proceedings is the additional legal issue raised in particular for adjudication vide the appeal ITA No.2612/PUN/2012. 2. Assessee raised various grounds originally. However, during the proceedings before us, assessee filed concise grounds and the said grounds for A.Y. 2002-03 are as under : “Ground of appeal No.1: The Ld. AO erred in CIT(A) erred in confirming the levy

KIRLOSKAR BROTHERS LIMITED,,PUNE vs. DCIT, CIRCLE 11(1),, PUNE

In the result, the appeal of the assessee for A

Bench: Shri D. Karunakara Rao, Am & Shri Vikas Awasthy, Jm आयकर अपील सं आयकर अपील सं. / Ita Nos. 2611 & 2612/Pun/2012 आयकर अपील सं आयकर अपील सं िनधा"रण वष" िनधा"रण वष" / Assessment Years : 2002-03 & 2003-04 िनधा"रण वष" िनधा"रण वष"

reassessment proceedings is the additional legal issue raised in particular for adjudication vide the appeal ITA No.2612/PUN/2012. 2. Assessee raised various grounds originally. However, during the proceedings before us, assessee filed concise grounds and the said grounds for A.Y. 2002-03 are as under : “Ground of appeal No.1: The Ld. AO erred in CIT(A) erred in confirming the levy