ASSISTANT COMMISSIONER OF INCOME-TAX,, PUNE vs. NORD DRIVE SYSTEMS PVT. LTD.,, PUNE

In the result, the appeal as well as cross objection are

Bench: Shri R.S. Syal & Shri Partha Sarathi Chaudhuryआयकर अपील सं. / Ita No.825/Pun/2016 िनधा"रण वष" / Assessment Year : 2011-12 Acit, Circle-2, Vs. Nord Drive Systems Pvt. Ltd., Pune 282/2, 283/2, Plot No.15, Village Mann, Mulshi, Pune – 411 057 Pan : Aaccn0708R Appellant Respondent C.O. No.12/Pun/2018 (Arising Out Of Ita No.825/Pun/2016) िनधा"रण वष" / Assessment Year : 2011-12 Nord Drive Systems Pvt. Ltd., Vs. Acit, Circle-2, 282/2, 283/2, Plot No.15, Pune Village Mann, Taluka Mulshi, Adj. Hinjewadi Midc, Phase-Ii, Pune – 411 057 Pan : Aaccn0708R Cross Objector Appellant In The Appeal Assessee By Shri Sharad Shah & Shri Rohit Tapadia Revenue By Shri T. Vijaya Bhaskar Reddy Date Of Hearing 27-11-2019 Date Of Pronouncement 28-11-2019 आदेश / Order

5) of section 144C in Co. No.12/PUN/2018 Nord Drive Systems Pvt. Ltd., respect of any objection filed on or after the 1st day of July, 2012, by the assessee under sub-section (2) of section 144C in pursuance of which the Assessing Officer has passed an order completing the assessment or reassessment

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

reassessed\nRs.42,04,70,990/- by the Ld. AO vide draft assessment order passed u/s\n143(3)/254 r.w.s. 144B r.w.s. 144C(1) dated 31.03.2023 which was\nchallenged by the assessee by filing objections before the Ld. DRP.\n2.3 Before the Ld. DRP, the assessee raised the following objections\npertaining to allocation of RHQ charges :\n1.\n“6.1. Issue

LIQUIDHUB ANALYTICS PVT. LTD. (NOW MERGED WITH CAPGEMINI TECHNOLOGY SERVICES INDIA LTD),PUNE vs. NFAC, PUNE

In the result, the appeal filed by the assessee is allowed

Bench: Shri R. K. Panda & Shri Vinay Bhamoreassessment Year : 2020-21

144C(13) dated July 26, 2024 on the name of the Appellant company which has ceased to exist pursuant to the merger with Capgemini Technology Services India Limited wef 1st April, 2020, duly approved by National Company Law Tribunal (NCLT) order dated 24 June 2021, thereby making the entire assessment proceedings as void-ab-initio and is liable

ANANDA GORAKHANATH PAWAR,SATARA vs. ASSESSING OFFICER, WARD 3, SATARA, SATARA

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

Bench: Shri R. K. Panda & Shri Vinay Bhamoreआयकर अपील सं. / Ita No.1796/Pun/2025 िनधा"रण वष" / Assessment Year : 2018-19 Ananda Gorakhanath Pawar, Vs. Ito, Ward-3, Satara. At Post Ambawade, Khatav, Satara- 415506. Pan : Blhpp6081R Appellant Respondent Assessee By Shri R. C. Doshi : Revenue By : Shri Milind Debaje Date Of Hearing : 28.08.2025 Date Of Pronouncement : 28.08.2025 आदेश / Order Per Vinay Bhamore, Jm: This Appeal Filed By The Assessee Is Directed Against The Order Dated 30.06.2025 Passed By Ld. Cit(A)/Nfac For The Assessment Year 2018-19. 2. The Appellant Has Filed The Following Grounds Of Appeal :- “1. The Learned Cit Has Erred Both On Facts & In Law In Dismissing The Appeal Of The Appellant By Refusing To Condone The Delay Of 26 Days On Grounds Of Period Of Limitation, Notwithstanding The Fact That Appellant Has Submitted The Application & Explained The Reasons For Delay.

reassessment dated 29/03/2022. b) The Copy of the approval given by the prescribed authority was not enclosed with notice u/s 148A(b), u/s 148 as well as order u/s 184A(d) of the Act as required by CBDT guidelines and various judicial pronouncement. c) The information of cash withdrawal from bank does not suggest escapement of income liable

AKTIEBOLAGET TETRA PAK,PUNE vs. ASISTANT COMMISSIONER OF INCOME TAX (INT TAX), PUNE

In the result, both the appeals are allowed

Bench: Shri R.S. Syal & Shri Partha Sarathi Chaudhuryआयकर अपील सं. / Ita No.265 & 211/Pun/2021 िनधा"रण वष" / Assessment Years : 2012-13 & 2013-14

section 144C(1) of the Act on 27-12-2019 computing total income at Rs.9,46,20,724/-. The assessee remained unsuccessful before the Dispute Resolution Panel (DRP) on its contention that the initiation of re-assessment proceedings after four years from the end of the assessment year was not valid. That is how, the final assessment order was passed

AKTIEBOLAGET TETRA PAK,PUNE vs. ASISTANT COMMISSIONER OF INCOME TAX (INT TAX), PUNE

In the result, both the appeals are allowed

Bench: Shri R.S. Syal & Shri Partha Sarathi Chaudhuryआयकर अपील सं. / Ita No.265 & 211/Pun/2021 िनधा"रण वष" / Assessment Years : 2012-13 & 2013-14

section 144C(1) of the Act on 27-12-2019 computing total income at Rs.9,46,20,724/-. The assessee remained unsuccessful before the Dispute Resolution Panel (DRP) on its contention that the initiation of re-assessment proceedings after four years from the end of the assessment year was not valid. That is how, the final assessment order was passed

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

144C(13) r.w.s. 143(3) r.w.s. 147 of the Income-tax Act, 1961 (in short ‘the Act’). The assessee also filed Cross Objections against the appeals of Revenue. 2. Both the appeals filed by the Revenue relating to assessment years 2005-06 and 2006-07 and Cross Objections filed by the assessee were heard together and are being disposed

DEPUTY DIRECTOR OF INCOME-TAX 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

144C(13) r.w.s. 143(3) r.w.s. 147 of the Income-tax Act, 1961 (in short ‘the Act’). The assessee also filed Cross Objections against the appeals of Revenue. 2. Both the appeals filed by the Revenue relating to assessment years 2005-06 and 2006-07 and Cross Objections filed by the assessee were heard together and are being disposed

SHRI GURUDEV CHANDRASHEKHAR KARANTH,PUNE vs. INCOME TAX DEPARTMENT CIT(DRP-3), MUMBAI

In the result, Grounds Number 1 and 2 raised by the Assessee are allowed

Bench: Dr.Manish Borad & Shri Vinay Bhamoreआयकर अपील सं. / Ita No.147/Pun/2025 िनधा"रण वष" / Assessment Year: 2018-19 Shri Gurudev Chandrashekhar V Income Tax Department Karanth, S. Cit(Drp-3), Mumbai-1. 21 Cozy Retreat, Sindh Colony, Aundh, Pune – 411007. Maharashtra. Pan: Cgnpk6203J Appellant/ Assessee Respondent / Revenue Assessee By Shri B.C.Malakar – Advocate Revenue By Shri Prakash L Pathade – Cit-Dr Date Of Hearing 04/03/2025 Date Of Pronouncement 02/06/2025 आदेश/ Order Per Vinay Bhamore, Jm: This Is An Appeal Filed By The Assessee Against The Assessment Order Under Section 147 R.W.S 144C(13) Of The Income Tax Act, 1961 Dated 23.12.2024 For The A.Y.2018-19, Emanating From The Order Of The Dispute Resolution Panel U/S.144C(5) Of The Act, Dated 20.12.2024. The Assessee Has Raised The Following Grounds Of Appeal :

144C(13) of the Income Tax Act, 1961 dated 23.12.2024 for the A.Y.2018-19, emanating from the order of the Dispute Resolution Panel u/s.144C(5) of the Act, dated 20.12.2024. The Assessee has raised the following grounds of appeal : ITA No.147/PUN/2025 [A] “1. On the facts and in the circumstances of the case and in law the Hon'ble Dispute Resolution

NALCO COMPANY ,USA,,PUNE vs. COMMISSIONER OF INCOME-TAX, (IT/TP),, PUNE

In the result, appeal of the assessee in ITA No

Bench: Shri R.S.Syal, Vp & Shri Partha Sarathi Chaudhury, Jm आयकर अपील सं. / Ita No. 736/Pun/2019 धनधाारण वषा / Assessment Year : 2013-14

144C (13) and 153(3) of the Income Tax Act, 1961 (hereinafter referred to as „the Act‟) as per the grounds of appeal on record. 2. In ITA No.736/PUN/2019 for the assessment year 2013-14, the assessee has raised following grounds: “1:0 Re. Validity of order u/s.263: 1.1. The Commissioner of Income-tax (International Tax/Transfer pricing) (hereinafter referred

NALCO COMPANY,PUNE vs. THE ASSISTANT COMMISSIONER OF INCOME TAX (INT. TAXATION), CIRCLE-2, PUNE

In the result, appeal of the assessee in ITA No

Bench: Shri R.S.Syal, Vp & Shri Partha Sarathi Chaudhury, Jm आयकर अपील सं. / Ita No. 736/Pun/2019 धनधाारण वषा / Assessment Year : 2013-14

144C (13) and 153(3) of the Income Tax Act, 1961 (hereinafter referred to as „the Act‟) as per the grounds of appeal on record. 2. In ITA No.736/PUN/2019 for the assessment year 2013-14, the assessee has raised following grounds: “1:0 Re. Validity of order u/s.263: 1.1. The Commissioner of Income-tax (International Tax/Transfer pricing) (hereinafter referred

BMC SOFTWARE ASIA PACIFIC PTE LTD,SINGAPORE vs. ACIT (INTERNATIONAL TAX) CIRCLE-1, PUNE

In the result, the appeal is allowed

Bench: Shri R.S. Syal & Shri Partha Sarathi Chaudhuryनिर्धारण वषा / Assessment Year: 2010-11 Bmc Software Asia Pacific Pte Vs. Acit (International Tax), Ltd., Circle-1, Pune 600, North Bridge Road, 20-01/10 Park View Square, Singapore – 188778 Pan : Aaecb0642A Appellant Respondent

144C(13) of the Income-tax Act, 1961 (hereinafter referred to as „the Act‟) in relation to the assessment year 2010-11. 2. Briefly, the facts of the case are that the assessee is a Singapore based company, which did not file its return of income for the year under consideration. On verification of certain details

JOHN DEERE INDIA PVT.LTD,,PUNE vs. ASSISTANT COMMISSIONER OF INCOME TAX,, PUNE

In the result, the appeal is partly allowed

Bench: Shri R.S. Syal & Shri Partha Sarathi Chaudhuryआयकर अपील सं. / Ita No.1254/Pun/2017 िनधा"रण वष" / Assessment Year : 2007-08

144C of the Income-tax Act, 1961 (hereinafter also called `the Act’) on 12-09-2011. Subsequently, it 2 John Deere India Pvt. Ltd., was observed that the assessee had made payments to the tune of Rs.5,19,28,969/- on account of various I.T. support services, use or right to use software, access to server (scientific equipment) and leased