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

reassessment proceedings initiated are invalid and void and hence be quashed. 3. The learned Departmental Representative for the Revenue fairly pointed out ‘yes’ that the issue raised in Cross Objections is against reopening of assessment under section 147 of the Act. 4. The learned Authorized Representative for the assessee took us through factual aspects of the case and pointed

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

INA BEARINGS INDIA PVT. LTD,,PUNE vs. DEPUTY COMMISSIONER OF INCOME TAX,,

In the result, the appeal of the assessee is allowed to the

Bench: Shri R.S. Syal & Shri Partha Sarathi Chaudhuryआयकर अपील सं. / Ita No.43/Pun/2017 िनधा"रण वष" / Assessment Year : 2010-11

reassessment proceedings pending before the Assessing Officer as on 1st October, 2009”. Thus, it is overt that even for the assessment year under consideration, namely, 2010-11, the benefit of the second proviso would be available by virtue of the Explanation given at the end of sub-section (2) of 92C. We, therefore, hold that

INA BEARINGS INDIA PVT. LTD,,PUNE vs. DEPUTY COMMISSIONER OF INCOME TAX,, PUNE

In the result, the appeal of the assessee is dismissed and that

Bench: Shri R.S. Syal & Shri Partha Sarathi Chaudhuryआयकर अपील सं. / Ita No.148/Pun/2017 िनधा"रण वष" / Assessment Year : 2009-10

reassessment proceedings pending before the Assessing Officer as on 1st October, 2009”. Thus, it is overt that even for the assessment year under consideration, namely, 2009-10, the benefit of the second proviso would be available by virtue of the Explanation given at the end of sub-section (2) of 92C. We, therefore, hold that

ASSISTANT COMMISSIONER OF INCOME TAX,, PUNE vs. INA BEARINGS INDIA PRIVATE LIMITED,, PUNE

In the result, the appeal of the assessee is dismissed and that

Bench: Shri R.S. Syal & Shri Partha Sarathi Chaudhuryआयकर अपील सं. / Ita No.148/Pun/2017 िनधा"रण वष" / Assessment Year : 2009-10

reassessment proceedings pending before the Assessing Officer as on 1st October, 2009”. Thus, it is overt that even for the assessment year under consideration, namely, 2009-10, the benefit of the second proviso would be available by virtue of the Explanation given at the end of sub-section (2) of 92C. We, therefore, hold that