DEPUTY COMMISSIONER OF INCOME-TAX, CIRCLE - 1(2),, PUNE vs. FIAT INDIA AUTOMOBILES LTD,, PUNE

In the result, appeal of the Revenue is dismissed

Bench: Shri Inturi Rama Rao & Shri Partha Sarathi Chaudhury

transfer pricing assessment proceedings in compliance to the TPO‟s direction. In this context, it was mentioned by the Ld. CIT (Appeals) that though the assessee has submitted average margins of the comparable companies incorrectly, the same cannot be considered to be a failure on assessee‟s part to disclose fully and truly material facts because what has been wrongly

RANAJIT SURESH RAJAMANE,SOLAPUR vs. ITO, WARD 1, PANDHARPUR, PANDHARPUR

In the result, the appeal of the assessee is allowed

Bench: Dr. Manish Borad & Ms. Astha Chandraआयकर अपील सं. / Ita No.1678/Pun/2024 धििाारण वर्ा / Assessment Year: 2014-15 Ranajit Suresh Rajamane, Vs Ito Ward 1, Shukrawar Peth, Pandharpur Tembhurni Madha Solapur- 413211 Maharashtra Pan-Bmepr3878N Appellant Respondent

147 r.w.s 144 of the Act dated 21.12.2018. 2. Assessee has raised following grounds of appeal:- (i) The Id CIT(A) erred in law and on facts in confirming addition of Rs 1,14.25,000/- u/s 69A as unexplained money in respect of 50% of sale consideration on sale of property. 2 (ii)The Id CIT(A) erred

MR. ABRAR FAKIRMOHMMAD SHAIKH,SOLAPUR vs. INCOME TAX OFFICER(INTERNATIONAL TAXATION), NASHIK

In the result, the appeal filed by the assessee stands partly allowed

Bench: Shri Inturi Rama Rao & Shri S. S. Viswanethra Raviआयकर अपील सं. / Ita No.208/Pun/2023 िनधा"रण वष" / Assessment Year : 2014-15 Mr. Abrar Fakirmohmmad Vs. Ito (International Shaikh, Taxation), Nashik. At Manakeshwar, North Solapur, Tal. Bhoom, Barshi, Solapur- 413213. Pan : Chfps0191E Appellant Respondent Assessee By : Shri Rajiv Khandelwal Revenue By : Shri Prashant Gadekar Date Of Hearing : 10.10.2023 Date Of Pronouncement : 18.10.2023 आदेश / Order Per Inturi Rama Rao, Am: This Is An Appeal Filed By The Assessee Directed Against The Final Assessment Order Dated 20.12.2022 Passed U/S 147 R.W.S. 144C(13) Of The Income Tax Act, 1961 (‘The Act’) For The Assessment Year 2014-15. 2 2. Briefly, The Facts Of The Case Are That The Appellant Is An Individual & Non-Resident Indian In Terms Of Income-Tax Purpose. The Return Of Income For The Assessment Year 2014-15 Was Filed On 05.07.2014 Disclosing Total Income Of Rs.1,85,740/-. Against The Said Return Of Income, No Scrutiny Assessment Was Made. Subsequently, On Receipt Of The Information That The Appellant Made Cash Deposit Of Rs.1,20,40,000/- With Solapur District Co- Operative Central Bank, The Assessing Officer Formed An Opinion That The Income Had Escaped Assessment To Tax. Accordingly, The Assessing Officer Had Issued A Notice U/S 148 On 31.03.2021. In Response To Said Notice U/S 148, The Appellant Filed The Return Of Income On 03.04.2021 Disclosing Same Income As Declared In The Original Return Of Income. Against The Said Return Of Income, The Assessment Was Completed By The Assessing Officer Vide Order Dated 20.12.2022 Passed U/S 144C(13) R.W.S. 147 Of The Act At A Total Income Of Rs.1,23,98,740/-. While Doing So, The Assessing Officer Brought To Tax A Sum Of Rs.1,21,80,000/- Being The Amount Of Cash Deposits In The Bank I.E. Cash Deposits Of Rs.1,20,40,000/- Made With Solapur District Co-

reassessment proceedings, confirmed the addition made on account of unexplained cash deposits by holding that the appellant was not able to prove the sources of money in the bank from which the cash was withdrawn and the reasons for withdrawal of substantial cash from one account and deposit in another account. The appellant had also failed to provide the evidence

M/S ACCORD MEDIPLUS PVT LTD,PUNE vs. INCOME TAX OFFICER, WARD-1(1), PUNE, PUNE

reassessment order as well as additions made therein may\nplease be quashed.\nITA Nos.13 to 17/PUN/2024\nM/s. Accord Mediplus Pvt. Ltd.\n7. On the facts and in the circumstances of the case, Ld. CIT-\nAppeal as well as Ld. AO have erred in law and on facts, in\nsustaining/making the addition of Rs.8,96,41,183/- without\nappreciating the real

CAPGEMINI TECHNOLOGY SERVICES INDIA LIMITED ( SUCCESSOR OF ARICENT TECHNOLOGIES HOLDINGS LIMITED),PUNE vs. ASSISTANT COMMISSIONER OF INCOME TAX, CIRCLE 1(1), PUNE, PUNE

In the result, the appeal of the assessee is allowed

Bench: Shri R.K. Panda & Ms. Astha Chandra

Transfer Pricing Officer, where the assessee had maintained information and documents as prescribed under section 92D, declared the international transaction under Chapter X, and, disclosed all the material facts relating to the transaction; and (e)the amount of undisclosed income referred to in section 271AAB. (7)The penalty referred to in sub-section (1) shall be a sum equal

M/S ACCORD MEDIPLUS PVT LTD,PUNE vs. INCOME TAX OFFICER, WARD-1(1), PUNE, PUNE

Bench: Dr.Manish Borad & Shri Vinay Bhamore

reassessment order as well as additions made therein may please be quashed. M/s. Accord Mediplus Pvt. Ltd. 7. On the facts and in the circumstances of the case, Ld. CIT- Appeal as well as Ld. AO have erred in law and on facts, in sustaining/making the addition of Rs. 8,96,41,183/- without appreciating the real intent behind introduction

M/S ACCORD MEDIPLUS PVT LTD,PUNE vs. INCOME TAX OFFICER, WARD-1(1), PUNE, PUNE

Bench: Dr.Manish Borad & Shri Vinay Bhamore

reassessment order as well as additions made therein may please be quashed. M/s. Accord Mediplus Pvt. Ltd. 7. On the facts and in the circumstances of the case, Ld. CIT- Appeal as well as Ld. AO have erred in law and on facts, in sustaining/making the addition of Rs. 8,96,41,183/- without appreciating the real intent behind introduction

M/S ACCORD MEDIPLUS PVT LTD,PUNE vs. INCOME TAX OFFICER, WARD-1(1), PUNE, PUNE

Bench: Dr.Manish Borad & Shri Vinay Bhamore

reassessment order as well as additions made therein may please be quashed. M/s. Accord Mediplus Pvt. Ltd. 7. On the facts and in the circumstances of the case, Ld. CIT- Appeal as well as Ld. AO have erred in law and on facts, in sustaining/making the addition of Rs. 8,96,41,183/- without appreciating the real intent behind introduction

M/S ACCORD MEDIPLUS PVT LTD,PUNE vs. INCOME TAX OFFICER, WARD-1(1), PUNE, PUNE

Bench: Dr.Manish Borad & Shri Vinay Bhamore

reassessment order as well as additions made therein may please be quashed. M/s. Accord Mediplus Pvt. Ltd. 7. On the facts and in the circumstances of the case, Ld. CIT- Appeal as well as Ld. AO have erred in law and on facts, in sustaining/making the addition of Rs. 8,96,41,183/- without appreciating the real intent behind introduction

PUNE MATHADI HAMAL AND OTHER MANUAL WORKERS BOARD,PUNE vs. INCOME TAX OFFICER, WARD-5(1), PUNE, PUNE

In the result, appeal of the assessee is partly allowed

Bench: Shri S.S.Godara & Dr. Dipak P. Ripoteआयकर अपील सं. / Ita No.1012/Pun/2023 िनधा"रण वष" / Assessment Year : 2018-19 Pune Mathadihamal & Other The Income Tax Manual Workers Board, V Officer, Shramashakti Bhavan, S Ward-5(1), Pune. Coomercial Plot No.1, Market Yard, Pune – 411037. Pan: Aaalp0097L Appellant/ Assessee Respondent /Revenue Assessee By Shri Vipul Joshi – Ar Revenue By Shri Ajay Kumar Keshari & Shri Rajesh Gawali– Dr’S Date Of Hearing 17/04/2024 Date Of Pronouncement 27/06/2024 आदेश/ Order Per Dr. Dipak P. Ripote, Am: This Appeal Filed By The Assessee Is Against The Orders Of Ld.Commissionerof Income Tax(Appeals)[Nfac], Under Section 250 Of The Act Dated 14.07.2023 :

Transfer Pricing Officer for the Assessment year 2008-2009, 2009-2010 & 2011-2012 has accepted the transcation of payment of management fees paid to NLC by NLT and therefore the same having been made entirely for business consideration incurred wholly and exclusively for the purposes of business. Hence no addition was held to be sustainable for the assessment year

DEPUTY COMMISSIONER OF INCOME TAX, JALGAON vs. TARADEVI RATANLAL BAFNA, JALGAON

147 are applicable to\nfacts of this case and the assessment year under consideration is deemed to be case where income chargeable\nto tax has escaped assessment.\n\nPlease acknowledge receipt of this letter\n\nBHARAT DEVRAJ SHEGAONKAR\nACIT CEN CIR 2, NASHIK\n\n5. He, therefore, issued notice u/s 148 of the Act on 19.03.2020. The assessee\nin response

ASSISTANT COMMISSIONER OF INCOME TAX, JALGAON vs. SIDHARTH RATANLAL BAFNA, JALGAON

147 are applicable to\nfacts of this case and the assessment year under consideration is deemed to be case where income chargeable\nto tax has escaped assessment.\n\nPlease acknowledge receipt of this letter\n\nBHARAT DEVRAJ SHEGAONKAR\nACIT CEN CIR 2, NASHIK\n\n5. He, therefore, issued notice u/s 148 of the Act on 19.03.2020. The assessee\nin response

ASSISTANT COMMISSIONER OF INCOME TAX, JALGAON vs. SIDHARTH RATANLAL BAFNA, JALGAON

147 are applicable to\nfacts of this case and the assessment year under consideration is deemed to be case where income chargeable\nto tax has escaped assessment.\nPlease acknowledge receipt of this letter\n\nBHARAT DEVRAJ SHEGAONKAR\nACIT CEN CIR 2, NASHIK\n\n5. He, therefore, issued notice u/s 148 of the Act on 19.03.2020. The assessee\nin response

DIMPLE RAJESH OSWAL,PUNE vs. INCOME TAX OFFICER WARD 5(1), PUNE

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

Bench: Shri R. K. Pandaassessment Year : 2016-17

u/s 143(3) r.w.s. 147 of the Act has determined the total income at Rs.19,60,971/-, however, in the computation statement he has determined the same at Rs.31,97,261/- which is not correct. 7. The second plank of his argument is that the assessee has purchased the property during the year 2012 for a consideration of Rs.46

JAWAHAR LAL NEHRU PORT TRUST,NAVI MUMBAI vs. ACIT PANVEL, PANVEL

In the result, all the three appeals filed by the Revenue are dismissed and all the three appeals filed by the assessee are partly allowed

Bench: Shri R. K. Panda & Ms Astha Chandra

reassessment proceedings even the income which has escaped assessment has to be computed in accordance with the provisions of the Act which will include section 11 as is in the present case. It will not be correct to say that while computing income under section 148 the entire gross receipts are to be taxed. Further, it is not the case

DEPUTY COMMISSIONER OF INCOME-TAX vs. THE JAWAHARLAL NEHRU PORT TRUST,, RAIGAD

In the result, all the three appeals filed by the Revenue are dismissed and all the three appeals filed by the assessee are partly allowed

Bench: Shri R. K. Panda & Ms Astha Chandra

reassessment proceedings even the income which has escaped assessment has to be computed in accordance with the provisions of the Act which will include section 11 as is in the present case. It will not be correct to say that while computing income under section 148 the entire gross receipts are to be taxed. Further, it is not the case

JAWAHAR LAL NEHRU PORT TRUST,NAVI MUMBAI vs. ACIT PANVEL, PANVEL

In the result, all the three appeals filed by the Revenue are dismissed and all the three appeals filed by the assessee are partly allowed

Bench: Shri R. K. Panda & Ms Astha Chandra

reassessment proceedings even the income which has escaped assessment has to be computed in accordance with the provisions of the Act which will include section 11 as is in the present case. It will not be correct to say that while computing income under section 148 the entire gross receipts are to be taxed. Further, it is not the case

DEPUTY COMMISSIONER OF INCOME-TAX vs. THE JAWAHARLAL NEHRU PORT TRUST,, RAIGAD

In the result, all the three appeals filed by the Revenue are dismissed and all the three appeals filed by the assessee are partly allowed

Bench: Shri R. K. Panda & Ms Astha Chandra

reassessment proceedings even the income which has escaped assessment has to be computed in accordance with the provisions of the Act which will include section 11 as is in the present case. It will not be correct to say that while computing income under section 148 the entire gross receipts are to be taxed. Further, it is not the case

DEPUTY COMMISSIONER OF INCOME-TAX vs. THE JAWAHARLAL NEHRU PORT TRUST,, RAIGAD

In the result, all the three appeals filed by the Revenue are dismissed and all the three appeals filed by the assessee are partly allowed

Bench: Shri R. K. Panda & Ms Astha Chandra

reassessment proceedings even the income which has escaped assessment has to be computed in accordance with the provisions of the Act which will include section 11 as is in the present case. It will not be correct to say that while computing income under section 148 the entire gross receipts are to be taxed. Further, it is not the case