SACHIN RAMDAS MOHITE,,SATARA vs. PR. COMMISSIONER OF INCOME-TAX-3,, PUNE

Appeal is allowed in above terms

Bench: Shri S.S. Godara, Jm & Shri G.D. Padmahshali, Am

124) is reproduced as under : "Section 68, read with section 263 of the Income-tax Act, 1961 - Cash

KRISH WINES,JALGAON vs. ACIT CIRCLE 1,, JALGAON

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

124(3)(a) of the Income Tax\nAct precludes the assessee from questioning the jurisdiction of the\nassessing officer, if he does not do so within 30 days of receipt of notice\nunder Section 142 (1).\n2. In the present case, the facts did not warrant the order made by the\nHigh Court. At the same time, this Court

DY. COMMISSIONER OF INCOME TAX, PUNE vs. INDUS BIOTECH PRIVATE LIMITED, PUNE

Appeal is dismissed

Bench: Shri R.K. Panda & Shri S.S. Godara"नधा"रण वष" / Assessment Year : 2018-19 Dcit, Vs. Indus Biotech Pvt. Ltd. Circle-1(1), 1, Rahul Residency, Pune Plot Nos.6 & 7, Off Salunke Vihar Road, Kondhwa, Kondhwa Bk B.O., Pune – 411048 Maharashtra Pan: Aaaci5708E Appellant Respondent

124 (Ker) • CIT vs Pranlal P Doshi 201 ITR 756 (Guj) 8.4 The third burden which was on A.O. was to establish that cessation if at all has happened, has happened in the year under appeal. After all, liability to tax can be fixed in the year to which it pertains and to no other year. Merely because A.O. chose

RAJDEEP BUILDCON PVT LTD, AHMEDNAGAR,AHMEDNAGAR vs. DY. COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE 1(2), PUNE, PUNE

In the result, the appeal filed by the assessee in ITA

Bench: SHRI R. K. PANDA (Vice President), SHRI VINAY BHAMORE (Judicial Member)

124 TTJ (Jodh.) 674 "The expression 'assessment or reassessment’ used in section 153A connotes determination of total income pursuant to return required to be filed in the case of a person where a search is initiated under section 132 or requisition is made under section 132A. The expression ‘assessment' or 'reassessment’ used in this section

RAJDEEP BUILDCOM PRIVATE LIMITED,AHMEDNAGAR vs. DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE - 1(2), PUNE, PUNE

In the result, the appeal filed by the assessee in ITA

Bench: SHRI R. K. PANDA (Vice President), SHRI VINAY BHAMORE (Judicial Member)

124 TTJ (Jodh.) 674 "The expression 'assessment or reassessment’ used in section 153A connotes determination of total income pursuant to return required to be filed in the case of a person where a search is initiated under section 132 or requisition is made under section 132A. The expression ‘assessment' or 'reassessment’ used in this section

RAJDEEP BUILDCON PRIVAT LIMITED, AHMEDNAGAR,AHMEDNAGAR vs. DY. COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE 1(2), PUNE, PUNE

In the result, the appeal filed by the assessee in ITA

Bench: SHRI R. K. PANDA (Vice President), SHRI VINAY BHAMORE (Judicial Member)

124 TTJ (Jodh.) 674 "The expression 'assessment or reassessment’ used in section 153A connotes determination of total income pursuant to return required to be filed in the case of a person where a search is initiated under section 132 or requisition is made under section 132A. The expression ‘assessment' or 'reassessment’ used in this section

LOKMANGAL KARMACHARYANCHI SAHAKARI PATSANSTHA MARYADIT,SOLAPUR vs. ITO WARD2(3), SOLAPUR

In the result, appeal of the assessee is allowed

Bench: Dr.Manish Boradआयकर अपील सं. / Ita No.1083/Pun/2025 Assessment Year : 2018-19

68,749/-. Lower authorities have denied the deduction as Lokmangal Cooperative Bank is not a Cooperative Society. 6. This issue is no longer res integra by virtue of catena of decisions taking consistent view that interest income earned from deposits with Cooperative Banks is eligible for deduction u/s.80P(2)(d) of the Act. Recently, this Bench in the case

SHREE ADINATH SAHAKARI SAKHAR KARKHANA LTD,,SOLAPUR vs. DEPUTY COMMISSIONER OF INCOME-TAX, CIRCLE - 1,, SOLAPUR

Bench: Shri S.S.Godara, Jm & Shri Dr. Dipak P. Ripote, Am आयकर अपीऱ सं. / Ita No.3035 To 3038/Pun/2017 ननधधारण वषा / Assessment Year : 1998-99 To 2001-02

68,930 when the cane was purchased at different prices as noted by AO himself at page 2 of his order. 5. Without prejudice to the above, the CIT(A) did not even allow deduction under clause 5A which the CIT(A)-V had accepted in Shree Dnyaneshwar pursuant to directions of the Hon'ble Supreme Court

SHREE ADINATH SAHAKARI SAKHAR KARKHANA LTD,,SOLAPUR vs. DEPUTY COMMISSIONER OF INCOME-TAX, CIRCLE - 1,, SOLAPUR

Bench: Shri S.S.Godara, Jm & Shri Dr. Dipak P. Ripote, Am आयकर अपीऱ सं. / Ita No.3035 To 3038/Pun/2017 ननधधारण वषा / Assessment Year : 1998-99 To 2001-02

68,930 when the cane was purchased at different prices as noted by AO himself at page 2 of his order. 5. Without prejudice to the above, the CIT(A) did not even allow deduction under clause 5A which the CIT(A)-V had accepted in Shree Dnyaneshwar pursuant to directions of the Hon'ble Supreme Court

SHREE ADINATH SAHAKARI SAKHAR KARKHANA LTD,,SOLAPUR vs. DEPUTY COMMISSIONER OF INCOME-TAX, CIRCLE - 1,, SOLAPUR

Bench: Shri S.S.Godara, Jm & Shri Dr. Dipak P. Ripote, Am आयकर अपीऱ सं. / Ita No.3035 To 3038/Pun/2017 ननधधारण वषा / Assessment Year : 1998-99 To 2001-02

68,930 when the cane was purchased at different prices as noted by AO himself at page 2 of his order. 5. Without prejudice to the above, the CIT(A) did not even allow deduction under clause 5A which the CIT(A)-V had accepted in Shree Dnyaneshwar pursuant to directions of the Hon'ble Supreme Court

SHREE ADINATH SAHAKARI SAKHAR KARKHANA LTD,,SOLAPUR vs. DEPUTY COMMISSIONER OF INCOME-TAX, CIRCLE - 1,, SOLAPUR

Bench: Shri S.S.Godara, Jm & Shri Dr. Dipak P. Ripote, Am आयकर अपीऱ सं. / Ita No.3035 To 3038/Pun/2017 ननधधारण वषा / Assessment Year : 1998-99 To 2001-02

68,930 when the cane was purchased at different prices as noted by AO himself at page 2 of his order. 5. Without prejudice to the above, the CIT(A) did not even allow deduction under clause 5A which the CIT(A)-V had accepted in Shree Dnyaneshwar pursuant to directions of the Hon'ble Supreme Court

DY. COMMISSIONER OF INCOME TAX CIRCLE-1(1) , PUNE vs. FIAT INDIA AUTOMOBILES PRIVATE LIMITED, PUNE

In the result, the appeal filed by the assessee in ITA

Bench: SHRI MANISH BORAD (Accountant Member), SHRI VINAY BHAMORE (Judicial Member)

section 115JB(2) of the IT Act. 3. After considering the submissions of the assessee, the Assessing Officer passed the rectification order dated 31.03.2022 u/s 154 r.w.s. 143(3) of the IT Act and determined deemed total income u/s 115JB of the IT Act at Rs.2,39,02,89,117/- and raised a demand of Rs.40,68

M/S. FIAT INDIA AUTOMOBILES PRIVATE LIMITED,PUNE vs. ACIT CIRCLE 1(1), PUNE

In the result, the appeal filed by the assessee in ITA

Bench: SHRI MANISH BORAD (Accountant Member), SHRI VINAY BHAMORE (Judicial Member)

section 115JB(2) of the IT Act. 3. After considering the submissions of the assessee, the Assessing Officer passed the rectification order dated 31.03.2022 u/s 154 r.w.s. 143(3) of the IT Act and determined deemed total income u/s 115JB of the IT Act at Rs.2,39,02,89,117/- and raised a demand of Rs.40,68

DEPUTY COMMSSIONER OF INCOME-TAX,, PUNE vs. IGATE GLOBAL SOLUTIONS LTD.,, PUNE

In the result, both the appeals are partly allowed

Bench: Shri R.S. Syal & Shri Partha Sarathi Chaudhuryआयकर अपील सं. / Ita. No.342/Pun/2014 िनधा"रण वष" / Assessment Year : 2009-10

68,330/- (Rs.1,91,52,577/- minus Rs.1,14,84,247/-) cannot qualify for credit against the tax liability arising under the Act. 27 and IT(TP) A.No.10/Bang/2014 32. The ld. AR relied on the judgment in Wipro Ltd. vs. DCIT (2016) 382 ITR 179 (Karn) to contend that credit for the full amount of foreign tax at Rs.1

SRL CONSTRUCTION PVT LTD,JALNA vs. ACIT, CENTRAL CIRCLE 2, AURANGABAD, AURANGABAD

In the result, appeal of the assessee is dismissed

Bench: Dr.Dipak P. Ripote & Shri Vinay Bhamoreआयकर अपील सं. / Ita No.847/Pun/2024 िनधा"रण वष" / Assessment Year : 2019-20 Srl Construction Pvt. Ltd., V The Acit, 197, Khasgaon, Jafrabad, S Central Circle-2, Jalna – 444203. Aurangabad. Pan: Aaqcs7227L Appellant/ Assessee Respondent /Revenue Assessee By Shri Prateekjha – Ar Revenue By Shri Ajay Kumar Keshari – Cit(Dr) Date Of Hearing 16/12/2024 Date Of Pronouncement 29/01/2025 आदेश/ Order Per Dr.Dipak P.Ripote, Am : This Is An Appeal Filed By The Assessee Against The Order Of Ld.Principal Commissioner Of Income Tax(Central)-Nagpur, Passed Under Section 263 Of The Income Tax Act, 1961; Dated 08.03.2024 For A.Y.2019-20. The Assessee Has Raised The Following Grounds Of Appeal : “1. A) On The Facts & Circumstance Prevailing In The Case & In Law, Honorable Pr. Cit (Central), Nagpur Has Erred In Not Considering The Submission Made By The Appellant In Fair And

68,600/- in which payments were made in cash more than Rs.10,000/- in each transaction. Similarly, ld.Pr.CIT studied the Return of Income for A.Y.2019-20 and A.Y.2018-19 and then arrived at a prima-facie opinion that WDV of the Asset was incorrectly mentioned. 4.3.1 Therefore, the pleading of the ld.AR that the Pr.CIT has merely relied on the Proposal submitted

SHARADA ELECTORS PRIVATE LIMITED,PUNE vs. PCIT, PUNE-3, PUNE

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

Bench: Dr.Manish Borad & Shri Vinay Bhamore

section 263 of the Act, we find that since the assessee has himself not pressed Ground No.4 relating to disallowance u/s.14A r.w. Rule 8D of the Act at Rs.1,68,194/-, this itself indicates that ld. PCIT has assumed valid jurisdiction. So the grounds challenging the assumption of jurisdiction by the ld. PCIT are hereby dismissed. 11. Now coming

MEENAMANI GANGA BUILDER LLP,PUNE vs. ASSISTANT COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE 2(3), PUNE

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

section 132(4A) are not applicable to the assessee. The\nRevenue has not taken the statements of any of the buyers to prove that they have\nin fact given any on-money over and above what is mentioned in the registered\nsale deed.\n19.\nReferring to page 66 of the paper book, the Ld. Counsel for the assessee\ndrew

MEENAMANI GANGA BUILDER LL,PUNE vs. ASSISTANT COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE 2(3), PUNE

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

section 132(4A) are not applicable to the assessee. The\nRevenue has not taken the statements of any of the buyers to prove that they have\nin fact given any on-money over and above what is mentioned in the registered\nsale deed.\n19. Referring to page 66 of the paper book, the Ld. Counsel for the assessee\ndrew

MEENAMANI GANGA BUILDER LLP,PUNE vs. ASSISTANT COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE 2(3), PUNE

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

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

68 and 69 of the paper book would show that some negotiations were going on. Further in the draft booking form the rate per square feet mentioned is 6500 whereas in the booking form where the signature of the director is mentioned the rate per square feet is 3700. 20. In his alternate submission, he submitted that 6500 includes