DR. PRATAP PANDHIRANATH PATIL,PUNE vs. PCIT - 2, PUNE

In the result, the appeal filed by the assessee is allowed as per terms indicated above

Bench: Dr.Manish Borad & Shri Vinay Bhamore

68 of the Income Tax Act, 1961. II. To examine the feasibility of addition on account of agriculture expenditure of Rs.4,36,820/- under Section 69C of the Income Tax Act, 1961.” 9. Aggrieved assessee is now in appeal before this Tribunal. 10. Ld. Counsel for the assessee made multifold arguments. Firstly, he stated that ld. PCIT erred

DINESHKUMAR RAMCHANDRA TULSYAN (HUF),,NASHIK vs. INCOME-TAX OFFICER, WARD - 1(5),, NASHIK

In the result, both the appeals filed by the assessee are partly allowed

Bench: Shri R. K. Panda & Ms. Astha Chandraassessment Year : 2014-15 Dineshkumar Ramchandra Tulsyan (Huf) Ito, Ward 1(5), 214B, Laxmi Niwas, Mahatma Nagar, Vs. Nashik Nashik – 422007 Pan: Aachd5953R (Appellant) (Respondent) Assessment Year : 2014-15 Smt. Sumandevi Dineshkumar Tulsyan Ito, Ward 1(5), 214B, Laxmi Niwas, Mahatma Nagar, Vs. Nashik Nashik – 422007 Pan: Ackpt1322Q (Appellant) (Respondent)

144A of the Act vide letter dated 26.12.2016 who gave directions which have been reproduced by the Assessing Officer in the body of the assessment order. The Assessing Officer confronted the directions given by the JCIT to the assessee. 7. The Assessing Officer noted that the Investigation Wing, Kolkata had conducted search and seizure action at the premises of entry

SMT. SUMANDEVI DINESHKUMAR TULSYAN,,NASHIK vs. INCOME-TAX OFFICER, WARD - 1(5),, NASHIK

144A of the Act\nvide letter dated 26.12.2016 who gave directions which have been reproduced by\nthe Assessing Officer in the body of the assessment order. The Assessing Officer\nconfronted the directions given by the JCIT to the assessee.\nThe Assessing Officer noted that the Investigation Wing, Kolkata had\nconducted search and seizure action at the premises of entry operators

PUNE ZILHA MADHYAWARTI SAHAKARI BANK SEVAKANCHI SAHAKARI PATSANSTHA MARYADIT,PUNE vs. PR. CTI -3, PUNE

In the result, appeal of the assessee is allowed

Bench: Dr.Manish Borad & Shri Vinay Bhamoreआयकर अपील सं. / Ita No.1086/Pun/2025 Assessment Year : 2021-22

68,150/- and concluded the assessment. 4. Subsequently, ld. PCIT examined the assessment record and under the provisions of section 263 of the Act issued a show cause notice to the assessee on 18.02.2025 and main issues raised therein is that (1) assessee is not entitled for deduction u/s.80P(2)(d) of the Act for the interest income from

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

68,194/- u/s.14A r.w. Rule 8D. For the other issues, he submitted that for some issues details have been furnished and some issues are debatable in nature and ld. AO has taken one of the permissible view. For some issues details have been furnished to the satisfaction of ld. AO and detailed enquiry has been undertaken. Reference made

ABIL REALTY PVT. LTD.,PUNE vs. ITO, WARD 1(1), PUNE, PUNE

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

Bench: Shri R. K. Panda & Ms. Astha Chandraassessment Year : 2016-17 Abil Realty Pvt. Ltd. Ito, Ward 1(1), Pune Abil House, 2 Ganesh Khind Road, Vs. Range Hill Corner, Pune – 411007 Pan: Aaica8531I (Appellant) (Respondent) Assessee By : Shri Sanket M Joshi & Mandar Joshi Department By : Shri Amol Khairnar Cit-Dr Date Of Hearing : 08-01-2025 Date Of Pronouncement : 19-03-2025 O R D E R

68, the scope of limited scrutiny on this issue should have ended there and the Assessing Officer could not have proceeded to carry out further enquiries on other tax aspects. 14. Referring to the CBDT Instructions on limited scrutiny cases dated 29.12.2015, 14.07.2016 and 30.11.2017, copies of which are placed in the paper book from pages

SOLAPUR DIST M S K SAMITI H MASTER T AND N T PATH MYDT PANDHARPUR,PANDHARPUR vs. ITO, WARD 2, PANDHARPUR

In the result appeal of the assessee is dismissed

Bench: Shri S.S.Godara & Dr. Dipak P. Ripoteआयकर अपील सं. / Ita No.804/Pun/2023 िनधा"रण वष" / Assessment Year : 2017-18 Solapur Dist M S K Samiti H The Income Tax Officer, Master T & N T Path V Ward-2, Pandharapur. Mydtpandharpur, S 3980, Station Road, Pandharpur. Maharashtra – 413304. Pan: Aanas9890E Appellant/ Assessee Respondent /Revenue Assessee By None Revenue By Shri Sourabh Nayak – Addl.Cit(Dr) Date Of Hearing 15/02/2024 Date Of Pronouncement 08/03/2024 आदेश/ Order Per Dr. Dipak P. Ripote, Am: This Is An Appeal Filed By The Assessee Against The Order Of Ld.Commissioner Of Income Tax(Appeals)[Nfac], Passed Under Section 250 Of The Income Tax Act, 1961 Dated 11.05.2023 Emanating From Assessment Order Dated 30.07.2019Passed Under Section 144 R.W.S 144A Of The Income Tax Act, 1961. The Assessee Has Raised The Following Grounds Of Appeal : “1. The Assessee Was In Presumption That Co Operative Societies Income Is Exempt Under 80P Generally Maximum Co Solapur Dist M S K Samiti H Master T & N T Path Mydt Pandharpur [A]

144A of the Income Tax Act, 1961. The assessee has raised the following grounds of appeal : “1. The assessee was in presumption that Co Operative Societies income is Exempt under 80P Generally maximum co Solapur Dist M S K Samiti H Master T and N T Path Mydt Pandharpur [A] operativesocieties are under this presumption. So that they have

CLARION TECHNOLOGIES PVT. LTD.,,PUNE vs. DEPUTY COMMISSIONER OF INCOME-TAX,,

In the result, the appeal of assessee is allowed

Bench: Shri R.S. Syal & Shri S.S. Viswanethra Ravi

68 ITR 594 which held that the decision of appellate authority on the same facts may constitute information within the meaning of section 34(1)(b) of the Act. Considering the same the Hon‟ble High Court of Punjab and Haryana answered the question in affirmation and held the decision of appellate authority is a source of information

DEPUTY COMMISSIONER OF INCOME-TAX vs. CLARION TECHNOLOGIES PVT. LTD.,, PUNE

In the result, the appeal of assessee is allowed

Bench: Shri R.S. Syal & Shri S.S. Viswanethra Ravi

68 ITR 594 which held that the decision of appellate authority on the same facts may constitute information within the meaning of section 34(1)(b) of the Act. Considering the same the Hon‟ble High Court of Punjab and Haryana answered the question in affirmation and held the decision of appellate authority is a source of information

M/S. HARMONY CONSTUCTION,NASHIK vs. INCOME-TAX OFFICER, WARD -1(3), NASHIK

The appeal of the assessee is ALLOWED

Bench: Shri S.S. Viswanethra Ravi & Shri G. D. Padmahshaliआयकर अपऩल सं. / Ita No. 234/Pun/2020 निर्धारण वर्ा / Assessment Year : 2014-15 M/S Harmony Construction ‘Rim’ Bungalow, Nr Taran Talav, Gaikhe Colony, Nashik Rd, Nashik – 422101 Pan: Aaffh4263F . . . . . . . अपऩलधथी / Appellant बनाम / V/S Income Tax Officer, Ward 1(3), Nashik . . . . . . . प्रत्यथी / Respondent द्वारा / Appearances Assessee By : Shri Sanket Joshi Revenue By : Shri Ramnath Murkunde सपिवधई की तधरऩख / Date Of Conclusive Hearing : 14/10/2022 घोर्णध की तधरऩख / Date Of Pronouncement : 21/11/2022 आदेश / Order Per G. D. Padmahshali, Am; This Appeal Challenges The Order Of Commissioner Of Income Tax (Appeals)-1, Nashik [For Short “Cit(A)”] Dt. 13/11/2019 Passed U/S 250 Of The Income-Tax Act, 1961 [For Short “The Act”], Which Arose From Assessment Order Dt. 22/12/2016 Passed U/S 143(3) By The Income Tax Officer, Ward-1(3), Nashik [For Short “Ao”] For Assessment Year [For Short “Ay”] 2014-15. 2. The Appellant Assessee Raised Following Grounds;

144A of the Act, who in turn after considering the representation of the appellant, directed the Ld. AO to bring to tax an amount of ₹68,27,500/- being the difference of stamp duty value [for short “SDV”] of 11 units found higher than the sale consideration recorded in transfer agreement u/s 43CA, consequently following the direction the assessment

BHAGWAN RAGHUNATH PATHARE,,PUNE vs. INCOME-TAX OFFICER, WARD - 7(3),, PUNE

In the result, the appeal of the assessee is allowed for statistical purposes

68 Kharadi for which he had attached a copy of 7/12 extract and the sale details for reference. The Return copies/Bank Accounts was submitted stating that the Assessee had a Bhagwan R. Pathare A.Y. 2012-13 vested equal right in the land on the basis of inheritance and as a member of lineal descendents of Joint Hindu Family. The Assessee

DEPUTY COMMISSIONER OF INCOME TAX CENTRAL CIRCLE-2(2), PUNE vs. M/S. BILCARE LIMITED, PUNE

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

Bench: Shri Inturi Rama Rao & Shri S. S. Viswanethra Raviआयकर अपीऱ सं. / Ita No.273/Pun/2021 निर्धारण वर्ा / Assessment Year: 2016-17 Dcit, Central Circle-2(2), Vs. M/S. Bilcare Limited, Pune. 601, Icc Trade Tower, Pune- 411016. Pan : Aabcb2242F Appellant Respondent आयकर अपीऱ सं. / Ita No.334/Pun/2021 निर्धारण वर्ा / Assessment Year: 2016-17 M/S. Bilcare Limited, Vs. Dcit, Central Circle- 6Th Floor, B Wing, Icc 2(2), Pune. Trade Tower, Senapati Bapat Road, Pune- 411006. Pan : Aabcb2242F Appellant Respondent

144A of the Act vide letter dated 18.12.2019 for issuance of a direction on the issue of disallowance of allowability of long term capital loss arising on sale of shares of BSPL of Rs.922 crores. The ld. Joint Commissioner of Income Tax vide order dated 30.12.2019 given following directions :- ―(i) The loss on sale of shares of Rs.922 crore claimed

M/S. BILCARE LIMITED,PUNE vs. DEPUTY COMMISSIONER OF INCOME TAX CENTRAL CIRCLE-2(2), PUNE

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

Bench: Shri Inturi Rama Rao & Shri S. S. Viswanethra Raviआयकर अपीऱ सं. / Ita No.273/Pun/2021 निर्धारण वर्ा / Assessment Year: 2016-17 Dcit, Central Circle-2(2), Vs. M/S. Bilcare Limited, Pune. 601, Icc Trade Tower, Pune- 411016. Pan : Aabcb2242F Appellant Respondent आयकर अपीऱ सं. / Ita No.334/Pun/2021 निर्धारण वर्ा / Assessment Year: 2016-17 M/S. Bilcare Limited, Vs. Dcit, Central Circle- 6Th Floor, B Wing, Icc 2(2), Pune. Trade Tower, Senapati Bapat Road, Pune- 411006. Pan : Aabcb2242F Appellant Respondent

144A of the Act vide letter dated 18.12.2019 for issuance of a direction on the issue of disallowance of allowability of long term capital loss arising on sale of shares of BSPL of Rs.922 crores. The ld. Joint Commissioner of Income Tax vide order dated 30.12.2019 given following directions :- ―(i) The loss on sale of shares of Rs.922 crore claimed

DEPUTY COMMISSIONER OF INCOME-TAX, CIRCLE - 5,, PUNE vs. JAYANT AVINASH DAVE,, PUNE

In the result, the cross appeals are partly allowed for statistical purposes and the CO is dismissed as infructuous

Bench: Shri R.S. Syal & Shri S.S. Viswanethra Raviआयकर अपीऱ सं. / Ita No.23/Pun/2019 निर्धारण वषा / Assessment Year : 2015-2016 Jayant Avinash Dave Vs. Dcit, Office No.801-804, 8Th Floor, Circle 5, Pune Amar Business Park, Sadanand Estates, Plot No.1, S.No.105, Baner Road, Pune – 411045 Pan: Aaqpd6875J Appellant Respondent आयकर अपीऱ सं. / Ita No.182/Pun/2019 निर्धारण वषा / Assessment Year : 2015-2016 Dcit, Vs. Jayant Avinash Dave Circle 5, Pune 46/2/1B, Kaka Halwai Industrial Estate, Pune Satara Road, Pune – 411009 Pan: Aaqpd6875J Appellant Respondent Cross Objection No.11/Pun/2022 (Arising Out Of Ita No.182/Pun/2019 निर्धारण वषा / Assessment Year : 2015-2016 Jayant Avinash Dave Vs. Dcit, Office No.801-804, 8Th Floor, Amar Circle 5, Pune Business Park, Sadanand Estates, Plot No.1, S.No.105, Baner Road, Pune – 411045 Pan: Aaqpd6875J Cross Objector Respondent & Co No.11/Pun/2022

68,33,360/-. A company, namely, Begu Diesel Start Systems Pvt. Ltd. (hereinafter called `the Indian company‘) was incorporated on 16.10.1996. The assessee and a Germany company started business pursuant to the Joint venture agreement dated 16.12.1996. and CO No.11/PUN/2022 The assessee, along with his wife, held 51% shares in the Indian company, while the remaining 49% held by BorgWarner

JAYANT AVINASH DAVE,PUNE vs. DEPUTY COMMISSIONER OF INCOME-TAX, CIRCLE 5 , PUNE

In the result, the cross appeals are partly allowed for statistical purposes and the CO is dismissed as infructuous

Bench: Shri R.S. Syal & Shri S.S. Viswanethra Raviआयकर अपीऱ सं. / Ita No.23/Pun/2019 निर्धारण वषा / Assessment Year : 2015-2016 Jayant Avinash Dave Vs. Dcit, Office No.801-804, 8Th Floor, Circle 5, Pune Amar Business Park, Sadanand Estates, Plot No.1, S.No.105, Baner Road, Pune – 411045 Pan: Aaqpd6875J Appellant Respondent आयकर अपीऱ सं. / Ita No.182/Pun/2019 निर्धारण वषा / Assessment Year : 2015-2016 Dcit, Vs. Jayant Avinash Dave Circle 5, Pune 46/2/1B, Kaka Halwai Industrial Estate, Pune Satara Road, Pune – 411009 Pan: Aaqpd6875J Appellant Respondent Cross Objection No.11/Pun/2022 (Arising Out Of Ita No.182/Pun/2019 निर्धारण वषा / Assessment Year : 2015-2016 Jayant Avinash Dave Vs. Dcit, Office No.801-804, 8Th Floor, Amar Circle 5, Pune Business Park, Sadanand Estates, Plot No.1, S.No.105, Baner Road, Pune – 411045 Pan: Aaqpd6875J Cross Objector Respondent & Co No.11/Pun/2022

68,33,360/-. A company, namely, Begu Diesel Start Systems Pvt. Ltd. (hereinafter called `the Indian company‘) was incorporated on 16.10.1996. The assessee and a Germany company started business pursuant to the Joint venture agreement dated 16.12.1996. and CO No.11/PUN/2022 The assessee, along with his wife, held 51% shares in the Indian company, while the remaining 49% held by BorgWarner

INCOME TAX OFFICER, WARD-2(2), PUNE, PUNE vs. MS S S LANDMARKS, PUNE

In the result, both the appeals filed by the Revenue are dismissed

Bench: Dr.Manish Borad & Shri Vinay Bhamoreआयकर अपील सं. / Ita Nos.977 & 972/Pun/2023 "नधा"रण वष" / Assessment Years : 2014-15 & 2016-17 Income Tax Officer, Vs. M/S. S. S. Landmarks, Pune Unit U, Shakti Chamber, S.No.77-1/1A/1/3, Sangamwadi, Pune 411 003 Maharashtra Pan : Aadas1463K Appellant Respondent

144A was sought which was also not granted and it was lastly pointed out that the letter dated 28.12.2016 with enclosures provided on 29.12.2016 was without any show cause. c. In fact, a quick appreciation of the order sheet (at Page 81 of the Paper Book) reveals that the AO had already passed the assessment order even without going through

INCOME TAX OFFICER, PUNE vs. MS S S LANDMARKS, PUNE

In the result, both the appeals filed by the Revenue are dismissed

Bench: Dr.Manish Borad & Shri Vinay Bhamoreआयकर अपील सं. / Ita Nos.977 & 972/Pun/2023 "नधा"रण वष" / Assessment Years : 2014-15 & 2016-17 Income Tax Officer, Vs. M/S. S. S. Landmarks, Pune Unit U, Shakti Chamber, S.No.77-1/1A/1/3, Sangamwadi, Pune 411 003 Maharashtra Pan : Aadas1463K Appellant Respondent

144A was sought which was also not granted and it was lastly pointed out that the letter dated 28.12.2016 with enclosures provided on 29.12.2016 was without any show cause. c. In fact, a quick appreciation of the order sheet (at Page 81 of the Paper Book) reveals that the AO had already passed the assessment order even without going through