DATTATRAY HANMANTRAO DESAI,KARAD vs. PRINCIPAL COMMISSIONER OF INCOME TAX, PUNE

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

Bench: Shri R. K. Panda & Ms Astha Chandraassessment Year : 2018-19

68 of the Act. iii) The AO, upon verification of the relevant details/documents, shall record his clear findings as to the identity of the creditor, genuineness of the transactions and creditworthiness of the respective creditors, in respect of the transactions under consideration. 10. Aggrieved with such order of the PCIT, the assessee is in appeal before the Tribunal

SHREE SANT SAVTA GRAMIN BIGAR SETI SAHAKARI PATHSANSTA MARAYADIT,NASHIK vs. ASSESSMENT UNIT, INCOME TAX DEPARTMENT, DELHI

In the result, appeal of the Assessee is partly allowed

Bench: Dr.Dipak P. Ripote & Shri Vinay Bhamoreआयकर अपऩल सं. / Ita No.1625/Pun/2025 निर्धारण वषा / Assessment Year: 2017-18 Shree Sant Savta Gramin Bigar V Assessment Unit, Seti Sahakari Pathsanstha S. Income Tax Department, Maryadit, Delhi. Pimpalgaon, Niphad, Nashik – 422209. Pan: Aacas4098M Appellant/ Assessee Respondent / Revenue Assessee By None Revenue By Shri Dayanand Jawalikar – Addl.Cit Date Of Hearing 14/10/2025 Date Of Pronouncement 31/10/2025 आदेश/ Order Per Dr. Dipak P. Ripote, Am: This Appeal Filed By The Assessee Is Against The Order Of Ld.Commissioner Of Income Tax(Appeal)[Nfac], Passed Under Section 250 Of The Income Tax Act, 1961 For A.Y.2017-18, Dated 27.11.2024 Emanating From Assessment Order U/S.143(3) Of The I.T.Act, Dated 15.12.2019. The Assessee Has Raised Following Grounds Of Appeal :

68 of the Act. Accordingly, Ground No.2 and 3are allowed. ” 7.2 Similarly in the case of ITO vs Shri Kshetra Bhimashankar Gramin Bigar Sheti Sahakari Patsanstha Maryadit in ITA No.473/PUN/2025 ITAT Pune held as under : Quote “8. The Commissioner of Income Tax(appeal) has discussed in the order that the cash deposits were out of the daily cash depositedby various

ASSISTANT COMMISSIONER OF INCOME-TAX,CENTRAL CIRCLE - 2(2),, PUNE vs. M/S SINHGAD TECHNICAL EDUCATION SOCIETY (TRUST), PUNE

In the result, the appeal of the Revenue in ITA

Bench: Shri Inturi Rama Rao & Shri S. S. Viswanethra Ravisl. It(Ss)A No./ Name Of Appellant Name Of Respondent Asst. No.

68 of the Act. The onus was upon the assessee to have produced cogent material to rebut the aforesaid presumption which he had failed to displace. The assessee retracted from the said statement, vide letters dated November 24, 1998, and March 11, 1999, during the course of assessment proceedings. However, no value could be attached thereto in the present case

R R CONSTRUCTIONS,PUNE vs. INCOME TAX OFFICER, PUNE

In the result, appeal of the assessee is partly allowed

Bench: Dr.Dipak P. Ripote & Shri Vinay Bhamoreआयकर अपऩल सं. / Ita No.2609/Pun/2025 निर्धारण वषा / Assessment Year: 2017-18 R R Constructions, V The Income Tax 25, Atur Terracces, 896, Nana S Officer, Peth, Pune – 411002. Pmt Building, Pune. Pan: Aacar2725E Appellant/ Assessee Respondent / Revenue Assessee By None. Revenue By Shri Harshit Bari – Dr Date Of Hearing 16/12/2025 Date Of Pronouncement 18/12/2025 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(Appeal)[Nfac], Passed Under Section 250 Of The Income Tax Act, 1961 For The A.Y.2017-18 Dated 14.08.2025 Emanating From The Assessment Order Passed Under Section 143(3) Of The Act, Dated 02.12.2019. The Assessee Has Raised The Following Grounds Of Appeal : “1) The Learned Commissioner Of Income Tax Appeals Nfac, Erred In Passing An Order Confirming The Addition Made Under Section 68 When

section 68 when ITA No.2609/PUN/2025 [A] the detailed submission was made and a request for personal hearing through VC mode was also made, and the order was passed without granting an opportunity of VC hearing, thus violating the principle of natural justice. Just and proper relief be granted to the assessee in this respect. 2) The authorities below erred

JAYDEV MAHADEV ARYA,LATUR vs. ITO WARD 1, LATUR, LATUR

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

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

section 68/ 69 of the IT Act, 1961.In many cases, the depositors may be mere name-lenders. 4. Details of your assessee: Details as provided in the enclosed excel sheet contains Name (surname first) and PAN of the assessees along with their account numbers of account held by them in the Society. Financial Year-wise credits have been provided

INCOME TAX OFFICER WARD 1 , LATUR vs. VIMAL JAYDEV ARYA, LATUR

In the result, the appeal filed by the Revenue is partly allowed and the CO filed by the assessee is dismissed

Bench: Shri R. K. Panda & Ms. Astha Chandraassessment Year : 2015-16

section 68/ 69 of the IT Act, 1961.In many cases, the depositors may be mere name-lenders. 4. Details of your assessee: Details as provided in the enclosed excel sheet contains Name (surname first) and PAN of the assessees along with their account numbers of account held by them in the Society. Financial Year-wise credits have been provided

JAYDEV MAHADEV ARYA,LATUR vs. ITO WARD 1, LATUR, LATUR

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

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

section 68/ 69 of the IT Act, 1961.In many cases, the depositors may be mere name-lenders. 4. Details of your assessee: Details as provided in the enclosed excel sheet contains Name (surname first) and PAN of the assessees along with their account numbers of account held by them in the Society. Financial Year-wise credits have been provided

TIBCO SOFTWARE BV,,PUNE vs. ASSISTANT COMMISSIONER OF INCOME-TAX, (INTERNATIONAL TAXATION), CIRCLE -2,, PUNE

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

Bench: Shri Inturi Rama Rao & Shri S.S. Viswanethra Ravisl.

158. Secondly, under the definition of "copyright" in Section 14 of the Copyright Act, the emphasis is that it is an exclusive right granted to the holder thereof. This condition is not satisfied in the case of JTM because the license granted to it by the Assessee is expressly stated in clause 20.1 as a "non exclusive restricted license

TIBCO SOFTWARE BV,,PUNE vs. ASSISTANT COMMISSIONER OF INCOME-TAX, (IT), CIRCLE-2,, PUNE

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

Bench: Shri Inturi Rama Rao & Shri S.S. Viswanethra Ravisl.

158. Secondly, under the definition of "copyright" in Section 14 of the Copyright Act, the emphasis is that it is an exclusive right granted to the holder thereof. This condition is not satisfied in the case of JTM because the license granted to it by the Assessee is expressly stated in clause 20.1 as a "non exclusive restricted license

TIBCO SOFTWARE B.V.,,PUNE vs. DEPUTY COMMISSIONER OF INCOME TAX, (IT), CIRCLE - 2,, PUNE

Appeal is allowed for statistical purposes

Bench: Shri R.S.Syal & Sonjoy Sarma,Jm Assessment Year : 2014-15 Tibco Software B.V. ...... Appellant C/O Tibco Software India P.Ltd. 3 Floor, Binnarius,Deepak Complex, National Games Road, Shastri Nagar, Yerwada, Pune – 411 006. Pan : Aaect3252G V/S. Dcit(It),Circle-2, Pune ……Respondent

158. Secondly, under the definition of "copyright" in Section 14 of the Copyright Act, the emphasis is that it is an exclusive right granted to the holder thereof. This condition is not satisfied in the case of JTM because the license granted to it by the Assessee is expressly stated in clause 20.1 as a "non exclusive restricted license

M.M. PATEL PUBLIC CHARITABLE TRUST,SOLAPUR vs. PCIT- CENTRAL, PUNE, PUNE

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

158\nТахтап 199 and Allahabad High Court in the case of Oxford Academy for\nCareer Development v. Chief CIT [20091.315 ITR 382\n29. All the three High Courts after examining the issue, in the light of the\nobject of Section 12A of the Act and Section 21 of the General Clauses Act\nheld that the order

S T CO-OPERATIVE CREDIT SOCIETY,PUNE vs. ITO, WARD 5(1), PUNE

In the result, appeal of the assessee is allowed

Bench: Dr.Dipak P. Ripote & Shri Vinay Bhamoreआयकर अपील सं. / Ita No.2136/Pun/2024 िनधा"रण वष" / Assessment Year: 2020-21 S T Co-Operative Credit V The Income Tax Officer, Society, S Ward-5(1), Pune. Swargate S T Depo, Veer Savarkar Nagar, Swargate Bus Stand, Pune – 411037. Pan: Aabas6856L Appellant/ Assessee Respondent / Revenue Assessee By Shri Kishor B Phadke – Ar Revenue By Shri Prakash L Pathade – Dr Date Of Hearing 13/11/2024 Date Of Pronouncement 18/11/2024 आदेश/ Order Per Dr. Dipak P. Ripote, Am: This Is An Appeal Filed By The Assessee Directed Against The Order Of Ld.Commissioner Of Income Tax(Appeal)[Nfac], Under Section 250 Of The Income Tax Act, 1961 Dated 09.08.2024 For A.Y.2020-21. The Assessee Has Raised The Following Grounds Of Appeal : “1. The Learned Cit(A) Erred In Dismissing The Appeal Of The Appellant By Refusing To Condone The Delay Of 108 Days In Filing The Appeal Without Appreciating That The Said Delay Was Due To Reasonable Cause As Explained In The Application For Condonation Of Delay Filed Before Cit(A) & Therefore, The Said Delay Ought To Have Been Condoned In The Interest Of Justice & The Appeal Should Have Been Adjudicated On Merits. 2. The Learned Cit(A) Ought To Have Appreciated That The Deduction U/S 80P Was Allowable In Respect Of Interest Earned From Deposits Made By Cooperative Banks As Consistently Held By Honorable

68,448/- earned by assessee from PDCC Bank and S.T.Co-operative Bank Limited is eligible for deduction u/sec.80P or not! 5. The Hon’ble High Court of Andhra Pradesh and Telangana in the case of Vavveru Co-operative Rural Bank Ltd. [2017] 396 ITR 371analysed the provisions of Section 80P, succinctly distinguished the decision of Hon’ble Supreme Court

REHAU POLYMERS PVT.LTD,,PUNE vs. ASSISTANT COMMISSIONER OF INCOME-TAX, CIRCLE - 8,, PUNE

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

68,30,646\nTNMM\n7\nPurchase of Fixed Assets\n13,92,23,545\nTNMM\n8\nPayment towards consultancy and\n0\nNA\nprofessional services\n9\nPayment towards technical\n11,80,799\nTNMM\nservices\n10\nPurchase of Stores, spares and\n81,46,129\nTNMM\nsample\n11\nExpenditure Reimbursed Paid\n47,37,318\nCUP\n12\nGuarantee Commission Paid\n78,89,367\nOTHER\nMETHOD

JAIN IRRIGATION SYSTEMS LTD,,JALGAON vs. DEPUTY COMMISSIONER OF INCOME-TAX, CIRCLE - 2,, JALGAON

Appeal is partly allowed in above terms

Bench: Shri S.S.Godara & Dr.Dipak P.Ripoteआयकरअपीलसं. / Ita No.227/Pun/2018 िनधा"रणवष" / Assessment Year : 2013-14 Jain Irrigation Systems Ltd., The Deputy Commissioner Of Jain Plastic Park, N.H No.6, Vs Income Tax, Circle-2, Jalgaon – 425001. . Jalgaon. Pan: Aaacj 7163 Q Appellant/ Assessee Respondent /Revenue Assessee By Shri Percy Pardiwala; Shri Prashant Maheshwari & Ms.Monicamulchandani – Ar’S Revenue By Shri B Koteswara Rao – Dr Date Of Hearing 23/09/2022 Date Of Pronouncement 22/12/2022 आदेश/ Order Per S.S.Godara, Jm: This Assessee’Sappeal For Assessment Year 2013-14Is Directed Against Thedeputy Commissioner Of Income Tax, Cricle-2, Jalgaon’S Assessment Order Dated 29.10.2017, Framed In Furtherance To The Dispute Resolution Panel-3, Mumbai (Drp)’S Direction Dated 25.09.2017 Passed In Objection No.78, In Proceedings U/S 143(3) R,.W.S 144C(5) Of The Income Tax Act, 1961 [In Short “The Act”].

68,40,000/-, calculated at the ad-hoc rate of 12% on the interest free securitydeposits given to related parties in relation to two flats at Walkeshwar, Mumbai by merely following the order of learned CIT(A) for AY 2008-09 and ignoring the various arguments of the Appellant, including order of learnedCIT(A) for AY 2005-06 deciding

PARANJAPE PENDSE ASSOCIATES,PUNE vs. DCIT, CIRCLE-3, PUNE, PUNE

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

Bench: Shri R. K. Panda & Shri S.S. Godaraassessment Year : 2014-15

68,143/- out of which the CIT(A) / NFAC deleted an amount of Rs.1,65,18,143/- and sustained an amount of Rs.2,50,000/- only out of the adhoc disallowance of expenses @ 20%, details of which are given at para 7 of this order. We find the Hon'ble Supreme Court in the case of CIT vs. Reliance Petro

M/S. SIZE CONTROL GAUGES AND TOOLS PVT.LTD,,PUNE vs. DEPUTY COMMISSIONER OF INCOME-TAX, CIRCLE - 6,, PUNE

Bench: Shri S.S.Godara, Jm & Shri Dr. Dipak P. Ripote, Am आयकर अपीऱ सं. / Ita No.1778 To 1782/Pun/2019 ननधधारण वषा / Assessment Year : 2007-08 To 2011-12 M/S. Size Control Gauges & Tools Pvt. Ltd., Plot No.100/101, Tiny Industries Co-Op. Estate Ltd., Pisoli Road, Kondhwa(Bk), Pune – 411 048. .......अपऩलधथी / Appellant Pan : Aaccs3670F

section 143(2) after filing the return of income which had rendered the Assessment Order bad in law liable to be set aside. 3. The CIT(A) erred in not deleting the disallowance of Rs.20,31,158/- out of purchases though the purchases were fully verifiable and the payments were made through bank. 4. Without prejudice to Ground

M/S. SIZE CONTROL GAUGES AND TOOLS PVT.LTD,,PUNE vs. DEPUTY COMMISSIONER OF INCOME-TAX, CIRCLE - 6,, PUNE

Bench: Shri S.S.Godara, Jm & Shri Dr. Dipak P. Ripote, Am आयकर अपीऱ सं. / Ita No.1778 To 1782/Pun/2019 ननधधारण वषा / Assessment Year : 2007-08 To 2011-12 M/S. Size Control Gauges & Tools Pvt. Ltd., Plot No.100/101, Tiny Industries Co-Op. Estate Ltd., Pisoli Road, Kondhwa(Bk), Pune – 411 048. .......अपऩलधथी / Appellant Pan : Aaccs3670F

section 143(2) after filing the return of income which had rendered the Assessment Order bad in law liable to be set aside. 3. The CIT(A) erred in not deleting the disallowance of Rs.20,31,158/- out of purchases though the purchases were fully verifiable and the payments were made through bank. 4. Without prejudice to Ground

M/S. SIZE CONTROL GAUGES AND TOOLS PVT.LTD,,PUNE vs. DEPUTY COMMISSIONER OF INCOME-TAX, CIRCLE - 6,, PUNE

Bench: Shri S.S.Godara, Jm & Shri Dr. Dipak P. Ripote, Am आयकर अपीऱ सं. / Ita No.1778 To 1782/Pun/2019 ननधधारण वषा / Assessment Year : 2007-08 To 2011-12 M/S. Size Control Gauges & Tools Pvt. Ltd., Plot No.100/101, Tiny Industries Co-Op. Estate Ltd., Pisoli Road, Kondhwa(Bk), Pune – 411 048. .......अपऩलधथी / Appellant Pan : Aaccs3670F

section 143(2) after filing the return of income which had rendered the Assessment Order bad in law liable to be set aside. 3. The CIT(A) erred in not deleting the disallowance of Rs.20,31,158/- out of purchases though the purchases were fully verifiable and the payments were made through bank. 4. Without prejudice to Ground