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

iii) of the Income-tax Act, 1961, on the facts and circumstances of the case, and in law, the Ld. CIT(A) has erred in confirming the action of the Learned Assessing Officer [„Ld.AO‟] in reopening the assessment proceedings without any „reason to believe‟ as required by the provisions of section 147. It is prayed that the reassessment proceedings

ALNESH AKIL SOMJI,PUNE vs. ASSISTANT COMMISSIONER OF INCOME TAX, PUNE

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

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

68 of its order, after referring-to and relying upon the judgment of the apex court in the case of CIT vs Rajendra Prasad Moody (supra), Hon‟ble Allahabad High Court has concluded that “proper investment means correct investment with intention to earn profit but their lordships have nowhere held positive income. Without prejudice to the above

M/S. TATA TECHNOLOGIES LTD.,,PUNE vs. DEPUTY DIRECTOR OF INCOME-TAX,,

In the result, appeal of assessee is partly allowed

Bench: Ms. Sushma Chowla, Jm & Shri Anil Chaturvedi, Am आयकर अपीऱ सं. / Ita No.1433/Pun/2014 यििाारण वषा / Assessment Year : 2007-08 M/S. Tata Technologies Limited, Plot No.25, Rajiv Gandhi Infotech Park, अऩीऱाथी/Appellant Hingewadi, Pune – 411057 …. Pan: Aaact3092N Vs. The Dy. Director Of Income Tax …. प्रत्यथी / Respondent (International Taxation)-Ii, Pune

68,423 AMC for software USA ANSYS Inc 8,38,536 Software license USA Beta Cae Systems S.A 10,53,360 Software license Greece Beta Cae Systems S.A 1,46,300 Software license Greece Parametric Technology 1,37,009 Software license USA Corporation Proforma Corporation 40,329 Software license USA Spicer Corporation 42,437 Software license USA Tata Technologies

JOHN DEERE INDIA PVT. LTD.,,PUNE vs. DEPUTY DIRECTOR OF INCOME-TAX,,

In the result, all the appeals of assessee are allowed

Bench: Ms. Sushma Chowla, Jm & Shri Anil Chaturvedi, Am आयकर अपीऱ सं. / Ita Nos.905 & 906/Pun/2015 यििाारण वषा / Assessment Years :2007-08 & 2008-09

1), End User License was granted by Dakota Software Corporation under and subject to Master Agreement, as referred in the paras above and statement of work between Dakota Software Corporation and any other legal entity which was licensing access and use of software and instruction to access or use software. Then under clause 2.1 it is provided the access

JOHN DEERE INDIA PVT. LTD.,,PUNE vs. DEPUTY DIRECTOR OF INCOME-TAX,,

In the result, all the appeals of assessee are allowed

Bench: Ms. Sushma Chowla, Jm & Shri Anil Chaturvedi, Am आयकर अपीऱ सं. / Ita Nos.905 & 906/Pun/2015 यििाारण वषा / Assessment Years :2007-08 & 2008-09

1), End User License was granted by Dakota Software Corporation under and subject to Master Agreement, as referred in the paras above and statement of work between Dakota Software Corporation and any other legal entity which was licensing access and use of software and instruction to access or use software. Then under clause 2.1 it is provided the access

JOHN DEERE EQIPMENT P. LTD.,,PUNE vs. DEPUTY DIRECTOR OF INCOME-TAX,,

In the result, all the appeals of assessee are allowed

Bench: Ms. Sushma Chowla, Jm & Shri Anil Chaturvedi, Am आयकर अपीऱ सं. / Ita Nos.905 & 906/Pun/2015 यििाारण वषा / Assessment Years :2007-08 & 2008-09

1), End User License was granted by Dakota Software Corporation under and subject to Master Agreement, as referred in the paras above and statement of work between Dakota Software Corporation and any other legal entity which was licensing access and use of software and instruction to access or use software. Then under clause 2.1 it is provided the access

JOHN DEERE EQIPMENT P. LTD.,,PUNE vs. DEPUTY DIRECTOR OF INCOME-TAX,,

In the result, all the appeals of assessee are allowed

Bench: Ms. Sushma Chowla, Jm & Shri Anil Chaturvedi, Am आयकर अपीऱ सं. / Ita Nos.905 & 906/Pun/2015 यििाारण वषा / Assessment Years :2007-08 & 2008-09

1), End User License was granted by Dakota Software Corporation under and subject to Master Agreement, as referred in the paras above and statement of work between Dakota Software Corporation and any other legal entity which was licensing access and use of software and instruction to access or use software. Then under clause 2.1 it is provided the access

DEPUTY COMMISSIONER OF INCOME-TAX CIRCLE -5, PUNE vs. SERUM INSTITUTE OF INDIA PVT LTD.,, PUNE

In the result, the appeal filed by the Revenue stands dismissed

26. However, in the return of income, this expenditure incurred on Research & Development and products though capitalized in the books of account was claimed as deduction as revenue expenditure u/s 37(1) or u/s 35(1)(iv) of the Act. The Assessing Officer was of the opinion that such expenditure is capital in nature and cannot be allowed as revenue

PRAKASH RAMAN CHAUDHARI,,NASHIK vs. INCOME-TAX OFFICER,,

In the result, all the appeals of assessee are allowed

Bench: Ms. Sushma Chowla, Jm & Shri Anil Chaturvedi, Am आयकर अपीऱ सं. / Ita Nos.737 To 740/Pun/2016 यििाारण वषा / Assessment Years : 2006-07, 2008-09, 2010-11 & 2011-12 Prakash Raman Chaudhari, Garden View Bunglow, Saptashrungi Colony, Old Gangapur Naka, अऩीऱाथी/Appellant Nashik – 422005 …. Pan:Aajpc9817C Vs. The Income Tax Officer (Central)-I, …. प्रत्यथी / Respondent Nashik

iii) which would be in addition to tax, if any, payable by the said person. The section thus requires the concerned Officer to record satisfaction in the course ITA Nos.742 to 747/PUN/2016 of any proceedings under the Act, that the person has concealed the particulars of his income or furnished inaccurate particulars of his income. After recording the satisfaction

PRAKASH RAMAN CHAUDHARI,,NASHIK vs. INCOME-TAX OFFICER,,

In the result, all the appeals of assessee are allowed

Bench: Ms. Sushma Chowla, Jm & Shri Anil Chaturvedi, Am आयकर अपीऱ सं. / Ita Nos.737 To 740/Pun/2016 यििाारण वषा / Assessment Years : 2006-07, 2008-09, 2010-11 & 2011-12 Prakash Raman Chaudhari, Garden View Bunglow, Saptashrungi Colony, Old Gangapur Naka, अऩीऱाथी/Appellant Nashik – 422005 …. Pan:Aajpc9817C Vs. The Income Tax Officer (Central)-I, …. प्रत्यथी / Respondent Nashik

iii) which would be in addition to tax, if any, payable by the said person. The section thus requires the concerned Officer to record satisfaction in the course ITA Nos.742 to 747/PUN/2016 of any proceedings under the Act, that the person has concealed the particulars of his income or furnished inaccurate particulars of his income. After recording the satisfaction

PRAKASH RAMAN CHAUDHARI,,NASHIK vs. INCOME-TAX OFFICER,,

In the result, all the appeals of assessee are allowed

Bench: Ms. Sushma Chowla, Jm & Shri Anil Chaturvedi, Am आयकर अपीऱ सं. / Ita Nos.737 To 740/Pun/2016 यििाारण वषा / Assessment Years : 2006-07, 2008-09, 2010-11 & 2011-12 Prakash Raman Chaudhari, Garden View Bunglow, Saptashrungi Colony, Old Gangapur Naka, अऩीऱाथी/Appellant Nashik – 422005 …. Pan:Aajpc9817C Vs. The Income Tax Officer (Central)-I, …. प्रत्यथी / Respondent Nashik

iii) which would be in addition to tax, if any, payable by the said person. The section thus requires the concerned Officer to record satisfaction in the course ITA Nos.742 to 747/PUN/2016 of any proceedings under the Act, that the person has concealed the particulars of his income or furnished inaccurate particulars of his income. After recording the satisfaction

PRAKASH RAMAN CHAUDHARI,,NASHIK vs. INCOME-TAX OFFICER,,

In the result, all the appeals of assessee are allowed

Bench: Ms. Sushma Chowla, Jm & Shri Anil Chaturvedi, Am आयकर अपीऱ सं. / Ita Nos.737 To 740/Pun/2016 यििाारण वषा / Assessment Years : 2006-07, 2008-09, 2010-11 & 2011-12 Prakash Raman Chaudhari, Garden View Bunglow, Saptashrungi Colony, Old Gangapur Naka, अऩीऱाथी/Appellant Nashik – 422005 …. Pan:Aajpc9817C Vs. The Income Tax Officer (Central)-I, …. प्रत्यथी / Respondent Nashik

iii) which would be in addition to tax, if any, payable by the said person. The section thus requires the concerned Officer to record satisfaction in the course ITA Nos.742 to 747/PUN/2016 of any proceedings under the Act, that the person has concealed the particulars of his income or furnished inaccurate particulars of his income. After recording the satisfaction

MEGHA PRAKASH CHAUDHARI,,NASHIK vs. INCOME-TAX OFFICER,,

In the result, all the appeals of assessee are allowed

Bench: Ms. Sushma Chowla, Jm & Shri Anil Chaturvedi, Am आयकर अपीऱ सं. / Ita Nos.737 To 740/Pun/2016 यििाारण वषा / Assessment Years : 2006-07, 2008-09, 2010-11 & 2011-12 Prakash Raman Chaudhari, Garden View Bunglow, Saptashrungi Colony, Old Gangapur Naka, अऩीऱाथी/Appellant Nashik – 422005 …. Pan:Aajpc9817C Vs. The Income Tax Officer (Central)-I, …. प्रत्यथी / Respondent Nashik

iii) which would be in addition to tax, if any, payable by the said person. The section thus requires the concerned Officer to record satisfaction in the course ITA Nos.742 to 747/PUN/2016 of any proceedings under the Act, that the person has concealed the particulars of his income or furnished inaccurate particulars of his income. After recording the satisfaction

MEGHA PRAKASH CHAUDHARI,,NASHIK vs. INCOME-TAX OFFICER,,

In the result, all the appeals of assessee are allowed

Bench: Ms. Sushma Chowla, Jm & Shri Anil Chaturvedi, Am आयकर अपीऱ सं. / Ita Nos.737 To 740/Pun/2016 यििाारण वषा / Assessment Years : 2006-07, 2008-09, 2010-11 & 2011-12 Prakash Raman Chaudhari, Garden View Bunglow, Saptashrungi Colony, Old Gangapur Naka, अऩीऱाथी/Appellant Nashik – 422005 …. Pan:Aajpc9817C Vs. The Income Tax Officer (Central)-I, …. प्रत्यथी / Respondent Nashik

iii) which would be in addition to tax, if any, payable by the said person. The section thus requires the concerned Officer to record satisfaction in the course ITA Nos.742 to 747/PUN/2016 of any proceedings under the Act, that the person has concealed the particulars of his income or furnished inaccurate particulars of his income. After recording the satisfaction

MEGHA PRAKASH CHAUDHARI,,NASHIK vs. INCOME-TAX OFFICER,,

In the result, all the appeals of assessee are allowed

Bench: Ms. Sushma Chowla, Jm & Shri Anil Chaturvedi, Am आयकर अपीऱ सं. / Ita Nos.737 To 740/Pun/2016 यििाारण वषा / Assessment Years : 2006-07, 2008-09, 2010-11 & 2011-12 Prakash Raman Chaudhari, Garden View Bunglow, Saptashrungi Colony, Old Gangapur Naka, अऩीऱाथी/Appellant Nashik – 422005 …. Pan:Aajpc9817C Vs. The Income Tax Officer (Central)-I, …. प्रत्यथी / Respondent Nashik

iii) which would be in addition to tax, if any, payable by the said person. The section thus requires the concerned Officer to record satisfaction in the course ITA Nos.742 to 747/PUN/2016 of any proceedings under the Act, that the person has concealed the particulars of his income or furnished inaccurate particulars of his income. After recording the satisfaction

MEGHA PRAKASH CHAUDHARI,,NASHIK vs. INCOME-TAX OFFICER,,

In the result, all the appeals of assessee are allowed

Bench: Ms. Sushma Chowla, Jm & Shri Anil Chaturvedi, Am आयकर अपीऱ सं. / Ita Nos.737 To 740/Pun/2016 यििाारण वषा / Assessment Years : 2006-07, 2008-09, 2010-11 & 2011-12 Prakash Raman Chaudhari, Garden View Bunglow, Saptashrungi Colony, Old Gangapur Naka, अऩीऱाथी/Appellant Nashik – 422005 …. Pan:Aajpc9817C Vs. The Income Tax Officer (Central)-I, …. प्रत्यथी / Respondent Nashik

iii) which would be in addition to tax, if any, payable by the said person. The section thus requires the concerned Officer to record satisfaction in the course ITA Nos.742 to 747/PUN/2016 of any proceedings under the Act, that the person has concealed the particulars of his income or furnished inaccurate particulars of his income. After recording the satisfaction

MEGHA PRAKASH CHAUDHARI,,NASHIK vs. INCOME-TAX OFFICER,,

In the result, all the appeals of assessee are allowed

Bench: Ms. Sushma Chowla, Jm & Shri Anil Chaturvedi, Am आयकर अपीऱ सं. / Ita Nos.737 To 740/Pun/2016 यििाारण वषा / Assessment Years : 2006-07, 2008-09, 2010-11 & 2011-12 Prakash Raman Chaudhari, Garden View Bunglow, Saptashrungi Colony, Old Gangapur Naka, अऩीऱाथी/Appellant Nashik – 422005 …. Pan:Aajpc9817C Vs. The Income Tax Officer (Central)-I, …. प्रत्यथी / Respondent Nashik

iii) which would be in addition to tax, if any, payable by the said person. The section thus requires the concerned Officer to record satisfaction in the course ITA Nos.742 to 747/PUN/2016 of any proceedings under the Act, that the person has concealed the particulars of his income or furnished inaccurate particulars of his income. After recording the satisfaction

MEGHA PRAKASH CHAUDHARI,,NASHIK vs. INCOME-TAX OFFICER,,

In the result, all the appeals of assessee are allowed

Bench: Ms. Sushma Chowla, Jm & Shri Anil Chaturvedi, Am आयकर अपीऱ सं. / Ita Nos.737 To 740/Pun/2016 यििाारण वषा / Assessment Years : 2006-07, 2008-09, 2010-11 & 2011-12 Prakash Raman Chaudhari, Garden View Bunglow, Saptashrungi Colony, Old Gangapur Naka, अऩीऱाथी/Appellant Nashik – 422005 …. Pan:Aajpc9817C Vs. The Income Tax Officer (Central)-I, …. प्रत्यथी / Respondent Nashik

iii) which would be in addition to tax, if any, payable by the said person. The section thus requires the concerned Officer to record satisfaction in the course ITA Nos.742 to 747/PUN/2016 of any proceedings under the Act, that the person has concealed the particulars of his income or furnished inaccurate particulars of his income. After recording the satisfaction