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

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

Section 80HHC deals with deductions in respect of profits from export of computer software etc. 23. There also the words used are "export out of India". But to be eligible for deduction under the aforesaid provision, mere export out of India is not sufficient. What is to be exported out of India should be from India to a place

JOSHI WADEWALE HADAPSAR,,PUNE vs. DEPUTY COMMISSIONER OF INCOME-TAX,,

In the result, appeals in the case of Mrs

Bench: Ms. Sushma Chowla, Jm & Shri D. Karunakara Rao, Am आयकर अपीऱ सं. / Ita Nos.95 & 96/Pun/2016 यििाारण वषा / Assessment Years : 2009-10 & 2010-11

68, 69, 69A, 69B, 69C & 69D. 18. It is necessary to refer to Explanation 5A which reads as under: ―Explanation 5A – Where, in the course of a search initiated under section 132 on or before the 1st day of June 2007, the assessee is found to be the owner of (i) Any money, bullion, jeweler or other valuable article

MRS. VASUNDHARA SHAILESH JOSHI,,PUNE vs. DEPUTY COMMISSIONER OF INCOME-TAX,,

In the result, appeals in the case of Mrs

Bench: Ms. Sushma Chowla, Jm & Shri D. Karunakara Rao, Am आयकर अपीऱ सं. / Ita Nos.95 & 96/Pun/2016 यििाारण वषा / Assessment Years : 2009-10 & 2010-11

68, 69, 69A, 69B, 69C & 69D. 18. It is necessary to refer to Explanation 5A which reads as under: ―Explanation 5A – Where, in the course of a search initiated under section 132 on or before the 1st day of June 2007, the assessee is found to be the owner of (i) Any money, bullion, jeweler or other valuable article

JOSHI WADEWALE SHEWALWADI,,PUNE vs. DEPUTY COMMISSIONER OF INCOME-TAX,,

In the result, appeals in the case of Mrs

Bench: Ms. Sushma Chowla, Jm & Shri D. Karunakara Rao, Am आयकर अपीऱ सं. / Ita Nos.95 & 96/Pun/2016 यििाारण वषा / Assessment Years : 2009-10 & 2010-11

68, 69, 69A, 69B, 69C & 69D. 18. It is necessary to refer to Explanation 5A which reads as under: ―Explanation 5A – Where, in the course of a search initiated under section 132 on or before the 1st day of June 2007, the assessee is found to be the owner of (i) Any money, bullion, jeweler or other valuable article

MRS. VASUNDHARA SHAILESH JOSHI,,PUNE vs. DEPUTY COMMISSIONER OF INCOME-TAX,,

In the result, appeals in the case of Mrs

Bench: Ms. Sushma Chowla, Jm & Shri D. Karunakara Rao, Am आयकर अपीऱ सं. / Ita Nos.95 & 96/Pun/2016 यििाारण वषा / Assessment Years : 2009-10 & 2010-11

68, 69, 69A, 69B, 69C & 69D. 18. It is necessary to refer to Explanation 5A which reads as under: ―Explanation 5A – Where, in the course of a search initiated under section 132 on or before the 1st day of June 2007, the assessee is found to be the owner of (i) Any money, bullion, jeweler or other valuable article

JOSHI WADEWALE SHEWALWADI,,PUNE vs. DEPUTY COMMISSIONER OF INCOME-TAX,,

In the result, appeals in the case of Mrs

Bench: Ms. Sushma Chowla, Jm & Shri D. Karunakara Rao, Am आयकर अपीऱ सं. / Ita Nos.95 & 96/Pun/2016 यििाारण वषा / Assessment Years : 2009-10 & 2010-11

68, 69, 69A, 69B, 69C & 69D. 18. It is necessary to refer to Explanation 5A which reads as under: ―Explanation 5A – Where, in the course of a search initiated under section 132 on or before the 1st day of June 2007, the assessee is found to be the owner of (i) Any money, bullion, jeweler or other valuable article

JOSHI WADEWALE PRABHAT CINEMA,,PUNE vs. DEPUTY COMMISSIONER OF INCOME-TAX,,

In the result, appeals in the case of Mrs

Bench: Ms. Sushma Chowla, Jm & Shri D. Karunakara Rao, Am आयकर अपीऱ सं. / Ita Nos.95 & 96/Pun/2016 यििाारण वषा / Assessment Years : 2009-10 & 2010-11

68, 69, 69A, 69B, 69C & 69D. 18. It is necessary to refer to Explanation 5A which reads as under: ―Explanation 5A – Where, in the course of a search initiated under section 132 on or before the 1st day of June 2007, the assessee is found to be the owner of (i) Any money, bullion, jeweler or other valuable article

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

37. Coming to the next decision of Ahmedabad Bench of Tribunal in ITO Vs. Veeda Clinical Research (P) Ltd. (supra), he admitted that it clearly decides the issue. In this regard, he again pointed out that the issue has been considered and decided by AAR in Intertek Testing Services India (P.) Ltd., In re_* (2008) 307 ITR 418 (AAR), which

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

37. Coming to the next decision of Ahmedabad Bench of Tribunal in ITO Vs. Veeda Clinical Research (P) Ltd. (supra), he admitted that it clearly decides the issue. In this regard, he again pointed out that the issue has been considered and decided by AAR in Intertek Testing Services India (P.) Ltd., In re_* (2008) 307 ITR 418 (AAR), which

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

37. Coming to the next decision of Ahmedabad Bench of Tribunal in ITO Vs. Veeda Clinical Research (P) Ltd. (supra), he admitted that it clearly decides the issue. In this regard, he again pointed out that the issue has been considered and decided by AAR in Intertek Testing Services India (P.) Ltd., In re_* (2008) 307 ITR 418 (AAR), which

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

37. Coming to the next decision of Ahmedabad Bench of Tribunal in ITO Vs. Veeda Clinical Research (P) Ltd. (supra), he admitted that it clearly decides the issue. In this regard, he again pointed out that the issue has been considered and decided by AAR in Intertek Testing Services India (P.) Ltd., In re_* (2008) 307 ITR 418 (AAR), which

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

68,417/- and ₹ 32,77,864/- in assessment year 2011-12. Further, unexplained investment in jewellery was added in the hands of assessee by Assessing Officer at ₹ 21,073/- in assessment year 2006-07, ₹ 13,298/- in assessment year 2008-09, ₹4,38,888/- in assessment year 2010-11 and ₹ 3,18,182/- in assessment year 2011-12. Another addition

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

68,417/- and ₹ 32,77,864/- in assessment year 2011-12. Further, unexplained investment in jewellery was added in the hands of assessee by Assessing Officer at ₹ 21,073/- in assessment year 2006-07, ₹ 13,298/- in assessment year 2008-09, ₹4,38,888/- in assessment year 2010-11 and ₹ 3,18,182/- in assessment year 2011-12. Another addition

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

68,417/- and ₹ 32,77,864/- in assessment year 2011-12. Further, unexplained investment in jewellery was added in the hands of assessee by Assessing Officer at ₹ 21,073/- in assessment year 2006-07, ₹ 13,298/- in assessment year 2008-09, ₹4,38,888/- in assessment year 2010-11 and ₹ 3,18,182/- in assessment year 2011-12. Another addition

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

68,417/- and ₹ 32,77,864/- in assessment year 2011-12. Further, unexplained investment in jewellery was added in the hands of assessee by Assessing Officer at ₹ 21,073/- in assessment year 2006-07, ₹ 13,298/- in assessment year 2008-09, ₹4,38,888/- in assessment year 2010-11 and ₹ 3,18,182/- in assessment year 2011-12. Another addition

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

68,417/- and ₹ 32,77,864/- in assessment year 2011-12. Further, unexplained investment in jewellery was added in the hands of assessee by Assessing Officer at ₹ 21,073/- in assessment year 2006-07, ₹ 13,298/- in assessment year 2008-09, ₹4,38,888/- in assessment year 2010-11 and ₹ 3,18,182/- in assessment year 2011-12. Another addition

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

68,417/- and ₹ 32,77,864/- in assessment year 2011-12. Further, unexplained investment in jewellery was added in the hands of assessee by Assessing Officer at ₹ 21,073/- in assessment year 2006-07, ₹ 13,298/- in assessment year 2008-09, ₹4,38,888/- in assessment year 2010-11 and ₹ 3,18,182/- in assessment year 2011-12. Another addition