RAJARSHI SHAHU SHIKSHAN SANSTHA INAM DHAMANI,SANGLI vs. ITO EXEMPTION, KOLHAPUR, KOLHAPUR

In the result, all the appeals filed by the assessee are partly allowed as per terms indicated hereinabove

Bench: Dr.Manish Borad & Shri Vinay Bhamoreआयकर अपील सं. / Ita Nos.1121 To 1126/Pun/2024 Assessment Years : 2012-13 To 2017-18

2), etc.).” 5. Though the assessee has raised various grounds of appeal including the additional grounds, we will first take up the legal issue raised in Ground No.1 challenging the assumption of jurisdiction by the Assessing officer for carrying out the re-assessment proceedings. 6. We take the basis of facts for A.Y. 2012-13. The facts in brief

RAJARSHI SHAHU SHIKSHAN SANSTHA INAM DHAMANI,SANGLI vs. ITO EXEMPTION, KOLHAPUR, KOLHAPUR

In the result, all the appeals filed by the assessee are partly allowed as per terms indicated hereinabove

Bench: Dr.Manish Borad & Shri Vinay Bhamoreआयकर अपील सं. / Ita Nos.1121 To 1126/Pun/2024 Assessment Years : 2012-13 To 2017-18

2), etc.).” 5. Though the assessee has raised various grounds of appeal including the additional grounds, we will first take up the legal issue raised in Ground No.1 challenging the assumption of jurisdiction by the Assessing officer for carrying out the re-assessment proceedings. 6. We take the basis of facts for A.Y. 2012-13. The facts in brief

RAJARSHI SHAHU SHIKSHAN SANSTHA INAM DHAMANI,SANGLI vs. ITO EXEMPTION, KOLHAPUR, KOLHAPUR

In the result, all the appeals filed by the assessee are\npartly allowed as per terms indicated hereinabove

section 68\nof the Act. However, so far as the issue of assumption of\njurisdiction u/s.147 of the Act is concerned, there is no\nspecific finding by ld.CIT(A).\n8. Now the assessee is in appeal before this Tribunal raising\nvarious issues including the legal issue and claimed that in\nview of judgment of Hon'ble Apex Court

RAJARSHI SHAHU SHIKSHAN SANSTHA INAM DHAMANI,SANGLI vs. ITO EXEMPTION , KOLHAPUR, KOLHAPUR

In the result, all the appeals filed by the assessee are\npartly allowed as per terms indicated hereinabove

section 68\nof the Act. However, so far as the issue of assumption of\njurisdiction u/s.147 of the Act is concerned, there is no\nspecific finding by ld.CIT(A).\n8. Now the assessee is in appeal before this Tribunal raising\nvarious issues including the legal issue and claimed that in\nview of judgment of Hon'ble Apex Court

RAJARSHI SHAHU SHIKSHAN SANSTHA INAM DHAMANI,SANGLI vs. ITO EXEMPTION, KOLHAPUR

In the result, all the appeals filed by the assessee are\npartly allowed as per terms indicated hereinabove

section 68\nof the Act. However, so far as the issue of assumption of\njurisdiction u/s.147 of the Act is concerned, there is no\nspecific finding by ld.CIT(A).\n8. Now the assessee is in appeal before this Tribunal raising\nvarious issues including the legal issue and claimed that in\nview of judgment of Hon'ble Apex Court

INCOME-TAX OFFICER vs. SERUM INSTITUTE OF INDIA RESEARCH FOUNDATION,, PUNE

In the result, appeal of the Revenue is dismissed

Bench: Shri D.Karunakara Rao, Am & Shri Vikas Awasthy, Jm आयकर आयकर अपील आयकर आयकर अपील अपील संसंसंसं. / Ita No.621/Pun/2016 अपील िनधा"रण िनधा"रण वष" िनधा"रण िनधा"रण वष" वष" / Assessment Year : 2005-06 वष"

section 12AA or not. Therefore, I agree with the learned authorised representative that the amount of Rs. 68,50,000 being in the nature of corpus donation is not taxable under the Income-tax Act being in the nature of capital receipt and therefore, addition of Rs. 68,50,000 made by the Assessing Officer towards the taxable income

DY. COMMISSIONER OF INCOME TAX, SATARA CIRCLE, SATARA, SATARA vs. SHRI SIDDHANATH NAGARI SAHAKARI PATSANSTHA MARYA DAHIWADI, TAL. MAN SATARA

In the result, the appeal of the Revenue in ITA No

68,141/- from its\ninvestments with Co-operative Banks. In the computation of total income\nsubmitted during course of scrutiny, the assessee claimed that it is a Co-\noperative Society and as such income of Rs.5,15,78,931/- from above-stated\ninterest receipts is deductible under section 80P of the Act. The Ld. AO held\nthat section

DY. COMMISSIONER OF INCOME TAX, SATARA CIRCLE, SATARA, SATARA vs. SHRI SIDDHANATH NAGARI SAHAKARI PATSANSTHA MARYA DAHIWADI, MAN,SATARA

In the result, the appeal of the Revenue in ITA No

68,141/- from its\ninvestments with Co-operative Banks. In the computation of total income\nsubmitted during course of scrutiny, the assessee claimed that it is a Co-\noperative Society and as such income of Rs.5,15,78,931/- from above-stated\ninterest receipts is deductible under section 80P of the Act. The Ld. AO held\nthat section

CAPGEMINI TECHNOLOGY SERVICES INDIA LIMITED ( SUCCESSOR OF ARICENT TECHNOLOGIES HOLDINGS LIMITED),PUNE vs. ASSISTANT COMMISSIONER OF INCOME TAX, CIRCLE 1(1), PUNE, PUNE

In the result, the appeal of the assessee is allowed

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

2) of section 249, grant immunity from imposition of penalty under section 270A and initiation of proceedings under section 276C or section 286CC, where the proceedings for penalty under section 270A has not been initiated under the circumstances referred to in sub-section (9) of the said section 270A. (4) The Assessing Officer

HAVELI TALUKA VEEJ KAMGAR SAHAKARI PATHSANSTHA MARYADIT,PUNE vs. INCOME TAX OFFICER WARD 6 (1) PUNE, PMT BUILDING, SWARGATE

In the result, the appeal of the assessee is allowed

68 and the Hon'ble\nKolkata High Court in the case of CIT Vs. Southern Eastern Employees\nCooperative Credit Society Ltd. 390 ITR 524 took a view that the income\narising on the surplus invested in short term deposits and securities cannot\nbe attributed to the activities of the society and, therefore, not eligible for\nexemption u/s.80P(2

M/S. L.B. KUNJIR,PUNE vs. DEPUTY COMMISSIONER OF INCOME TAX, CIRCLE 7, PUNE, PUNE

In the result, the two appeals filed by the assessee are allowed and the three appeals filed by Revenue are dismissed

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

68 and 69 to 69D. Since, I have already upheld that the additional income corresponding to excess stock is taxable u/s 69B of the Act, therefore, as per provisions of section 115BBE(2), no deduction for this amount can be allowed to the appellant in any assessment year. Accordingly, the contention raised by the appellant is rejected. The grounds

DCIT, PUNE vs. L B KUNJIR, PUNE

In the result, the two appeals filed by the assessee are allowed and the three appeals filed by Revenue are dismissed

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

68 and 69 to 69D. Since, I have already upheld that the additional income corresponding to excess stock is taxable u/s 69B of the Act, therefore, as per provisions of section 115BBE(2), no deduction for this amount can be allowed to the appellant in any assessment year. Accordingly, the contention raised by the appellant is rejected. The grounds

DCIT CIRCLE 7, BODHI TOWER SALISBURY PARK vs. L B KUNJIR, PUNE

In the result, the two appeals filed by the assessee are allowed and the three appeals filed by Revenue are dismissed

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

68 and 69 to 69D. Since, I have already upheld that the additional income corresponding to excess stock is taxable u/s 69B of the Act, therefore, as per provisions of section 115BBE(2), no deduction for this amount can be allowed to the appellant in any assessment year. Accordingly, the contention raised by the appellant is rejected. The grounds

M/S. L.B. KUNJIR,PUNE vs. DEPUTY COMMISSIONER OF INCOME TAX, CIRCLE 7, PUNE, PUNE

In the result, the two appeals filed by the assessee are allowed and the three appeals filed by Revenue are dismissed

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

68 and 69 to 69D. Since, I have already upheld that the additional income corresponding to excess stock is taxable u/s 69B of the Act, therefore, as per provisions of section 115BBE(2), no deduction for this amount can be allowed to the appellant in any assessment year. Accordingly, the contention raised by the appellant is rejected. The grounds

DEPUTY COMMISSIONER OF INCOME TAX, CIRCLE-7, PUNE vs. LB KUNJIR, PUNE

In the result, the two appeals filed by the assessee are allowed and the three appeals filed by Revenue are dismissed

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

68 and 69 to 69D. Since, I have already upheld that the additional income corresponding to excess stock is taxable u/s 69B of the Act, therefore, as per provisions of section 115BBE(2), no deduction for this amount can be allowed to the appellant in any assessment year. Accordingly, the contention raised by the appellant is rejected. The grounds

MANOJ JAIKUMAR TIBREWALA,,NASHIK vs. ASSISTANT COMMISSIONER OF INCOME-TAX, CENTRAL CIRCLE -1,, NASHIK

Accordingly. We make it clear that the assessee shall be at liberty to file all the relevant details in consequential proceedings. This last appeal ITA No. 609/Pun/2019 is allowed for statistical p...

Bench: Shri S.S. Godara & Dr. Dipak P. Ripoteit(Ss)A Nos. 06 & 07/Pun/2017 (Assessment Years: 2012-13 & 2013-14) Shri Manoj Jaikumar Tibrewala Acit, Central Circle-1 Vastu Shilp, Ground Floor Kendriya Rajaswa Bhavan Godavari Housing Society Vs. Gadkari Chowk Boys Town School Road Old Agra Road, Nashik Nashik 422005 Pan – Aakpt7009G Appellant Respondent Appellant By: Shri Pamod S. Shingte Respondent By: Shri S.P. Walimbe Date Of Hearing: 25.04.2022 Date Of Pronouncement: 10.05.2022

section 2(22)(e) is redundant. It is bound to be for a specific purpose. The question for determination is as to what is the purpose for which this Explanation. has been incorporated when the Hon'ble Supreme Court in the case of Ashokbhai Chimanbhai have held that the profits of business do not accrue from

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

SETH RAMDAS NATHUBHAI DHARMADAYA VISHWASTA NIDHI,,PUNE vs. INCOME-TAX OFFICER,(EXEMPTIONS) -1,, PUNE

Bench: Shri R.S. Syal & Shri Partha Sarathi Chaudhury"नधा"रण वष" / Assessment Year : 2011-12 Seth Ramdas Nathubhai Dharmadaya Vs. Ito Vishwasta Nidhi, (Exemptions)-1, C/O. Shah Khandelwal Jain & Pune Associates, Chartered Accountants, Level 3, Business Bay, Plot No.84, Wellesley Road, Near Rto, Pune 411 001 Pan : Aaatr6805N Appellant Respondent

68,12,295/- the net income over the expenditure was arrived at Rs.42,98,82,657/-. 4. During the assessment proceedings, the ld. Assessing Officer (AO) had issued a show cause notice to the assessee asking to justify the payment made to trustees, being interested persons in view of the provisions of section

INCOME-TAX OFFICER vs. KESHAVSMURTI NAGARI SAHAKARI PATPEDHI LTD.,, RAIGAD

Bench: Ms. Sushma Chowla, Jm & Shri Anil Chaturvedi, Am आयकर अपीऱ सं. / Ita No.936/Pun/2015 यििाारण वषा / Assessment Year : 2010-11 The Income Tax Officer, अऩीऱाथी/Appellant Ward 5, Panvel …. Vs. Keshavsmurti Nagari Sahakari Patpedhi Ltd., Shop No.1G/F, Anpurna Niwas, Shivaji Road, Tal – Panvel, …. प्रत्यथी / Respondent Dist – Raigad – 410206 Pan: Aaaak7390L प्रत्याक्षेप सं./Co No.30/Pun/2017 यििाारण वषा / Assessment Year : 2010-11 (Out Of Ita No.936/Pun/2015) Keshavsmurti Nagari Sahakari Patpedhi Ltd., Shop No.1G/F, Anpurna Niwas, Shivaji Road, Tal – Panvel, … प्रत्याक्षेऩक/ Cross Objector Dist – Raigad – 410206 Pan: Aaaak7390L Vs. The Income Tax Officer, …. प्रत्यथी / Respondent Ward 5, Panvel

6 CO No.30/PUN/2017 of decisions of the Pune Bench of Tribunal and latest being ITO Vs. M/s. Kundalika Nagari Sahakari Patsanstha Maryadit (supra). The learned Authorized Representative for the assessee also pointed out that strictly in the alternate, the assessee being Credit Co-operative Society having earned interest on the deposits made with other Co-operative Banks was entitled