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

68,175.00 Bank Charges RTGS RECEIPT RECEIPT/07- 08/160 31-3-2012 Cr PATHARDI LAND Journal 154 3,18,84,136.00 (PARKSYDE) BEING Cr Closing Balance 3,60,34,136.00 4,79,61,222.00 1,19,27,086.00 4,79,61,222.000 4,79,61,222.00 Perusal of the above ledger account clearly shows that apart from money to be received

CAPGEMINI TECHNOLOGY SERVICES INDIA LTD,,PUNE vs. DEPUTY COMMISSIONER OF INCOME-TAX, CIRCLE - 11,, PUNE

In the result, both the appeals are partly allowed

Bench: Shri R.S. Syal & Shri Partha Sarathi Chaudhury

68 onwards of the paper book. As per the Scheme of arrangement u/s.391 and 394 of the Companies Act, 1956, it has been provided that all the assets and liabilities of the undertaking of the amalgamating company shall stand transferred and vest in and deemed to be the assets and liabilities of the amalgamated company. Clause

ASSISTANT COMMISSIONER OF INCOME-TAX, CIRCLE -11,, PUNE vs. CAPGEMINI TECHNOLOGY SERVICES INDIA LIMITED , (FORMERLY IGATE GLOBAL SOLUTIONS LTD.),, PUNE

In the result, both the appeals are partly allowed

Bench: Shri R.S. Syal & Shri Partha Sarathi Chaudhury

68 onwards of the paper book. As per the Scheme of arrangement u/s.391 and 394 of the Companies Act, 1956, it has been provided that all the assets and liabilities of the undertaking of the amalgamating company shall stand transferred and vest in and deemed to be the assets and liabilities of the amalgamated company. Clause

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

INCOME TAX OFFICER, PUNE vs. SAGAR CONSTRUCTION COMPANY, PUNE

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

Bench: Shri R. K. Panda & Ms. Astha Chandraassessment Year : 2017-18

68 of the Income Tax Act, 1961? 2. Whether on the facts and circumstances of the case and in law, the Hon'ble CIT(A) was justified in deleting the of Rs.17,80,059/- made on account of interest paid on alleged unsecured loans is 37 of the Income tax Act, 1961? 3. Whether on the facts

GOPAL EXTRUSIONS PVT LTD,,JALGAON vs. INCOME-TAX OFFICER, WARD - 1(2),, JALGAON

Bench: Dr.Manish Borad & Shri Vinay Bhamoreआयकर अपील सं. / Ita. No.1633/Pun/2017 Assessment Year : 2008-09

90 certain amount as share capital from taxmann.com 56 (Bombay) various shareholders, in view of fact that summons served to shareholders under section 131 were unserved with remark that addressees were not available, and, moreover, those shareholders were first time assessees and were not earning enough income to make deposits in question, impugned addition made by AO under

SATISH VISHNU THOMBARE, INCOME TAX OFFICER, WARD-1, AHMEDNAGAR, AHMEDNAGAR vs. VARSHA PRAFULLA ZENDE, AHMEDNAGAR

In the result, the appeal of the Revenue is dismissed

Bench: Shri R.K. Panda & Ms. Astha Chandraआयकर अपील सं. / Ita No.1656/Pun/2024 धििाारण वर्ा / Assessment Year : 2010-11 Satish Vishnu Thombare, Varsha Prafulla Zende, Income Tax Officer, Prop Of Bleach Chem Enterprises, Ward-1, Ahmednagar Vs. Industrial Estate, Shrirampur, Maharashtra-413709 Pan : Aabpz2541C अपीलार्थी / Appellant प्रत्यर्थी / Respondent Assessee By : Miss Shivani Shah (Virtual) Department By : Shri Akhilesh Srivastva Date Of Hearing : 06-08-2025 Date Of 29-10-2025 Pronouncement : आदेश / Order

68,49 16850 84 traders Pvt. G Chem Dist. 3 Ltd. Enterprise Ahmednaga s r Total 429452 From the above it is revealed that bogus Companies run by Shri. Anand Sharma and Group has provided bogus Commission entries to Bleach Chem Enterprises, Prop. Smt. Varsha Prafulla Zende (PAN- AACPZ2541C) during FY 2009-10 to the tune of Rs.4

GRI RENEWABLE INDUSTRIES S L (FORMERLY KNOWN AS GONVARRI EOLICA S L),MADRID vs. ASSISTANT COMMISSIONER OF INCOME-TAX (INTERNATIONAL TAXATION) CIRCLE -1, PUNE

In the result, the appeal is partly allowed

Bench: Shri R.S. Syal & Shri Partha Sarathi Chaudhuryआयकर अपील सं. / Ita No.202/Pun/2021 "नधा"रण वष" / Assessment Year : 2016-17

section 90(1) of the Act leaving no room for any separate notification for the importation. The sequitur is that that the authorities below were not justified in denying the benefit of the straight rate of tax at 10% as per the DTAA read with Portuguese DTAA and also additionally charging Surcharge and Education cess. 14 GRI Renewable Industries

BIZ SECURE LABS PVT.LTD,,PUNE vs. DEPUTY COMMISSIONER OF INCOME-TAX, CIRCLE - 1(1),, PUNE

In the result, the appeal of the Revenue is dismissed and that

Bench: Shri R.S. Syal & Shri Sonjoy Sarma"नधा"रण वष" / Assessment Year : 2012-13 Biz Secure Labs Pvt. Ltd., Vs. Dcit, 1206, Sadashiv Peth, Circle- 1(1), Pune 411 030 Pune Pan : Aadcb6188L Appellant Respondent

2. The first issue raised in this appeal is against the partial rejection of the claim of deduction u/s. 80IC of the Income-tax Act, 1961 (hereinafter also called ‘the Act’) to the extent of Rs.10,90,23,322/-. 3. Succinctly, the factual panorama is that the assessee filed its return declaring total income of Rs.19.14 crore after claiming deduction

BIZ SECURE LABS PRIVATE LIMITED,,PUNE vs. DEPUTY COMMISSIONER OF INCOME TAX,, PUNE

In the result, the appeal of the Revenue is dismissed and that

Bench: Shri R.S. Syal & Shri Sonjoy Sarma"नधा"रण वष" / Assessment Year : 2012-13 Biz Secure Labs Pvt. Ltd., Vs. Dcit, 1206, Sadashiv Peth, Circle- 1(1), Pune 411 030 Pune Pan : Aadcb6188L Appellant Respondent

2. The first issue raised in this appeal is against the partial rejection of the claim of deduction u/s. 80IC of the Income-tax Act, 1961 (hereinafter also called ‘the Act’) to the extent of Rs.10,90,23,322/-. 3. Succinctly, the factual panorama is that the assessee filed its return declaring total income of Rs.19.14 crore after claiming deduction

DEPUTY COMMISSIONER OF INCOME-TAX, CIRCLE - 1(1),, PUNE vs. BIZ SECURE LABS PVT.LTD,, PUNE

In the result, the appeal of the Revenue is dismissed and that

Bench: Shri R.S. Syal & Shri Sonjoy Sarma"नधा"रण वष" / Assessment Year : 2012-13 Biz Secure Labs Pvt. Ltd., Vs. Dcit, 1206, Sadashiv Peth, Circle- 1(1), Pune 411 030 Pune Pan : Aadcb6188L Appellant Respondent

2. The first issue raised in this appeal is against the partial rejection of the claim of deduction u/s. 80IC of the Income-tax Act, 1961 (hereinafter also called ‘the Act’) to the extent of Rs.10,90,23,322/-. 3. Succinctly, the factual panorama is that the assessee filed its return declaring total income of Rs.19.14 crore after claiming deduction

M/S. CHHEDA ELECTRICALS AND ELECTRONICS PVT.LTD,,PUNE vs. DEPUTY COMMISSIONER OF INCOME-TAX, CIRCLE - 1(1),, PUNE

In the result, both the appeals are dismissed

Bench: Shri R.S. Syal & Shri Partha Sarathi Chaudhury

90,68,947/- by taking the amount of profit as per parts II and III of Schedule VI to the Companies Act at Rs.5.46 crore as added by the amount of Income-tax u/s.40(a)(ii) and Deferred tax liability. Thereafter, tax was calculated at 18.50% on the book profit of Rs.6.90 crore and the assessee paid/adjusted the amount

M/S. CHHEDA ELECTRICALS AND ELECTRONICS PVT.LTD,,PUNE vs. INCOME-TAX OFFICER, WARD - 1(3),, PUNE

In the result, both the appeals are dismissed

Bench: Shri R.S. Syal & Shri Partha Sarathi Chaudhury

90,68,947/- by taking the amount of profit as per parts II and III of Schedule VI to the Companies Act at Rs.5.46 crore as added by the amount of Income-tax u/s.40(a)(ii) and Deferred tax liability. Thereafter, tax was calculated at 18.50% on the book profit of Rs.6.90 crore and the assessee paid/adjusted the amount

SANDVIK MACHINING SOLUTION AB, (FORMERLY KNOWN AS) SANDVIK TOLLING SEVERIGE AB),,PUNE vs. ASSISTANT COMMISSIONER OF INCOME-TAX, (IT), CIRCLE -2,, PUNE

In the result, the appeal of the assessee is allowed

Bench: Shri Anil Chaturvedi, Am & Shri S.S. Viswanethra Ravi, Jm

68,150/-. The case was selected for scrutiny and thereafter notices u/s 143(2) and 142(1) of the Act along with questionnaire were issued to the assessee. On perusal of the details in return of income furnished, it was noticed that assessee had received Rs.59,66,099/- from Sandvik Asia Private Limited (SAPL) on account of IT support services

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

section 9(1)(vi) of the Act or Article 12 of the DTAA. Article 12 of DTAA with USA stipulates and defines what is royalty and fees for technical services. The term ‘royalty’ as per clause 3 of Article 12 means payment of any kind received as consideration for the use of, or the right to use, any copyright

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

section 9(1)(vi) of the Act or Article 12 of the DTAA. Article 12 of DTAA with USA stipulates and defines what is royalty and fees for technical services. The term ‘royalty’ as per clause 3 of Article 12 means payment of any kind received as consideration for the use of, or the right to use, any copyright

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

section 9(1)(vi) of the Act or Article 12 of the DTAA. Article 12 of DTAA with USA stipulates and defines what is royalty and fees for technical services. The term ‘royalty’ as per clause 3 of Article 12 means payment of any kind received as consideration for the use of, or the right to use, any copyright

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

section 9(1)(vi) of the Act or Article 12 of the DTAA. Article 12 of DTAA with USA stipulates and defines what is royalty and fees for technical services. The term ‘royalty’ as per clause 3 of Article 12 means payment of any kind received as consideration for the use of, or the right to use, any copyright

ANANT KESHAV RAJEGAONKAR,NASHIK vs. THE ASSTT. COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE - 2, NASHIK, NASHIK

Bench: Dr.Manish Borad & Shri Vinay Bhamoreआयकर अपील सं. / Ita Nos.1249 To 1252/Pun/2024 Assessment Years : 2013-14, 2014-15 & 2015-16

Section 68 of the Act has been discharged and consequently the burden shifted over to the Assessing Officer to prove the contrary which the ld. Assessing Officer failed. 11. We further observe that the ld. CIT(A) has made a thorough examination of all these facts and also referred to various judicial pronouncements adjudicating similar type of issues