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

7. Subsequently, the assessee preferred appeal before ld.CIT(A) and even in the submissions made by the assessee before ld.CIT(A) it has been submitted that once the list of donors containing the names and addresses have been filed the assessee has discharged onus u/s.115BBC and there is no requirement to prove the source of donation unlike section 68

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

7. Subsequently, the assessee preferred appeal before ld.CIT(A) and even in the submissions made by the assessee before ld.CIT(A) it has been submitted that once the list of donors containing the names and addresses have been filed the assessee has discharged onus u/s.115BBC and there is no requirement to prove the source of donation unlike section 68

DEPUTY COMMISSIONER OF INCOME-TAX vs. M/S. HONEYWELL AUTOMATION INDIA LTD.,, PUNE

In the result, the appeal of Revenue is dismissed

Bench: Shri R.S. Syal & Shri S.S. Viswanethra Ravi

7 Wellwin Industry Ltd. (Segmental Data) 10.48% Mean 7.26% 11. The assessee was asked to explain the difference in the operating profit margins of comparable companies. Operating Profit Margin (Loss) of the assessee is (2.31)% for the aggregated system integration segment and (3.1)% for the aggregated distribution segment. 12. The assessee explained that the IS-Infra business should

M/S. HONEWELL AUTOMATION INDIA LTD.,,PUNE vs. DEPUTY COMMISSIONER OF INCOME-TAX,,

In the result, the appeal of Revenue is dismissed

Bench: Shri R.S. Syal & Shri S.S. Viswanethra Ravi

7 Wellwin Industry Ltd. (Segmental Data) 10.48% Mean 7.26% 11. The assessee was asked to explain the difference in the operating profit margins of comparable companies. Operating Profit Margin (Loss) of the assessee is (2.31)% for the aggregated system integration segment and (3.1)% for the aggregated distribution segment. 12. The assessee explained that the IS-Infra business should

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

94,03,000/- claimed to be\nreceived during FY 2012-13.\nc) No donation receipts books have been maintained for any of\nthe period starting from FY 2011-12 to FY 2018-19.\nd) Since most of the donors have denied having made any\ndonations to the assessee trust, the claim of donations made in the\nbooks of accounts from

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

94,03,000/- claimed to be\nreceived during FY 2012-13.\nc)\nNo donation receipts books have been maintained for any of\nthe period starting from FY 2011-12 to FY 2018-19.\nd)\nSince most of the donors have denied having made any\ndonations to the assessee trust, the claim of donations made in the\nbooks of accounts from

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

94,03,000/- claimed to be\nreceived during FY 2012-13.\nc) No donation receipts books have been maintained for any of\nthe period starting from FY 2011-12 to FY 2018-19.\nd) Since most of the donors have denied having made any\ndonations to the assessee trust, the claim of donations made in the\nbooks of accounts from

M/S. HONEYWELL AUTOMATION INDIA LIMITED,,PUNE vs. ACIT, CIRCLE-7, PUNE

In the result, the appeal of the assessee is partly allowed for statistical purposes

Bench: Shri D. Karunakara Rao, Am & Shri Vikas Awasthy, Jm आयकर अपील सं./ Ita No. 359/Pun/2013 िनधा#रण वष# / Assessment Year : 2008-09

94,040 as against income of Rs. 65,78,09,980 (as per the revised computation of income filed by the Appellant with the learned AO during the course of assessment proceedings); 2 M/s. Honeywell Automation India Ltd., A. Denial of tax holiday claim under section 10A of the Act amounting to Rs. 5,22,56,867 with respect

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

NILESH POPATLAL GADA,PUNE vs. INCOME TAX OFFICER WARD 2(4) , PUNE

In the result, appeal of the assessee is Partly Allowed

Bench: DR.DIPAK P. RIPOTE (Accountant Member), SHRI VINAY BHAMORE (Judicial Member)

section 68 of the Act. We have perused the submission of the assessee. It is observed that assessee had filed copy of cash book (page 88-90 of PB). As per said cash book, the opening cash balance was Rs.18,24,582/- then, cash on 05.11.2016 was 7 Rs.21,16,177/-. There was no transaction between

M/S GIRIRAJ ENTERPRISES,PUNE vs. DCIT, CENTRAL CIRCLE 1(1), PUNE, PUNE

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

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

section 94 (7) of the act holding it to be sham and fictitious transaction is devoid of any merit. Accordingly on the merits also, orders of the lower authorities are reversed and ground number 4 – 7 of the appeal are allowed.” 20. We find Jaipur Bench of the Tribunal in the case of Agencies Rajasthan

SHRI MANOJ MADANLAL CHHAJED,PUNE vs. ASSISTANT COMMISSIONER OF INCOME TAX, CIRCLE -1(1)PUNE, PUNE

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

Bench: Shri Inturi Rama Rao & Shri S. S. Viswanethra Raviआयकर अपील सं. / It(Ss)A Nos.91 To 96/Pun/2022 िनधा"रण वष" / Assessment Years : 2012-13 To 2017-18 Shri Manoj Madanlal Vs. Acit, Central Circle- Chhajed, 1(1), Pune. 601, A-8 Building, Karishma Housing Society, Near Sangam Press, Kothrud, Pune- 411029. Pan : Aalpc4991M Appellant Respondent आयकर अपील सं. / It(Ss)A Nos.97 & 98/Pun/2022 िनधा"रण वष" / Assessment Years : 2012-13 & 2015-16 Acit, Circle-1(1), Pune. Vs. Shri Manoj Madanlal Chhajed, 601, A-8 Building, Karishma Housing Society, Near Sangam Press, Kothrud, Pune- 411029. Pan : Aalpc4991M Appellant Respondent आयकर अपील सं. / Ita No.725/Pun/2022 िनधा"रण वष" / Assessment Year: 2018-19 Shri Manoj Madanlal Vs. Acit, Circle-1(1), Pune. Chhajed, 601, A-8 Building, Karishma Housing Society, Near Sangam Press, Kothrud, Pune- 411029. Pan : Aalpc4991M Appellant Respondent

7 IT(SS)A Nos.91 to 96/PUN/2022 IT(SS)A Nos.97 & 98/PUN/2022 d) The Appellant states that the Assessing Officer erred in creating additions of Rs. 6,27,20,500/- and the Appellate Authority erred in partially confirming the unjust additions of Rs. 4,94,20,500/- u/s 69C of the Income Tax Act. 1961 without bringing any incriminating

KAPIL ALCOTECH LLP,AURANGABAD vs. DEPUTY COMMISSIONER OF INCOME TAX CIRCLE - 1, AURANGABAD

In the result, the appeal filed by the assessee is partly allowed for statistical purposes

Bench: Shri R. K. Panda & Ms Astha Chandraassessment Year : 2020-21

7 with specific remuneration payment clause in accordance with CBDT Circular No.739 dated 25.03.1996 before the Assessing Officer in the assessment stage is incorrect since the assessee had filed the copy of the supplementary deed, the scanned copy of which has already been reproduced by the Assessing Officer in the body of the assessment order. A perusal of the remuneration

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

94,642 Belgium 84,13,219 1,23,432 84,13,219 Canada 7,52,27,873 11,57,102 6,28,15,596 Japan 2,51,97,787 5,15,69,314 2,51,97,787 Switzerland 2,15,35,045 2,30,520 1,59,93,284 Malaysia

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

94,642 Belgium 84,13,219 1,23,432 84,13,219 Canada 7,52,27,873 11,57,102 6,28,15,596 Japan 2,51,97,787 5,15,69,314 2,51,97,787 Switzerland 2,15,35,045 2,30,520 1,59,93,284 Malaysia

ARIHANT JEWELLERS,PUNE vs. CIT (A)-6 INCOME TAX OFFICE WARD 9 (1), PUNE

In the result, the appeal filed by the assessee is allowed for statistical purposes

Bench: Justice (Retd.) C V Bhadang & Shri R. K. Pandaassessment Year : 2017-18

7. Similarly, in absence of any proper explanation regarding the nature and source of deposits of Rs.10 lacs on 27.05.2016 and Rs.9 lacs on 26.09.2016 in the current account held in Kotak Mahindra Bank, the Assessing Officer made addition of the same to the total income of the assessee by invoking the provisions of section 68

CRYSTAL GLAZING & CLADDING,PUNE vs. INCOME TAX OFFICER, WARD-7(1), PUNE, PUNE

In the result, the appeal of assessee is allowed for statistical purpose

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

94,419/- Unexplained Expenses U/Sec.37(1) of the Act Total 1,74,61,831/- 3. The learned CIT(A) failed to appreciate that the various notices fixed for hearing were not received by the appellant. 4. The learned CIT(A) failed to appreciate that he ought to have verified whether proper notice has been served or not, before passing

KUMAR URBAN DEVELOPMENT PVT. LTD (SUCCESSOR KUMAR HOUSING CORPORATION PVT LTD),PUNE vs. DCIT CIRCLE 14, PUNE

94,82,438\n3,24,31,438\nG\nKUL aura\n8,06,41,870\n7,66,07,270\nH\nKumar Puram\n3,09,53,228\n1,52,13,248\n1\nOther advances\n2,39,52,862\nTOTAL\n40,99,28,990\n40,99,28,990\n6.6.6\nFrom the tabulation provided in the preceding paragraph, the relief\nis restricted

SWATHI KEWAL NEMMANIWAR,KINWAT NANDED vs. ASST. DEPUTY COMMISSIONER OF INCOME TAX, CIRCLE, NANDED, NANDED

In the result, appeal of the assessee is partly allowed

Bench: SHRI SATBEER SINGH GODARA, JUDICIAL MEMBER AND DR.DIPAK P. RIPOTE (Accountant Member)

94,430/- as against the returned income of Rs. 31,44,430/- by the Appellant, under the facts and circumstances of the case. 3. The learned Authorities below are not justified in making an addition of Rs.51,50,000/-, under section 68 as unexplained cash credit, under the facts and circumstances of the case. 4. The learned Authorities below