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52 results for “transfer pricing”+ Cash Depositclear

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Key Topics

Section 143(3)45Addition to Income32Section 14725Section 14818Reassessment13Deduction13Section 43(5)12Disallowance12Section 143(2)11

ASSISTANT COMMISSIONER OF INCOME TAX, KOLHAPUR vs. NATHMAL RUPCHAND JAIN, KOLHAPUR

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

ITA 1295/PUN/2024[2020-21]Status: DisposedITAT Pune27 Jan 2025AY 2020-21

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

For Appellant: Shri Suhas P BoraFor Respondent: Shri Amol Khairnar CIT-DR
Section 132Section 133(6)Section 143(2)Section 145(3)Section 69A

transferring the money through hawala to persons in Delhi also does not seem plausible. The cash was deposited in months of April and May while the purchase from M/s Rishabh Trading Company was done in October and moreover why would an assessee first show bogus sales and then to offset the same undertake bogus purchases and generate cash for making

Showing 1–20 of 52 · Page 1 of 3

Section 10(38)11
Section 56(2)10
Section 5710

MR. ABRAR FAKIRMOHMMAD SHAIKH,SOLAPUR vs. INCOME TAX OFFICER(INTERNATIONAL TAXATION), NASHIK

In the result, the appeal filed by the assessee stands partly allowed

ITA 208/PUN/2023[2014-15]Status: DisposedITAT Pune18 Oct 2023AY 2014-15

Bench: Shri Inturi Rama Rao & Shri S. S. Viswanethra Raviआयकर अपील सं. / Ita No.208/Pun/2023 िनधा"रण वष" / Assessment Year : 2014-15 Mr. Abrar Fakirmohmmad Vs. Ito (International Shaikh, Taxation), Nashik. At Manakeshwar, North Solapur, Tal. Bhoom, Barshi, Solapur- 413213. Pan : Chfps0191E Appellant Respondent Assessee By : Shri Rajiv Khandelwal Revenue By : Shri Prashant Gadekar Date Of Hearing : 10.10.2023 Date Of Pronouncement : 18.10.2023 आदेश / Order Per Inturi Rama Rao, Am: This Is An Appeal Filed By The Assessee Directed Against The Final Assessment Order Dated 20.12.2022 Passed U/S 147 R.W.S. 144C(13) Of The Income Tax Act, 1961 (‘The Act’) For The Assessment Year 2014-15. 2 2. Briefly, The Facts Of The Case Are That The Appellant Is An Individual & Non-Resident Indian In Terms Of Income-Tax Purpose. The Return Of Income For The Assessment Year 2014-15 Was Filed On 05.07.2014 Disclosing Total Income Of Rs.1,85,740/-. Against The Said Return Of Income, No Scrutiny Assessment Was Made. Subsequently, On Receipt Of The Information That The Appellant Made Cash Deposit Of Rs.1,20,40,000/- With Solapur District Co- Operative Central Bank, The Assessing Officer Formed An Opinion That The Income Had Escaped Assessment To Tax. Accordingly, The Assessing Officer Had Issued A Notice U/S 148 On 31.03.2021. In Response To Said Notice U/S 148, The Appellant Filed The Return Of Income On 03.04.2021 Disclosing Same Income As Declared In The Original Return Of Income. Against The Said Return Of Income, The Assessment Was Completed By The Assessing Officer Vide Order Dated 20.12.2022 Passed U/S 144C(13) R.W.S. 147 Of The Act At A Total Income Of Rs.1,23,98,740/-. While Doing So, The Assessing Officer Brought To Tax A Sum Of Rs.1,21,80,000/- Being The Amount Of Cash Deposits In The Bank I.E. Cash Deposits Of Rs.1,20,40,000/- Made With Solapur District Co-

For Appellant: Shri Rajiv KhandelwalFor Respondent: Shri Prashant Gadekar
Section 144CSection 144C(13)Section 147Section 148Section 5

cash deposits of Rs.1,21,40,000/- and Rs.83.002/-. 3. Being aggrieved, the appellant is in appeal before us in the present appeal. 4. Ground of appeal no.1 was not pressed during the course of hearing of appeal, hence dismissed as withdrawn. 5. Ground of appeal no.2 challenges the action of the Assessing Officer in resorting to the provisions

RIETER INDIA PVT.LTD,,SATARA vs. ASSISTANT COMMISSIONER OF INCOME-TAX, CIRCLE - 5,, PUNE

In the result, the appeal is partly allowed

ITA 1947/PUN/2018[2014-15]Status: DisposedITAT Pune28 Apr 2022AY 2014-15

Bench: Shri R.S. Syal & Shri S.S. Viswanethra Raviनिर्धारण वषा / Assessment Year : 2014-15 Rieter India Private Limited, Vs. Acit, Gat No.768/2, Circle-5, Shindewadi-Bhor Road, Pune Village Wing, Taluka Khandala, District Satara – 412 801 Pan : Aaacr3556P Appellant Respondent

Section 143(3)

deposit, we hold that the authorities below rightly took it as a part of non-operating revenue. 7.2. The other item is `Recovery of contribution to Provident Fund on behalf of employees‟ amounting to Rs.15,79,187/-. On 9 Rieter India Private Limited being called upon to explain the nature of this item, the ld. AR submitted that the assessee

MRS SHANTABAI JASRAJ LODHA,AHMEDNAGAR vs. INCOME TAX OFFICER, WARD-1, AHMEDNAGAR, AHMEDNAGAR

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

ITA 1389/PUN/2023[2017-18]Status: DisposedITAT Pune16 Jan 2024AY 2017-18

Bench: the AO as follows:

For Appellant: NoneFor Respondent: Shri Sourabh Nayak

prices. So I deposited same amount including addition of Rs.30,000/- out of my saving account on 22.11.2016.” 4. The ld. AO did not accept the submissions of assessee and on further verification of Bank of Maharashtra‟s statement, he found out that there was some cash deposit of Rs.16.36 lakhs on 08.06.2016 and on 09.06.2016 and there was withdrawal

KRISH WINES,JALGAON vs. ACIT CIRCLE 1,, JALGAON

In the result, the appeal filed by the assessee is dismissed

ITA 2098/PUN/2024[2017-18]Status: DisposedITAT Pune27 Oct 2025AY 2017-18
Section 142(1)Section 143(2)Section 145Section 69A

transferred from the ITO, Ward\n2(2), Jalgaon to DCIT, Circle – 2, Jalgaon (now Circle – 1, Jalgaon) on 08.04.2019\nas per jurisdiction. Notice u/s 142(1) of the Act on 20.05.2019 along with\nquestionnaire asking the assessee to file certain details regarding the scrutiny\nassessment.\nSecond notice u/s 142(1) of the Act was issued on 31.10.2019\nrequesting the assessee

SEMPERTRANS INDIA PRIVATE LIMITED,ROHA vs. INCOME-TAX OFFICER, PANVEL

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

ITA 1778/PUN/2024[AY 2020-21]Status: DisposedITAT Pune14 Nov 2025
Section 144Section 144CSection 144C(8)Section 153Section 92CSection 92D

transfer pricing, etc.;\nMonitoring of worldwide tax rate and optimization of tax burden\nfor Semperit's local entities;\nCoordination on local tax compliance;\nTax compliance and monitoring of TP documentation\nEngineering\nand\nMaintenance\nAE assures a group-wide standard with main focus on:\ndesign and strategic planning of investment-projects of Group\ncompanies;\nsupport, installation and engineering on site

SANGEETA BASAVRAJ MANGRULE,,AURANGABAD vs. ASSISTANT COMMISSIONER OF INCOME-TAX, CIRCLE - 2,, AURANGABAD

Appeal is dismissed in above terms

ITA 706/PUN/2019[2015-16]Status: DisposedITAT Pune11 Aug 2022AY 2015-16
For Appellant: NoneFor Respondent: Shri M.G. Jasnani
Section 10(38)Section 131Section 143(3)

transferred to the beneficiaries via share broker‟s account. Almost all the proprietorship accounts where cash was deposited never filed their return of income tax. Moreover they tended to close such accounts very often, so that they could evade any STR/FIU/Income Tax Authorities. If one went through the KYCs of such proprietorship accounts, it could be seen that they were

SARIKA AMIT SANAP,,AURANGABAD vs. ASSISTANT COMMISSIONER OF INCOME-TAX, CIRCLE - 3,, AURANGABAD

In the result, assessee‟s appeal is dismissed

ITA 77/PUN/2019[2015-16]Status: DisposedITAT Pune16 Aug 2022AY 2015-16
For Appellant: NoneFor Respondent: Shri M.G. Jasnani
Section 10Section 10(38)Section 131

transferred to the beneficiaries via share broker's account. Almost all the proprietorship accounts where cash was deposited never filed their return of income tax. Moreover they tended to close such accounts very often, so that they could evade any STR/FIU/income Tax Authorities. If one went through the KYCs of such proprietorship accounts, it could be seen that they were

SONAL SANDEEP SATAV,PUNE vs. PCIT, PUNE-2, PUNE

In the result, the appeal of the assessee is dismissed

ITA 945/PUN/2024[2018-19]Status: DisposedITAT Pune03 Dec 2024AY 2018-19

Bench: Ms. Astha Chandra & Shree G.D. Padmahshali

For Appellant: Shri Sarang GudhateFor Respondent: Shri Ajay Kumar Keshari
Section 142(1)Section 143(2)Section 143(3)Section 263

Transfer Pricing Officer for determination of arm's length price in respect of international transactions reported for the relevant assessment year. Then paragraph 4, along with its sub paragraphs 4.1 to 47 deal with disallowance under section 40(a)(ia) in the context of commission exceeding Re. 18.00 crore paid by the Assessee during the relevant assessment year, even though

DEPUTY COMMISSIONER OF INCOME-TAX,, NASHIK vs. M/S. ASHOKA BUILDCON LTD,, NASHIK

In the result, appeal of the assessee in ITA No

ITA 1135/PUN/2017[2011-12]Status: DisposedITAT Pune22 Sept 2021AY 2011-12

Bench: Shri R.S.Syal, Vp & Shri Partha Sarathi Chaudhury, Jm आयकर अपील सं. / Ita No. 1088/Pun/2017 धनधाारण वषा / Assessment Year : 2011-12

For Appellant: Shri Pramod ShingteFor Respondent: Shri S.P Walimbe
Section 143(3)Section 147Section 148Section 234C

prices were paid through banking channels. The Assessing Officer, however, enquired with the banks of these suppliers and noted that immediately after the deposit of cheques issued by the assessee, the cash was either withdrawn immediately or amount was transferred

ASHOKA BUILDCON LIMITED,,NASHIK vs. ASSISTANT COMMISSIONER OF INCOME TAX,, NASHIK

In the result, appeal of the assessee in ITA No

ITA 1088/PUN/2017[2011-12]Status: DisposedITAT Pune22 Sept 2021AY 2011-12

Bench: Shri R.S.Syal, Vp & Shri Partha Sarathi Chaudhury, Jm आयकर अपील सं. / Ita No. 1088/Pun/2017 धनधाारण वषा / Assessment Year : 2011-12

For Appellant: Shri Pramod ShingteFor Respondent: Shri S.P Walimbe
Section 143(3)Section 147Section 148Section 234C

prices were paid through banking channels. The Assessing Officer, however, enquired with the banks of these suppliers and noted that immediately after the deposit of cheques issued by the assessee, the cash was either withdrawn immediately or amount was transferred

DEPUTY COMMISSIONER OF INCOME TAX, AURANGABAD vs. VISTA NIRMAN PVT. LTD., MUMBAI

ITA 1340/PUN/2023[2011-12]Status: DisposedITAT Pune05 Aug 2024AY 2011-12

Bench: Shri R. K. Panda & Ms Astha Chandraassessment Year : 2011-12

For Appellant: Shri Jaiprakash BairagraFor Respondent: Shri Ajay Kumar Keshari
Section 132Section 133(6)Section 133ASection 142(1)Section 143(3)Section 147Section 148Section 151(1)

cash deposits were made in the Jamakharchi accounts of individuals as well as shell companies having no business activities / fixed assets. M/S. VISTA NIRMAN PRIVATE LIMITED is one such entity where such routed transaction took place. An inquiry was made in terms of running data analysis from e-records available in the ITBA database. As the financial analysis

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

ITA 557/PUN/2024[2020-21]Status: DisposedITAT Pune09 Aug 2024AY 2020-21

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

For Appellant: Shri K P DewaniFor Respondent: Shri Pankaj Kumar
Section 143(2)Section 143(3)Section 250Section 250(1)Section 68Section 69C

price is more than the stamp duty value of the property, we find merit in the arguments of the Ld. Counsel for the assessee that there is no case for making addition u/s 56(2)(x) of the Act. Accordingly, the order of the CIT(A) / NFAC is set aside on this issue and the grounds of appeal No.7

MANGAL ANNASAHEB JADHAV,,PUNE vs. INCOME TAX OFFICER,, AHMEDNAGAR

In the result, Ground No.1 and 2 are dismissed and Ground

ITA 665/PUN/2017[2012-13]Status: DisposedITAT Pune06 May 2022AY 2012-13

Bench: Shri Satbeer Singh Godara, Jm & Dr. Dipak P. Ripote, Am आयकरअपीलसं. / Ita No.665/Pun/2017 िनधा"रणवष" / Assessment Year : 2012-13 Mangal A. Jadhav, The Income Tax Officer, Ward-1, M/S.Shah Khandelwal Jain & Vs Ahmednagar. Associates, Level 3, Riverside Business Bay, Plot No.84, Wellesley Road, Near Rto, Pune - 411001. Pan: Ahypj 9285 D Appellant/ Revenue Respondent/ Assessee Assessee By Shri Rajiv Thakkar – Ar Revenue By Shri S P Walimbe - Dr Date Of Hearing 19/04/2022 Date Of Pronouncement 06/05/2022 आदेश/ Order Per Dr. Dipak P. Ripote, Am: This Is An Appeal Filed By The Assessee Directed Against The Order Of Ld.Commissioner Of Income Tax(Appeals)-2, Pune Dated 09.12.2016For The Assessment Year 2012-13. The Assessee Raised The Following Grounds Of Appeal: “1. On Facts & Circumstances Prevailing In The Case & As Per Provisions Fit Scheme Of The Income-Tax Act, 1961 (‘The Act’) It Be Held That Addition Of Rs. 10,57,073/- Made By The Ao, Doubting The Opening Cash Balance Which Is Further Deposited Into Bank & Upheld By Cit(A), Is Merely On- Guesswork & Conjectures & Is Improper, Unjustified, Incorrect & Contrary To Provisions Of Law & Facts Prevailing In The Case. No Such Addition Is Warranted In The Case Of The Appellant. The Addition Made By The Ao & Upheld By Cit (A) Be Deleted. The Appellant Be Granted Just & Proper Relief In This Respect. 2. On Facts & Circumstances Prevailing In The Case & As Per Provisions & Scheme Of The Income-Tax Act, 1961 (‘The Act’) It Be Held That Addition Of Rs. 60,00,000/- Made By Theao, Doubting The Advances Against Booking Of Flats Received In Cash In Which Were Further Deposited Into Bank & Upheld By Cit(A), Is Merely On Guesswork & Conjectures & Is Improper, Unjustified, Incorrect & Contrary To Provisions Of Law & Facts Prevailing

deposited into bank, and upheldby CIT(A), is merely on guesswork & conjectures and is improper, unjustified, incorrect and contrary to provisions of law and facts prevailing in the case. No such addition is warranted in the case of the appellant. The addition made by the AO and upheld by CIT(A) be deleted. The appellant be granted just and proper

GANPAT MUKUNDRAO MURKUTE,,PUNE vs. ASSISTANT COMMISSIONER OF INCOME-TAX,,

ITA 2141/PUN/2013[2006-07]Status: DisposedITAT Pune02 Feb 2018AY 2006-07

Bench: Ms. Sushma Chowla, Jm & Shri Anil Chaturvedi, Am

Section 143(2)Section 143(3)Section 148

transfer of land of Rs.4,85,75,000/- to have been received by the assessee and thus made an addition of Rs.2,35,54,470/- on account of net short term capital gains. Aggrieved by the order of AO, assessee carried the matter before Ld.CIT(A), who upheld the order of AO by holding as under : “3.4 The submission made

SH. MAHENDRA R. VITKAR,PUNE vs. ITO, WARD 10(2),, PUNE

ITA 1208/PUN/2010[2006-07]Status: DisposedITAT Pune02 Feb 2018AY 2006-07

Bench: Ms. Sushma Chowla, Jm & Shri Anil Chaturvedi, Am

Section 143(2)Section 143(3)Section 148

transfer of land of Rs.4,85,75,000/- to have been received by the assessee and thus made an addition of Rs.2,35,54,470/- on account of net short term capital gains. Aggrieved by the order of AO, assessee carried the matter before Ld.CIT(A), who upheld the order of AO by holding as under : “3.4 The submission made

ITO WARD 9(4),, PUNE vs. SH. MAHENDRA R. VITKAR, PUNE

ITA 1213/PUN/2010[2006-07]Status: DisposedITAT Pune02 Feb 2018AY 2006-07

Bench: Ms. Sushma Chowla, Jm & Shri Anil Chaturvedi, Am

Section 143(2)Section 143(3)Section 148

transfer of land of Rs.4,85,75,000/- to have been received by the assessee and thus made an addition of Rs.2,35,54,470/- on account of net short term capital gains. Aggrieved by the order of AO, assessee carried the matter before Ld.CIT(A), who upheld the order of AO by holding as under : “3.4 The submission made

AMIT BHASKARRAO SANAP,,AURANGABAD vs. ASSISTANT COMMISSIONER OF INCOME-TAX, CIRCLE -3, , AURANGABAD

In the result, appeal of the Assessee is Dismissed

ITA 78/PUN/2019[2015-16]Status: DisposedITAT Pune19 Oct 2022AY 2015-16

Bench: Shri Partha Sarathi Chaudhury & Dr. Dipak P. Ripoteआयकर अपील सं. / Ita No.78/Pun/2019 िनधा"रण वष" / Assessment Year : 2015-16 Amit Bhaskarrao Sanap, The Assistant A-2, N-4, Cidco, Aurangabad, Vs Commissioner Of Income Maharashtra – 431001. Tax, Circle-3, Aurangabad. Pan: Auips 4177 L Appellant/ Assessee Respondent /Revenue Assessee By None. Revenue By Shri S P Walimbe & Shri Arvind Desai – Dr Date Of Hearing 25/07/2022 Date Of Pronouncement 19/10/2022 आदेश/ Order Per Dr. Dipak P. Ripote, Am: This Appeal Filed By The Assessee Is Directed Against The Order Of Ld.Commissioner Of Income Tax(Appeals)-2, Aurangabad, Dated 13.11.2018 For The A.Y. 2015-16. The Assessee Has Raised The Following Grounds Of Appeal: “1. The Order Of The Learned Commissioner (A), Aurangabad Confirming The Addition Of Rs.1,93.17.241/- Made By The A.O. In Computing The Income U/S 56 Instead Of Exempt U S. 10(38) Of The Act Of The Appellant Is Contrary To Law & Facts Of The Case.

Section 10(38)Section 56

deposited in various bank accounts and hen finally, we used to transfer it to party / beneficiaries bank account. For doing so, e used to get a commission income in cash from party @ 0.10 paisa per 100 Rupees of cheque amount. Our companies buy the shares ITA No.78/PUN/2019 for A.Y. 2015-16 Amit Bhaskarrao Sanap Vs. ACIT, Circle-3, (A) afterthe

DY.COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE 1, AURANGBAD, AURANGBAD vs. SANJAY SUGANCHAND KASLIWAL, AURANGABAD

In the result, the appeal filed by the Revenue is dismissed\nand the Cross Objection filed by the assessee is partly allowed as\nper terms indicated above

ITA 1339/PUN/2024[2015]Status: DisposedITAT Pune24 Mar 2025
Section 133ASection 143(3)Section 148Section 271DSection 69D

deposited in his bank account nor there is\npurchase of any land or other asset in cash which could\ncorroborate the receipt of such a huge amount. Further it was\nrequested that to verify the veracity of the claim made by Mr.\nPankaj Radheshyam Agrawal before the police authorities the\nAssessing Officer should call for the income-tax return, financial

ACIT CIRCLE-12, PUNE, PUNE vs. DHIRAJ BHAUSAHEB NIKAM, PUNE

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

ITA 1375/PUN/2025[2014-15]Status: DisposedITAT Pune11 Feb 2026AY 2014-15

Bench: Shri R. K. Panda & Shri Vinay Bhamoreassessment Year : 2014-15 Acit, Circle – 12, Pune Dhiraj Bhausaheb Nikam Vs. 515/516, Purva Plaza, Sadashiv Peth, Pune – 411030 Pan: Aahpn5137C (Appellant) (Respondent) Assessee By : None Department By : Shri Deepak Kumar Kedia, Jcit (Through Virtual) Date Of Hearing : 10-02-2026 Date Of Pronouncement : 11-02-2026 O R D E R Per R.K. Panda, Vp:

For Appellant: NoneFor Respondent: Shri Deepak Kumar Kedia, JCIT
Section 10(38)Section 142(1)Section 143(2)Section 2(47)

prices of M/s. Anukaran Commercial Enterprises Ltd has been jagged up through cartel of interlinked companies controlled and managed by entry operators for the purpose of providing accommodation entry of 5 bogus long term capital gain. Rejecting the various explanations given by the assessee and relying on various decisions, the Assessing Officer rejected the claim of exemption