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11 results for “transfer pricing”+ Permanent Establishmentclear

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Key Topics

Section 80G(5)33Section 80G30Section 12A18Limitation/Time-bar9Exemption8Section 104Section 2504Section 143(3)4Addition to Income4

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

permanent establishment\nissues, tax implications of M & A activities, transfer pricing, etc.;\nMonitoring of worldwide tax rate and optimization of tax burden

SHREE CHAITANYA-RAM FOUNDATION,BAVDHAN vs. CIT EXEMPTION, PUNE

In the result, both the appeals filed by the assessee are allowed for statistical purposes

Disallowance3
Section 112
Section 12A(1)(ac)2
ITA 2618/PUN/2025[2025-2026]Status: DisposedITAT Pune21 Jan 2026AY 2025-2026

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

For Appellant: Shri Nikhil S PathakFor Respondent: Shri Prashant Gadekar, CIT
Section 12(1)(ac)Section 12ASection 12A(1)(ac)Section 80GSection 80G(5)

establish the genuineness of its charitable activities without appreciating the submissions by the assesse company: (2) that on the facts and in the circumstances of the case and considering the principles of natural justice, the matter should be set aside to the file of the Assessing Officer to be decided afresh after considering the merits of the application and providing

SHREE CHAITANYA-RAM FOUNDATION,BAVDHAN PUNE vs. CIT EXEMPTION, PUNE

In the result, both the appeals filed by the assessee are allowed for statistical purposes

ITA 2619/PUN/2025[2025-2026]Status: DisposedITAT Pune21 Jan 2026AY 2025-2026

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

For Appellant: Shri Nikhil S PathakFor Respondent: Shri Prashant Gadekar, CIT
Section 12(1)(ac)Section 12ASection 12A(1)(ac)Section 80GSection 80G(5)

establish the genuineness of its charitable activities without appreciating the submissions by the assesse company: (2) that on the facts and in the circumstances of the case and considering the principles of natural justice, the matter should be set aside to the file of the Assessing Officer to be decided afresh after considering the merits of the application and providing

MITCON FORUM FOR SOCIAL DEVELOPMENT,PUNE vs. CIT EXEMPTION, PUNE

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

ITA 613/PUN/2025[2024-25]Status: DisposedITAT Pune24 Apr 2025AY 2024-25

Bench: Dr.Dipak P. Ripote & Shri Vinay Bhamoreआयकर अपील सं. / Ita No.613/Pun/2025 िनधा"रण वष" / Assessment Year: 2024-25 Mitcon Forum For Social V The Commissioner Of Development, S Income Tax(Exemption), Kebera Chambers, 1St Floor, Pune. Shivajinagar, Pune – 411005. Maharashtra Pan: Aalcm9558M Appellant/ Assessee Respondent / Revenue Assessee By Shri Sharad A Vaze – Ar Revenue By Shri Ramnath P Murkude – Cit-Dr Date Of Hearing 22/04/2025 Date Of Pronouncement 24/04/2025 आदेश/ Order Per Dr. Dipak P. Ripote, Am: This Appeal Filed By The Assessee Is Against The Order Of Ld.Commissioner Of Income Tax-Exemption, Pune Passed Under Section 80G(5) Of The Income Tax Act, 1961; Dated 19.02.2025. 2. The Assessee Has Raised The Following Ground Of Appeal : “1. On The Basis Of Facts & In The Circumstances Of The Case & As Per Law, The Commissioner Of Income Tax,(Exemptions) Pune, Is Not

Section 10Section 11Section 12ASection 13(1)Section 80GSection 80G(5)Section 80G(5)(iii)

established by law, or is an institution financed wholly or in part by the Government or a local authority; (vi) in relation to donations made after the 31st day of March, 1992, the institution or fund is for the time being approved by the Principal Commissioner or Commissioner; (emphasis supplied) (vii)………… (viii) ………. (ix)………….. Provided that the institution or fund referred

VALLABHDAS VALJI JILHA VACHANALAYA,JALGAON vs. THE COMMISSIONER OF INCOME TAX, EXEMPTION - PUNE, PUNE

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

ITA 1423/PUN/2023[N.A.]Status: DisposedITAT Pune18 Apr 2024

Bench: Shri S.S.Godara & Dr. Dipak P. Ripoteआयकरअपीलसं. / Ita No.1423/Pun/2023 िनधा"रणवष" / Assessment Year :- Vallabhdas Valjijilha The Commissioner Of Vachanalaya, Vs Income Tax- 227, Navi Peth, Jalgaon, Exemption, Pune. Jalgaon – 425001. Pan: Aabtv0802C Appellant/ Assessee Respondent /Revenue Assessee By None. Revenue By Shri Ajay Kumar Keshari – Dr Date Of Hearing 17/04/2024 Date Of Pronouncement 18/04/2024 आदेश/ Order Per Dr. Dipak P. Ripote, Am: This Is Assessee’S Appeal Against The Order Of Ld.Commissioner Of Income Tax(Exemption), Pune Under Section 80G Of The Act, Dated 26.10.2023. The Ld.Cit(E) Dismissed The Application Of The Assessee On The Ground That The Application Is Time Barred. The Assessee Has Raised The Following Ground(S) Of Appeal : “1) On The Facts & Circumstances Of The Case & In Law, Thecommissioner Of Income-Tax (Exemption) Pune Has Erred In Rejecting The Application In Form 10Ab Under Section 80G(5) Of The Vallabhdas Valji Jilha Vachanalaya [A]

Section 10Section 12ASection 80GSection 80G(5)

established by law, or is an institution financed wholly or in part by the Government or a local authority; (vi) in relation to donations made after the 31st day of March, 1992, the institution or fund is for the time being approved by the Principal Commissioner or Commissioner; (emphasis supplied) (vii)………… (viii) ………. (ix)………….. Provided that the institution or fund referred

M/S. BIRMANI CHARITABLE FOUNDATION ,NASHIK vs. COMMISSIONER OF INCOME TAX (EXEMPTION), PUNE, PUNE

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

ITA 113/PUN/2024[--]Status: DisposedITAT Pune28 Mar 2024

Bench: Shri S.S.Godara & Dr. Dipak P. Ripoteआयकर अपील सं. / Ita No.113/Pun/2024 िनधा"रण वष" / Assessment Year : N.A. M/S.Birmani Charitable The Commissioner Of Foundation, V Income Tax(Exemption), H 227, Deepak Mahal, Lam S Pune. Road, Deolali Camp, Dist.Nashik – 422401. Pan: Aaicb8213B Appellant/ Assessee Respondent /Revenue Assessee By Shri Sanket M Joshi – Ar Revenue By Shri Keyur Patel – Cit(Dr) Date Of Hearing 28/03/2024 Date Of Pronouncement 28/03/2024 आदेश/ Order Per Dr. Dipak P. Ripote, Am: This Appeal Is Filed By The Assessee Against The Order Of Ld.Commissioner Of Income Tax(Exemption), Pune Dated 03.11.2023 Passed Under Section 80G Of The Income Tax Act, 1961 Rejecting The Assessee’S Application Filed In Form No.10Ab For Approval Under Section 80G(5) Of The Act. The Assessee Has Raised The Following Grounds Of Appeal : M/S.Birmani Charitable Foundation [A]

Section 10Section 12ASection 80GSection 80G(5)

permanently disentitle the appellant from obtaining approval u/s 80G(5) even though it is genuinely engaged in carrying out charitable objects since February 2020 which could never have been the intention of the case. 5. The appellant craves leave to add/alter/amend any of the grounds of appeal.” 2 M/s.Birmani Charitable Foundation [A] Submission of ld.AR: 2. The ld.Authorised Representative(ld.AR

GENDER LAB FOUNDATION,THANE vs. COMMISSIONER OF INCOME TAX (EXEMPTION), PUNE

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

ITA 193/PUN/2024[-]Status: DisposedITAT Pune30 Apr 2024

Bench: Shri S.S.Godara & Dr. Dipak P. Ripoteआयकर अपील सं. / Ita No.193/Pun/2024 िनधा"रण वष" / Assessment Year :- Gender Lab Foundation, The Commissioner Of Flat No.2203-4, A Wing, Vs Income Tax, Tribeca Building, Hiranandani Exemption, Pune. Estate, G B Road, Chitalsar Manpada, B.O., Thane. Maharashtra – 400607. Pan: Aajcg4122B Appellant/ Assessee Respondent /Revenue Assessee By None. Revenue By Shri Keyur Patel – Cit(Dr) Date Of Hearing 29/04/2024 Date Of Pronouncement 30/04/2024 आदेश/ Order Per Dr. Dipak P. Ripote, Am: This Is Assessee’S Appeal Against The Order Of Ld.Commissioner Of Income Tax(Exemption), Pune Under Section 80G Of The Act, Dated 15.12.2023. The Ld.Cit(E) Dismissed The Application Of The Assessee On The Ground That The Application Is Time Barred. The Assessee Has Raised The Following Ground(S) Of Appeal : “1. The Cit E, Failed To Appreciate That The Appellant, Gender Lab Gender Lab Foundation [A]

Section 119(2)(b)Section 12ASection 80GSection 80G(5)

permanent registration u/s.80G – 04.07.2023. 5. The question before us is whether the application of the assessee was time barred or not? 4 Gender Lab Foundation [A] To decide this question, we have to first understand the relevant statutory provisions of the Income Tax Act. 5.1 The relevant part of Section 80G(5) of the Income tax Act is reproduced here

AADHAR SHIKSHAN SANSTHA YELAVI,SANGLI vs. CIT, EXEMPTION, PUNE , PUNE

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

ITA 748/PUN/2024[-]Status: DisposedITAT Pune12 Sept 2024

Bench: Ms.Astha Chandra & Dr. Dipak P. Ripoteआयकर अपील सं. / Ita No.748/Pun/2024 िनधा"रण वष" / Assessment Year : N.A. Aadhar Shikshan Sanstha The Commissioner Of Yelavi, V Income Tax, Exemption, At Post Yelavi, Tal Tasgaon, S Pune. Dist. Sangli, Sangli – 416416. Pan: Aaata3972D Appellant/ Assessee Respondent /Revenue Assessee By Smt. Deepa Khare – Ar Revenue By Shri Mirtyunjoy Barnwal – Dr Date Of Hearing 11/09/2024 Date Of Pronouncement 12/09/2024 आदेश/ Order Per Dr. Dipak P. Ripote, Am: This Is Assessee’S Appeal Against The Order Of Ld.Commissioner Of Income Tax(Exemption), Pune Under Section 80G Of The Act, Dated 15.02.2024. The Ld.Cit(E) Dismissed The Application Of The Assessee On The Ground That The Application Is Time Barred. The Assessee Has Raised The Following Ground(S) Of Appeal : “1. The Id Cit Exemption Erred In Law & On Facts In Treating The Application Under Clause (Iit) Of First Proviso To Sub-Section (5) Of Section 80G As Non- Maintainable On The Ground Of Being Filed Aadhar Shikshan Sanstha Yelavi [A]

Section 10Section 11Section 80GSection 80G(5)Section 80G(5)(vi)

permanent registration u/s.80G – 25.09.2023. 5. The question before us is whether the application of the assessee was time barred or not? To decide this question, we have to first understand the relevant statutory provisions of the Income Tax Act. 3 Aadhar Shikshan Sanstha Yelavi [A] 5.1 The relevant part of Section 80G(5) of the Income tax Act is reproduced

SSHBPSS RAMCHANDRA GOPAL SHELAR SHERLARMAMA YOG SANSHODHAN SEVA PRATISHTHAN,PUNE vs. CIT EXEMPTION, PUNE, PUNE

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

ITA 844/PUN/2024[-]Status: DisposedITAT Pune24 Jun 2024

Bench: Shri S.S.Godara & Dr. Dipak P. Ripoteआयकर अपील सं. / Ita No.844/Pun/2024 िनधा"रण वष" / Assessment Year : - Sshbpss Ramchandra Gopal V The Commissioner Of Shelar Shherlarmama Yog S Income Tax(Exemption), Sanshodhan Seva Pratishthan, Pune. S.No.124, Maeers Mit College Campus, Paud Road, Kothrud, Pune – 411038. Pan: Aaqts9502D Appellant / Assessee Respondent / Revenue Assessee By None. Revenue By Shri P.R.Mane – Dr Date Of Hearing 19/06/2024 Date Of Pronouncement 24/06/2024 आदेश/ Order Per Dr. Dipak P. Ripote, Am: This Is An Appeal Filed By The Assessee Against The Order Of Ld.Commissioner Of Income-Tax-Exemption, Pune U/Sec.80G Of The Act Dated 26.03.2024. The Ld.Cit(E) Dismissed The Application Of The Assessee On The Ground That The Application Is Time Barred. The Assessee Has Raised Following Grounds Of Appeal : Sshbpss Ramchandra Gopal Shelar Sherlarmama Yog Sanshodhan Seva Pratishthan

Section 80GSection 80G(5)

permanent registration u/sec.80G(5) in Form No.10AB on 29.09.2023. 5. The question before us is whether the application of the assessee was time barred or not? To decide this question, we have to first understand the relevant statutory provisions of the Income Tax Act. 5.1 The relevant part of Section 80G(5) of the Income tax Act is reproduced here

BRAHM PRECISION MATERIALS PVT. LTD.,AURANGABAD vs. COMMISSIONER OF INCOME TAX (APPEALS), NATIONAL FACELESS APPEAL CENTRE, NEW DELHI

In the result, appeal of the assessee for A

ITA 425/PUN/2025[2020-21]Status: DisposedITAT Pune13 Oct 2025AY 2020-21
Section 143(3)Section 250

price of such\ninvestment then loss of such investment is a capital loss.\n\n20. At the cost of repetition, brief facts relating to this issue\nare that in order to expand its business overseas and also to\nincrease its export sales and other Revenue in the field of\nmanufacturing of high precision caging components and\nAerospace and Defence Industries

BRAHM PRECISION MATERIALS PVT LTD,AURANGABAD vs. CIT(A), NATIONAL FACELESS APPEAL CENTRE (NFAC) DELHI

In the result, appeal of the assessee for A

ITA 1183/PUN/2023[2018-19]Status: DisposedITAT Pune13 Oct 2025AY 2018-19
Section 143(3)Section 250Section 68

price of such\ninvestment then loss of such investment is a capital loss.\n20. At the cost of repetition, brief facts relating to this issue\nare that in order to expand its business overseas and also to\nincrease its export sales and other Revenue in the field of\nmanufacturing of high precision caging components and\nAerospace and Defence Industries