DEPUTY COMMISSIONER OF INCOME-TAX, CIRCLE - 1(1),, PUNE vs. M/S. IAC INTERNATIONAL AUTOMOTIVE INDIA PVT.LTD,, PUNE

In the result, the appeal of the Revenue is dismissed

Bench: Ms. Astha Chandra & Shree Dr. Dipak P. Ripote

Transfer Pricing Officer (“TPO”) under the provisions of section 92CA(1) of the Act in order to determine the Arm‟s Length Price (“ALP”) in respect of such international transactions. 2.2 The assessee undertook the following international transactions with its AEs during AY 2013-14 and benchmarked each transaction by selecting the Most Appropriate Method (“MAM”) mentioned in the table

M.M. PATEL PUBLIC CHARITABLE TRUST,SOLAPUR vs. PCIT- CENTRAL, PUNE, PUNE

In the result, the appeal of the assessee is partly allowed

transferring the jurisdiction of the person, the transferee Income-\ntax Authorities as mentioned in section 116 of the Act shall exercise all\nthe powers and perform the functions as stipulated in the Act in respect\nof all the proceedings which may be commenced after the date of such\norder in respect of any year and such power includes passing

UTTAM ENERGY LIMITED,PUNE vs. ACIT CIRCLE-12, PUNE

Appeal of the Assessee is partly allowed

Bench: Dr.Dipak P. Ripote & Shri Vinay Bhamoreआयकर अपील सं. / Ita No.2033/Pun/2019 िनधा"रण वष" / Assessment Year: 2015-16 Uttam Energy Limited, The Acit, Circle-12, Mahendra Chamber, Mayfair V Pune. Co-Op Housing Society, S A-4, Dhole Patil Road, Pune – 411001. Pan: Aabcu4100H Appellant/ Revenue Respondent /Assessee Assessee By Shri Ch Naniwadekar & Kiran Sanmane – Ar;S Revenue By Shri Deepak Garg – Cit Date Of Hearing 16/05/2024 Date Of Pronouncement 30/05/2024 आदेश/ Order Per Dr. Dipak P. Ripote, Am: This Appeal Has Been Filed By The Assessee Against The Final Assessment Order Of The Learned Acit, Circle-12, Pune Passed U/Sec. 143(3) R.W.S. 144C(13) Of The Of The Income Tax Act, 1961 (In Short "The Act") After Giving Effect To The Learned Drp’S Order Dated 24.09.2019. 1.1 The Assessee Has Raised The Following Grounds Of Appeal :

Transfer Pricing Officer (TPO) on 18/09/2017 for determination of Arm’s length Price of Specified Domestic Transactions. The TPO passed the order on 30/10/2018 suggesting adjustment of Rs.4 crores. The Assessee filed an appeal before the Dispute resolution Panel (DRP). The Assessee had taken a legal ground of jurisdiction of the TPO before the DRP. The Assessee relied

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

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

Bench: Shri R. K. Panda & Ms. Astha Chandraassessment Year : 2021-22

transfer of all significant risk and rewards of ownership of goods to buyer. The amount recognized as sale is exclusive of GST, interest and Dharmada, if any, charged in invoice Sales are net of VAT/GST. Sale is net of goods returns, if any. 14.2 The above accounting policy followed by the appellant regarding the recognition of revenue clearly suggests that

ASST. COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-1(1), PUNE, PUNE vs. GIRIRAJ ENTERPRISES, PUNE

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

Bench: Shri R. K. Panda & Ms. Astha Chandraassessment Year : 2021-22

transfer of all significant risk and rewards of ownership of goods to buyer. The amount recognized as sale is exclusive of GST, interest and Dharmada, if any, charged in invoice Sales are net of VAT/GST. Sale is net of goods returns, if any. 14.2 The above accounting policy followed by the appellant regarding the recognition of revenue clearly suggests that

DCIT CIRCLE 1 NASHIK, NASHIK vs. SHREE SAI PROPERTIES, NASHIK

In the result, appeal of the Revenue is dismissed

Bench: Dr. Manish Borad & Shri Vinay Bhamore

section 143(3). In large number of cases we find that the above distinction is not kept in mind by the Assessing Officer. It is for this reason that we have spelt out the difference between the regular assessment and the block assessment under Chapter XIV-B.” 22. Ld. Counsel for the assessee has also referred to following decisions wherein

PRECISION CAMSHAFTS LIMITED,PUNE vs. DCIT CIRCLE 1, SOLAPUR

In the result, appeal of the assessee is partly allowed

Bench: Shri Rama Kanta Panda & Shri Vinay Bhamoreआयकर अपऩल सं. / Ita No.2744/Pun/2024 निर्धारण वषा / Assessment Year: 2021-22 Precision Camshafts Limited, V Assessment Unit, E-102/103, Akkalkot Road S Income Tax Department Midc, Solapur – 413006. (National Faceless Maharashtra. Assessment Center), Jurisdiction : Pne C(1), Range 63, Deputy Commissioner Of Income Tax („Dcit‟), Circle-1, Solapur. Pan: Aabcp1086B Appellant/ Assessee Respondent / Revenue Assessee By Shri Nikhil S Pathak - Ar Revenue By Shri Prakash L Pathade – Cit(Dr) Date Of Hearing 21/08/2025 Date Of Pronouncement 12/11/2025 आदेश/ Order Per Vinay Bhamore, Jm: This Is An Appeal Filed By Assessee Against The Assessment Order Under Section 143(3) R.W.S 144C(13) Read With Section 144B Of The Act, 1961 Dated 24.10.2024 For A.Y.2021-22 Emanating From Dispute Resolution Panel‟S Order Passed Under Section 144C(5) Of

Section 92 (3) of the Act. The appellant company craves leave to add, alter, amend or delete any of the above grounds of appeal.” 1.1 Additional Ground filed : “1] The learned A.O. / DRP erred in making an addition on protective basis of Rs.13,81,700/- by adopting the Arm's Length interest rate @ 2.40% as against 1.90% adopted

MEENAMANI GANGA BUILDER LLP ,PUNE vs. PCIT (CENTRAL), PUNE , PUNE

In the result, the appeal of the assessee is dismissed

4) [2011] 16\ntaxman.com 271 (Lucknow)\n9. On the other hand, ld. Departmental Representative\nvehemently argued supporting the order of ld PCIT stating that\nIdentity and creditworthiness of the cash creditors and\ngenuniness of the transaction cannot be examined merely on\nthe basis of confirmation letters and ld. AO ought to have\ncarried out further more inquiries as contemplated

LIQUIDHUB ANALYTICS PVT. LTD. (NOW MERGED WITH CAPGEMINI TECHNOLOGY SERVICES INDIA LTD),PUNE vs. NFAC, PUNE

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

Bench: Shri R. K. Panda & Shri Vinay Bhamoreassessment Year : 2020-21

Transfer Pricing Officer about the amalgamation between SPENI and SPNI under Sections 391 to 394 of the Companies Act effective from 1 April 2015 and that the Assessing Officer could not have proceeded to pass the assessment order against a non-existent entity. The Tribunal has in fact observed that apart from the first communication dated 02 January 2017, there

DY COMMISSIONER OF INCOME-TAX, SANGLI CIRCLE,, SANGLI vs. ANAND DEVELOPERS, SANGLI

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

132 of the Act were conducted in the residential and business premises of the M/s Ramsina Group of cases on 19.12.2014. During such search seizure operations, it was found that M/s. Prarthana Infra had made several cash payments on various dates aggregating to a sum of Rs.8,47,00,000/- to Mr. Vihang Shah and Mr. Anand Shah as advance

ANAND DEVELOPERS,SANGLI vs. INCOME-TAX OFFICER, WARD 2(1), SANGLI

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

132 of the Act were conducted in the residential and business premises of the M/s Ramsina Group of cases on 19.12.2014. During such search seizure operations, it was found that M/s. Prarthana Infra had made several cash payments on various dates aggregating to a sum of Rs.8,47,00,000/- to Mr. Vihang Shah and Mr. Anand Shah as advance

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

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

132 or section 132A,\nafter the expiry of one month from the date on which he was served with a\nnotice under sub-section (1) of section 153A or sub-section (2) of section\n153C or after the completion of the assessment, whichever is earlier.\n(4) Subject to the provisions of sub-section (3), where an assessee calls

UBS BUSINESS SOLUTIONS (INDIA) PRIVATE LIMITED (SUCCESSOR TO CREDIT SUISSE SERVICES (INDIA) PVT LTD),PUNE vs. PCIT, PUNE - 1, PUNE, MAHARASHTRA

In the result, appeal of the Assessee is allowed

Bench: Ms.Astha Chandra & Dr.Dipak P. Ripoteआयकर अपऩल सं. / Ita No.1407/Pun/2025 निर्धारण वषा / Assessment Year: 2020-21 Ubs Business Solutions (India) V The Principal Pvt. Ltd. (Successor To Credit S. Commissioner Of Suisse Services (India) Pvt Income Tax, Ltd.), Pune-1. Cluster A, Eon Free Zone, Plot No.1, S.No.77, Ground To 5Th Floors In Wing 1, 3Rd To 5Th Floor In Wing 2, Kharadi Midc Knowledge Park, Pune – 411014. Pan: Aabcu8718M Appellant/ Assessee Respondent / Revenue Assessee By Shri Rajendra Agiwal - Ar Revenue By Shri Amit Bobde – Cit(Dr) Date Of Hearing 23/09/2025 Date Of Pronouncement 28/11/2025 आदेश/ Order Per Dr. Dipak P. Ripote, Am: This Appeal Is Filed By The Assessee Against The Order Of Ld.Principal Commissioner Of Income Tax, Pune-1 Passed Under Section 263 Of The Income Tax Act, 1961 For A.Y.2020-21, Dated 31.03.2025 Emanating From Assessment Order U/S.143(3) R.W.S 144B

Transfer Pricing Report which is appearing on page no 373 in factual paper book. It is submitted that this is purely a figure of reimbursement of expenses. However, it was the submission of the assessee that when it provides services to associated enterprises the assessee recovers 14.5% markup on cost eligible for markup. Such as cost is to be seen

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

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

transferred from the office of the ITO 2(4), Kolkata to ACIT, Central Circle – 1, Aurangabad. Notice u/s 142(1) of the Act was issued. Further notices u/s 133(6) of the Act were also issued to different entities from which the share amounts were received by the assessee company during the impugned assessment year. 4 CO No.21/PUN/2024 6. Subsequently

ASHWINI SAHAKARI RUNGNALAYA & RESEARCH CENTER,,SOLAPUR vs. COMMISSIONER OF INCOME-TAX, (EXEMPTIONS),, PUNE

Bench: Hon’Ble Shri S. S. Viswanethra Ravi & Shri G. D. Padmahshaliआयकर अपील सं. / Ita No. 714/Pun/2018 Ashwini Sahakari Rugnalaya & Research Centre 7107/1, Plot No. 180, North Sadar Bazar, Solapur-413003. Pan: Aaaja0041K . . . . . . . अपीलार्थी / Appellant

transferred to Ld. CIT(E) jurisdiction. The Ld. CIT(E) vide notice dt. 24/03/2017 revived former cancellation proceedings and before culmination had granted reasonable opportunities to enable the assessee to rebut Revenue’s negative observations/findings. After analysis of facts with an elaborate discussion laid in para 4, the Ld. CIT(E) by the impugned order dt.28/03/2018 has finally withdrawn/cancelled

DHAS KISHOR RAMCHANDRA, AURANGABAD vs. DWARKAPRASAD BHIKULAL SONI, JALNA

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

Bench: SHRI R. K. PANDA (Vice President), SHRI VINAY BHAMORE (Judicial Member)

132 of the IT Act was carried out in the case of the assessee on 23.09.2021. Notices u/s 142(1) were issued and assessee furnished information during the course of assessment proceedings. After considering the reply of the assessee, the Assessing Officer completed the assessment u/s 143(3) determining total income at Rs.6,55,61,287/- as against the income

ITO, NASHIK vs. ANKIT NARESH TULSIAN, NASHIK

In the result, appeal of the Revenue is dismissed

132 of the Income Tax Act, 1961, by the DDIT(Inv.)\nKolkata.\n3. Whether on the facts and circumstances of the case and in\nlaw, the Ld. CIT(A) has erred in not appreciating dated\n30.03.2015. Shri Anil Kumar Khemka confessed to facilitating\naccommodation entries through the manipulation of scraps,\nincluding MISHKAFIN and outlined the modus operandi where\nbeneficiaries were

BAJAJ HOUSING FINANCE LIMITED,PUNE vs. ITO, WARD-8(1), PUNE, PUNE

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

Bench: Dr.Manish Borad

Transfer Pricing Officer, where the assessee had maintained information and documents as prescribed under section 92D, declared the international transaction under Chapter X, and, disclosed all the material facts relating to the transaction; and (e) the amount of undisclosed income referred to in section 271AAB. 12. It was also pointed that as per section 270A

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

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

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

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