M/S PERSISTENT SYSTEMS LIMITED,PUNE vs. ASSESSMENT UNIT, INCOME-TAX DEPARTMENT, PUNE

In the result, appeal of the Assessee is Partly Allowed

Bench: Shri S.S.Godara & Dr. Dipak P. Ripoteआयकरअपीलसं. / Ita No.692/Pun/2022 िनधा"रणवष" / Assessment Year : 2018-19 M/S.Persistent Systems Assessment Unit, Income Limited, V Tax Department. “Bhageerath” 402, Senapati S Bapat Road, Pune – 411016. Pan: Aabcp 1209 Q Appellant/ Assessee Respondent /Revenue Assessee By Shri Dhanesh Bafna& Shriaditya Vaidya– Ar’S Revenue By Shri Suhas Kulkarni - Irs Addl Commissioner Of Income Tax Date Of Hearing 26/09/2023 Date Of Pronouncement 02/11/2023 आदेश/ Order Per Dr. Dipak P. Ripote, Am: This Appeal Filed By The Assessee Is Directed Against The Assessment Order, Dated 20.07.2022 Under Section 143(3) R.W.S. 144C(13) Read With Section 144B Of The Income Tax Act, 1961 For A.Y.2018-19. The Assessee Has Raised The Following Grounds Of Appeal: “Ground 1: Order Is Invalid / Non Est  On The Facts & In The Circumstances Of The Case & In Law, The Assessment Unit (‘Au’) Has Erred In Passing The Draft Assessment M/S.Persistent Systems Limited [A]

144B of the Income Tax Act, 1961 (‘the Act’) with regard to granting an opportunity for personal hearing via video conference and without providing an opportunity to the Appellant to file a written submission in response to the Show-cause notice. Dispute Resolution Panel (‘Ld. DRP’) erred in upholding the same by contending that there was no denial of opportunity

QUBIX BUSINESS PARK PRIVATE LIMITED,PUNE vs. DEPUTY COMMISSIONER OF INCOME TAX, CIRCLE-8, PUNE, PUNE

In the result, Ground No.2 of the assessee is allowed for statistical purpose

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

Transfer Pricing Officer under sub- Section (3) of Section 92CA and even under Section 144C(8). The DRP may confirm, reduce or enhance the variations proposed in the draft order and wherefore the word eligible assessee in Clause (1) and (15) and the proposed draft order referred to under Clause 144c(1) and (8) will have to be given full

PRODAIR AIR PRODUCTS INDIA PRIVATE LIMITED, PUNE,PUNE vs. ASSISTANT COMMISSIONER OF INCOME TAX, CIRCLE-4, PUNE, PUNE

In the result, the appeal of the Assessee is Dismissed

Bench: Shri Satbeer Singh Godara & Dr. Dipak P. Ripoteआयकर अपील सं. / Ita No.495/Pun/2022 िनधा"रण वष" / Assessment Year : 2018-19 Prodair Air Products India The Assistant Private Limited, V Commissioner Of 602 Pentagon 5, Magarpatta S Income Tax, Circle-4, City, Hadapsar, Pune – 411013. Pune. Pan: Aafcp0045E Appellant/ Assessee Respondent /Revenue Assessee By Shri Chandni Shah & Ridhi Maru – Ar Revenue By Shri Subhakant Sahu – Irs, Dr Date Of Hearing 21/09/2023 Date Of Pronouncement 14/12/2023

Transfer Pricing Officer passed an order dated 24.07.2021. After that as per section 144C of the Act, the AO(National Faceless Assessment Centre passed draft assessment order under section 144C of the Act. The assessee’s filed objections before Dispute Resolution Panel(DRP) as per section 144C(2) of the Act. The relevant provision of section 144C are reproduced here

LEAR AUTOMOTIVE INDIA P. LTD. ,PUNE vs. ASSISTANT COMMISSIONER OF INCOME TAX, CIRCLE-8, PUNE, PUNE

transfer pricing adjustment pertaining to the allocation of RHQ charges.", "result": "Allowed", "sections": [ "144C(5)", "143(3)", "144C(13)", "92CA(3)", "254", "144B

ARISTON GROUP INDIA PRIVATE LIMITED,PUNE vs. THE ASSESSEMENT UNIT, INCOME TAX DEPARTMENT, NFAC AND THE DCIT, CIRCLE 1(1), PUNE, PUNE

In the result, appeal of the assessee is partly allowed

Bench: Shri R.K.Panda & Shri Vinay Bhamoreआयकर अपील सं. / Ita No.1680/Pun/2024 िनधा"रण वष" / Assessment Year: 2020-21 Ariston Group India Private The Assessment Unit, Limited, Income Tax Department, 1St Floor, Office No.103, V National Faceless Mayfai Tower, Wakdewadi, S. Assessment Centre, Shivaji Nagar, Pune-411005. Delhi(“Nfac”), The Dcit, Circle-1(1), Pune. Pan: Aaoca7042D Appellant/ Assessee Respondent / Revenue Assessee By Shri Ketan Ved – Ar Revenue By Shri Prakash L Pathade – Cit(Dr) Date Of Hearing 15/01/2025 Date Of Pronouncement 09/04/2025 आदेश/ Order Per Vinay Bhamore, Jm: This Is An Appeal Filed By The Assessee Against The Assessment Order Passed Under Section 143(3) R.W.S 144C(3) Read With Section 144B Of The Income Tax Act, 1961, Dated 18.06.2024 For A.Y.2020- 21. The Assessee Has Raised The Following Grounds Of Appeal : “Based On The Facts & Circumstances Of The Case, Ariston Group India Private Limited (Hereinafter Referred To As "Ariston India' Or 'The Appellant) Prefers An Appeal For The Assessment Year 2020-21 Against

144B of the Income Tax Act, 1961, dated 18.06.2024 for A.Y.2020- 21. The Assessee has raised the following grounds of appeal : “Based on the facts and circumstances of the case, Ariston Group India Private Limited (hereinafter referred to as "Ariston India' or 'the Appellant) prefers an appeal for the assessment year 2020-21 against ITA No.1680/PUN/2024 [A] the order dated

CUMMINS GENERATOR TECHNOLOGIES INDIA PRIVATE LIMITED,PUNE vs. THE ASSESSMENT UNIT, INCOME TAX DEPARTMENT, NFAC AND THE ACIT, CIRCLE 1(1), PUNE, PUNE

In the result, appeal of the assessee is partly allowed

Bench: Dr.Dipak P. Ripote & Shri Vinay Bhamoreआयकर अपीलसं. / Ita No.1641/Pun/2024 िनधा"रण वष" / Assessment Year: 2020-21 Cummins Generator V The Assessment Unit, Technologies India Pvt. Ltd., S Income Tax Department, Tower A, 6Th Floor, Cummins Nfac & The Acit, India Offie Campus, Balewadi, Circle-1(1), Pune. Pune – 411045. Pan: Aabcc1533E Appellant/ Assessee Respondent / Revenue Assessee By Shri Ketan Ved – Ar Revenue By Shir Prakash L Pathade – Cit(Dr) Date Of Hearing 05/12/2024 Date Of Pronouncement 19/12/2024 आदेश/ Order Per Dr. Dipak P. Ripote, Am: This Is An Appeal Filed By The Assessee Against The Order Of Assessing Officer Passed Under Section 143(3) R.W.S. 144C(13) Read With Section 144B Of The Income Tax Act, 1961 Dated 07.06.2024; To Give Effect To The Order Of Dispute Resolution Panel Dated 18.05.2024. The Grounds Of Appeal Raised By The Assessee Are As Under : “1. Ground For Not Following The Directions Of The Hon'Ble Dispute Resolution Panel (Hereinafter Referred To As "Drp")

Transfer Pricing Officer preferred an appeal before Dispute Resolution Panel. Dispute Resolution Panel decided the objections raised by assessee vide order dated 18.05.2024. Then the Assessing Officer passed an order under section 143(3) r.w.s. 144C(13) r.w.s. 144B

DATTATRAY HANMANTRAO DESAI,KARAD vs. PRINCIPAL COMMISSIONER OF INCOME TAX, PUNE

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

Bench: Shri R. K. Panda & Ms Astha Chandraassessment Year : 2018-19

144B of the Act is erroneous in so far as it is prejudicial to the interest of Revenue. He, therefore, partly set aside the order of the Assessing Officer for the limited purpose of examining the transaction involving unsecured loans and other financial transactions. He further directed the Assessing Officer to specifically examine the following aspects: i) The AO shall

DCIT, SWARGATE PUNE vs. CUMMINS INDIA LTD , PUNE

In the result, appeal of the assessee bearing ITA No

144B of the Act while completing the assessment by not\nissuing any show cause notice, including a personal hearing\nthrough video conferencing despite specific request of the\nAppellant, while proposing a variation prejudicial to the Appellant.\nIn view of the same, the assessment needs to be declared null and\nvoid.\nGrounds on Transfer Pricing issue\n2. General ground: Transfer pricing

CUMMINS INDIA LIMITED,,PUNE vs. ASSISTANT COMMISSIONER OF INCOME-TAX, CIRCLE - 1(1),, PUNE

In the result, appeal of the assessee bearing ITA No

144B of the Act while completing the assessment by not\nissuing any show cause notice, including a personal hearing\nthrough video conferencing despite specific request of the\nAppellant, while proposing a variation prejudicial to the Appellant.\nIn view of the same, the assessment needs to be declared null and\nvoid.\n\nGrounds on Transfer Pricing issue\n\n2. General ground

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

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 ITA No.2744/PUN/2024 [A] the Act, dated 06.09.2024 and Draft Assessment Order passed under section 144C(1) of the Act, dated 20.12.2023. The Assessee has raised the following grounds of appeal : “The following grounds are taken without prejudice

M/S VODAFONE GLOBAL SERVICES P LTD,,PUNE vs. ASSISTANT COMMISSIONER OF INCOME-TAX, CIRCLE 1(1),, PUNE

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

Bench: Dr.Manish Borad & Shri Vinay Bhamoreआयकर अपील सं. / Ita No.660/Pun/2022 Assessment Year : 2018-19

Transfer Pricing (TP') Assessment proceedings. 10. The Assessee submits that the variation/reduction of 3 percent to be allowed while determining the arm's length price as envisaged under the proviso to Section 92C(2) of the Act. C. Initiation of penalty proceedings under section 270(A) of the Act. 11. Initiating the penalty proceedings under section

JADE GLOBAL SOFTWARE PRIVATE LIMITED,PUNE vs. ASSESSMENT UNIT, NATIONAL FACELESS ASSESSMENT CENTRE, PUNE

In the result, the Appeal of the Assessee is allowed for statistical purpose

section 144B of the Income Tax Act, 1961; dated 05.07.2024 for Assessment Year 2020-21. The assessee has raised the following grounds of appeal :\n\"1. Incorrect rejection of TP Study by the Transfer Pricing

ZS ASSOCIATES INDIA PVT.LTD,,PUNE vs. DEPUTY COMMISSIONER OF INCOME-TAX, CIRCLE -12,, PUNE

In the result, appeal of the assessee is dismissed as withdrawn

Bench: Dr.Dipak P. Ripote & Shri Vinay Bhamoreआयकर अपऩल सं. / Ita No.211/Pun/2022 निर्धारण वषा / Assessment Year: 2017-18 Zs Associates India Private V The Additional / Joint / Limited, S Deputy / Assistant Tower 3, World Trade Centre, Commissioner Of Kharadi, Pune – 411014. Income Tax, Dcit, Circle-12, Pune. Pan:Aaacz2157Q Appellant/ Assessee Respondent /Revenue Assessee By Shri Ninad Patade (Through Virtual) Revenue By Shri Prakash L Pathade Date Of Hearing 11/12/2025 Date Of Pronouncement 06/02/2026 आदेश/ Order Per Dr. Dipak P. Ripote, Am: In This Case, Assessee Has Filed An Appeal Against The Assessment Order Dated 16.02.2022 Passed U/S.143(3) R.W.S 144C(13) Read With Section 144B Of The Act, 1961 For The A.Y.2017- 18, Emanating From Order Of The Dispute Resolution Panel U/S.144C(5) Of The Act, Dated 06.12.2021, Which In Turn Emanates From Draft Assessment Order U/S.143(3) R.W.S 144C(1) Of The Act

144B of the Act, 1961 for the A.Y.2017- 18, emanating from order of the Dispute Resolution Panel u/s.144C(5) of the Act, dated 06.12.2021, which in turn emanates from Draft Assessment Order u/s.143(3) r.w.s 144C(1) of the Act, ITA No.211/PUN/2022 [A] dated 31.03.2021. The Assessee has raised following grounds of appeal : “Based on the facts and circumstances

B & R INDUSTRIAL AUTOMATION PVT. LTD.,PUNE vs. DCIT, CIRCLE 1(1), PUNE

Bench: SHRI VINAY BHAMORE (Judicial Member)

144B of the Act, dated 26.09.2024 emanating from Dispute Resolution Panel’s order under section 144C of the Act, ITA No.2469/PUN/2024 [A] dated 06.09.2024 emanating from Draft Assessment Order dated 22.12.2023. The Grounds of appeal raised by the Assessee are as under : “That on the facts and circumstances of the case and in law. 1 The impugned order

PRECISION CAMSHAFTS LTD.,SOLAPUR vs. ASSESSMENT UNIT, INCOME TAX DEPARTMENT (NFAC), SOLAPUR

In the result, appeal of the assessee is allowed

Bench: Ms. Astha Chandra & Dr.Dipak P. Ripoteआयकर अपील सं. / Ita No.1962/Pun/2024 िनधा"रण वष" / Assessment Year: 2020-21 Precision Camshafts Ltd., V Assessment Unit, Income Tax E-102/103, Akkalkot Road, S Department (National Midc, Solapur – 413006. Faceless Assessment Center), Maharashtra. Jurisdiction Details : Pne- C(1), Range 63, Circle-1, Solapur. Pan: Aabcp1086B Appellant/ Assessee Respondent / Revenue Assessee By Shri Nikhil Pathak – Ar Revenue By Shri Prakash L Pathade – Cit(Dr) Date Of Hearing 17/06/2025 Date Of Pronouncement 10/07/2025 आदेश/ Order Per Dr. Dipak P. Ripote, Am: This Is An Appeal Filed By The Assessee Directed Against The Order Of Assessment Unit, Income Tax Department Under Section 143(3) R.W.S 144C(3) Read With Section 144B Of The Income Tax Act, 1961 For A.Y.2020-21 Dated 25.07.2024, Emanating From Order Of Dispute Resolution Panel U/S.144C(5) Of The Act For A.Y.2020-21

section 144B of the Income Tax Act, 1961 for A.Y.2020-21 dated 25.07.2024, emanating from order of Dispute Resolution Panel u/s.144C(5) of the Act for A.Y.2020-21, ITA No.1962/PUN/2024 [A] dated 10.06.2024. The Assessee has raised the following grounds of appeal : “A. Transfer Pricing

DCIT, CIRCLE 8 PUNE, PUNE vs. ALFA LAVAL INDIA PVT LTD, PUNE

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

sections": [ "143(1)", "143(2)", "142(1)", "92CA(3)", "143(3)", "144C(3)", "144B", "40(a)(ia)", "14A", "40(a)(i)", "ICDS", "37", "40" ], "issues": "Whether the Ld. CIT(A) erred in deleting the additions made by the Assessing Officer concerning transfer pricing

VOLKSWAGEN GROUP TECHNOLOGY SOLUTIONS INDIA PVT. LTD.,PUNE vs. NATIONAL FACELESS ASSESSMENT CENTER, ASSESSMENT UNIT DELHI, DELHI

In the result, appeal of the assessee is partly allowed

Bench: Dr.Dipak P. Ripote & Shri Vinay Bhamoreआयकर अपील सं. / Ita No.1950/Pun/2024 िनधा"रण वष" / Assessment Year: 2020-21 Volkswagen Group Technology V National Faceless Solutions India Pvt. Ltd., S Assessment Center, Embassy Techzone, 9Th Floor, Assessment Unit, Delhi. 1.3 Congo Building, Rajiv Gandhi, Infotech Park, Infotech Park Hinjavadi, Pune – 411057. Maharashtra. Pan: Aafcv1368L Appellant/ Assessee Respondent / Revenue Assessee By Shri Nikhil Pathak – Ar Revenue By Shri Prakash L Pathade – Cit(Dr) Date Of Hearing 15/05/2025 Date Of Pronouncement 28/05/2025

144B of the Income Tax Act, 1961 for A.Y.2020-21 dated 25.07.2024. The Assessee has raised the following grounds of appeal : ITA No.1950/PUN/2024 [A] “1. On the facts and in the circumstances of the case, and in law, the Ld. Assessing Officer ('AO') / Ld. Dispute Resolution Panel ('DRP') has erred in proposing to enhance the income of the Appellant

BNY MELLON INTERNATIONAL OPERATIONS (INDIA) PVT. LTD.,,PUNE vs. ASSESSING OFFICER, NATIONAL E-ASSESSMENT CENTRE,, DELHI

The appeal of the assessee is PARTLY ALLOWED

Bench: Shri Satbeer Singh Godara & Shri G. D. Padmahshaliआयकर अपील सं. / Ita No. 699/Pun/2021 धििाारण वर्ा / Assessment Year : 2017-18 Bny Mellon International Operations (India) Pvt. Ltd., Tower S3, Level 1, Cybercity, Magarpatta City, Hadapsar, Pune-411013 Pan: Aadcm 9640 E . . . . . . . अपीलाथी / Appellant बिाम / V/S National E-Assessment Centre, Delhi . . . . . . .प्रत्यथी / Respondent द्वारा / Appearances Assessee By : Shri Nitesh Joshi Revenue By : Shri Rakesh Jha सुनवाई की तारीख / Date Of Conclusive Hearing : 03/08/2023 घोषणा की तारीख / Date Of Pronouncement : 08/08/2023 आदेश / Order Per G. D. Padmahshali, Am; This Appeal Is Directed Against The Order Of The National Faceless Assessment Centre, Delhi, [‘Ao’ Hereinafter] Dt. 29/10/2021 Passed U/S 143(3) R.W.S. 144C(13) R.W.S. 144B Of The Income-Tax Act, 1961 [‘The Act’ Hereinafter] For The Ay 2017-18. Itat-Pune Page 1 Of 16

144B of the Income-tax Act, 1961 (the Act), in accordance with section 253(1)(d) of the said Act, on the following amongst other grounds each of which is in the alternative and without prejudice to any others; 1. That the AO erred in passing the impugned Order making an addition by way of transfer pricing

EATON TECHNOLOGIES PRIVATE LIMITED,PUNE vs. PRINCIPAL COMMISSIONER OF INCOME TAX, PUNE

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

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

144B of the Act as erroneous in so far as it is prejudicial to the interests of the revenue. 5.1 Since proper enquiries with regard to correctness of the claim and verification of all the aspects involved have not been made, the order under section 143(3) read with section 144C(13) read with section 1448 of the Act, dated