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

transfer pricing documentation, assessee applied filter to reject the companies having negative worth showing that the assessee has rejected companies whose capital has been eroded as a result of continuous losses, that persistent operating loss makers have been rejected by assessee on the most conservative approach and requested to include Mahindra Ashtec Limited and Artson Engineering Ltd. as comparables

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

transfer pricing documentation, assessee applied filter to reject the companies having negative worth showing that the assessee has rejected companies whose capital has been eroded as a result of continuous losses, that persistent operating loss makers have been rejected by assessee on the most conservative approach and requested to include Mahindra Ashtec Limited and Artson Engineering Ltd. as comparables

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

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 below: Sr. Nature of International Amount

M/S EATON POWER QUALITY P.LTD.,PUNE vs. ACIT, PUNE

In the result, the appeal of assessee in ITA No

Bench: Shri Anil Chaturvedi, Am & Shri Vikas Awasthy, Jm

145, Off Mumbai-Pune Road, Pimpri, Pune – 411018 PAN : AAACC6943R .......अऩीऱाथी / Appellant बनाम / V/s. The Dy. Commissioner of Income Tax, Circle – 4, Pune ……प्रत्यथी / Respondent Assessee by : Shri Vishal Kalra Revenue by : Shri Rajeev Kumar सुनवाई की तारीख / Date of Hearing : 14-06-2018 घोषणा की तारीख / Date of Pronouncement : 11-09-2018 आदेश / ORDER PER VIKAS AWASTHY, JM : These

M/S. EATON POWER QUALITY PRIVATE LTD.,,PUNE vs. DEPUTY COMMISSIONER OF INCOME-TAX,,

In the result, the appeal of assessee in ITA No

Bench: Shri Anil Chaturvedi, Am & Shri Vikas Awasthy, Jm

145, Off Mumbai-Pune Road, Pimpri, Pune – 411018 PAN : AAACC6943R .......अऩीऱाथी / Appellant बनाम / V/s. The Dy. Commissioner of Income Tax, Circle – 4, Pune ……प्रत्यथी / Respondent Assessee by : Shri Vishal Kalra Revenue by : Shri Rajeev Kumar सुनवाई की तारीख / Date of Hearing : 14-06-2018 घोषणा की तारीख / Date of Pronouncement : 11-09-2018 आदेश / ORDER PER VIKAS AWASTHY, JM : These

GOODYEAR SOUTH ASIA TYRES PVT.LTD,,AURANGABAD vs. ASSISTANT COMMISSIONER OF INCOME-TAX, CIRCLE - 1,, AURANGABAD

In the result, both the appeals are partly allowed

Bench: Shri R.S. Syal & Shri Partha Sarathi Chaudhuryिनधा"रण वष" / Assessment Year : 2014-15

section 92C(2) of the Act not warranting any transfer pricing addition. We, therefore, order to delete the addition of Rs.26.87 crore and odd. 36. No other ground was pressed by the ld. AR. Such grounds, therefore, stand dismissed. A.Y. 2015-16 : 37. The only issue pressed in this appeal raised through Ground Nos. 1 to 6 and additional ground

GOODYEAR SOUTH ASIA TYRES PVT.LTD,,AURNAGABAD vs. ASSISTANT COMMISSIONER OF INCOME-TAX, CIRCLE - 1,, AURANGABAD

In the result, both the appeals are partly allowed

Bench: Shri R.S. Syal & Shri Partha Sarathi Chaudhuryिनधा"रण वष" / Assessment Year : 2014-15

section 92C(2) of the Act not warranting any transfer pricing addition. We, therefore, order to delete the addition of Rs.26.87 crore and odd. 36. No other ground was pressed by the ld. AR. Such grounds, therefore, stand dismissed. A.Y. 2015-16 : 37. The only issue pressed in this appeal raised through Ground Nos. 1 to 6 and additional ground

DEPUTY COMMISSIONER OF INCOME-TAX,, PUNE vs. EATON FLUID POWER LTD.,, PUNE

In the result, the appeal of Revenue for assessment year 2011-12 is dismissed being devoid of any merit

Bench: Shri Anil Chaturvedi, Am & Shri Vikas Awasthy, Jm

145, Off Mumbai-Pune Road, Pimpri, Pune – 411018 PAN : AAACV8426E ……प्रत्यथी / Respondent Assessee by : Shri Vishal Kalra Revenue by : Shri Rajeev Kumar सुनवाई की तारीख / Date of Hearing : 17-07-2018 घोषणा की तारीख / Date of Pronouncement : 15-10-2018 आदेश / ORDER PER VIKAS AWASTHY, JM : These are bunch of four cross appeals by the assessee and Revenue

DEPUTY COMMISSIONER OF INCOME-TAX vs. EATON FLUID POWER LTD.,, PUNE

In the result, the appeal of Revenue for assessment year 2011-12 is dismissed being devoid of any merit

Bench: Shri Anil Chaturvedi, Am & Shri Vikas Awasthy, Jm

145, Off Mumbai-Pune Road, Pimpri, Pune – 411018 PAN : AAACV8426E ……प्रत्यथी / Respondent Assessee by : Shri Vishal Kalra Revenue by : Shri Rajeev Kumar सुनवाई की तारीख / Date of Hearing : 17-07-2018 घोषणा की तारीख / Date of Pronouncement : 15-10-2018 आदेश / ORDER PER VIKAS AWASTHY, JM : These are bunch of four cross appeals by the assessee and Revenue

EATON FLUID POWER LTD.,,PUNE vs. DEPUTY COMMISSIONER OF INCOME-TAX,,

In the result, the appeal of Revenue for assessment year 2011-12 is dismissed being devoid of any merit

Bench: Shri Anil Chaturvedi, Am & Shri Vikas Awasthy, Jm

145, Off Mumbai-Pune Road, Pimpri, Pune – 411018 PAN : AAACV8426E ……प्रत्यथी / Respondent Assessee by : Shri Vishal Kalra Revenue by : Shri Rajeev Kumar सुनवाई की तारीख / Date of Hearing : 17-07-2018 घोषणा की तारीख / Date of Pronouncement : 15-10-2018 आदेश / ORDER PER VIKAS AWASTHY, JM : These are bunch of four cross appeals by the assessee and Revenue

EATON FLUID POWER LTD.,,PUNE vs. DEPUTY COMMISSIONER OF INCOME-TAX,,

In the result, the appeal of Revenue for assessment year 2011-12 is dismissed being devoid of any merit

Bench: Shri Anil Chaturvedi, Am & Shri Vikas Awasthy, Jm

145, Off Mumbai-Pune Road, Pimpri, Pune – 411018 PAN : AAACV8426E ……प्रत्यथी / Respondent Assessee by : Shri Vishal Kalra Revenue by : Shri Rajeev Kumar सुनवाई की तारीख / Date of Hearing : 17-07-2018 घोषणा की तारीख / Date of Pronouncement : 15-10-2018 आदेश / ORDER PER VIKAS AWASTHY, JM : These are bunch of four cross appeals by the assessee and Revenue

BEKAERT INDUSTRIES P. LTD,PUNE vs. ACIT, PUNE

In the result, appeal of the assessee is allowed as indicated above

Bench: Ms. Sushma Chowla, Jm & Shri D. Karunakara Rao, Am आयकर अपीऱ सं. / Ita No.2376/Pun/2012 यििाारण वषा / Assessment Year :2008-09 Bekaert Industries Pvt. Ltd., Amar Paradigm, Near D Mart, S.No.110/11/3, Baner Road, अऩीऱाथी/Appellant Baner, Pune - 411045 …. Pan: Aaacb8571E Vs. The Asst. Commissioner Of Income Tax, …. प्रत्यथी / Respondent Circle 1(1), Pune

145/-. Thereafter, the assessee filed revised return of income declaring similar income. The assessee was engaged in the business of manufacture of Steel Tyre Cord & Hose Reinforcement Wire. The assessee had entered into international transactions with its associated enterprises totaling ₹ 58.11 crores. The Assessing Officer thus, made reference under section 92CA(1) of the Act to the Transfer Pricing Officer

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

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

transferred from the ITO, Ward 2(2), Jalgaon to DCIT, Circle – 2, Jalgaon (now Circle – 1, Jalgaon) on 08.04.2019 as per jurisdiction. Notice u/s 142(1) of the Act on 20.05.2019 along with questionnaire asking the assessee to file certain details regarding the scrutiny assessment. Second notice u/s 142(1) of the Act was issued on 31.10.2019 requesting the assessee

RAJKAMAL STONE METAL WORKS,AMBEGAON KHURD, DIST. PUNE vs. ACIT CIRCLE 5 PUNE, PUNE

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

Bench: Shri R. K. Panda & Ms Astha Chandraassessment Year : 2017-18

price by passing necessary journal entries. 5. However, the Assessing Officer was not satisfied with the arguments of the assessee. He noted that the assessee firm and the sister concern has purchased the lands for business purpose. However, as no business was carried on in these lands, the same was transferred to the partners which amounts to a transfer resulting

PUNE MATHADI HAMAL AND OTHER MANUAL WORKERS BOARD,PUNE vs. INCOME TAX OFFICER, WARD-5(1), PUNE, PUNE

In the result, appeal of the assessee is partly allowed

Bench: Shri S.S.Godara & Dr. Dipak P. Ripoteआयकर अपील सं. / Ita No.1012/Pun/2023 िनधा"रण वष" / Assessment Year : 2018-19 Pune Mathadihamal & Other The Income Tax Manual Workers Board, V Officer, Shramashakti Bhavan, S Ward-5(1), Pune. Coomercial Plot No.1, Market Yard, Pune – 411037. Pan: Aaalp0097L Appellant/ Assessee Respondent /Revenue Assessee By Shri Vipul Joshi – Ar Revenue By Shri Ajay Kumar Keshari & Shri Rajesh Gawali– Dr’S Date Of Hearing 17/04/2024 Date Of Pronouncement 27/06/2024 आदेश/ Order Per Dr. Dipak P. Ripote, Am: This Appeal Filed By The Assessee Is Against The Orders Of Ld.Commissionerof Income Tax(Appeals)[Nfac], Under Section 250 Of The Act Dated 14.07.2023 :

145 taxmann.com 278 (Amritsar - Trib.)] (iii) Alpha Educational Trust v. DCIT (Exemption) - [2023] 150 taxmann.com 20 (Chennai - Trib.) III. Proposition 3: If an Application for Registration is not disposed off within 6 months, then same isdeemed to be accepted/approved, in terms of section 12AA(2). Sardari Lai Oberoi memorial Charitable Trust v. ITO [2005] 3 SOT 229 (Delhi)] SambandhOrganisation

ACIT, CENTRAL CIRCLE-1, NASHIK, NASHIK vs. RAJENDRA RASIKLAL SHAH, NASHIK

In the result, the appeal of the Revenue is dismissed

Bench: Dr.Manish Borad & Ms. Astha Chandraआयकर अपील सं. / Ita No.1015/Pun/2024 Assessment Year : 2013-14

price, the assessee had given up or 13 Rajendra Rasiklal Shah relinquished his right of specific performance and as consideration of relinquishing that right, the assessee was paid a sum of Rs. 6,00,000/-. The right, title and interest acquired under the agreement of sale clearly fall within the definition of capital asset (Section 2(14)). Instead of assigning

COMPUTERLAND UK LIMITED,,PUNE vs. ASSISTANT COMMISSIONER OF INCOME-TAX, (IT)-1,, PUNE

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

Bench: Shri R.S.Syal, Vp & Shri Partha Sarathi Chaudhury, Jm आयकर अपील सं. / Ita No. 2505/Pun/2017 धनधाारण वषा / Assessment Year : 2013-14 Computerland Uk Limited C/O. Ventura India Private Limited Commerzone, Building No. 2 & 7, 1St Floor, Survey No.144 & 145, Samrat Ashoka Path, Off. Airport Road, Yerwada, Pune-411 014. Pan : Aaecc4565H .......अपीलाथी / Appellant बनाम / V/S.

145, Samrat Ashoka Path, Off. Airport Road, Yerwada, Pune-411 014. PAN : AAECC4565H .......अपीलाथी / Appellant बनाम / V/s. The Assistant Commissioner of Income Tax (IT)-1, Pune. ……प्रत्यथी / Respondent Assessee by : Shri Rajendra Agiwal Revenue by : Shri Rajiv Kumar सुनवाई की तारीख / Date of Hearing : 01.12.2021 घोषणा की तारीख / Date of Pronouncement : 06.12.2021 आदेश / ORDER PER PARTHA SARATHI CHAUDHURY, JM: This

GRUPO ANTOLIN INDIA PVT. LTD., (ERSTWHILE KNOWN AS GRUPO ANTOLIN PUNE PRIVATE LIMITED),PUNE vs. DCIT, CIRCLE 1(2),, PUNE

In the result, appeal of assessee is partly allowed

Bench: Ms. Sushma Chowla, Jm & Shri Anil Chaturvedi, Am आयकर अपीऱ सं. / Ita No.299/Pun/2013 यििाारण वषा / Assessment Year : 2008-09

2,20,75,181/-. The Assessing Officer proposed the said TP adjustment in the draft assessment order, against which the assessee filed objections before the Dispute Resolution Panel (DRP), which were rejected. The DRP held that TPO had correctly observed that higher wastage was during the months of July and August, 2007 which could be 6 considered as extraordinary

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

section 143(3) r.w.s. 144C(13) of the Act by Assistant Commissioner of Income Tax, Circle-4, Pune. Brief Facts of the Case : 2. In this case the Assessee had filed return of Income on 29/11/2017 declaring a Loss of Rs.3,01,04,36,145/-. Since there Prodair Air Products India Pvt. Ltd., [A] was International transactions with the Associated