REHAU POLYMERS PVT.LTD,,PUNE vs. ASSISTANT COMMISSIONER OF INCOME-TAX, CIRCLE - 8,, PUNE

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

71,58,603/-.", "held": "The Tribunal held that the Transfer Pricing Officer (TPO) made the adjustment without adopting any prescribed method for determining the Arm's Length Price (ALP). The Tribunal relied on various High Court and Tribunal decisions stating that determining ALP without following prescribed methods is unsustainable in law.", "result": "Allowed", "sections": [ "143(3)", "144C(13)", "143(2

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

2%, as claimed by the\nrespondent assessee. This determination of ALP of technical know-how\nroyalty by the TPO was ad hoc and arbitrary as held by the CIT(A) and the\nTribunal.\n(e) In the above view, the question as proposed does not give rise to any\nsubstantial question of law. Thus, not entertained. \"...\n13. In the case

M/S KOLTE PATIL DEVELOPERS LTD,PUNE vs. DCIT,CIRCLE-7, PUNE, PUNE

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

Bench: Shri R. K. Panda & Shri Vinay Bhamoreassessment Year : 2014-15

71,500 2,91,800 05/02/2014 B5/402 Ahmadi Saifuddin Sher 33,65,500 34,00,100 34,600 Total 2,48,13,900 2,73,16,150 25,02,250 6. In appeal, the CIT(A) / NFAC following the decision of the Pune Bench of the Tribunal in the case of Rahul Constructions Vs. DIT, where it was held that

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

In the result, the appeal of the assessee is dismissed

2. Further, the assessment proceeding of the years preceding to\nAY 2019-20 (i.e. AY 2016-17 to AY 2018-19) were carried out by the\nLd. AO and the order under section 143(3) r.w.s.153A of the Act for\nthese years are duly passed. And, in all these years the query of\nunsecured loans was raised and that

DEPUTY COMMISSIONER OF INCOME TAX CENTRAL CIRCLE-2(2), PUNE vs. M/S. BILCARE LIMITED, PUNE

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

Bench: Shri Inturi Rama Rao & Shri S. S. Viswanethra Raviआयकर अपीऱ सं. / Ita No.273/Pun/2021 निर्धारण वर्ा / Assessment Year: 2016-17 Dcit, Central Circle-2(2), Vs. M/S. Bilcare Limited, Pune. 601, Icc Trade Tower, Pune- 411016. Pan : Aabcb2242F Appellant Respondent आयकर अपीऱ सं. / Ita No.334/Pun/2021 निर्धारण वर्ा / Assessment Year: 2016-17 M/S. Bilcare Limited, Vs. Dcit, Central Circle- 6Th Floor, B Wing, Icc 2(2), Pune. Trade Tower, Senapati Bapat Road, Pune- 411006. Pan : Aabcb2242F Appellant Respondent

2) or 74(1) except when the loss has not been C.O. No.14/PUN/2021 determined in pursuance of return of income filed in accordance with the provisions of sub-section (3) of section 139. 55. The Hon‟ble Delhi High Court in the case of CIT vs. Nalva Investments Ltd. in ITA No.822/2005, judgment dated 07.08.2020 in a case involving

M/S. BILCARE LIMITED,PUNE vs. DEPUTY COMMISSIONER OF INCOME TAX CENTRAL CIRCLE-2(2), PUNE

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

Bench: Shri Inturi Rama Rao & Shri S. S. Viswanethra Raviआयकर अपीऱ सं. / Ita No.273/Pun/2021 निर्धारण वर्ा / Assessment Year: 2016-17 Dcit, Central Circle-2(2), Vs. M/S. Bilcare Limited, Pune. 601, Icc Trade Tower, Pune- 411016. Pan : Aabcb2242F Appellant Respondent आयकर अपीऱ सं. / Ita No.334/Pun/2021 निर्धारण वर्ा / Assessment Year: 2016-17 M/S. Bilcare Limited, Vs. Dcit, Central Circle- 6Th Floor, B Wing, Icc 2(2), Pune. Trade Tower, Senapati Bapat Road, Pune- 411006. Pan : Aabcb2242F Appellant Respondent

2) or 74(1) except when the loss has not been C.O. No.14/PUN/2021 determined in pursuance of return of income filed in accordance with the provisions of sub-section (3) of section 139. 55. The Hon‟ble Delhi High Court in the case of CIT vs. Nalva Investments Ltd. in ITA No.822/2005, judgment dated 07.08.2020 in a case involving

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 92C(f) is considered as most appropriate method to benchmark this transaction As per Rule 10AB. the determination of ALP in relation to international transaction shall be the price which has been charged or would have been charged or paid for the same or similar uncontrolled transaction, with or between non-associated enterprises, under similar circumstances, considering

KATERRA TECHNOLOGY SERVICES LLP,PUNE vs. ASSISTANT COMMISSIONER OF INCOME-TAX, CIRCLE -2,, PUNE

In the result, appeal of the assessee is allowed

Bench: Shri Partha Sarathi Chaudhury & Shri G.D. Padmahshalikaterra Technology Services Vs Acit, Circle-2, Llp, Unit No.301 & 302, Pune. 3Rd Floor, Nextgen Avenue Building, Off Senapati Bapat Road, Shivajinagar, Bhamburda, Tq. Haveli, Pune. Pan: Aarfk 3667 L Appellant/Assessee Respondent / Revenue Assessee By : Shri Ketan Ved, Ca Revenue By : Shri Anurag Shrivastava, Cit Dr Date Of Hearing : 18/05/2023 Date Of Pronouncement : 24/05/2023 O R D E R Per Partha Sarathi Chaudhury, Jm: This Appeal Preferred By The Assessee Emanates From The Findings Of Ld.Drp-3, Mumbai-2, Dated 19.05.2022 For A.Y.2018-19 As Per The Following Grounds Of Appeal:- “The Ld. Assessing Officer ["Ao"], Ld. Transfer Pricing Officer ["Tpo"] & Hon'Ble Dispute Resolution Panel Cdrp") Erred In Law & In Fact In Assessing The Total Income Of Inr 1,71,54,680 As Against Returned Income Of Inr 88,61,750 As Computed By The Appellant In Its Return Of Income. Transfer Pricing Adjustment On Account Of The International Transaction Relating To Information Technology Enabled Services ("Ites”) - Inr 82,92,925 1. On The Facts & Circumstances Of The Case & In Law, The Order Passed Under Section 143(3) R.W.S. 144C Of The Income Tax Act, 1961 ("The Act") By The Ld.Ao Is Erroneous & Bad In Law; 2. The Ld. Ao/Tpo/ Hon'Ble Drp Has Erred In Upholding Katerra Technology Services Llp

71,54,680 as against returned income of INR 88,61,750 as computed by the Appellant in its return of income. Transfer Pricing adjustment on account of the international transaction relating to Information Technology enabled Services ("ITeS”) - INR 82,92,925 1. On the facts and circumstances of the case and in law, the order passed under section

REXEL INDIA PRIVATE LIMITED,PUNE vs. DEPUTY COMMISSIONER OF INCOME TAX, PUNE

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

price allocation exercise as at\n31/03/2015. Le. the valuation date. As noted in the foregoing\nparagraphs, Accounting Standard-14 further requires that any excess\nof the amount of the consideration over the value of net assets of the\namalgamating company acquired by the amalgamated company\nshould be recognised in the amalgamated company's financial\nstatements as goodwill on amalgamation. Therefore

INCOME TAX OFFICER, WARD - 3(1), PUNE, PUNE vs. SACHIN GOVIND APTE, PUNE

Accordingly, Grounds of appeal raised by the Revenue are dismissed

Bench: Dr.Dipak P. Ripote & Shri Vinay Bhamoreआयकर अपऩल सं. / Ita No.1720/Pun/2025 निर्धारण वषा / Assessment Years: 2013-14 The Income Tax Officer, V Sachin Govind Apte, Ward-3(1), Pune. S. 759-63, Prabhat Road, Erandwana, Pune – 411004. Pan: Aavpa9458P Appellant/ Revenue Respondent /Assessee Assessee By Ms.Vaishnavi Badwe Revenue By Shri Amit Bobde - Cit(Dr) Date Of Hearing 16/12/2025 Date Of Pronouncement 03/02/2026 आदेश/ Order Per Dr. Dipak P. Ripote, Am: This Is An Appeal Filed By The Revenue Against The Order Of Ld.Commissioner Of Income Tax(Appeal)[Nfac], Passed Under Section 250 Of The Income Tax Act, 1961 For The A.Y.2013-14 Dated 15.05.2025 Emanating From The Assessment Order Passed Under Section 143(3) Of The Act, Dated 30.03.2016. The Revenue Has Raised The Following Grounds Of Appeal : “1. Whether On The Facts & Circumstances Of The Case & In Law The Hon'Ble Cit (A) Was Justified In Deleting The Addition Of Rs.78,72,000/- Made Under Head Stcg & Disallowance Of Deduction U/S 54F Of The It. Act, 1961? 2. Whether On The Facts & Circumstances Of The Case & In Law The Hon‟Ble Cti (A) Was Justified In Deleting The Addition Of Rs.1,20,00,000/- Made On Account Of Deemed Dividend U/S Section 2(22)(E) Of The I.T. Act, 1961?

71-79 of the paper book. The said Dissolution Deed was registered on 04/03/2013. The relevant covenants of the said Dissolution Deed are reproduced here under : 1) That the partnership firm was established by the parties to these presents by virtue of the Deed of Partnership dated 04/10/2006 under the name & style of m/s Empire Ventures having its registered office

DEPUTY COMMISSIONER OF INCOME-TAX vs. THE JAWAHARLAL NEHRU PORT TRUST,, RAIGAD

In the result, all the three appeals filed by the Revenue are dismissed and all the three appeals filed by the assessee are partly allowed

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

section 43B of the Act. He similarly noted that the assessee had also made payment of Rs.6.40 crores to LIC on account of employees’ gratuity fund from the date of its incorporation till 31.03.2003 whereas the expenses for the year was only Rs.1.10 crores. Thus the assessee has made additional claim of Rs.5.30crores. According to the Assessing Officer since

JAWAHAR LAL NEHRU PORT TRUST,NAVI MUMBAI vs. ACIT PANVEL, PANVEL

In the result, all the three appeals filed by the Revenue are dismissed and all the three appeals filed by the assessee are partly allowed

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

section 43B of the Act. He similarly noted that the assessee had also made payment of Rs.6.40 crores to LIC on account of employees’ gratuity fund from the date of its incorporation till 31.03.2003 whereas the expenses for the year was only Rs.1.10 crores. Thus the assessee has made additional claim of Rs.5.30crores. According to the Assessing Officer since

DEPUTY COMMISSIONER OF INCOME-TAX vs. THE JAWAHARLAL NEHRU PORT TRUST,, RAIGAD

In the result, all the three appeals filed by the Revenue are dismissed and all the three appeals filed by the assessee are partly allowed

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

section 43B of the Act. He similarly noted that the assessee had also made payment of Rs.6.40 crores to LIC on account of employees’ gratuity fund from the date of its incorporation till 31.03.2003 whereas the expenses for the year was only Rs.1.10 crores. Thus the assessee has made additional claim of Rs.5.30crores. According to the Assessing Officer since

JAWAHAR LAL NEHRU PORT TRUST,NAVI MUMBAI vs. ACIT PANVEL, PANVEL

In the result, all the three appeals filed by the Revenue are dismissed and all the three appeals filed by the assessee are partly allowed

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

section 43B of the Act. He similarly noted that the assessee had also made payment of Rs.6.40 crores to LIC on account of employees’ gratuity fund from the date of its incorporation till 31.03.2003 whereas the expenses for the year was only Rs.1.10 crores. Thus the assessee has made additional claim of Rs.5.30crores. According to the Assessing Officer since

DEPUTY COMMISSIONER OF INCOME-TAX vs. THE JAWAHARLAL NEHRU PORT TRUST,, RAIGAD

In the result, all the three appeals filed by the Revenue are dismissed and all the three appeals filed by the assessee are partly allowed

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

section 43B of the Act. He similarly noted that the assessee had also made payment of Rs.6.40 crores to LIC on account of employees’ gratuity fund from the date of its incorporation till 31.03.2003 whereas the expenses for the year was only Rs.1.10 crores. Thus the assessee has made additional claim of Rs.5.30crores. According to the Assessing Officer since

JAWAHAR LAL NEHRU PORT TRUST,NAVI MUMBAI vs. ACIT PANVEL, PANVEL

In the result, all the three appeals filed by the Revenue are dismissed and all the three appeals filed by the assessee are partly allowed

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

section 43B of the Act. He similarly noted that the assessee had also made payment of Rs.6.40 crores to LIC on account of employees’ gratuity fund from the date of its incorporation till 31.03.2003 whereas the expenses for the year was only Rs.1.10 crores. Thus the assessee has made additional claim of Rs.5.30crores. According to the Assessing Officer since

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

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

2) and 142(1) of the Act were issued\nand served on the assessee in response to which the assessee filed the requisite\ndetails. Since the assessee has entered into certain international transactions, the\nAssessing Officer referred the matter to the Transfer Pricing Officer (TPO) for\ndetermining the Arm's Length Price (ALP) of the international transactions. The\nTPO vide

SPECTRAFORCE TECHNOLOGIES (INDIA) PRIVATE LIMITED,PUNE vs. ACIT, CIRCLE 5, PUNE, PUNE

In the result, appeal of the assessee is partly allowed for statistical purposes as per terms indicated hereinabove

Bench: Dr.Manish Borad & Ms. Astha Chandra

section 92C(3) and Rule 10B(3) are satisfied in the present case. 8. That on the facts and circumstances of the case and in law, the Ld. AO/Ld. TPO/DRP has erred in enhancing the income of Appellant by Rs. 2,90,89,437 while holding that the Appellant's international transaction pertaining to provision of Staff 8 Augmentation Service