KNORR-BREMSE TECHNOLOGY CENTRE INDIA PRIVATE LIMITED,PUNE vs. DY. CIT, CIRCLE-14,, PUNE

Appeal is dismissed

Bench: Shri R.S.Syal, Vp & Shri Partha Sarathi Chaudhury, Jm Assessment Year: 2015-16

transfer pricing adjustment as per the rectified order of Rs.2,93,74,360. 10. Incorrect levy of interest under section 234A of the Act Erred on the facts and in law by levying interest under section 234

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

Appeal is allowed in above terms

Bench: Shri S. S. Godara & Shri Dr. Dipak P. Ripoteआयकर अपील सं. / Ita No.1207/Pun/2017 िनधा"रण वष" / Assessment Year: 2009-10 Grupo Antolin India Private Vs. Dcit, Circle-1(2), Pune. Limited, B 25, Midc, Ranjangaon, Taluka: Shirur, Pune- 412220. Pan : Aaaca6730G Appellant Respondent Assessee By : Shri J. D. Mistri Revenue By : Shri Piyush Kumar Singh Yadav Date Of Hearing : 22.09.2022 Date Of Pronouncement : 13.10.2022 आदेश / Order Per S. S. Godara, Jm: This Assessee’S Appeal For Assessment Year 2009-10 Arises Against The Cit(A)- 13, Pune’S Order Dated 10.02.2017 Passed In Case No. Pn/Cit(A)-13/Dcit, Circle-1(2), Pune/45/2013-14/606 Involving Proceedings U/S 143(3) R.W.S. 144C(1) Of The Income Tax Act, 1961; In Short “The Act”. Heard Both The Parties. Case File Perused. 2. The Assessee Pleads The Following Substantive Grounds In The Instant Appeal :-

transfer pricing 8 adjustment representing the entire sum of Rs.3.66 crores which stands upheld in the CIT(A)’s order. 10. We have given our thoughtful consideration to vehement arguments against and in support of the impugned addition. Learned senior counsel explained the assessee’s arrangement with its group entities in light of the service agreement dated 02.10.2003 as well

DEPUTY DIRECTOR OF INCOME-TAX vs. SCHLUMBERGER GLOBAL SUPPORT CENTRE LTD.,, PUNE

In the result, appeal of Revenue is dismissed and appeal of assessee is disposed of as indicated above

Bench: Ms. Sushma Chowla, Jm & Shri Anil Chaturvedi, Am आयकर अपीऱ सं. / Ita No.1264/Pun/2015 नििाारण वषा / Assessment Year : 2011-12 The Deputy Director Of Income Tax अऩीऱाथी / Appellant (International Taxation), Circle-2, Pune. … बिाम / V/S. M/S. Schlumberger India Technology Centre Pvt. Ltd., (Formerly Known As Schlumberger Global Support Centre Ltd.-India Branch) Office No. 701, 7Th Floor, Bldg. No. 9, Commerzone, Survey No.144/145, Samrat Ashok Path, Off Air Port Road, Yerwada, … प्रत्यथी / Respondent Pune-411 006. Pan :Aalcs2048C आयकर अपीऱ सं. / Ita No.1280/Pun/2015 नििाारण वषा / Assessment Year : 2011-12 M/S. Schlumberger India Technology Centre Pvt. Ltd., (Formerly Known As Schlumberger Global Support Centre Ltd.-India Branch) Office No. 701, 7Th Floor, Bldg. No. 9, Commerzone, Survey No. 144/145, Samrat Ashok Path, Off Air Port Road, Yerwada, अऩीऱाथी / Appellant Pune-411 006. … Pan :Aalcs2048C बिाम / V/S. The Joint Director Of Income Tax, … प्रत्यथी / Respondent (International Taxation), Pune. A.Y. 2011-12

Section 234 B of the Act. 5. The learned Authorized Representative for the assessee pointed out that the only issue raised by the Revenue is against exclusion of functionally comparable companies only on the basis of turnover i.e. Infosys BPO. He further pointed out that the CIT(A) had directed the Assessing Officer / Transfer Pricing

M/S. SCHLUMBERGER INDIA TECHNOLOGY CENTRE PVT. LTD.,,PUNE vs. JOINT DIRECTOR OF INCOME-TAX,,

In the result, appeal of Revenue is dismissed and appeal of assessee is disposed of as indicated above

Bench: Ms. Sushma Chowla, Jm & Shri Anil Chaturvedi, Am आयकर अपीऱ सं. / Ita No.1264/Pun/2015 नििाारण वषा / Assessment Year : 2011-12 The Deputy Director Of Income Tax अऩीऱाथी / Appellant (International Taxation), Circle-2, Pune. … बिाम / V/S. M/S. Schlumberger India Technology Centre Pvt. Ltd., (Formerly Known As Schlumberger Global Support Centre Ltd.-India Branch) Office No. 701, 7Th Floor, Bldg. No. 9, Commerzone, Survey No.144/145, Samrat Ashok Path, Off Air Port Road, Yerwada, … प्रत्यथी / Respondent Pune-411 006. Pan :Aalcs2048C आयकर अपीऱ सं. / Ita No.1280/Pun/2015 नििाारण वषा / Assessment Year : 2011-12 M/S. Schlumberger India Technology Centre Pvt. Ltd., (Formerly Known As Schlumberger Global Support Centre Ltd.-India Branch) Office No. 701, 7Th Floor, Bldg. No. 9, Commerzone, Survey No. 144/145, Samrat Ashok Path, Off Air Port Road, Yerwada, अऩीऱाथी / Appellant Pune-411 006. … Pan :Aalcs2048C बिाम / V/S. The Joint Director Of Income Tax, … प्रत्यथी / Respondent (International Taxation), Pune. A.Y. 2011-12

Section 234 B of the Act. 5. The learned Authorized Representative for the assessee pointed out that the only issue raised by the Revenue is against exclusion of functionally comparable companies only on the basis of turnover i.e. Infosys BPO. He further pointed out that the CIT(A) had directed the Assessing Officer / Transfer Pricing

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 Officer.\n\n1.1 The TPO erred on facts and in law in rejecting the Transfer Pricing documentation (TP Study) maintained by the Assessee stating that

KOSO INDIA PVT.LTD,,NASHIK vs. DEPUTY COMMISSIONER OF INCOME-TAX, CIRCLE - 1,, NASHIK

In the result, the appeal is partly allowed for statistical

Bench: Shri R.S. Syal & Shri Partha Sarathi Chaudhuryआयकर अपील सं. / Ita No.3044/Pun/2017 िनधा"रण वष" / Assessment Year : 2013-14 Koso India Private Limited, Vs. Dcit, Circle-1 H-33 & 34, Midc, Ambad, Nashik Nashik – 422 010 Pan : Aacck3621N Appellant Respondent

234 of the paper book. Such calculation of the margins was accepted by the TPO, who computed the transfer pricing adjustment by considering such working capital adjusted margins of the three comparables. The assessee did not assail such working capital adjustment before the DRP, which was, in fact, accepted by the 5 Koso India Private Limited TPO himself. Ex consequenti

IMERYS NEWQUEST (INDIA) P. LTD.,,PUNE vs. DEPUTY COMMISSIONER OF INCOME-TAX,,

In the result, appeal of the assessee is partly allowed in the terms aforesaid

Bench: Shri Anil Chaturvedi, Am & Shri Vikas Awasthy, Jm आयकर अपील सं. / Ita No. 590/Pun/2015 "नधा"रण वष" / Assessment Year : 2010-11

234 Imerys Singapore For Use TNMM of Technology and Know how 6 Reimbursement of 7,58,793 NA Expenses To Imerys Singapore. Total 24,16,37,889 3. The assessee adopted CUP as the most appropriate method to benchmark its international transaction except payment of royalty. To benchmark the royalty paid to Imerys Singapore for use of technology and know

JAIN IRRIGATION SYSTEMS LTD,,JALGAON vs. DEPUTY COMMISSIONER OF INCOME-TAX, CIRCLE - 2,, JALGAON

Appeal is partly allowed in above terms

Bench: Shri S.S.Godara & Dr.Dipak P.Ripoteआयकरअपीलसं. / Ita No.227/Pun/2018 िनधा"रणवष" / Assessment Year : 2013-14 Jain Irrigation Systems Ltd., The Deputy Commissioner Of Jain Plastic Park, N.H No.6, Vs Income Tax, Circle-2, Jalgaon – 425001. . Jalgaon. Pan: Aaacj 7163 Q Appellant/ Assessee Respondent /Revenue Assessee By Shri Percy Pardiwala; Shri Prashant Maheshwari & Ms.Monicamulchandani – Ar’S Revenue By Shri B Koteswara Rao – Dr Date Of Hearing 23/09/2022 Date Of Pronouncement 22/12/2022 आदेश/ Order Per S.S.Godara, Jm: This Assessee’Sappeal For Assessment Year 2013-14Is Directed Against Thedeputy Commissioner Of Income Tax, Cricle-2, Jalgaon’S Assessment Order Dated 29.10.2017, Framed In Furtherance To The Dispute Resolution Panel-3, Mumbai (Drp)’S Direction Dated 25.09.2017 Passed In Objection No.78, In Proceedings U/S 143(3) R,.W.S 144C(5) Of The Income Tax Act, 1961 [In Short “The Act”].

Transfer Pricing matters 5. Related Party Transactions 5.1 On the facts and in the circumstances of the case and in law, the learned AO/the Hon’ble DRP have erred in disallowing the interest of Rs. 68,40,000/-, calculated at the ad-hoc rate of 12% on the interest free securitydeposits given to related parties in relation to two flats

MS IMSOFER MANUFACTURING INDIA PRIVATE LIMITED (NOW KNOWN AS FERRERO INDIA PRIVATE LIMITED),PUNE vs. DEPUTY COMMISSIONER OF INCOME TAX, CIRCLE 1(1)– PUNE AND NATIONAL FACELESS ASSESSMENT CENTRE, DELHI, PUNE AND NFAC (DELHI)

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

Bench: Shri R. K. Panda & Shri Vinay Bhamoreआयकर अपील सं. / Ita No.1316/Pun/2024 िनधा"रण वष" / Assessment Year : 2012-13 M/S. Imsofer Manufacturing Vs. Dcit, Circle-1(1), Pune. India Private Limited (Now Known As Ferrero India Private Limited), World Trade Center, 8Th Floor, Tower-3, Kharadi- 411014. Pan : Aabci6450N Appellant Respondent Assessee By : Shri Siddhesh Chaugule & Nagma Gupta Revenue By Shri Amol Khairnar : Date Of Hearing : 18.12.2024 Date Of Pronouncement : 11.03.2025 आदेश / Order Per Vinay Bhamore, Jm: This Appeal Filed By The Assessee Is Directed Against The Order Dated 16.04.2024 Passed By Ld. Cit(A)/Nfac For The Assessment Year 2012-13. 2. The Appellant Has Raised The Following Grounds Of Appeal :- “General Grounds: 1. On The Facts & Circumstances Of The Case & In Law, The Hon. Cit(A) Has Erred In Passing Order Under Section 250 Of The Act I.E. Levying Penalty Of Inr 3,55,82,949/-. Legal Grounds:

transfer pricing (TP) Audit, the erstwhile TPO, proposed an adjustment of Rs.17,64,79,234/- on account of import of raw material and other transaction (Manufacturing segment) and an adjustment of Rs.2,03,65,830/- on account of availability of consultancy services (Receipts of service) in his TP order dated 24th Oct 2016. Hence, a total TP adjustment of Rs.19

M/S. T - 3 ENERGY SERVICES INDIA PVT. LTD.,,PUNE vs. JOINT COMMISSIONER OF INCOME-TAX,,

In the result, appeal of assessee is allowed

Bench: Ms. Sushma Chowla, Jm & Shri Anil Chaturvedi, Am आयकर अपीऱ सं. / Ita No.826/Pun/2015 यििाारण वषा / Assessment Year : 2010-11 M/S. T-3 Energy Services India Pvt. Ltd., D-Ii/65-1, Midc, Telco Road, अऩीऱाथी/Appellant Chinchwad, Pune – 411019 …. Pan: Aacct9805F Vs. The Jt. Commissioner Of Income Tax, …. प्रत्यथी / Respondent Range – 10, Pune

Transfer Pricing Officer (TPO) for computing arm's length price in respect of international transactions entered into by the assessee with its associated enterprises. The TPO vide order dated 10.10.2013 under section 92CA(3) of the Act accepted international transactions of assessee at ₹ 19,48,32,921/- with its associated enterprises to be at arm's length. The Assessing Officer

CARRARO INDIA PVT.LTD,,PUNE vs. DEPUTY COMMISSIONER OF INCOME-TAX, CIRCLE - 1(1),, PUNE

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

Bench: Ms. Sushma Chowla, Jm & Shri D. Karunakara Rao, Am आयकर अपील सं. / Ita No.15/Pun/2018 िनधा"रण वष" / Assessment Year : 2006-07 Carraro India Pvt. Ltd., B-2/2, Midc, Ranjangaon, Pune-412210. अपीलाथ"/Appellant Pan : Aaacc5292M …. Vs. Dcit, Circle-1(1), …. ""थ" / Respondent Pune. Assessee By : Shri Rajendra Agiwal Revenue By : Shri Amol Kamal सुनवाई क" तारीख / घोषणा क" तारीख / Date Of Hearing : 19.06.2019 Date Of Pronouncement: 17.07.2019 आदेश / Order Per D. Karunakara Rao, Am : This Appeal Is Filed By The Assessee Against The Order Of The Assessing Officer/Tpo/Drp For The Assessment Year 2006-07. 2. The Assessee Raised 16 Grounds In Its Appeal. Grounds No.2 To 11 Relate To The Tp Adjustments. Grounds No.1 & 12 To 16 Relate To Other Non-Tp/General/Consequential Issues. 3. Referring To Various Tp Related Grounds In This Appeal, Ld. Counsel For The Assessee Submitted That The Apparent Typographical Mistakes In The Pli-Related Calculations Are Corrected & The Benefits Of +/-5% Available U/S 92C(2) Of The Act Are Granted, The Assessee Is At Home & No Addition

Transfer Pricing Officer, the Assessing Officer made a draft assessment order u/s. 143(3) r.w.s. 144C(1) of the Income-tax Act, 1961 dated 30/11/2009 by incorporating the said adjustments. In the draft assessment order, the Assessing Officer proposed addition of Rs.4,73,14,991/-. In the said order, other Non-TP additions on account of (i) Prior period expenditure

FRANCOIS COMPRESSOR INDIA PVT.LTD,,PUNE vs. DEPUTY COMMISSIONER OF INCOME-TAX, CIRCLE - 1(2),, PUNE

In the result, the appeal filed by the assessee stands partly allowed for statistical purposes

Bench: Shri Inturi Rama Rao, Am & Shri Partha Sarathi Chaudhury, Jm आयकर अपील सं. / Ita No.2504/Pun/2017 िनधा"रण वष" / Assessment Year : 2013-14 ………. अपीलाथ" / Francois Compressor India Pvt. Ltd., Gat No.147/1(New), Lavale Road, Appellant Pirangut, Tal. Mulshi, Dist. Pune – 412115. Pan : Aabcf0496K. बनाम V/S ………. ""यथ" / The Dy.Commissioner Of Income Tax, Circle 1 (2), Pune. Respondent Assessee By : Shri Sharad Shah. Revenue By : Shri Amol Kamat. सुनवाई क" तारीख / Date Of Hearing : 05.08.2021 घोषणा क" तारीख / Date Of Pronouncement : 18.08.2021 आदेश / Order Per Inturi Rama Rao, Am: This Is An Appeal Filed By The Assessee Directed Against The Final Assessment Order Dt.31.08.2017 Passed Under Sec.143(3) R.W.S. 144C(13) Of The Income Tax Act, 1961 (Hereinafter Referred To “The Act”) For The Assessment Year 2013-14. 2. The Brief Facts Of The Case Are As Under : The Appellant Is A Company Incorporated Under The Provisions Of The Companies Act, 1956. It Is Engaged In The Business Of Development & Sale

234 TNMM Belgium. (Import) 7 Ateliers Francois SA, Purchase of Capital 3,44,961 CUP Belgium. Goods 8 Moteurs et-Francois, Interest on External 9,46,705 CUP Belgium Commercial Borrowing (Euro) Moteurs et-Francois, 9 Interest on External 95,68,678 CUP Commercial Belgium Borrowings (USD) Moteurs et-Francois, 10 External 1,65,18,000 CUP Commercial Belguim Borrowings

AVINASH DATTATRAY MULEY,PUNE vs. PCIT, PUNE, PUNE

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

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

Transfer Pricing Officer, as the case may be, shall be deemed to be erroneous in so far as it is prejudicial to the interests of the revenue, if, in the opinion of the Principal [Chief Commissioner or Chief Commissioner or Principal) Commissioner or Commissioner,- (a) the order is passed without making inquiries or verification which should have been made

ARTH FOUNDATION,NASHIK vs. COMMISSIONER OF INCOME TAX (EXEMPTION), PUNE, PUNE

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

Bench: Dr.Dipak P. Ripote & Shri Vinay Bhamoreआयकर अपऩल सं. / Ita No.2258/Pun/2025 निर्धारण वषा / Assessment Year: 2026-27 Arth Foundation, V Commissioner Of Income Flat No.3, Tulip Apartment, S Tax (Exemption), Pune. Suyojit Garden, Gangapur Road, Nashik – 422013. Pan: Aahta2324C Appellant/ Assessee Respondent / Revenue Assessee By Ca Trishala R Jain (Virtual) Revenue By Shri Amol Khairnar – Cit(Dr) Date Of Hearing 21/01/2026 Date Of Pronouncement 29/01/2026 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), Passed Under Section 80G Of The Income Tax Act, 1961 Dated 01.08.2025. The Assessee Has Raised The Following Grounds Of Appeal : ―1. The Learned Cit(E), Pune Has Erred In Rejecting The 1 Application Of The Appellant Trust Filed U/S 80G(5)(Iii) Of The Act Without Considering The Merits Of The Case.

234, the other in Indian Chamber of Commerce v. CIT [1975] 101 ITR 796 and the third in Addl. CIT v. Surat Art Silk Cloth Manufacturers Association [1980] 121 ITR l/[1980] 2 Taxman 501, where the speech made by the Finance Minister, while introducing the exclusionary clause in section 2(15) of the Act, was relied upon

MANJREKAR FOUNDATION,PUNE vs. CIT, EXEMPTION, PUNE, PUNE

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

Bench: Dr.Dipak P. Ripote & Shri Vinay Bhamoreआयकर अपऩल सं. / Ita No.2338/Pun/2025 निर्धारण वषा / Assessment Year: - Manjrekar Foundation, V Cit Exemption, Near Goodluckchowk, Decan S Pune. Gymkhana, Bhandarkar Road, Deccan Gymkhana, Pune – 411004. Pan: Aactm7144D Appellant/ Assessee Respondent / Revenue Assessee By Smt Deepa Khare Revenue By Shri Amol Khairnar – Cit(Dr) Date Of Hearing 22/01/2026 Date Of Pronouncement 27/01/2026 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), Passed Under Section 80G Of The Income Tax Act, 1961 Dated 30.08.2025. The Assessee Has Raised The Following Grounds Of Appeal : ―1. The Ld. Cit Exemption Erred In Law & On Facts In Treating The Application Under Clause (Iii) Of First Proviso To Sub-Section (5) Of Section 80G As Non- Maintainable On The Ground Of Being Filed Beyond The Statutory Period As Provided In Clause (Iii) Of First Proviso To Section 80G (5) & Thereby Rejecting The Same Without Going Into The Merits.

234, the other in Indian Chamber of Commerce v. CIT [1975] 101 ITR 796 and the third in Addl. CIT v. Surat Art Silk Cloth Manufacturers Association [1980] 121 ITR l/[1980] 2 Taxman 501, where the speech made by the Finance Minister, while introducing the exclusionary clause in section 2(15) of the Act, was relied upon

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

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

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

234, the other in Indian Chamber of Commerce v. CIT [1975] 101 ITR 796 and the third in Addl. CIT v. Surat Art Silk Cloth Manufacturers Association [1980] 121 ITR l/[1980] 2 Taxman 501, where the speech made by the Finance Minister, while introducing the exclusionary clause in section 2(15) of ITA No.613/PUN/2025 [A] the Act, was relied

BRAHMAN SABHA KARVEER,MAHARASHTRA vs. CIT EXEMPTION PUNE, CIT EXEMPTION PUNE

In the result, appeal of the assessee is allowed for

Bench: Shri Rama Kanta Panda & Shri Satbeer Singh Godara

234, the other in Indian Chamber of Commerce v. CIT [1975] 101 ITR 796 and the third in Addl. CIT v. Surat Art Silk Cloth Manufacturers Association [1980] 121 ITR l/[1980] 2 Taxman 501, where the speech made by the Finance Minister, while introducing the exclusionary clause in section 2(15) of the Act, was relied upon

HERITAGE YOUTH FOUNDATION,ICHALKARANJI vs. CIT, EXEMPTION PUNE, PUNE

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

Bench: Shri S.S.Godara & Dr. Dipak P. Ripoteआयकर अपील सं. / Ita No.579/Pun/2024 िनधा"रण वष" / Assessment Year : - Heritage Youth Foundation, V The Commissioner Of C/O.Kamlesh Laddha, Plot S Income Tax-Exemption, No.11, Near Arvind Process Pune. Industrial Estate, Ichalkaranji, Maharashtra – 416115. Pan: Aacah5120M Appellant / Assessee Respondent / Revenue Assessee By None Revenue By Shri Keyur Patel – Dr Date Of Hearing 12/06/2024 Date Of Pronouncement 19/06/2024 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 16.02.2024. The Ld.Cit(E) Dismissed The Application Of The Assessee On The Ground That The Application Is Time Barred. The Assessee Has Raised Following Grounds Of Appeal : “1. The Id Cit Exemption Erred In Law & On Facts In Treating The Application Under Clause (Iii) Of First Proviso To Sub-Section (5) Of Section 80G As Non- Maintainable On The Ground Of Being Filed Beyond Heritage Youth Foundation [A]

234, the other in Indian Chamber of Commerce v. CIT [1975] 101 ITR 796 and the third in Addl. CIT v. Surat Art Silk Cloth Manufacturers Association [1980] 121 ITR l/[1980] 2 Taxman 501, where the speech made by the Finance Minister, while introducing the exclusionary clause in section 2(15) of the Act, was relied upon