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

250/-. Assessee is a listed company having its headquarter situated at Solapur, Maharashtra, India. 3. Assessee Company is engaged in manufacturing of camshafts for Railways and Auto Industry. Assessee‟s case was selected for scrutiny. Since there were international transactions, the case was referred to Transfer Pricing Officer(TPO) u/s.92CA of the Act, with the approval of Competent Authority.PCL International

NAV MAHARASHTRA CHAKAN OIL MILLS LTD,PUNE vs. INCOME TAX OFFICER, WARD-2(4), PUNE, PUNE

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

Bench: Dr.Dipak P. Ripote & Shri Vinay Bhamoreआयकर अपील सं. / Ita Nos.1871 & 1872/Pun/2024 िनधा"रण वष" / Assessment Years: 2013-14 & 2014-15 Nav Maharashtra Chakan Oil V The Income Tax Officer, Mills Limited, S Ward-2(4), Pune. 43, Nav Maharashtra House, Near Shaniwar Wada, Shaniwar Peth, Pune – 411030. Pan: Aaacn9941J Appellant / Assessee Respondent / Revenue Assessee By Shri Nikhil Pathak – Advocate Revenue By Shri Prakash L Pathade – Cit(Dr) Date Of Hearing 16/10/2024 Date Of Pronouncement 22/10/2024 आदेश/ Order Per Dr. Dipak P. Ripote, Am: These Are Two Appeals Filed By The Assessee Against The Two Separate Orders Of Ld.Commissioner Of Income Tax(Appeal), Pune Dated 27.07.2022 & 20.11.2023 For A.Y.2013-14 & 2014-15 Respectively. Since The Issue Involved Is Common, Both These Appeals Were Heard Together & Decided By The Common Order.

Section 250(6) of the Act, ld.CIT(A) has to state the points for determination and the reasons for his decision, meaning thereby ld.CIT(A) has to discuss the merits of the addition. In this case, assessee has raised the issue that Specified Domestic Transactions u/sec.92BA were excluded by Finance Act, 2017. Admittedly, the Transfer Pricing

NAV MAHARASHTRA CHAKAN OIL MILLS LTD.,PUNE vs. ITO WARD 2(4) PUNE, PUNE

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

Bench: Dr.Dipak P. Ripote & Shri Vinay Bhamoreआयकर अपील सं. / Ita Nos.1871 & 1872/Pun/2024 िनधा"रण वष" / Assessment Years: 2013-14 & 2014-15 Nav Maharashtra Chakan Oil V The Income Tax Officer, Mills Limited, S Ward-2(4), Pune. 43, Nav Maharashtra House, Near Shaniwar Wada, Shaniwar Peth, Pune – 411030. Pan: Aaacn9941J Appellant / Assessee Respondent / Revenue Assessee By Shri Nikhil Pathak – Advocate Revenue By Shri Prakash L Pathade – Cit(Dr) Date Of Hearing 16/10/2024 Date Of Pronouncement 22/10/2024 आदेश/ Order Per Dr. Dipak P. Ripote, Am: These Are Two Appeals Filed By The Assessee Against The Two Separate Orders Of Ld.Commissioner Of Income Tax(Appeal), Pune Dated 27.07.2022 & 20.11.2023 For A.Y.2013-14 & 2014-15 Respectively. Since The Issue Involved Is Common, Both These Appeals Were Heard Together & Decided By The Common Order.

Section 250(6) of the Act, ld.CIT(A) has to state the points for determination and the reasons for his decision, meaning thereby ld.CIT(A) has to discuss the merits of the addition. In this case, assessee has raised the issue that Specified Domestic Transactions u/sec.92BA were excluded by Finance Act, 2017. Admittedly, the Transfer Pricing

SEQUENCE DESIGN (INDIA) PRIVATE LIMITED,PUNE MAHARASHTRA vs. JOINT COMMISSIONER OF INCOME TAX CIRCLE 1(1) PUNE, PUNE

In the result, appeal of the assessee is allowed

Bench: Dr.Manish Borad & Shri Vinay Bhamoreआयकर अपील सं. / Ita No.2106/Pun/2024 Assessment Year : 2015-16

section 250 of the Act under the jurisdiction of National Faceless Appeal Centre, Delhi by ignoring CBDT Notification. He erred in not appreciating that the jurisdiction of the present appeal was with Commissioner of Income Tax (Appeals) 13, Pune as per the above notification 2. Penalty is not warranted on the adjustment

DCIT, SWARGATE vs. ELICA PB WHIRLPOOL KITCHEN APPLIANCES PRIVATE LIMITED, PUNE

In the result, appeal of the Revenue in ITA No

Bench: SHRI VINAY BHAMORE (Judicial Member)

250 of the Income Tax Act, 1961 for A.Y.2014-15both dated 19.12.2024. We treat appeal in ITA No.407/PUN/2025 as the lead case. The Revenue in ITA No.407/PUN/2025 has raised the following grounds of appeal : ITA Nos.383 & 407/PUN/2025 [R] “1) Whether on the facts and circumstances of the case the Ld. CIT(A) was right in deleting the penalty

DCIT, SWARGATE PUNE vs. ELICA PB WHIRLPOOL KITCHEN APPLIANCES PRIVATE LIMITED, PUNE

In the result, appeal of the Revenue in ITA No

Bench: the Hon'ble Tribunal which may please be granted.” Submission of ld.AR : 2. Ld.AR for the assessee submitted that Quantum Addition has been deleted by ITAT for A.Y.2014-15 in Assessee's own case in

250 of the Income Tax Act, 1961 for A.Y.2014-15both dated 19.12.2024. We treat appeal in ITA No.407/PUN/2025 as the lead case. The Revenue in ITA No.407/PUN/2025 has raised the following grounds of appeal : ITA Nos.383 & 407/PUN/2025 [R] “1) Whether on the facts and circumstances of the case the Ld. CIT(A) was right in deleting the penalty

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

Transfer Pricing Study Report and the scientific methodology adopted by the Appellant to determine hourly rates and their benchmarking with third parties using Comparable Uncontrolled Price method ("CUP") 10. That on the facts and circumstances of the case and in law, the PCIT ought to have appreciated that the provisions of section 10AA(9) read with section 80IA

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

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

250, wherein while referring to section 54 of the Transfer of Property Act, it has been held that, "sale is a transfer of ownership in exchange for a price

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

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

250, wherein while referring to section 54 of the Transfer of Property Act, it has been held that, "sale is a transfer of ownership in exchange for a price

JAGANNATH SAMBHAJI SATAV,PUNE vs. ITO WARD 12(4), PUNE, PUNE

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

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

price and therefore the profits during the relevant accounting year. The situation emerges that the assessee has received whatever consideration was due in a substantive manner and the assessee cannot be allowed to take the plea that since those cheques were dishonoured within the meaning of the agreement, the agreement is invalidated. As per provisions of section

DY. COMMISSIONER OF INCOME TAX, CIRCLE 1(1) ,PUNE, SWARGATE vs. GRUPO ANTOLIN INDIA PRIVATE LIMITED, PUNE

The appeal of the Revenue is allowed for statistical purposes in above terms

Bench: Hon’Ble Shri G. D. Padmahshali & Hon’Ble Shri Vinay Bhamoreआयकर अपऩल सं. / Ita No. 1118/Pun/2023 निर्धारण वषा / Assessment Year : 2012-13 Dy. Commissioner Of Income Tax, Central Circle-1(2), Pune . . . . . . . अपीलार्थी / Appellant

Transfer Price [in short ‘TP’] adjustment for ₹5,68,19,782/- was made in relation to consideration against ‘receipt of advisory services’. The Ld. AO accordingly incorporated the TP adjustment and framed an assessment u/s 143(3) r.w.s. 144C(3) r.w.s. 92CA(4) of the Act and assessed the taxable income at ₹3,60,52,690/- as against retuned loss

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:

250 of the Act i.e. levying penalty of INR 3,55,82,949/-. Legal grounds: 2 2. On the facts and circumstances of the case and in law, the learned AO erred in not imposing penalty based on the additions as confirmed by the learned CIT(A) in quantum appeal of the Appellant. 3. On the facts and circumstances

DEPUTY COMMISSIONER OF INCOME-TAX, CIRCLE - 5,, PUNE vs. RENISHAW METROLOGY SYSTEMS LTD,, PUNE

The appeal of the Revenue is partly allowed for statistical purposes in above terms

Bench: Hon’Ble Smt Astha Chandra, Judical Member & Shri G. D. Padmahshaliआयकर अपील सं. / Ita No. 0628/Pun/2021 िनधा"रण वष" / Assessment Year : 2013-14 Dy. Commissioner Of Income Tax, Central Circle-5, Pune . . . . . . . अपीलाथ" / Appellant

Transfer Price [in short ‘TP’] adjustment for total sum of ₹4,29,42,878/- was made in relation to (1) provision of software development ₹45,25,254/- (2) provision of sales & marketing support services ITAT-Pune Page 2 of 10 DCIT Vs Renishaw Metrology Systems Ltd. ITA No. 628/PUN/2021 AY: 2013-14 ₹1,42,00,046/- (3) management service fees

ACIT CIRCLE-12, PUNE, PUNE vs. DHIRAJ BHAUSAHEB NIKAM, PUNE

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

Bench: Shri R. K. Panda & Shri Vinay Bhamoreassessment Year : 2014-15 Acit, Circle – 12, Pune Dhiraj Bhausaheb Nikam Vs. 515/516, Purva Plaza, Sadashiv Peth, Pune – 411030 Pan: Aahpn5137C (Appellant) (Respondent) Assessee By : None Department By : Shri Deepak Kumar Kedia, Jcit (Through Virtual) Date Of Hearing : 10-02-2026 Date Of Pronouncement : 11-02-2026 O R D E R Per R.K. Panda, Vp:

section 2(47) of IT Act, 1961. In absence of any satisfactory details, the Assessing Officer was of the opinion that the entire transaction appears to be sham. 5. The Assessing Officer analyzed the share price of M/s Anukaran Commercial Enterprises Ltd and M/s. Shree Ganesh Spinners Ltd on different dates for comparison and observed that there are huge changes

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

250/-. Subsequently, ld. AO initiated the penalty proceedings by issuance of notice u/s.274 r.w.s. u/s.270A of the Act on 16.07.2021 for under reporting of income in consequence of misreporting of income. However, as per the ld.AO assessee failed to comply to the notice of hearing and ld. AO concluding the proceedings levying penalty u/s.270A

BANSAL LAND DEVELOPERS,PANVEL vs. INCOME-TAX OFFICER WARD 1, PANVEL

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

Bench: Shri R. K. Panda & Ms. Astha Chandraassessment Year : 2016-17

Price of the same is shown at Rs.1,24,07,367/- as pointed out by the Auditor in his Audit Report dated 13.10.2016. Please explain why the difference of Rs.38,69,867/- should not be included in your income as provided in section 43CA of the Income Tax Act.” 4. The assessee in response to the same filed the following

TRUMPF (INDIA) PRIVATE LIMITED,PUNE vs. INCOME TAX OFFICER, WARD 14(5), PUNE

In the result, appeal of the assessee is dismissed

Bench: Ms.Astha Chandra & Dr.Dipak P. Ripoteआयकर अपील सं./Ita No.1448/Pun/2025 िनधा"रण वष" / Assessment Year: 2010-11 Trumpf (India) Private Limited, V The Income Tax Officer, Raisoni Industrial Park, S. Ward-14(5), Pune. S.No.276, Hissa No.1, Village Mann, Taluka – Mulshi, Pune – 411057. Maharashtra. Pan: Aacct8008J Appellant/ Assessee Respondent / Revenue Assessee By Shri Abdulkadir Jawadwala– Ar(Virtual) Revenue By Shri Akhilesh Srivastva – Addl.Cit(Dr) Date Of Hearing 10/07/2025 Date Of Pronouncement 16/07/2025 आदेश/ Order Per Dr. Dipak P. Ripote, Am: The Assessee Has Filed An Appeal Against The Order Of Ld.Addl./Joint Commissioner Of Income Tax (Appeal)-12, Delhi Passed Under Section 250 Of The Income Tax Act, 1961 Dated 25.03.2025 For A.Y.2010-11, Emanating From The Order U/S.143(3) Of The Act, Dated 03.11.2024. The Assessee Has Raised The Following Grounds Of Appeal :

section 250 of the Income Tax Act, 1961 dated 25.03.2025 for A.Y.2010-11, emanating from the order u/s.143(3) of the Act, dated 03.11.2024. The Assessee has raised the following grounds of appeal : ITA No.1448/PUN/2025 [A] “1. General: The learned DCIT erred in law and on the facts and in circumstances of the case in making an addition/disallowance

MARUTI NIVRUTTI BHUJBAL,PUNE vs. ITO, WARD 14(1), PUNE, PUNE

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

Bench: Dr.Manish Borad

250 of the Income Tax Act, 1961 dated 31/12/2024 and order under section 143(3) read with section 147 of the Income Tax Act, 1961 dated 28/12/2011 passed by the learned Income Tax Officer, Ward 1(3), Pune which need to be cancelled and relief sought by the Assessee should be granted 3. The learned CIT(A) has erred

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 :

250 of the Act dated 14.07.2023 : Submission of Authorised Representative (ld.AR) for Assessee: 2. The ld.AR submitted written submissions, relevant part of the same is reproduced here as under : Pune Mathadi Hamal and Other Manual Workers Board [A] The board is a welfare authority constituted by Govt, of Maharashtra. The board is constituted by Govt, of Maharashtra in terms