DCIT CIRCLE 8 , PUNE vs. MAHLE ANAND THERMAL SYSTEMS PVT. LTD, PUNE

In the result, the appeal and the CO filed by the assessee are partly allowed and the appeals filed by the Revenue are dismissed

Bench: Shri R. K. Panda & Ms. Astha Chandraassessment Year : 2014-15

Transfer Pricing Officer (TPO) for determining the arm’s length price (ALP) of the international transactions. The TPO accepted the transaction of Payment of R&D expenses at ALP. In the computation of total income, the assessee had claimed weighted deduction u/s.35(2AB) of the Act amounting to Rs.26,73,42,263/- on Research and development expenses. The assessee

DCIT,CIRCLE-8 , PUNE vs. MAHALE ANAND THERMAL SYSTEMS PVT. LTD. , PUNE

In the result, the appeal and the CO filed by the assessee are partly allowed and the appeals filed by the Revenue are dismissed

Bench: Shri R. K. Panda & Ms. Astha Chandraassessment Year : 2014-15

Transfer Pricing Officer (TPO) for determining the arm’s length price (ALP) of the international transactions. The TPO accepted the transaction of Payment of R&D expenses at ALP. In the computation of total income, the assessee had claimed weighted deduction u/s.35(2AB) of the Act amounting to Rs.26,73,42,263/- on Research and development expenses. The assessee

MAHLE ANAND THERMAL SYSTEMS PRIVATE LIMITED,PUNE vs. DY COMMISSIONER OF INCOME TAX, PUNE

In the result, the appeal and the CO filed by the assessee are partly allowed and the appeals filed by the Revenue are dismissed

Bench: Shri R. K. Panda & Ms. Astha Chandraassessment Year : 2014-15

Transfer Pricing Officer (TPO) for determining the arm’s length price (ALP) of the international transactions. The TPO accepted the transaction of Payment of R&D expenses at ALP. In the computation of total income, the assessee had claimed weighted deduction u/s.35(2AB) of the Act amounting to Rs.26,73,42,263/- on Research and development expenses. The assessee

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

251 CUP TNMM (finished goods) 3. Purchase of Non-clonable ID tags, 24,73,743 Other TNMM reader and applicator Method 4. Sale of clinical supplies 18,45,660 Other TNMM Method 5. Lease of PVdC Coating Machine 8,75,00,000 CUP TNMM 6. Loan Guarantee Given Nil Other Other Method Method 7. Performance Guarantee Given Nil Other Other

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

251 CUP TNMM (finished goods) 3. Purchase of Non-clonable ID tags, 24,73,743 Other TNMM reader and applicator Method 4. Sale of clinical supplies 18,45,660 Other TNMM Method 5. Lease of PVdC Coating Machine 8,75,00,000 CUP TNMM 6. Loan Guarantee Given Nil Other Other Method Method 7. Performance Guarantee Given Nil Other Other

DCIT, CIRCLE-8, PUNE vs. MAHLE ANAND THERMAL SYSTEMS PVT. LTD., PUNE

2), it is manifested that any expenditure of capital nature incurred on scientific research, other than the cost of land etc., qualifies for full one time deduction in the year of such incurring. Unlike sub-section (2AB), sub-section (1) does not require any specific approval from the prescribed authority for this purpose. Further, there is no stipulation that

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

251/- for A.Y. 2016-17 is upheld.\nAccordingly, this ground of appeal is dismissed.\"\n4.1 Before the Ld. CIT(A), the assessee also challenged non-granting of\nbrought forward business loss allowance and unabsorbed depreciation\naggregating to Rs.4,74,83,007/- incurred by the assessee in earlier years.\nThe assessee also preferred an appeal against the action

MAHLE BEHR INDIA PVT. LTD.,,PUNE vs. DEPUTY COMMISSIONER OF INCOME-TAX,, PUNE

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

Transfer Pricing\nOfficer (TPO) for determining the arm's length price (ALP) of the international\ntransactions. The TPO accepted the transaction of Payment of R&D expenses at\nALP. In the computation of total income, the assessee had claimed weighted\ndeduction u/s.35(2AB) of the Act amounting to Rs.26,73,42,263/- on Research and\ndevelopment expenses. The assessee

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

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

251/- which is duly recorded in the books of account has been offered as ‘business income’ However, due to other expenditure incurred during the year the net income is declared as Nil on account of brought forward losses. However, during the course of assessment proceedings, assessee has suo motu filed the revised computation of income and the profit from sale

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:

251 (1)(b) of the Act. Non-levy of penalty under section 271(1)(c); 2. On the facts and circumstances of the case and in law, the Hon'ble ITAT has heard the quantum appeal of the appellant. Accordingly, as per the section 275(1)(A), learned AO be directed to impose penalty based on the order

DY. COMMISSIONER OF INCOME TAX, CIRCLE-1(1), PUNE, PUNE vs. BANK OF MAHARASHTRA, PUNE

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

transferred.\n(c) On the applicability of circulars instructions the Hon'ble Supreme Court in the case of \"Catholic Syrian Bank Ltd vs CIT(supra), has held that under section 119 of the Act, the CBDT is entitled to issue Circulars to explain or tone down the rigours of law and to ensure fair enforcement of its provisions. These circulars

BANK OF MAHARASHTRA ,PUNE vs. ASST COMMISSIONER OF INCOME TAX, CIRCLE 1(1), PUNE, PUNE

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

Bench: Shri R. K. Panda & Shri Vinay Bhamoreassessment Year : 2016-17

251(1)(a) of the Act and send the matter back to the AO for verification on the issue of disallowance of write back provision for standard assets amounting to Rs.31,14,41,362/-. 4) On the facts and the circumstances and in law, the ld CIT(A) erred in not appreciating the fact that the assessee had failed

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

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

KAPIL ALCOTECH LLP,AURANGABAD vs. DEPUTY COMMISSIONER OF INCOME TAX CIRCLE - 1, AURANGABAD

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

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

251 1,16,010.00 80,350.00 35,660.00 01/04/2019 Radico NV Distilleries Maharashtra Ltd. Journal 254 1,77,996.00 75,000.00 1,02,996.00 01/04/2019 Radico NV Distilleries Maharashtra Ltd. Journal 255 1,70,669.00 1,31,250.00 39,419.00 01/04/2019 Allied Blenders and Distillers Pvt. Ltd Journal 256 1,31,730.00 61,300.00 70,430.00 01/04/2019 Good Drop Wine

MR SHAIKH SHAKIL SHAIKH IBRAHIM BAGWAN,JALGAON vs. ITO, WRD-1(4), JALGAON, JALGAON

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

Bench: Dr. Manish Borad & Shri Vinay Bhamoreआयकर अपील सं. / Ita No.2160/Pun/2025 धििाारण वर्ा / Assessment Year: 2017-18 Mr. Shaikh Shakil Shaikh Vs Ito, Ward-1(4), Ibrahim Bagwan, Jalgaon Prop. Of Javed Vegetable Company (Jvc), Barbhai Galli, Bodwad-425310, Dist-Jalgaon Maharashtra Pan-Attpb3077C Appellant Respondent

251 of the Income-tax Act, 1961 dated 06.08.2025 which is arising out of Order passed u/s.147 of the Act dated 07.03.2025. 2. Assessee has raised following grounds of appeal:- 1. On the facts and in the circumstances of the case and in law, the Id. CIT(A), has erred in upholding the action of the AO in making