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

26,689\n2\nRehau Polymers (Suzhou) Co. Ltd.\n76,01,305\n3\nRehau AG\n3,89,30,609\nTotal\n6,71,58,603\n5. The TPO asked the assessee to justify the ALP computed in respect of\ninternational transactions. From the details / documents / information furnished by\nthe assessee, the TPO noted that the assessee has not been able to specify

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

26, 27, Bhosari\nMIDC, Pune-411026\nPAN: AAACL1978K\nअपीलार्थी / Appellant\nAsst. Commissioner of\nIncome Tax,\nVs.\nCircle – 8, Pune\nप्रत्यर्थी / Respondent\nAssessee by :\nShri Dhanesh Bafna &\nMiss Riddhi Maru\nDepartment by :\nShri Prakash L. Pathade\nDate of hearing :\n23-07-2025\nDate of\nPronouncement :\n10-10-2025\nआदेश / ORDER\nPER ASTHA CHANDRA, JM :\nThe appeal filed by the assessee

QUBIX BUSINESS PARK PRIVATE LIMITED,PUNE vs. DEPUTY COMMISSIONER OF INCOME TAX, CIRCLE-8, PUNE, PUNE

In the result, Ground No.2 of the assessee is allowed for statistical purpose

Bench: DR.DIPAK P. RIPOTE (Accountant Member), SHRI VINAY BHAMORE (Judicial Member)

Transfer Pricing Officer under sub- Section (3) of Section 92CA and even under Section 144C(8). The DRP may confirm, reduce or enhance the variations proposed in the draft order and wherefore the word eligible assessee in Clause (1) and (15) and the proposed draft order referred to under Clause 144c(1) and (8) will have to be given full

CAPGEMINI TECHNOLOGY SERVICES INDIA LIMITED ( SUCCESSOR OF ARICENT TECHNOLOGIES HOLDINGS LIMITED),PUNE vs. ASSISTANT COMMISSIONER OF INCOME TAX - CIRCLE 1(1), PUNE

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

Bench: Ms.Astha Chandra & Dr.Dipak P. Ripoteआयकर अपील सं. / Ita No.2804/Pun/2024 िनधा"रण वष" / Assessment Year: 2021-22 Capgemini Technology V The Assistant Services India Limited[As S Commissioner Of Income Successor In Interest Of Tax-1(1)(1), Pune. Erstwhile Aricent Technologies (Holdings) Limited-Since Amalgamated], Plot No.14, Rajiv Gandhi Infotech Park, Hinjewadi, Phase-Iii, Midc Sez, Village Man, Taluka Mulshi, District- Pune – 411057. Maharashtra. Pan: Aacck8280B Appellant/ Assessee Respondent / Revenue Assessee By Shri Nikhil Pathak – Ar Revenue By Shri Prakash L Pathade –Cit(Dr) Date Of Hearing 19/06/2025 Date Of Pronouncement /06/2025 आदेश/ Order Per Dr. Dipak P. Ripote, Am: This Is An Appeal Filed By The Assessee Against The Assessment Order Under Section 143(3) R.W.S 144C(13) Of The Income Tax Act, 1961 Dated 29.10.2024 For The A.Y.2021-22, Emanating From The

section 29288 of the Act in our ITA No.2804/PUN/2024 [A] opinion cannot come to the rescue of the TPO this being a jurisdictional issue Since in the instant case, despite number of letters addressed by the assessee to the TPO to drop the proceedings on the ground that the same are being proposed on a non-existing company

DCIT, SWARGATE PUNE vs. CUMMINS INDIA LTD , PUNE

In the result, appeal of the assessee bearing ITA No

transfer pricing purposes in seven\n(7) earlier years in view of inter alia binding order of the\nTribunal?\n(iii) Whether in the facts and in the circumstances of the\ncase and in law the Tribunal erred in passing the\nimpugned order dated 28th September 2022 purporting\nto rely on decision of Delhi High Court in the case

CUMMINS INDIA LIMITED,,PUNE vs. ASSISTANT COMMISSIONER OF INCOME-TAX, CIRCLE - 1(1),, PUNE

In the result, appeal of the assessee bearing ITA No

transfer pricing purposes in seven\n(7) earlier years in view of inter alia binding order of the\nTribunal?\n\n(iii) Whether in the facts and in the circumstances of the\ncase and in law the Tribunal erred in passing the\nimpugned order dated 28th September 2022 purporting\nto rely on decision of Delhi High Court in the case

ASSISTANT COMMISSIONER OF INCOME TAX, KOLHAPUR vs. UNDERCARRIAGE AND TRACTOR PARTS PRIVATE LIMITED, KOLHAPUR

In the result, the appeal of the Revenue is dismissed

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

section 92D. Perusal of Transfer pricing study report shows that the appellant has adopted CUP as most appropriate method for all the transactions with the AEs. Following are the details given by the appellant in its TP study report on page 26

M/S VODAFONE GLOBAL SERVICES P LTD,,PUNE vs. ASSISTANT COMMISSIONER OF INCOME-TAX, CIRCLE 1(1),, PUNE

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

Bench: Dr.Manish Borad & Shri Vinay Bhamoreआयकर अपील सं. / Ita No.660/Pun/2022 Assessment Year : 2018-19

Section 144B of the Income Tax Act, 1961. Consequently, the entire assessment deserves to be quashed. The Appellant craves leave to add to or alter, by deletion, substitution, modification or otherwise or amend or withdraw the Additional 3 M/s. Vodafone Global Services Private Limited Grounds of Appeal herein and to submit such statements, documents and papers as may be considered

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

INCOME TAX OFFICER WARD 1 JALNA, JALNA vs. VIKRAM TEA PROCESSOR PRIVATE LIMITED, JALNA

In the result, both the appeals filed by the Revenue are dismissed

Bench: Shri R. K. Panda & Ms Astha Chandraassessment Year : 2013-14

26-09-2025 O R D E R PER R.K. PANDA, VP: The above 2 appeals filed by the Revenue are directed against the separate orders dated 31.08.2024 of the Ld. CIT(A), Pune - 13 relating to assessment year 2013-14. For the sake of convenience, both the appeals were heard together and are being disposed of by this common

INCOME TAX OFFICER , JALNA vs. VIKRAM TEA PROCESSOR PRIVATE LIMITED , JALNA

In the result, both the appeals filed by the Revenue are dismissed

Bench: Shri R. K. Panda & Ms Astha Chandraassessment Year : 2013-14

26-09-2025 O R D E R PER R.K. PANDA, VP: The above 2 appeals filed by the Revenue are directed against the separate orders dated 31.08.2024 of the Ld. CIT(A), Pune - 13 relating to assessment year 2013-14. For the sake of convenience, both the appeals were heard together and are being disposed of by this common

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

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

Transfer Pricing adjustment of earlier years. 2.3 The learned CIT(A) erred on the facts and in law by not appreciating that there was a reasonable cause for not reporting the transaction of Rs 4,07,42,345/- in Form 3CEB considering the provisions of section 273B of the Act. 3. Initiation of Penalty Proceedings against the non-existing entity

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

section 17 of the Registration Act, 1908 w.e.f. 24.09.2001 vide Registration and Other Related Laws (Amendment) Act, 2001 which mandated that the title of an immovable property could be transferred only by way of a registered document. Prior to the said amendment, the title in immovable property could also be transferred by way of an unregistered agreement to sale/ contract

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

section 259 of the Companies Act of Singapore. The Hon‟ble High Court of Republic Singapore was pleased to grant the permission vide order dated 02.10.2015. Subsequently, the assessee company transferred the shares of 79,33,50,000 ordinary shares of BSPL held by the assessee company for total consideration of Singapore Dollar 1 to Bilcare Packaging Ltd., which

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

section 259 of the Companies Act of Singapore. The Hon‟ble High Court of Republic Singapore was pleased to grant the permission vide order dated 02.10.2015. Subsequently, the assessee company transferred the shares of 79,33,50,000 ordinary shares of BSPL held by the assessee company for total consideration of Singapore Dollar 1 to Bilcare Packaging Ltd., which

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

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

26. On perusal of the clause 2.3 as well as relevant clauses of the sale deed, it would reveal that the sale consideration was to be discharged by post-dated cheques in installments. The buyer of the property had only limited rights of development i.e. license to commence the work and the possession of the property to be handed over

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

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

26. On perusal of the clause 2.3 as well as relevant clauses of the sale deed, it would reveal that the sale consideration was to be discharged by post-dated cheques in installments. The buyer of the property had only limited rights of development i.e. license to commence the work and the possession of the property to be handed over