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

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

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

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

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

Section 35(1) (iv) Income Tax Act, 1961 at least to\nthe extent of One hundred percent.\n4. Facts of the case, in brief, are that the assessee is a company engaged in the\nbusiness of manufacture and sale of air conditioners, radiators, heat exchangers\nparts and components thereof which are used in cars and SUVs and in providing

DEPUTY COMMISSIONER OF INCOME-TAX, CIRCLE - 1(1),, PUNE vs. M/S. IAC INTERNATIONAL AUTOMOTIVE INDIA PVT.LTD,, PUNE

In the result, the appeal of the Revenue is dismissed

Bench: Ms. Astha Chandra & Shree Dr. Dipak P. Ripote

35. The TPO's Report is, subsequent to the Finance Act 2007. binding on the AO. Thus, it becomes all the more important to clarify the extent of the TPO's authority in this case, which is to determining the ALP for international transactions referred to him or her by the AO, rather than determining whether such services exist

DCIT, SWARGATE PUNE vs. CUMMINS INDIA LTD , PUNE

In the result, appeal of the assessee bearing ITA No

iv) import of cooling systems and stamping\nmachines; (v) payment of royalty for use of technology;\n(vi) rendering of internal audit services; (vii) receipt of\ndesign engineering and testing services; (viii) insite pro\nregistration charges; (ix) user licence fees; (x) receipt of\nwarranty service; and (xi) receipt of training service,\nwith its AE. For the purpose of benchmarking

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

In the result, appeal of the assessee bearing ITA No

iv) import of cooling systems and stamping\nmachines; (v) payment of royalty for use of technology;\n(vi) rendering of internal audit services; (vii) receipt of\ndesign engineering and testing services; (viii) insite pro\nregistration charges; (ix) user licence fees; (x) receipt of\nwarranty service; and (xi) receipt of training service,\nwith its AE. For the purpose of benchmarking

SATARA ENGINEERING PROJECTS AND EQUIPMENTS PRIVATE LIMITED,SATARA vs. DEPUTY COMMISSIONER OF INCOME TAX, CIRCLE, SATARA, SATARA

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

Bench: Dr.Manish Borad & Shri Vinay Bhamoreआयकर अपील सं. / Ita No.2450/Pun/2025 Assessment Year : 2024-25

transfer of a capital asset on which no depreciation is allowable under the Act shall be computed at the rate of twenty-two per cent: Provided also that where the person fails to satisfy the conditions contained in sub-section (2) in any previous year, the option shall become invalid in respect of the assessment year relevant to that previous

M.M. PATEL PUBLIC CHARITABLE TRUST,SOLAPUR vs. PCIT- CENTRAL, PUNE, PUNE

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

transferring the jurisdiction of the person, the transferee Income-\ntax Authorities as mentioned in section 116 of the Act shall exercise all\nthe powers and perform the functions as stipulated in the Act in respect\nof all the proceedings which may be commenced after the date of such\norder in respect of any year and such power includes passing

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

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

PIAGGIO VEHICLES PVT LTD ,PUNE vs. ACIT, CIRCLE 4, PUNE, PUNE

In the result, the appeal of the assessee is dismissed

Bench: Ms. Astha Chandra & Shree Dr. Dipak P. Ripote

pricing adjustment of Rs.7,36,97,574/- which were allowed by the Ld. CIT(A) relying on his decision in preceding AY 2015-16 in assessee’s own case involving the identical issues in respect of export of parts and component-service spares and export of parts and components – global sourcing and payment of corporate guarantee fees. Before

DCIT CIRCLE 1 NASHIK, NASHIK vs. SHREE SAI PROPERTIES, NASHIK

In the result, appeal of the Revenue is dismissed

Bench: Dr. Manish Borad & Shri Vinay Bhamore

35 ITA.No.987/PUN./2025 (M/s. Shree Sai Properties) Assessing Officer. We observe that the information contained in the alleged seized material is only having a reference of the words “367 Makhmalabad” and that referring to sale consideration received through cheque at Rs.81,33,300/- and the alleged on money payment of Rs.86,63,700/-. We note that during the course

SEMPERTRANS INDIA PRIVATE LIMITED,ROHA vs. INCOME-TAX OFFICER, PANVEL

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

Price ('ALP') of the payment for services as 'NIL' by\ndisregarding the detailed benchmarking approach and the\nmethodology adopted by the Appellant in its TP documentation\nmaintained under section 92D of the Act read with Rule 10D of the\nIncome Tax Rules, 1962 ('Rules').\n8. Upholding/confirming the action of Ld. TPO, in going beyond\nthe scope under section 92CA

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

35. We find the Ld. CIT granted registration u/s 12A only from the date of the application i.e. 10.02.2006 vide order dated 05.09.2007. The relevant observations of the Ld. CIT read as under: “In view of ITAT’s order holding that activities of the assessee are charitable in nature, registration u/s 12AA is granted to the assessee w.e.f

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

35. We find the Ld. CIT granted registration u/s 12A only from the date of the application i.e. 10.02.2006 vide order dated 05.09.2007. The relevant observations of the Ld. CIT read as under: “In view of ITAT’s order holding that activities of the assessee are charitable in nature, registration u/s 12AA is granted to the assessee w.e.f

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

35. We find the Ld. CIT granted registration u/s 12A only from the date of the application i.e. 10.02.2006 vide order dated 05.09.2007. The relevant observations of the Ld. CIT read as under: “In view of ITAT’s order holding that activities of the assessee are charitable in nature, registration u/s 12AA is granted to the assessee w.e.f

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

35. We find the Ld. CIT granted registration u/s 12A only from the date of the application i.e. 10.02.2006 vide order dated 05.09.2007. The relevant observations of the Ld. CIT read as under: “In view of ITAT’s order holding that activities of the assessee are charitable in nature, registration u/s 12AA is granted to the assessee w.e.f