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11 results for “transfer pricing”+ Section 36(1)(vi)clear

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Key Topics

Section 8018Section 143(3)14Section 26311Section 5710Section 143(2)6Section 12A6Deduction6Addition to Income5Section 104Section 80G

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

In the result, appeal of the Revenue is dismissed

ITA 987/PUN/2025[2014-15]Status: DisposedITAT Pune27 Jan 2026AY 2014-15

Bench: Dr. Manish Borad & Shri Vinay Bhamore

For Appellant: Shri Subodh Ratnaparkhi, CAFor Respondent: Shri Amit Bobde, CIT
Section 132Section 143(2)Section 143(3)Section 147Section 148Section 250

36 ITA.No.987/PUN./2025 (M/s. Shree Sai Properties) the Ld. AO extrapolated this information to presume further unaccounted sales of Rs. 7,93,62,371/- thereby making an addition of Rs. 8,80,26,071/- (Rs. 86,63,700+ Rs. 7,93,62,371) to the income of the assessee as unaccounted sales in respect of plots at survey

4
Disallowance3
Search & Seizure2

DCIT, CIRCLE 8 PUNE, PUNE vs. ALFA LAVAL INDIA PVT LTD, PUNE

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

ITA 2270/PUN/2024[2018-19]Status: DisposedITAT Pune10 Oct 2025AY 2018-19
Section 143(1)Section 143(2)Section 143(3)Section 14ASection 36(1)(va)Section 40Section 92C

36(1)(va) of the Act.\nSubsequently, the case was selected for scrutiny under CASS for the following\nreasons:\n“1.\nDeemed International Transactions\n2.\nLarge value of international transactions\n3.\nTransactions with Company whose Registration has been Cancelled by\nMCA\n4.\nDuty Drawback\n5.\nLower amount disallowed u/s 40(a)(ia) in ITR (Part A-OI) in comparison

DANA ANAND INDIA PRIVATE LIMITED,PUNE vs. DCIT, AKURDI,PUNE

ITA 1571/PUN/2024[2020-21]Status: DisposedITAT Pune04 Apr 2025AY 2020-21
Section 143(1)(a)Section 143(3)Section 154Section 37Section 37(1)Section 41Section 41(1)Section 80ASection 80G

36 of the Act, for computing income under the head,\n“Income from Business and Profession”.\n16. For claiming benefit under section 80G, deductions are considered at\nthe stage of computing “Total taxable income". Even if any payments\nunder section 80G forms part of CSR payments ( keeping in mind ineligible\ndeduction expressly providedu/s.80G), the same would already stand\nexcluded while

ASHISH NIRANJAN SHAH,,PUNE vs. PR. COMMISSIONER OF INCOME-TAX -4,, PUNE

In the result, appeal of the assessee is dismissed

ITA 697/PUN/2019[2014-15]Status: DisposedITAT Pune13 Oct 2023AY 2014-15

Bench: Shri S.S.Godara & Dr. Dipak P. Ripoteआयकर अपील सं. / Ita No.697/Pun/2019 िनधा"रण वष" / Assessment Year : 2014-15 Ashish Niranjan Shah, The Pr.Cit-4, Pune. 39, Mantri Court, Dr.Ambedkar V Road, Next To Rto, Sangam, S Pune – 411001. Pan: Aidps 7682 K Appellant/ Assessee Respondent /Revenue Assessee By Shri Kishor B Phadke – Ar Revenue By Shri Keyur Patel, Irs – Cit-Dr Date Of Hearing 28/07/2023 Date Of Pronouncement 13/10/2023 आदेश/ Order Per Dr. Dipak P. Ripote, Am: This Appeal Filed By The Assessee Is Directed Against The Order Of Ld.Pr.Commissioner Of Income Tax-4, Pune Dated26.03.2019 Under Section 263 Of The Income Tax Act, 1961. The Assessee Has Raised The Following Grounds Of Appeal : “1. Learned Pr. Cit- 4, Pune Erred In Law & On Facts In Treating The Assessment Order U/S 143(3) Being Erroneous & Thereby Prejudicial To The Revenue U/S 263 Without Appreciating That, The Learned Ao Has Allowed Appellant'S Claim Of Business Loss Amounting To Rs.10,20,14,068/- Incurred On Account Of Default In Payment By Nsel, With Due Application Of Mind & Verification. The Learned Pr. Cit Erred In Holding That, Ao Has Not Carried Out Any Enquiry With Respect To Business Loss Claimed By The Appellant & Not Applied His Ashish Niranjan Shah [A]

Section 143(3)Section 263Section 43(5)

Vi Total Bad Debt (39i + 39vi 0 39ii + 39iv + 39v) The Profit and Loss Account submitted by the Assessee is reproduced here under : EXPENDITURE AMOUNT INCOME AMOUNT TO GENERAL OFFICE 1823.57 BROKERAGE 24922.94 TO SUBSCRIPTION FEE 236574.00 INTEREST INCOME 4034073.00 TO SOFTWARE/COMPUTER 9303.14 PROFIT & LOSS ON 97784.56 TO TELEPHONE 14681.00 LOSS TR TO CAPITAL 98595156.30 TO SALARY 54194.00 TO ELECTRICITY

SHRI MANOJ MADANLAL CHHAJED,PUNE vs. ASSISTANT COMMISSIONER OF INCOME TAX, CIRCLE -1(1)PUNE, PUNE

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

ITA 725/PUN/2022[2018-19]Status: DisposedITAT Pune28 Jun 2023AY 2018-19

Bench: Shri Inturi Rama Rao & Shri S. S. Viswanethra Raviआयकर अपील सं. / It(Ss)A Nos.91 To 96/Pun/2022 िनधा"रण वष" / Assessment Years : 2012-13 To 2017-18 Shri Manoj Madanlal Vs. Acit, Central Circle- Chhajed, 1(1), Pune. 601, A-8 Building, Karishma Housing Society, Near Sangam Press, Kothrud, Pune- 411029. Pan : Aalpc4991M Appellant Respondent आयकर अपील सं. / It(Ss)A Nos.97 & 98/Pun/2022 िनधा"रण वष" / Assessment Years : 2012-13 & 2015-16 Acit, Circle-1(1), Pune. Vs. Shri Manoj Madanlal Chhajed, 601, A-8 Building, Karishma Housing Society, Near Sangam Press, Kothrud, Pune- 411029. Pan : Aalpc4991M Appellant Respondent आयकर अपील सं. / Ita No.725/Pun/2022 िनधा"रण वष" / Assessment Year: 2018-19 Shri Manoj Madanlal Vs. Acit, Circle-1(1), Pune. Chhajed, 601, A-8 Building, Karishma Housing Society, Near Sangam Press, Kothrud, Pune- 411029. Pan : Aalpc4991M Appellant Respondent

For Appellant: Shri Ratan SamalFor Respondent: Shri Keyur Patel
Section 132(4)Section 139(1)

prices. At many places only figures have been mentioned without noting whether these are amounts received or paid. I have recorded my statement for such amounts purely on my memory and so they could be vise-versa also. The dates recorded in the Diaries may differ with the dates recorded in the regular books of accounts or the dates

SONAL SANDEEP SATAV,PUNE vs. PCIT, PUNE-2, PUNE

In the result, the appeal of the assessee is dismissed

ITA 945/PUN/2024[2018-19]Status: DisposedITAT Pune03 Dec 2024AY 2018-19

Bench: Ms. Astha Chandra & Shree G.D. Padmahshali

For Appellant: Shri Sarang GudhateFor Respondent: Shri Ajay Kumar Keshari
Section 142(1)Section 143(2)Section 143(3)Section 263

Transfer Pricing Officer for determination of arm's length price in respect of international transactions reported for the relevant assessment year. Then paragraph 4, along with its sub paragraphs 4.1 to 47 deal with disallowance under section 40(a)(ia) in the context of commission exceeding Re. 18.00 crore paid by the Assessee during the relevant assessment year, even though

ASSISTANT COMMISSIONER OF INCOME TAX CENTRAL CIRCLE 2(1), PUNE, PUNE vs. PATIL CONSTRUCTION AND INFRASTRUCTURE LIMITED, MUMBAI

In the result, all the three appeals filed by the Revenue are allowed for statistical purposes

ITA 229/PUN/2025[2013-14]Status: DisposedITAT Pune23 Oct 2025AY 2013-14

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

For Appellant: S/Shri Rajiv KhandelwalFor Respondent: Shri Amit Bobde, CIT
Section 143(2)Section 80

price as per work completed whereas section 80IA stipulates development or maintenance of infrastructure facility. 4. Whether on the facts and in the circumstances of the case and in law the Ld. CIT(A) failed to appreciate the fact that the relationship between assessee and the government is that of the contractor and the contractee and the assessee has acted

JAYANTI S KUNDHADIYA, ASSISTANT COMMISSIONER OF INCOME TAX , CENTRAL CIRCLE-2(1), PUNE, PUNE vs. PATIL CONSTRUCTION AND INFRASTRUCTURE LIMITED, MUMBAI

In the result, all the three appeals filed by the Revenue are allowed for statistical purposes

ITA 231/PUN/2025[2015-16]Status: DisposedITAT Pune23 Oct 2025AY 2015-16

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

For Appellant: S/Shri Rajiv KhandelwalFor Respondent: Shri Amit Bobde, CIT
Section 143(2)Section 80

price as per work completed whereas section 80IA stipulates development or maintenance of infrastructure facility. 4. Whether on the facts and in the circumstances of the case and in law the Ld. CIT(A) failed to appreciate the fact that the relationship between assessee and the government is that of the contractor and the contractee and the assessee has acted

JAYANTI S KUNDHADIYA, ASSISTANT COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-2(1), PUNE, PUNE vs. PATIL CONSTRUCTION AND INFRASTRUCTURE LIMITED, MUMBAI

In the result, all the three appeals filed by the Revenue are allowed for statistical purposes

ITA 230/PUN/2025[2014-15]Status: DisposedITAT Pune23 Oct 2025AY 2014-15

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

For Appellant: S/Shri Rajiv KhandelwalFor Respondent: Shri Amit Bobde, CIT
Section 143(2)Section 80

price as per work completed whereas section 80IA stipulates development or maintenance of infrastructure facility. 4. Whether on the facts and in the circumstances of the case and in law the Ld. CIT(A) failed to appreciate the fact that the relationship between assessee and the government is that of the contractor and the contractee and the assessee has acted

SHAHU SHIKSHAN PRASARAK MANDAL, LATUR,LATUR vs. ACIT (EXMP.) CIRCLE, AURANGABAD, AURANGABAD

In the result, the appeal of the assessee is allowed for statistical\npurposes

ITA 951/PUN/2024[2020-21]Status: DisposedITAT Pune15 Jan 2025AY 2020-21
For Appellant: \nDepartment by
Section 10Section 12ASection 142(1)Section 143(3)Section 56Section 57

vi) and (via) are required to\nobtain the approval of CCIT / PCIT. The trust is running schools which\nare mostly granted by Government in the year between 1990-2000.\nCertificates from School Education Department, Government of\nMaharashtra confirming the amount of grants distributed to schools\nrun by trust is enclosed herewith as Annexure \"E\".\n2) Perusal of the Pay sheets

ASHWINI SAHAKARI RUNGNALAYA & RESEARCH CENTER,,SOLAPUR vs. COMMISSIONER OF INCOME-TAX, (EXEMPTIONS),, PUNE

ITA 714/PUN/2018[N.A]Status: DisposedITAT Pune07 Mar 2024

Bench: Hon’Ble Shri S. S. Viswanethra Ravi & Shri G. D. Padmahshaliआयकर अपील सं. / Ita No. 714/Pun/2018 Ashwini Sahakari Rugnalaya & Research Centre 7107/1, Plot No. 180, North Sadar Bazar, Solapur-413003. Pan: Aaaja0041K . . . . . . . अपीलार्थी / Appellant

For Appellant: Mr Pramod Shingte [‘Ld. AR’]For Respondent: Mr Keyur Patel [‘Ld. DR’]
Section 10Section 10(23)Section 11Section 12ASection 22Section 253(1)(c)

transferred to Ld. CIT(E) jurisdiction. The Ld. CIT(E) vide notice dt. 24/03/2017 revived former cancellation proceedings and before culmination had granted reasonable opportunities to enable the assessee to rebut Revenue’s negative observations/findings. After analysis of facts with an elaborate discussion laid in para 4, the Ld. CIT(E) by the impugned order dt.28/03/2018 has finally withdrawn/cancelled