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

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

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

transfer pricing proceedings, the TPO observed that the assessee had\nentered into various international transactions with its AEs. He observed that the\nassessee company has adopted TNMM Method for benchmarking the international\ntransaction of export of traded spares to the AEs. Further, the assessee company\nhas selected 6 companies as comparable for trading activity. From the submissions\nfiled

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

VOLKSWAGEN GROUP TECHNOLOGY SOLUTIONS INDIA PVT. LTD.,PUNE vs. NATIONAL FACELESS ASSESSMENT CENTER, ASSESSMENT UNIT DELHI, DELHI

In the result, appeal of the assessee is partly allowed

Bench: Dr.Dipak P. Ripote & Shri Vinay Bhamoreआयकर अपील सं. / Ita No.1950/Pun/2024 िनधा"रण वष" / Assessment Year: 2020-21 Volkswagen Group Technology V National Faceless Solutions India Pvt. Ltd., S Assessment Center, Embassy Techzone, 9Th Floor, Assessment Unit, Delhi. 1.3 Congo Building, Rajiv Gandhi, Infotech Park, Infotech Park Hinjavadi, Pune – 411057. Maharashtra. Pan: Aafcv1368L Appellant/ Assessee Respondent / Revenue Assessee By Shri Nikhil Pathak – Ar Revenue By Shri Prakash L Pathade – Cit(Dr) Date Of Hearing 15/05/2025 Date Of Pronouncement 28/05/2025

44,750 by holding that the international transaction of provision of IT services is not at arm's length price as envisaged under the Act. 2. On the facts and in the circumstances of the case, and in law, the Ld. AO/ Ld. DRP erred in disregarding the fact that none of the conditions, as set out in Section

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

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

section 54 of the Transfer of Property Act, it has been held that, "sale is a transfer of ownership in exchange for a price paid or promised or part paid and part-promised. The true test is, what is the intention of the parties to the transaction. If the intention is that title should pass immediately, even though the consideration

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

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

section 54 of the Transfer of Property Act, it has been held that, "sale is a transfer of ownership in exchange for a price paid or promised or part paid and part-promised. The true test is, what is the intention of the parties to the transaction. If the intention is that title should pass immediately, even though the consideration

OPTIVA INDIA TECHNOLOGIES PVT. LTD.,,PUNE vs. ACIT, CIRCLE - 2,, PUNE

In the result, appeal of the assessee is allowed

Bench: Dr.Manish Borad & Ms. Astha Chandraआयकर अपील सं. / Ita No.634/Pun/2022 Assessment Year : 2018-19

section 270A of the Act for under reporting of income. Prayer 7 Optiva India Technologies Pvt. Ltd. The Appellant craves leave to add, alter, supplement, amend, vary, withdraw, or otherwise modify the ground mentioned herein above at or before the time of hearing. All the aforesaid grounds of appeal are independent, in the alternative and without prejudice to one another

UBS BUSINESS SOLUTIONS (INDIA) PRIVATE LIMITED (SUCCESSOR TO CREDIT SUISSE SERVICES (INDIA) PVT LTD),PUNE vs. PCIT, PUNE - 1, PUNE, MAHARASHTRA

In the result, appeal of the Assessee is allowed

Bench: Ms.Astha Chandra & Dr.Dipak P. Ripoteआयकर अपऩल सं. / Ita No.1407/Pun/2025 निर्धारण वषा / Assessment Year: 2020-21 Ubs Business Solutions (India) V The Principal Pvt. Ltd. (Successor To Credit S. Commissioner Of Suisse Services (India) Pvt Income Tax, Ltd.), Pune-1. Cluster A, Eon Free Zone, Plot No.1, S.No.77, Ground To 5Th Floors In Wing 1, 3Rd To 5Th Floor In Wing 2, Kharadi Midc Knowledge Park, Pune – 411014. Pan: Aabcu8718M Appellant/ Assessee Respondent / Revenue Assessee By Shri Rajendra Agiwal - Ar Revenue By Shri Amit Bobde – Cit(Dr) Date Of Hearing 23/09/2025 Date Of Pronouncement 28/11/2025 आदेश/ Order Per Dr. Dipak P. Ripote, Am: This Appeal Is Filed By The Assessee Against The Order Of Ld.Principal Commissioner Of Income Tax, Pune-1 Passed Under Section 263 Of The Income Tax Act, 1961 For A.Y.2020-21, Dated 31.03.2025 Emanating From Assessment Order U/S.143(3) R.W.S 144B

section 263 does not authorise are give unfettered power to the Commissioner to revise each and every order if in his opinion the same has been passed without making enquiryshould have been made as held by the Mumbai ITAT in case of Narayan Tatu Rune vs. ITO (2016) 17 taxmann.com 227 (Mumbai) 22. Further, all the details of the repairs

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

44,75,01,310/-. The case was selected for scrutiny through CASS. Statutory notices u/s 143(2) and 142(1) of the Income Tax Act, 1961 (the “Act”) were issued and served upon the assessee. 3.1 A reference was made to the Transfer Pricing Officer (“TPO”) u/s 92CA(1) of the Act to determine the Arm’s Length Price

WIKA INSTRUMENTS INDIA PRIVATE LIMITED,PUNE vs. THE DEPUTY COMMISSIONER OF INCOME TAX, CIRCLE-12, PUNE

In the result, appeal of the Assessee is partly allowed

Bench: Dr.Manish Borad & Shri Vinay Bhamoreआयकर अपील सं. / Ita No.2767/Pun/2024 िनधा"रण वष" / Assessment Year: 2021-22 Wika Instruments India V The Dcit, Private Limited, S. Circle-12, Pune. Hi-Cliff Industrial Estate, Kesnand, Pune – 412207. Maharashtra. Pan: Aaacw2665A Appellant/ Assessee Respondent / Revenue Assessee By Shri Nikhil Mutha – Ar Revenue By Shri Prakash L Pathade – Cit-Dr Date Of Hearing 05/03/2025 Date Of Pronouncement 03/06/2025 आदेश/ Order Per Vinay Bhamore, Jm: This Is An Appeal Filed By The Assessee Against The Assessment Order Under Section 143(3) R.W.S 144C(13) Of The Act, Dated 25.10.2024 To Give Effect To The Order Of The Dispute Resolution Panel(Drp) Passed U/S.144C(5) Of The Act, Dated 26.09.2024 Emanating From Draft Assessment Order Under Section 144C(1) Of

44,193/-. 2.2 The Assessee filed Objections before the Dispute resolution Panel(DRP). The DRP vide its order dated 29/09/2024 directed the TPO/AO to delete the addition. Accordingly, the Assessing Officer passed Assessment Order u/s 143(3) r.w.s 144C(13) on 25/10/2024. The relevant paragraphs number 6, 7 and 8 of the Assessment Order are reproduced here as under

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

Transfer Pricing Officer (TPO) for determination of the arm's length\nprice of the international transactions who proposed Nil adjustment. However, the\nAssessing Officer took Rs.1,64,17,30,653/- as variation with respect to the TP\nadjustment. The Assessing Officer thereafter passed the draft assessment order\ndetermining the total income at Rs.338,51,08,520/- by making certain other

DEPUTY COMMISSIONER OF INCOME TAX, NASHIK vs. CHAKRAHAR CONTRACTORS AND ENGINEERS PRIVATE LIMITED, JALGAON

In the result, both the appeals of the Revenue are

Bench: Shri Rama Kanta Panda & Shri Vinay Bhamore

Transfer Pricing Officer, where the assessee had maintained 13 ITA.Nos.1939 & 1940/PUN./2024 information and documents as prescribed under section 92D, declared the international transaction under Chapter X, and, disclosed all the material facts relating to the transaction; and (e) the amount of undisclosed income referred to in section 271AAB. (7) The penalty referred to in sub-section (1) shall

DEPUTY COMMISSIONER OF INCOME TAX, NASHIK vs. CHAKRADHAR CONTRACTORS AND ENGINEERS PRIVATE LIMITED, JALGAON

In the result, both the appeals of the Revenue are

Bench: Shri Rama Kanta Panda & Shri Vinay Bhamore

Transfer Pricing Officer, where the assessee had maintained 13 ITA.Nos.1939 & 1940/PUN./2024 information and documents as prescribed under section 92D, declared the international transaction under Chapter X, and, disclosed all the material facts relating to the transaction; and (e) the amount of undisclosed income referred to in section 271AAB. (7) The penalty referred to in sub-section (1) shall

YASHWANTRAO CHAVAN MAHARASHTRA OPEN UNIVERSITY,NASHIK vs. COMMISSIONER OF INCOME TAX,-EXEMPTION, PUNE, PUNE

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

Bench: SHRI MANISH BORAD (Accountant Member), SHRI VINAY BHAMORE (Judicial Member)

Transfer Pricing Officer, as the case may be, had been the subject matter of any appeal filed on or before or after the 1st day of June, 1988, the powers of the Principal Commissioner or Commissioner under this sub-section shall extend and shall be deemed always to have extended to such matters as had not been considered and decided

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

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

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