M/S. HONEWELL AUTOMATION INDIA LTD.,,PUNE vs. DEPUTY COMMISSIONER OF INCOME-TAX,,

In the result, the appeal of Revenue is dismissed

Bench: Shri R.S. Syal & Shri S.S. Viswanethra Ravi

56 & 57, Hadapsar Industrial Estate, Hadapsar, Pune – 411013 PAN : AAACT3904F ……प्रत्यथी / Respondent Assessee by : Shri Ajit Kumar Jain Revenue by : Shri T. Vijaya Bhaskar Reddy सुनवाई की तारीख / Date of Hearing : 08-01-2020 घोषणा की तारीख / Date of Pronouncement : 03-03-2020 2 ITA Nos. 583 & 619/PUN/2015, A.Y. 2003-04 आदेश / ORDER PER S.S. VISWANETHRA RAVI, JM : These

DEPUTY COMMISSIONER OF INCOME-TAX vs. M/S. HONEYWELL AUTOMATION INDIA LTD.,, PUNE

In the result, the appeal of Revenue is dismissed

Bench: Shri R.S. Syal & Shri S.S. Viswanethra Ravi

56 & 57, Hadapsar Industrial Estate, Hadapsar, Pune – 411013 PAN : AAACT3904F ……प्रत्यथी / Respondent Assessee by : Shri Ajit Kumar Jain Revenue by : Shri T. Vijaya Bhaskar Reddy सुनवाई की तारीख / Date of Hearing : 08-01-2020 घोषणा की तारीख / Date of Pronouncement : 03-03-2020 2 ITA Nos. 583 & 619/PUN/2015, A.Y. 2003-04 आदेश / ORDER PER S.S. VISWANETHRA RAVI, JM : These

DEPUTY COMMISSIONER OF INCOME TAX, AURANGABAD vs. ASHISH JUGALKISHOR BHALA, JALNA

In the result, the appeal filed by the Revenue is partly allowed

Bench: Shri R. K. Panda & Ms. Astha Chandraassessment Year : 2021-22 Dcit, Aurangabad Ashish Jugalkishor Bhala Mamta Hospital, Shivaji Putla Road, Vs. Bharat Nagar, Jalna – 431203 Maharashtra Pan: Ahmpb3683K (Appellant) (Respondent) Assessee By : Shri Anand Partani Department By : Shri Ramnath P Murkunde Date Of Hearing : 01-04-2025 Date Of Pronouncement : 16-06-2025 O R D E R

section 56(2)(x) of the Income Tax Act. It is seen that the assessee has adopted fair market value of Rs.540/- per share which is not acceptable. The assessee has purchased 1,19,360 shares. Details of such purchase is as under: S.No. Name of the persons from whom you Total Number Value have purchased shares of Metarolls

M/S. HONEWELL AUTOMATION INDIA LTD.,,PUNE vs. DEPUTY COMMISSIONER OF INCOME-TAX,,

In the result, the appeal of Revenue is dismissed as infructuous

Bench: Shri R.S. Syal & Shri S.S. Viswanethra Ravi

56 & 57, Hadapsar Industrial Estate, Hadapsar, Pune – 411013 PAN : AAACT3904F ……प्रत्यथी / Respondent Assessee by : Shri Ajit Kumar Jain Revenue by : S/Shri Kalika Singh & Mahadevan A.M. Krishnan सुनवाई की तारीख / Date of Hearing : 25-05-2021 घोषणा की तारीख / Date of Pronouncement : 03-06-2021 2 ITA Nos.584 & 620/PUN/2015, A.Y. 2005-06 आदेश / ORDER PER S.S. VISWANETHRA RAVI, JM : These

DEPUTY COMMISSIONER OF INCOME-TAX vs. M/S. HONEYWELL AUTOMATION INDIA LTD.,, PUNE

In the result, the appeal of Revenue is dismissed as infructuous

Bench: Shri R.S. Syal & Shri S.S. Viswanethra Ravi

56 & 57, Hadapsar Industrial Estate, Hadapsar, Pune – 411013 PAN : AAACT3904F ……प्रत्यथी / Respondent Assessee by : Shri Ajit Kumar Jain Revenue by : S/Shri Kalika Singh & Mahadevan A.M. Krishnan सुनवाई की तारीख / Date of Hearing : 25-05-2021 घोषणा की तारीख / Date of Pronouncement : 03-06-2021 2 ITA Nos.584 & 620/PUN/2015, A.Y. 2005-06 आदेश / ORDER PER S.S. VISWANETHRA RAVI, JM : These

DHAS KISHOR RAMCHANDRA, AURANGABAD vs. DWARKAPRASAD BHIKULAL SONI, JALNA

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

Bench: SHRI R. K. PANDA (Vice President), SHRI VINAY BHAMORE (Judicial Member)

56(2)(x) made by the Assessing Officer, we find that Ld. CIT(A) has deleted both the additions by observing as under :- “5.2 I have gone through the submission of the appellant along with supporting documents submitted during the appellate proceedings as well as during the assessment proceedings before the Ld. AO. The appellant has contested the determination

M/S ACCORD MEDIPLUS PVT LTD,PUNE vs. INCOME TAX OFFICER, WARD-1(1), PUNE, PUNE

transferred out\nback to them or invested in other non-current investments. Thus\nneither the funds nor assets are owned by assessee.\n(υ) The assessee has not submitted as to how by any stretch of\nimagination, inspite of various hurdles as discussed and explained\nby the assessee as above, it was possible to complete and construct

M/S. HONEYWELL AUTOMATION INDIA LTD.,,PUNE vs. DEPUTY COMMISSIONER OF INCOME-TAX,,

In the result, appeal of the assessee in ITA No

Bench: Shri R.S.Syal, Vp & Shri Partha Sarathi Chaudhury, Jm

56 & 57, Hadapsar Industrial Estate, Hadapsar, Pune-411 013. PAN : AAACT3904F .......अपीलाथ" / Appellant बनाम / V/s. The Deputy Commissioner of Income Tax, Circle-11, Pune. ……""यथ" / Respondent Assessee by : Shri Kamal Shaney Revenue by : Smt. Nandita Kanchan सुनवाई क" तार"ख / Date of Hearing : 05.03.2019 घोषणा क" तार"ख / Date of Pronouncement : 06.03.2019 A.Y.2011-12 आदेश / ORDER PER PARTHA SARATHI CHAUDHURY

DEPUTY COMMISSIONER OF INCOME-TAX vs. M/S. HONEYWELL AUTOMATION INDIA LTD.,, PUNE

In the result, appeal of the assessee in ITA No

Bench: Shri R.S.Syal, Vp & Shri Partha Sarathi Chaudhury, Jm

56 & 57, Hadapsar Industrial Estate, Hadapsar, Pune-411 013. PAN : AAACT3904F .......अपीलाथ" / Appellant बनाम / V/s. The Deputy Commissioner of Income Tax, Circle-11, Pune. ……""यथ" / Respondent Assessee by : Shri Kamal Shaney Revenue by : Smt. Nandita Kanchan सुनवाई क" तार"ख / Date of Hearing : 05.03.2019 घोषणा क" तार"ख / Date of Pronouncement : 06.03.2019 A.Y.2011-12 आदेश / ORDER PER PARTHA SARATHI CHAUDHURY

M/S ACCORD MEDIPLUS PVT LTD,PUNE vs. INCOME TAX OFFICER, WARD-1(1), PUNE, PUNE

Bench: Dr.Manish Borad & Shri Vinay Bhamore

transferred out back to them or invested in other non-current investments. Thus neither the funds nor assets are owned by assessee. (v) The assessee has not submitted as to how by any stretch of imagination, inspite of various hurdles as discussed and explained by the assessee as above, it was possible to complete and construct a 75 bed hospital

M/S ACCORD MEDIPLUS PVT LTD,PUNE vs. INCOME TAX OFFICER, WARD-1(1), PUNE, PUNE

Bench: Dr.Manish Borad & Shri Vinay Bhamore

transferred out back to them or invested in other non-current investments. Thus neither the funds nor assets are owned by assessee. (v) The assessee has not submitted as to how by any stretch of imagination, inspite of various hurdles as discussed and explained by the assessee as above, it was possible to complete and construct a 75 bed hospital

M/S ACCORD MEDIPLUS PVT LTD,PUNE vs. INCOME TAX OFFICER, WARD-1(1), PUNE, PUNE

Bench: Dr.Manish Borad & Shri Vinay Bhamore

transferred out back to them or invested in other non-current investments. Thus neither the funds nor assets are owned by assessee. (v) The assessee has not submitted as to how by any stretch of imagination, inspite of various hurdles as discussed and explained by the assessee as above, it was possible to complete and construct a 75 bed hospital

M/S ACCORD MEDIPLUS PVT LTD,PUNE vs. INCOME TAX OFFICER, WARD-1(1), PUNE, PUNE

Bench: Dr.Manish Borad & Shri Vinay Bhamore

transferred out back to them or invested in other non-current investments. Thus neither the funds nor assets are owned by assessee. (v) The assessee has not submitted as to how by any stretch of imagination, inspite of various hurdles as discussed and explained by the assessee as above, it was possible to complete and construct a 75 bed hospital

DEPUTY COMMISSIONER OF INCOME-TAX CIRCLE -5, PUNE vs. SERUM INSTITUTE OF INDIA PVT LTD.,, PUNE

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

Transfer Pricing Officer) on relying the decision of the Bombay High Court in the 2 case of Everest Kanto Cylinders Ltd. vs. Commissioner of Income Tax, Mumbai 58 Taxmann.com 254" however, the facts of the case are not identical. Hence, the same should be treated as international transaction and should be; added to the total income of the assessee. 2

DEPUTY COMMSSIONER OF INCOME TAX CIRCLE-1(1), PUNE vs. FERRERO INDIA PVT.LTD, PUNE

X ["Computation of income from international transactions having regard to arm's length price"] and Section 92 (1) which states that any income arising from an international transaction shall be computed having regard to the ALP and Section 92C (1) which sets out the different methods of determining the ALP, makes it clear that the transfer pricing adjustment is made

GOODYEAR SOUTH ASIA TYRES PVT.LTD,,AURANGABAD vs. ASSISTANT COMMISSIONER OF INCOME-TAX, CIRCLE - 1,, AURANGABAD

In the result, both the appeals are partly allowed

Bench: Shri R.S. Syal & Shri Partha Sarathi Chaudhuryिनधा"रण वष" / Assessment Year : 2014-15

X of the Act. The additional ground urging to set aside the transfer pricing addition on this count, in the prevailing facts is, ergo, not allowed. Goodyear South Asia Tyres Pvt. Ltd., 30. Having seen that neither the ALP determination of the assessee nor the Revenue is as per law, the next thing is to find out if the payment

GOODYEAR SOUTH ASIA TYRES PVT.LTD,,AURNAGABAD vs. ASSISTANT COMMISSIONER OF INCOME-TAX, CIRCLE - 1,, AURANGABAD

In the result, both the appeals are partly allowed

Bench: Shri R.S. Syal & Shri Partha Sarathi Chaudhuryिनधा"रण वष" / Assessment Year : 2014-15

X of the Act. The additional ground urging to set aside the transfer pricing addition on this count, in the prevailing facts is, ergo, not allowed. Goodyear South Asia Tyres Pvt. Ltd., 30. Having seen that neither the ALP determination of the assessee nor the Revenue is as per law, the next thing is to find out if the payment

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

price is more than the stamp duty value of the property, we find merit in the arguments of the Ld. Counsel for the assessee that there is no case for making addition u/s 56(2)(x) of the Act. Accordingly, the order of the CIT(A) / NFAC is set aside on this issue and the grounds of appeal No.7

DEPUTY COMMISSIONER OF INCOME-TAX,, PUNE vs. EATON FLUID POWER LTD.,, PUNE

In the result, the appeal of Revenue for assessment year 2011-12 is dismissed being devoid of any merit

Bench: Shri Anil Chaturvedi, Am & Shri Vikas Awasthy, Jm

X of the Act and the relevant Rules. In fact, as found both by the CIT(A) as well as the Tribunal that neither the method selected as the most appropriate method to determine the ALP is challenged nor the comparables taken by the respondent assessee is challenged by the TPO. Therefore, the ad-hoc determination