IN THE INCOME TAX APPELLATE TRIBUNAL PUNE BENCHES “B”, PUNE BEFORE DR.MANISH BORAD, ACCOUNTANT MEMBER AND SHRI VINAY BHAMORE, JUDICIAL MEMBER आयकर अपील स.ं / ITA No.201/PUN/2025 Assessment Year : 2015-16 Shriniwas Engineering Auto Vs. ACIT, Circle-6, Components Pvt. Ltd., Pune Office No.5, Mansara Apartments, Near LIC Building, Shivajinagar, Pune 411016 Maharashtra PAN : AAJCS8944F Appellant Respondent Appellant by : Shri Hari Krishan Respondent by : Shri Amit Bobde Date of hearing : 13.10.2025 Date of pronouncement : 10.12.2025 आदेश / ORDER PER DR. MANISH BORAD, ACCOUNTANT MEMBER :

The captioned appeal at the instance of assessee is directed against the order dated 26.11.2024 framed by National Faceless Appeal Centre, Delhi emanating out of Assessment Order dated 30.12.2017 passed u/s.143(3) of the Income Tax Act, 1961 (in short ‘the Act’).

2. Assessee has raised following grounds of appeal :

“The following grounds of appeal are taken independently and without prejudice to one another.

1. The Ld. CIT(Appeals) has erred in dismissing the Ground No. (i) of the assessee in respect of the addition of ₹37,84,89,268 made by the Assessing Officer on account of the capital subsidy received fr