Central Circle 10, Mumbai (2008) 110 ITD 158 (Mum). (ii). Informed Technologies India Ltd. v. DCIT-3(2), Mumbai (162 ITD 153)

APTIVE COMPONENTS INDIA P.LTD (FORMERLY KNOWN AS M/S DELPHI AUTOMOTIVE SYSTEMS PVT. LTD.),NEW DELHI vs. DCIT CIRCLE-3(1), NEW DELHI

In the result, appeal of the assessee in respect of ground no

ITA 1129/DEL/2020[2005-06]Status: DisposedITAT Delhi19 Dec 2025AY 2005-06

Bench: Shri Challa Nagendra Prasad & Shri Brajesh Kumar Singh[Assessment Year: 2005-06] M/S Aptiv Components India Deputy Commissioner Of Income Private Limited Tax, (Formerly Known As M/S Delphi Vs Circle-3(1), Automotive Systems Pvt. Ltd.) Room No.-380B, C.R. Building P-24, Green Part Extn., Delhi- I.P. Estate, 110016. Delhi-110002. Pan- Aaacd0226E Assessee Revenue

Section 10ASection 143(3)

…e above, it is respectfully submitted that any disallowance made to the total income will increase profits eligible for deduction under section 10A of the Act. Reliance in this regard is placed on the case of Informed Technologies India Ltd. v. Dy. CIT [2017] 162 ITD 153 (Mum. Trib.) wherein the core issue is as to whether pursuant to disallowance of expenses under section 14A, a consequential enhancement of deduction allowable under section 10A is liable to be made or not. It was held as under: "6.2 We have given a thoughtful consideration to the factual position so averred by the Ld. A.R. before us and find th…

NAVBHARAT POTTERIES PRIVATE LIMITED,MUMBAI vs. DEPUTY COMMISSIONER OF INCOME TAX - CIRCLE 7(1)(1), MUMBAI

In the result, appeal filed by the assessee is partly allowed in above\nterms

ITA 2700/MUM/2024[2016-17]Status: DisposedITAT Mumbai05 Mar 2025AY 2016-17

Section 142(1)Section 143(3)Section 147Section 22Section 23(1)(c)Section 250

…Pune) (ii). ACIT, Circle-47(1), New Delhi Vs. Dr. Prabha Sanghi (2012) 139 ITD\n504 (Del); (iii). Premsudha Exports (P) Ltd. Vs. ACIT, Central Circle 10, Mumbai (2008)\n110 ITD 158 (Mum); and (iv). Informed Technologies India Ltd. Vs. DCIT3(2), Mumbai\n(2017) 162 ITD 153 (Mum). We find that in the case of Informed technologies India Ltd.\n(supra) the Tribunal after deliberating at length on the issue as regards the scope and\ngamut of Sec. 23(1)(c) of the Act, had observed as under :-\n“7.1 We have considered the rival submissions of either side and perused the\nrelevant material on record, including the orders o…

AMANDA JOY PURAVANKARA ,BENGALURU vs. ASSISTANT COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-1(4), BENGALURU

In the result, appeal of the assessee is allowed

ITA 109/BANG/2024[2015-16]Status: DisposedITAT Bangalore10 Apr 2024AY 2015-16

Bench: Shri George George K. & Shri Chandra Poojariassessment Year: 2015-16

For Appellant: Shri Narendra Sharma, A.RFor Respondent: Shri Ganesh R. Ghale, Standing Counsel for Revenue

Section 143(3)Section 23(1)(c)Section 234CSection 250

…rder passed by the learned CIT(A) and the addition made by the Assessing Officer and sustained by the learned CIT(A) is deleted.” 3.1 Similarly, this issue was considered by Mumbai Bench of Tribunal in the case of Informed Technologies India Ltd. reported in 162 ITD 153 (Mum), wherein held as under: “IT: As long as a property is let in earlier period and is found vacant for whole year under consideration, subject to condition that such vacancy of property is not for self occupation of same by assessee, ALV of said property would be determined under section 23(1)(c)”. 3.2 While adjudicating the above issue, the…

JAYABEN V. SHETH & OTHERS,MUMBAI vs. ACIT 19 (2), MUMBAI

In the result, appeal by assessee is allowed

ITA 7219/MUM/2018[2015-16]Status: DisposedITAT Mumbai11 Jan 2021AY 2015-16

Bench: Shri Vikas Awasthyआअसं. 7219 /मुं/2018 ("न.व.2015-16) M/S.Jayaben V Sheth & Others, 3, Ground Floor, Vincent View, Dr. B.A.Road, Dadar(E), Mumbai 400 014. : अपीलाथ"/ Appellant Pan:Aadfj4327Q बनाम/ Vs. The Acit 19(2), Matru Mandir, Tardeo, Mumbai 400 034 : ""थ"/ Respondent

For Appellant: Shri Phalgoon DesaiFor Respondent: Shri Ajay Pratap Singh

Section 143(1)Section 154Section 23Section 23(1)(c)

…ings under section 154 of the Act. The ld.Authorized Representative of the assessee in support of his contentions placed reliance on the following decisions: (i) Presudha Export vs. ACIT, 295 ITR (AT) 341(Mum) (ii) Informed Technologies India Ltd. vs. DCIT, 162 ITD 153 (Mum-Trib) 4 3. Per contra, Shri Ajay Pratap Singh, representing the Department vehemently defended the impugned order and prayed for dismissing the appeal of the assessee. The ld.Departmental Representative submitted that no material has been placed on record by the assessee to show steps taken for letting out property. The property in questio…

SONU REALTORS PVT. LTD.,MUMBAI vs. DCIT - 14 (3)(2), MUMBAI

In the result, appeal of the assessee is allowed

ITA 5081/MUM/2018[2013-14]Status: DisposedITAT Mumbai06 Dec 2019AY 2013-14

Bench: Shri Rajesh Kumar, Hon. & Shri Amarjit Singh, Hon.M/S. Sonu Realtors Pvt. Ltd., Vs. Dcit, Circle-14(3)(2), Plot No. 219, Laalasis, 11Th Mumbai Road, Chembur, Mumbai.

For Appellant: Shri J.P. Bairagra, CAFor Respondent: Shri V. Vinod Kumar, Sr.DR

Section 23Section 23(1)(a)Section 23(1)(c)

…7 (Pune) (ii). ACIT, Circle-47(1), New Delhi Vs. Dr. Prabha Sanghi (2012) 139 ITD 504 (Del); (iii). Premsudha Exports (P) Ltd. Vs. ACIT, Central Circle 10, Mumbai (2008) 110 ITD 158 (Mum); and (iv). Informed Technologies India Ltd. Vs. DCIT3(2), Mumbai (2017) 162 ITD 153 (Mum). We find that in the case of Informed technologies India Ltd. (supra) the Tribunal after deliberating at length on the issue as regards the scope and gamut of Sec. 23(1)(c) of the Act, had observed as under : “ “7.1 We have considered the rival submissions of either side and perused the relevant material on record, including the orders of t…

SONU REALTORS P.LTD,MUMBAI vs. DCIT 14(3)(2), MUMBAI

The appeal of the assessee is allowed

ITA 66/MUM/2017[2012-13]Status: DisposedITAT Mumbai19 Sept 2018AY 2012-13

Bench: Shri G. Manjunatha & Shri Ravish Soodita No. 2892 /Mum/2016 & Sonu Realtors Pvt. Ltd. Dcit – 14(3)(2) Plot No. 219, Laalasis, Mumbai 11Th Road, Chembur, Vs. Mumbai 400 071. Pan – Aaacs7073C Appellant Respondent Appellant By : Shri. J.P Bairagra Respondent By : Shri Rajat Mittal Date Of Hearing : 05.07.2018 Date Of Pronouncement :19.09.2018 O R D E R Per Ravish Sood, Jm The Present Appeals Filed By The Assessee For A.Y 2011-12 & A.Y 2012-13 Are Directed Against The Respective Orders Passed By The Cit(A)-22, Mumbai, Dated 22.01.2016 & 27.09.2016. As A Common Issue Is Involved In The Aforementioned Appeals, Thus, The Same Are Being Taken Up & Disposed Off Together By Way Of A Consolidate Order. We Shall First Take Up The Appeal Of The Assessee For A.Y 2011-12. The Assessee Assailing The Order Passed By The Cit(A) Has Raised Before Us The Following Grounds Of Appeal :

For Appellant: Shri. J.P BairagraFor Respondent: Shri Rajat Mittal

Section 143(2)Section 22Section 23(1)(a)Section 23(1)(c)

…on of Sec. 23(1)(c), relied on the following orders of the coordinate benches of the Tribunal: (i). Premsudha Exports (P) Ltd. Vs. ACIT, Central Circle 10, Mumbai (2008) 110 ITD 158 (Mum). (ii). Informed Technologies India Ltd. Vs. DCIT-3(2), Mumbai (2017) 162 ITD 153 (Mum) Sonu Realtors Pvt. Ltd. Vs. DCIT-14(3)(2), Mumbai 5 ITA No. 2892/Mum/2016 & ITA No. 66/Mum/2017 A.Ys 2011-12 & 2012-13 (iii). ACIT, Circle-47(1), New Delhi Vs. Dr. Prabha Sanghi (2012) 139 ITD 504 (Del) In the backdrop of his aforesaid contentions, it was submitted by the ld. A.R that as the CIT(A) had erred in concluding that the provis…

SONU REALTORS PVT. LTD.,MUMBAI vs. DCIT 14(3)(2), MUMBAI

The appeal of the assessee is allowed

ITA 2892/MUM/2016[2011-12]Status: DisposedITAT Mumbai19 Sept 2018AY 2011-12

Bench: Shri G. Manjunatha & Shri Ravish Soodita No. 2892 /Mum/2016 & Sonu Realtors Pvt. Ltd. Dcit – 14(3)(2) Plot No. 219, Laalasis, Mumbai 11Th Road, Chembur, Vs. Mumbai 400 071. Pan – Aaacs7073C Appellant Respondent Appellant By : Shri. J.P Bairagra Respondent By : Shri Rajat Mittal Date Of Hearing : 05.07.2018 Date Of Pronouncement :19.09.2018 O R D E R Per Ravish Sood, Jm The Present Appeals Filed By The Assessee For A.Y 2011-12 & A.Y 2012-13 Are Directed Against The Respective Orders Passed By The Cit(A)-22, Mumbai, Dated 22.01.2016 & 27.09.2016. As A Common Issue Is Involved In The Aforementioned Appeals, Thus, The Same Are Being Taken Up & Disposed Off Together By Way Of A Consolidate Order. We Shall First Take Up The Appeal Of The Assessee For A.Y 2011-12. The Assessee Assailing The Order Passed By The Cit(A) Has Raised Before Us The Following Grounds Of Appeal :

For Appellant: Shri. J.P BairagraFor Respondent: Shri Rajat Mittal

Section 143(2)Section 22Section 23(1)(a)Section 23(1)(c)

…on of Sec. 23(1)(c), relied on the following orders of the coordinate benches of the Tribunal: (i). Premsudha Exports (P) Ltd. Vs. ACIT, Central Circle 10, Mumbai (2008) 110 ITD 158 (Mum). (ii). Informed Technologies India Ltd. Vs. DCIT-3(2), Mumbai (2017) 162 ITD 153 (Mum) Sonu Realtors Pvt. Ltd. Vs. DCIT-14(3)(2), Mumbai 5 ITA No. 2892/Mum/2016 & ITA No. 66/Mum/2017 A.Ys 2011-12 & 2012-13 (iii). ACIT, Circle-47(1), New Delhi Vs. Dr. Prabha Sanghi (2012) 139 ITD 504 (Del) In the backdrop of his aforesaid contentions, it was submitted by the ld. A.R that as the CIT(A) had erred in concluding that the provis…

Central Circle 10, Mumbai (2008) 110 ITD 158 (Mum). (ii). Informed Technologies India Ltd. v. DCIT-3(2), Mumbai

Sections most often in play

Issues it is cited on

Judgments citing Central Circle 10, Mumbai (2008) 110 ITD 158 (Mum). (ii). Informed Technologies India Ltd. v. DCIT-3(2), Mumbai