CIT v. Biocon Ltd.

DCIT, CC-7(2), Mumbai vs. M/S. Patanjali Foods Ltd., ( Formerly Known As Ruchi Soya Industries Ltd, Mumbai

In the result the appeal filed by the revenue stands dismissed

Bench: Shri Sandeep Gosain & Shri Prabhash Shankar

…IN THE INCOME TAX APPELLATE TRIBUNAL “C” BENCH, MUMBAI BEFORE SHRI SANDEEP GOSAIN, JUDICIAL MEMBER & SHRI PRABHASH SHANKAR, ACCOUNTANT MEMBER I.T.A. No. 319& 321/Mum/2023 A.Ys: 2007-08 & 2011-12 Patanjali Food Ltd (Formerly Vs Dy. CIT, CC – 7(2) Known as Ruchi Soya 655, 6th Floor, Aayakar Industries Ltd) Bhavan, MK Road, Mumbai 616, Tulsiani Chambers, – 400020. Nariman Point, Mumbai PAN – AAACR2892L (Appellant) (Respondent) I.T.A. No. 1173 & 1174/Mum/2023 A.Ys: 2007-08, 2011-12 Dy. CIT, CC – 7(2) Vs Patanjali Food Ltd 655, 6th Floor, Aayakar (Formerly Known as Ruchi Bhavan, MK Road, Mumbai – Soya Industries Ltd)…

DCIT, CC-7(2), Mumbai vs. M/S. Patanjali Foods Ltd., ( Formerly Known As Ruchi Soya Industries Ltd, Mumbai

In the result the appeal filed by the revenue stands dismissed

Bench: Shri Sandeep Gosain & Shri Prabhash Shankar

…IN THE INCOME TAX APPELLATE TRIBUNAL “C” BENCH, MUMBAI BEFORE SHRI SANDEEP GOSAIN, JUDICIAL MEMBER & SHRI PRABHASH SHANKAR, ACCOUNTANT MEMBER I.T.A. No. 319& 321/Mum/2023 A.Ys: 2007-08 & 2011-12 Patanjali Food Ltd (Formerly Vs Dy. CIT, CC – 7(2) Known as Ruchi Soya 655, 6th Floor, Aayakar Industries Ltd) Bhavan, MK Road, Mumbai 616, Tulsiani Chambers, – 400020. Nariman Point, Mumbai PAN – AAACR2892L (Appellant) (Respondent) I.T.A. No. 1173 & 1174/Mum/2023 A.Ys: 2007-08, 2011-12 Dy. CIT, CC – 7(2) Vs Patanjali Food Ltd 655, 6th Floor, Aayakar (Formerly Known as Ruchi Bhavan, MK Road, Mumbai – Soya Industries Ltd)…

Booking.Com India Support & Marketing Services Private Limited, Mumbai vs. Deputy Commissioner of Income Tax, Circle 6(1)(2), Mumbai

In the result, appeal of the assessee is partly allowed

Bench: Shri Narendra Kumar Billaiya, Hon’Ble & Shri Sandeep Singh Karhail, Hon’Ble

…| आयकर अपीलीय अिधकरण "ायपीठ, मुंबई | IN THE INCOME TAX APPELLATE TRIBUNAL “B” BENCH, MUMBAI BEFORE SHRI NARENDRA KUMAR BILLAIYA, HON’BLE ACCOUNTANT MEMBER & SHRI SANDEEP SINGH KARHAIL, HON’BLE JUDICIAL MEMBER I.T.A. No. 3675/Mum/2025 Assessment Year: 2020-21 Booking.Com India Support Principal Commissioner of & Marketing Services Income Tax, Mumbai - 6 Vs Private Limited Unit No. 06, Level 7 Parinee Crescenzo Plot No. 38/39, G Block Road Bandra Kurla Complex Bandra (East) S.O. Mumbai - 400051 [PAN: AAECB5759L] अपीलाथ"/ (Appellant) "" यथ"/ (Respondent) Assessee by : Shri Ajit Jain, Shri Siddhesh Chaugule & Ms. S…

Goldman Sachs (India) Finance Private Limited, Mumbai vs. Assessment Unit, Income-Tax Department, New Delhi

Bench: Shri Saktijit Dey & Ms Padmavathy S, Am

…IN THE INCOME TAX APPELLATE TRIBUNAL “G” BENCH, MUMBAI BEFORE SHRI SAKTIJIT DEY, VICE PRESIDENT & MS PADMAVATHY S, AM I.T.A. No. 6761/Mum/2024 (Assessment Year: 2017-18) I.T.A. No. 6762/Mum/2024 (Assessment Year: 2018-19) I.T.A. No. 6763/Mum/2024 (Assessment Year: 2020-21) I.T.A. No. 6765/Mum/2024 (Assessment Year: 2022-23) Goldman Sachs (India) Finance Pvt. Assessment Unit, Income-tax Ltd., Department, 951-A, Rational House, New Delhi-999999 Vs. Appasaheb Marathe Marg, Prabhadevi, Mumbai-400025. PAN: AAACP2448J Appellant) : Respondent) Appellant /Assessee by : Shri Hitesh Thakkar, AR, : Shri Swapnil Choudhar…

Goldman Sachs (India) Finance Private Limited, Mumbai vs. Assessment Unit, Income-Tax Department, New Delhi

Bench: Shri Saktijit Dey & Ms Padmavathy S, Am

…IN THE INCOME TAX APPELLATE TRIBUNAL “G” BENCH, MUMBAI BEFORE SHRI SAKTIJIT DEY, VICE PRESIDENT & MS PADMAVATHY S, AM I.T.A. No. 6761/Mum/2024 (Assessment Year: 2017-18) I.T.A. No. 6762/Mum/2024 (Assessment Year: 2018-19) I.T.A. No. 6763/Mum/2024 (Assessment Year: 2020-21) I.T.A. No. 6765/Mum/2024 (Assessment Year: 2022-23) Goldman Sachs (India) Finance Pvt. Assessment Unit, Income-tax Ltd., Department, 951-A, Rational House, New Delhi-999999 Vs. Appasaheb Marathe Marg, Prabhadevi, Mumbai-400025. PAN: AAACP2448J Appellant) : Respondent) Appellant /Assessee by : Shri Hitesh Thakkar, AR, : Shri Swapnil Choudhar…

Goldman Sachs (India) Finance Private Limited, Mumbai vs. Assessment Unit, Income-Tax Department, New Delhi

Bench: Shri Saktijit Dey & Ms Padmavathy S, Am

…IN THE INCOME TAX APPELLATE TRIBUNAL “G” BENCH, MUMBAI BEFORE SHRI SAKTIJIT DEY, VICE PRESIDENT & MS PADMAVATHY S, AM I.T.A. No. 6761/Mum/2024 (Assessment Year: 2017-18) I.T.A. No. 6762/Mum/2024 (Assessment Year: 2018-19) I.T.A. No. 6763/Mum/2024 (Assessment Year: 2020-21) I.T.A. No. 6765/Mum/2024 (Assessment Year: 2022-23) Goldman Sachs (India) Finance Pvt. Assessment Unit, Income-tax Ltd., Department, 951-A, Rational House, New Delhi-999999 Vs. Appasaheb Marathe Marg, Prabhadevi, Mumbai-400025. PAN: AAACP2448J Appellant) : Respondent) Appellant /Assessee by : Shri Hitesh Thakkar, AR, : Shri Swapnil Choudhar…

Goldman Sachs (India) Finance Private Limited, Mumbai vs. Assessment Unit, Income-Tax Department, New Delhi

Bench: Shri Saktijit Dey & Ms Padmavathy S, Am

…IN THE INCOME TAX APPELLATE TRIBUNAL “G” BENCH, MUMBAI BEFORE SHRI SAKTIJIT DEY, VICE PRESIDENT & MS PADMAVATHY S, AM I.T.A. No. 6761/Mum/2024 (Assessment Year: 2017-18) I.T.A. No. 6762/Mum/2024 (Assessment Year: 2018-19) I.T.A. No. 6763/Mum/2024 (Assessment Year: 2020-21) I.T.A. No. 6765/Mum/2024 (Assessment Year: 2022-23) Goldman Sachs (India) Finance Pvt. Assessment Unit, Income-tax Ltd., Department, 951-A, Rational House, New Delhi-999999 Vs. Appasaheb Marathe Marg, Prabhadevi, Mumbai-400025. PAN: AAACP2448J Appellant) : Respondent) Appellant /Assessee by : Shri Hitesh Thakkar, AR, : Shri Swapnil Choudhar…

DCIT Cen Cir 1(4), Mumbai vs. Grasim Industries Ltd, Mumbai

In the result, appeal of the revenue and the assessee are partly allowed, and the additional ground of the assessee is dismissed

Bench: Shri Narendra Kumar Billaiya & Shri Anikesh Banerjee

…tion. It has further been contended that revenue has not accepted the decision of the Hon’ble Madras High Court in the case of CIT v. PVP Venture Ltd. (23 taxmann.com 286) and the decision of the Hon’ble Karnataka High Court in the case of CIT vs. Biocon Ltd.(430 ITR 151), which affirmed the decision of the Hon’ble Special Bench and has filed a Special Leave Petition before the Hon’ble Supreme Court, which has been admitted. The claim of ESOP deduction has not attained the finality. The Ld. CIT(A) ought not to have allowed the claim of the assessee. It was further submitted that the Ld. CIT(A) ought not to have p…

Grasim Industries Limited, Mumbai vs. DCIT, CC-1(4), Mumbai

In the result, appeal of the revenue and the assessee are partly allowed,

Bench: Shri Narendra Kumar Billaiya & Shri Anikesh Banerjee

…tion. It has further been contended that revenue has not accepted the decision of the Hon'ble Madras High Court in the case of CIT v. PVP Venture Ltd. (23 taxmann.com 286) and the decision of the Hon'ble Karnataka High Court in the case of CIT vs. Biocon Ltd.(430 ITR 151), which affirmed the decision of the Hon'ble Special Bench and has filed a Special Leave Petition before the Hon'ble Supreme Court, which has been admitted. The claim of ESOP deduction has not attained the finality. The Ld. CIT(A) ought not to have allowed the claim of the assessee. It was further submitted that the Ld. CIT(A) ought not to have p…

Procter & Gamble Hygiene and Health Care Limited, Mumbai vs. DCIT-2(3)(1), Mumbai

In the result, appeal of the assessee is partly allowed

Bench: SHRI AMIT SHUKLA (Judicial Member), SMT RENU JAUHRI (Accountant Member)

…IN THE INCOME TAX APPELLATE TRIBUNAL, ‘C’ BENCH MUMBAI BEFORE: SHRI AMIT SHUKLA, JUDICIAL MEMBER & SMT RENU JAUHRI, ACCOUNTANT MEMBER Procter & Gamble Vs. Assessment Unit, Hygiene and Health National Faceless Care Limited Assessment Centre, 495, P & G Plaza Delhi Cardinal Gracias Road (Dy. Commissioner of Chakala, Andheri (E) Income Tax-2(3)(1), Mumbai – 400 099 Mumbai PAN/GIR No.AAACP6332M (Appellant) .. (Respondent) Assessee by Shri Yogesh Thar & Shri Urvish Shah Revenue by Shri R.A. Dhyani, CIT DR Date of Hearing 15/07/2025 Date of Pronouncement 31/07/2025 आदेश / O R D E R PER AMIT SHUKLA (J.M): The afor…

Hdfc Bank Ltd (Successor to Hdfc Ltd), Mumbai vs. DCIT-2(3)(1), Mumbai

In the result, the appeal of the assessee bearing ITA No

Bench: Shri Anikesh Banerjee & Smt. Renu Jauhrihdfc Bank Limited Vs The Deputy Commissioner Of (As Successor To Housing Income-Tax-2(3)(1), Mumbai Development Corporation Room No.552, Aaykar Bhavan Finance Limited), M.K. Road, Mumbai-400 020 Hdfc Bank House, Corporate Tax Department, Senapati Bapat Marg, Lower Parel, Mumbai-400013 Pan: Aaach2702H Applicant Respondent

…e of HDFC Bank Ltd. (supra) with similar view taken by Hon'ble Special Bench, ITAT, Bangalore in the case of Biocon Ltd., vs. DCIT [2013] 144 ITD 21 (Bang)(SB), the same having been approved by Hon'ble Court of Karnataka reported in CIT vs. Biocon Ltd. [2021] 430 ITR 151 (Kar). 28.4. Considering the facts on record and the judicial precedents relied upon, claim made by the assessee by way of additional ground is allowed in respect of Assessment Year 2013-14. However, based on our reasoning given while admitting the additional ground raised by the assessee for Assessment Year 2013- 14 in ITA No.4983/Mum/2017, bein…

Anunta Technology Management Services Limited, Mumbai vs. Deputy Commissioner of Income Tax, Circle 4(1)(1), Mumbai

In the result, the appeal by the assessee is allowed

Bench: Shri Narendra Kumar Billaiyashri Sandeep Singh Karhailanunta Technology Management Services Ltd., Level – 2, Block – 6, Nirlon Knowledge Park, Goregaon East, S.O. Mumbai ............... Appellant Mumbai - 400063 Pan : Aakca6159M V/S Dcit – 4(1)(1), ……………… Respondent Mumbai Assessee By : Shri K.K. Ved Revenue By : Shri Rajesh Kumar Yadav, Cit-Dr

…IN THE INCOME TAX APPELLATE TRIBUNAL “A” BENCH, MUMBAI BEFORE SHRI NARENDRA KUMAR BILLAIYA, ACCOUNTANT MEMBER SHRI SANDEEP SINGH KARHAIL, JUDICIAL MEMBER Anunta Technology Management Services Ltd., Level – 2, Block – 6, Nirlon Knowledge Park, Goregaon East, S.O. Mumbai ............... Appellant Mumbai - 400063 PAN : AAKCA6159M v/s DCIT – 4(1)(1), ……………… Respondent Mumbai Assessee by : Shri K.K. Ved Revenue by : Shri Rajesh Kumar Yadav, CIT-DR Date of Hearing – 03/07/2025 Date of Order - 09/07/2025 O R D E R PER SANDEEP SINGH KARHAIL, J.M. The assessee has filed the present appeal against the impugned order da…

Bajaj Electricals Ltd, Mumbai vs. Addl CIT 2(1), Mumbai

Accordingly we remit the impugned issue back to the AO with similar directions. The grounds raised by the assessee in this regard are allowed for statistical purposes

Bench: Hon’Ble Justice (Retd.) C V Bhadang & Ms Padmavathy S, Am

…IN THE INCOME TAX APPELLATE TRIBUNAL “B” BENCH, MUMBAI BEFORE HON’BLE JUSTICE (RETD.) C V BHADANG, PRESIDENT & MS PADMAVATHY S, AM I.T.A. No. 4172/Mum/2013 (Assessment Year: 2009-10) Bajaj Electricals Limited, Addl.CIT-2(1), 45/47, Bombay Life Building, Veer Aayakar Bhavan, M.K. Road, Vs. Nariman Road, Fort, Mumbai-400001. Mumbai-400020. PAN: AAACB2484Q Appellant) : Respondent) I.T.A. No. 110/Mum/2016 (Assessment Year: 2010-11) Bajaj Electricals Limited, Addl.CIT-2(1), 51, Mulla House, M.G. Road, Aayakar Bhavan, M.K. Road, Vs. Fort, mumbai-400001. Mumbai-400020. PAN: AAACB2484Q Appellant) : Respondent) I.T.A. No.…

DCIT 2(1)(1), Mumbai vs. Bajaj Electricals Ltd, Mumbai

Accordingly we remit the impugned issue back to the AO with similar directions. The grounds raised by the assessee in this regard are allowed for statistical purposes

Bench: Hon’Ble Justice (Retd.) C V Bhadang & Ms Padmavathy S, Am

…IN THE INCOME TAX APPELLATE TRIBUNAL “B” BENCH, MUMBAI BEFORE HON’BLE JUSTICE (RETD.) C V BHADANG, PRESIDENT & MS PADMAVATHY S, AM I.T.A. No. 4172/Mum/2013 (Assessment Year: 2009-10) Bajaj Electricals Limited, Addl.CIT-2(1), 45/47, Bombay Life Building, Veer Aayakar Bhavan, M.K. Road, Vs. Nariman Road, Fort, Mumbai-400001. Mumbai-400020. PAN: AAACB2484Q Appellant) : Respondent) I.T.A. No. 110/Mum/2016 (Assessment Year: 2010-11) Bajaj Electricals Limited, Addl.CIT-2(1), 51, Mulla House, M.G. Road, Aayakar Bhavan, M.K. Road, Vs. Fort, mumbai-400001. Mumbai-400020. PAN: AAACB2484Q Appellant) : Respondent) I.T.A. No.…

Bajaj Electricals Ltd, Mumbai vs. Addl CIT 2(1), Mumbai

Accordingly we remit the impugned issue back to the AO with similar directions. The grounds raised by the assessee in this regard are allowed for statistical purposes

Bench: Hon’Ble Justice (Retd.) C V Bhadang & Ms Padmavathy S, Am

…IN THE INCOME TAX APPELLATE TRIBUNAL “B” BENCH, MUMBAI BEFORE HON’BLE JUSTICE (RETD.) C V BHADANG, PRESIDENT & MS PADMAVATHY S, AM I.T.A. No. 4172/Mum/2013 (Assessment Year: 2009-10) Bajaj Electricals Limited, Addl.CIT-2(1), 45/47, Bombay Life Building, Veer Aayakar Bhavan, M.K. Road, Vs. Nariman Road, Fort, Mumbai-400001. Mumbai-400020. PAN: AAACB2484Q Appellant) : Respondent) I.T.A. No. 110/Mum/2016 (Assessment Year: 2010-11) Bajaj Electricals Limited, Addl.CIT-2(1), 51, Mulla House, M.G. Road, Aayakar Bhavan, M.K. Road, Vs. Fort, mumbai-400001. Mumbai-400020. PAN: AAACB2484Q Appellant) : Respondent) I.T.A. No.…

Livlong Insurance Brokers Limited, Mumbai vs. PCIT -4, Mumbai

Bench: Shri Sandeep Gosain & Shri Prabhash Shankar

…IN THE INCOME-TAX APPELLATE TRIBUNAL “A” BENCH, MUMBAI BEFORE SHRI SANDEEP GOSAIN, JUDICIAL MEMBER & SHRI PRABHASH SHANKAR, ACCOUNTANT MEMBER ITA No.2864/MUM/2025 (A.Y. 2020-21) Livlong Insurance Brokers V/s. Principal Commissioner of Limited, IIFL House, Sun बनाम Income Tax, Mumbai - 4, Infotech Park, Plot No. B23, Room No. 629, 6th Floor, Road No. 16, Wagle Estate, Aayakar Bhavan, Maharishi Thane- 400 604, Maharashtra Karve Road, Mumbai 400020, Maharashtra स्थायी लेखा सं./जीआइआर सं./PAN/GIR No: AABCI5762M Appellant/अपीलार्थी .. Respondent/प्रतिवादी Appellant by : Shri Pritesh Mehta,AR Respondent by : Shri Adity…