DCIT v. Bank of Bahrain & Kuwait

NOMURA CAPITAL (INDIA) PRIVATE LIMITED ,MUMBAI vs. DEPUTY COMMISSIONER OF INCOME TAX CIRCLE 7(1)(1), MUMBAI

In the result, grounds raised by the assessee are allowed

Bench: SHRI AMIT SHUKLA (Judicial Member), SHRI GIRISH AGRAWAL (Accountant Member)

…IN THE INCOME TAX APPELLATE TRIBUNAL “B” BENCH MUMBAI BEFORE SHRI AMIT SHUKLA, JUDICIAL MEMBER AND SHRI GIRISH AGRAWAL, ACCOUNTANT MEMBER Assessment Year: 2012-13 Nomura Capital (India) Private Deputy Commissioner of Income Limited Tax - Circle -7(1)(1), Level 11 Ceejay House, Dr Mumbai Annie Besant Road, Plot F, Vs. Shiv Sagar Estate Worli, Mumbai – 400 018 (PAN: AADCN0596Q) (Appellant) (Respondent) Present for: Assessee : Shri Madhur Agarwal, Advocate Revenue : Shri Leyaqat Ali Aafaqui, Sr. DR Date of Hearing : 11.11.2025 Date of Pronouncement : 05.02.2026 O R D E R PER GIRISH AGRAWAL, ACCOUNTANT MEMBER: This a…

ICICI BANK LTD,MUMBAI vs. ADDL CIT RG 3 (1), MUMBAI

Bench: Smt. Beena Pillai & Shri Omkareshwar Chidara

…allowable as a deduction as the loss would have crystallized if the contract was closed on the Balance Sheet date. The Ld.AR also relied on the decision of Hon'ble Special Bench of the of the Mumbai Tribunal in case of Bank of Bahrain and Kuwait, reported in 132 TTJ 505 relying on the Supreme Court decision, has recently decided in August 2010 that MTM losses on forward contracts are allowable, as a binding obligation is created against the assessee as soon as a forward contract is entered into ITA No.4249 & 4159/Mum/2014 ICICI Bank Ltd. 30 and if an assessee follows the same consistent method for accounting for…

DCIT CIR 3(1), MUMBAI vs. ICICI BANK LTD, MUMBAI

Bench: Smt. Beena Pillai & Shri Omkareshwar Chidara

…allowable as a deduction as the loss would have crystallized if the contract was closed on the Balance Sheet date. The Ld.AR also relied on the decision of Hon'ble Special Bench of the of the Mumbai Tribunal in case of Bank of Bahrain and Kuwait, reported in 132 TTJ 505 relying on the Supreme Court decision, has recently decided in August 2010 that MTM losses on forward contracts are allowable, as a binding obligation is created against the assessee as soon as a forward contract is entered into 28 ITA No.4249 & 4159/Mum/2014 ICICI Bank Ltd. and if an assessee follows the same consistent method for accounting for…

TECH MAHINDRA LIMITED (EARLIER KNOWN AS MAHINDRA ENGINEERING SERVICES LTD,MUMBAI vs. DY COMMISSIONER OF INCOME TAX RANGE 1(3), MUMBAI

In the result, the appeal filed by the assessee is partly allowed and the appeal filed

Bench: Shri Prashant Maharishi, Am & Ms. Kavitha Rajagopal, Jm Tech Mahindra Limited Dy. Cit, Range 2(2) (Earlier Known As Mahindra Mumbai Engineering Services Limited) Vs. Gateway Building, Apollo Bunder, Mumbai-400 001 Pan/Gir No. Aaacm 3484 F (Assessee) (Revenue) : & Asst. Cit-2(3)(1) Tech Mahindra Ltd. Mumbai (Earlier Known As Mahindra Engineering Services Ltd.) Vs. Mahindra Tower, 1St Floor, B Wing, Dr. G M Bhosale Marg, P K Kurne Chowk, Worli, Mumbai-400 018 Pan/Gir No. Aaacm 3484 F (Revenue) : (Assessee)

…unal in assessee’s case for A.Y. 2008- 09 in ITA No. 2604/Mum/2012 vide order dated 20.03.2018 which held in favour of the assessee. The ld. AR also relied on the decision of the Special bench of the Tribunal in the case of DCIT vs. Bank of Bahrain & Kuwait (41 SOT 290 (Mum)) and the Hon'ble Jurisdictional High Court decision in the case of Inventurus Knowledge Services Pvt. Ltd. vs. ITO (in ITA No. 5922/Mum/2013). 19. On perusal of the order of the Tribunal in assessee’s case for A.Y. 2008-09, it is observed that on identical facts, the tribunal has decided this issue in favour of the assessee by allowing th…

DCIT 2(2), MUMBAI vs. MAHINDRA ENGINEERING SERVICES LTD, MUMBAI

In the result, the appeal filed by the assessee is partly allowed and the appeal filed

Bench: Shri Prashant Maharishi, Am & Ms. Kavitha Rajagopal, Jm Tech Mahindra Limited Dy. Cit, Range 2(2) (Earlier Known As Mahindra Mumbai Engineering Services Limited) Vs. Gateway Building, Apollo Bunder, Mumbai-400 001 Pan/Gir No. Aaacm 3484 F (Assessee) (Revenue) : & Asst. Cit-2(3)(1) Tech Mahindra Ltd. Mumbai (Earlier Known As Mahindra Engineering Services Ltd.) Vs. Mahindra Tower, 1St Floor, B Wing, Dr. G M Bhosale Marg, P K Kurne Chowk, Worli, Mumbai-400 018 Pan/Gir No. Aaacm 3484 F (Revenue) : (Assessee)

…unal in assessee’s case for A.Y. 2008- 09 in ITA No. 2604/Mum/2012 vide order dated 20.03.2018 which held in favour of the assessee. The ld. AR also relied on the decision of the Special bench of the Tribunal in the case of DCIT vs. Bank of Bahrain & Kuwait (41 SOT 290 (Mum)) and the Hon'ble Jurisdictional High Court decision in the case of Inventurus Knowledge Services Pvt. Ltd. vs. ITO (in ITA No. 5922/Mum/2013). 19. On perusal of the order of the Tribunal in assessee’s case for A.Y. 2008-09, it is observed that on identical facts, the tribunal has decided this issue in favour of the assessee by allowing th…

ICICI BANK LTD,MUMBAI vs. ADDL CIT RG (1), MUMBAI

Appeals are partly allowed

Bench: Shri Amit Shukla () & Ms. Padmavathy S. ()

…IN THE INCOME TAX APPELLATE TRIBUNAL MUMBAI BENCH “H”, MUMBAI BEFORE SHRI AMIT SHUKLA (JUDICIAL MEMBER) AND MS. PADMAVATHY S. (ACCOUNTANT MEMBER) I.T.A. No.4248/Mum/2014 A.Y. 2007-08 ICICI Bank Ltd The Deputy Commissioner of ICICI Bank Towers Income-tax, Circle-3(1), Bandra Kurla Complex vs Aayakar Bhavan Bandra (East), Mumbai-400 051 Mumbai-400 020 PAN : AAAC11195H APPELLANT RESPONDENT I.T.A. No.4158/Mum/2014 A.Y. 2007-08 The Deputy Commissioner of ICICI Bank Ltd Income-tax, Circle-3(1), ICICI Bank Towers Aayakar Bhavan vs Bandra Kurla Complex Mumbai-400 020 Bandra (East), Mumbai-400 051 PAN : AAAC11195H APPELL…

DCIT CIR 3(1), MUMBAI vs. ICICI BANK LTD, MUMBAI

Appeals are partly allowed

Bench: Shri Amit Shukla () & Ms. Padmavathy S. ()

…IN THE INCOME TAX APPELLATE TRIBUNAL MUMBAI BENCH “H”, MUMBAI BEFORE SHRI AMIT SHUKLA (JUDICIAL MEMBER) AND MS. PADMAVATHY S. (ACCOUNTANT MEMBER) I.T.A. No.4248/Mum/2014 A.Y. 2007-08 ICICI Bank Ltd The Deputy Commissioner of ICICI Bank Towers Income-tax, Circle-3(1), Bandra Kurla Complex vs Aayakar Bhavan Bandra (East), Mumbai-400 051 Mumbai-400 020 PAN : AAAC11195H APPELLANT RESPONDENT I.T.A. No.4158/Mum/2014 A.Y. 2007-08 The Deputy Commissioner of ICICI Bank Ltd Income-tax, Circle-3(1), ICICI Bank Towers Aayakar Bhavan vs Bandra Kurla Complex Mumbai-400 020 Bandra (East), Mumbai-400 051 PAN : AAAC11195H APPELL…

CONCENTRIX SERVICES INDIA PRIVATE LIMITED (FORMERLY KNOWN AS MINACS PRIVATE LIMITED, MINACS LIMITED & ADITY BIRLA MINACS WORLDWIDE LIMITED ),MUMBAI vs. JOINT COMMISSIONER OF IT (OSD)10(2)(2)ASSISTANT COMMISSIONER OF INCOME TAX-9(2)(2), MUMBAI

…INR 7,15,92,175/- by placing reliance upon the judgment of the Hon’ble Supreme Court in the case of CIT Vs. Woodward Governor India Private Limited: [SC] 312 ITR 254, decision of Special Bench of the Tribunal in the case of DCIT Vs. Bank of Bahrain & Kuwait : 41 SOT 290 (Mumbai Tribunal) (SB) and the decision of Mumbai Bench of the Tribunal in the case of ACIT-16(3) Vs. M/s Venus Jewel [ITA Nos. 7328 & 7239/Mum/2013, dated 31/07/2015]. 25.3. Being aggrieved by the above relief granted by the CIT(A), the Revenue is now in appeal before us on this issue. 25.4. Both the sides reiterated the stands taken before the a…

CONCENTRIX SERVICES INDIA PRIVATE LIMITED (FORMERLY KNOWN AS MINACS PRIVATE LIMITED, MINACS LIMITED & ADITY BIRLA MINACS WORLDWIDE LIMITED ),MUMBAI vs. DEPUTY COMMISSIONER OF INCOME TAX-10(2)(2), MUMBAI

…INR 7,15,92,175/- by placing reliance upon the judgment of the Hon’ble Supreme Court in the case of CIT Vs. Woodward Governor India Private Limited: [SC] 312 ITR 254, decision of Special Bench of the Tribunal in the case of DCIT Vs. Bank of Bahrain & Kuwait : 41 SOT 290 (Mumbai Tribunal) (SB) and the decision of Mumbai Bench of the Tribunal in the case of ACIT-16(3) Vs. M/s Venus Jewel [ITA Nos. 7328 & 7239/Mum/2013, dated 31/07/2015]. 25.3. Being aggrieved by the above relief granted by the CIT(A), the Revenue is now in appeal before us on this issue. 25.4. Both the sides reiterated the stands taken before the a…