M/s. JP Morgan Services India Pvt. Ltd. v. DCIT

33 SOT 327Income Tax Appellate Tribunal2009#14564 most cited
7

judgments rely on this decision, according to BharatTax’s citation analysis of 346,713 Indian tax judgments — from 2015 to 2023.

Also reported as

116 Taxmann 191

Judgments citing M/s. JP Morgan Services India Pvt. Ltd. v. DCIT

Picric Ltd vs. ITO Ward 14 (4)

In the result, the appeal of the assessee is allowed with directions contained in para 22 above

ITA 4115/DEL/2007[2004-2005]Status: DisposedITAT Delhi06 Apr 2023AY 2004-2005

Bench: Shri G.S. Pannu, Hon’Ble & Ms. Astha Chandra

For Appellant: Shri Neeraj Jain,AdvocateFor Respondent: Shri H.K. Chaudhary, CIT(DR)
Section 10BSection 143(1)Section 143(3)Section 80H

…ion Bench of Hon’ble Karnataka High Court in the case of CIT vs. Motorola India Electronics (P) Ltd. (2014) 46 taxmann.com 167. 9.4 The Ld. AR also relied on the decision of the Mumbai Bench of the Tribunal in JP Morgan Services India (P) Ltd. vs. DCIT (2009) 33 SOT 327 (Mumbai) and drew our attention to para 11 thereof. In that case also the assessee was 100% exporter and the Tribunal held that interest from fixed deposits and interest on staff loan were income falling under the head ‘business’ and were eligible for deduction under section 10A. [The provisions of section 10A and 10B are identical]. This decision…

Gateway Terminals India P.Ltd, Navi Mumbai vs. DCIT Panvel Circle, Mumbai

The appeal stands partly allowed in terms of our above order

ITA 300/MUM/2018[2012-13]Status: DisposedITAT Mumbai28 May 2020AY 2012-13
For Appellant: Shri Porus Kaka- Ld. Sr. CounselFor Respondent: Shri N. Padmanabhan- Ld. DR
Section 115JSection 143(3)Section 80Section 80I

…1 Gateway Terminals Private Ltd. Assessment Year-2012-13 आयकरअपीलीयअ"धकरण“जी” "यायपीठमुंबईम"। IN THE INCOME TAX APPELLATE TRIBUNAL “G” BENCH, MUMBAI "ीमनोजकुमारअ"वाल, लेखासद"यएवं सु"ीमधु"मताराय, "या"यकसद"यकेसम"। BEFORE SHRI MANOJ KUMAR AGGARWAL, AM AND MS. MADHUMITA ROY, JM आयकरअपीलसं./ I.T.A. No.300/Mum/2018 ("नधा"रणवष"/ Assessment Year: 2012-13) M/s. Gateway Terminals Pvt. Ltd. DCIT-Panvel Circle बनाम/ GTI House, Jawaharlal Nehru Port Ashar I.T. Park, Road No.16Z Sheva, District-Uran Vs. Wagle Estate Navi Mumbai-400 707. Thane (W)-400 604. "थायीलेखासं./जीआइआरसं./PAN/GIR No. AACCG-1899-E (अपीलाथ"/Appellant) (""य…

Laxmi Narain Khaitan, Noida vs. Addl. CIT, Noida

In the result appeal filed by assessee stands allowed

ITA 2952/DEL/2015[2002-03]Status: DisposedITAT Delhi12 Nov 2018AY 2002-03

Bench: Smt. Beena A Pillai & Shri Prashant Maharishiay: 2002-03 Shri Laxmi Narain Khaitan Vs. Addl.Cit, (Proprietor : M/S Vrindavan Range-Noida Carpets) Noida. A 41-42, Sector 2 Noida 201 301 Pan: Afrpk1398F (Appellant) (Respondent)

For Appellant: Sh. R.K.Gupta, Adv. &For Respondent: Sh. Surender Pal, Sr. D.R
Section 142Section 143Section 80Section 80H

…urpose of computing deduction under section 80HHC has been allowed. She submitted that the Tribunal while granting relief to assessee placed reliance upon the decision of Hon’ble Bombay High Court in the case of CIT us. Punit Commercial Ltd reported in (2001) 116 Taxmann 191. 4.1. Ld.AR further submitted that assessee is only carrying out export business and therefore the ratio laid down by Hon’ble Bombay High Court in the case of CIT vs. Punit Commercial Ltd., (supra) squarely covers the issue in favour of assessee. 5. Ld.Sr.DR though placed reliance upon the orders of authorities below, could not controvert the…

Value Labs LLP, Hyd, Hyderabad vs. DCIT, Circle-8(1), Hyderabad

In the result, grounds pertaining to ‘other income’ are considered allowed and grounds pertaining to interest income are considered allowed for statistical purposes

ITA 392/HYD/2016[2009-10]Status: DisposedITAT Hyderabad24 Jan 2018AY 2009-10

Bench: Smt. P. Madhavi Devi & Shri B. Ramakotaiah

For Appellant: Shri P. Murali Mohan Rao, ARFor Respondent: Smt. N. Swapna, DR
Section 10Section 10ASection 10BSection 56

…income and other income have direct nexus with the activity of business and that these receipts form part of business of assessee. It relied on the following case law: i. Order of ITAT, Mumbai in the case of M/s. JP Morgan Services India Pvt. Ltd., Vs. DCIT [33 SOT 327] (Mumbai); ii. Judgment in the case of CIT Vs. Punit Commercial Ltd., [116 Taxmann 191] (Bombay); iii. Judgment in the case of CIT Vs. Lok Holding [308 ITR 356] (Bombay); iv. Judgment in the case of CIT Vs. Eltek SGS (P) Ltd., [300 ITR 6] (Delhi); 4. Ld.CIT(A), however, did not accept the contentions and following the principles laid down by the…

J.P Morgan Services India P.Ltd, Mumbai vs. DCIT Cir 8(2), Mumbai

In the result, appeal filed by the assessee is treated as partly allowed

ITA 477/MUM/2013[2008-09]Status: DisposedITAT Mumbai25 May 2016AY 2008-09

Bench: Shri Mahavir Singh & Shri Ashwani Tanejaassessment Year: 2008-09 J.P. Morgan Services India P. Dcit 8(2) Ltd., Aayakar Bhavan, बनाम/ Prism Tower, Level No.9 To M.K. Rd Vs. 11, Link Rd, Mindspace, Mumbai-400020 Malad (W) Mumbai-400064 (Assessee) (Revenue) P.A. No.Aabcd0503B

Section 10ASection 143(3)Section 234BSection 271(1)(c)Section 92C

…Act. 8. It is the submission of the Counsel that the issue is covered by the decision of the Tribunal in assessee’s own case for A.Y. 2004-05 and to substantiate his claim, the assessee submitted the decision of the Tribunal in assessee’s own case reported in 33 SOT 327. Drawing our attention to Para-11 of the said order of the Tribunal, the Ld. Counsel for the assessee submitted that the Tribunal has directed to tax the interest under the head “Profits & gains of business or profession”. 9. The Ld. Departmental Representative relied upon the findings of the lower authorities. 10. We have carefully perused the o…

J.P. Morgan Services India P.Ltd, Mumbai vs. Asst CIT (OSD) 8(1), Mumbai

In the result, both the appeals of the assessee are partly allowed

ITA 7822/MUM/2011[2007-08]Status: DisposedITAT Mumbai30 Nov 2015AY 2007-08

Bench: Shri Amit Shukla & Shri Ashwani Tanejaassessment Year: 2006-07 & Assessment Year: 2007-08 J.P. Morgan Services P. Ltd., Dcit (Osd)-8(1) Technopolis Knowledge Park, Mumbai- बनाम/ 3Rd Floor, Mahakali Caves Vs. Road, Chakala Junction, Andheri(E) Mumba-400093 (Assessee) (Revenue) P.A. No.Aabcd0503B

…Act. 8. It is the submission of the Counsel that the issue is covered by the decision of the Tribunal in assessee’s own case for A.Y. 2004-05 and to substantiate his claim, the assessee submitted the decision of the Tribunal in assessee’s own case reported in 33 SOT 327. Drawing our attention to Para-11 of the said order of the Tribunal, the Ld. Counsel for the assessee submitted that the Tribunal has directed to tax the interest under the head “Profits & gains of business or profession”. 9. The Ld. Departmental Representative relied upon the findings of the lower authorities. 10. We have carefully perused the or…

J.P . Morgan Services India P. Ltd, Mumbai vs. DCIT (OSD) 8(1), Mumbai

In the result, both the appeals of the assessee are partly allowed

ITA 8987/MUM/2010[2006-07]Status: DisposedITAT Mumbai30 Nov 2015AY 2006-07

Bench: Shri Amit Shukla & Shri Ashwani Tanejaassessment Year: 2006-07 & Assessment Year: 2007-08 J.P. Morgan Services P. Ltd., Dcit (Osd)-8(1) Technopolis Knowledge Park, Mumbai- बनाम/ 3Rd Floor, Mahakali Caves Vs. Road, Chakala Junction, Andheri(E) Mumba-400093 (Assessee) (Revenue) P.A. No.Aabcd0503B

…Act. 8. It is the submission of the Counsel that the issue is covered by the decision of the Tribunal in assessee’s own case for A.Y. 2004-05 and to substantiate his claim, the assessee submitted the decision of the Tribunal in assessee’s own case reported in 33 SOT 327. Drawing our attention to Para-11 of the said order of the Tribunal, the Ld. Counsel for the assessee submitted that the Tribunal has directed to tax the interest under the head “Profits & gains of business or profession”. 9. The Ld. Departmental Representative relied upon the findings of the lower authorities. 10. We have carefully perused the or…

M/s. JP Morgan Services India Pvt. Ltd. v. DCIT (33 SOT 327) — Cited in 7 Judgments | BharatTax