Milton Laminates Ltd. v. CIT

SKY HIGH II LEASING COMPANY LIMITED ,MUMBAI vs. THE ASSISTANT COMMISSIONER OF INCOME TAX (INTERNATIONAL TAX) CIRCLE 4(2)(1), MUMBAI

Bench: Shri Amit Shukla, Jm & Ms Padmavathy S, Am

…IN THE INCOME TAX APPELLATE TRIBUNAL “I” BENCH, MUMBAI BEFORE SHRI AMIT SHUKLA, JM & MS PADMAVATHY S, AM I.T.A. No. 1546/Mum/2025 (Assessment Year: 2022-23) Sky High Lxxix Leasing Co. Ltd., The ACIT (IT), Circle-4(2)(1), Room No. 627, 6th Floor, 2, Grand Canal Square, Grand Canal Harbour, Dublin D02 A342, Vs. Kautalya Bhavan, G. Block, Ireland, State outside India-D02 A342. Bandra Kurla Complex, PAN: ABFCS0570G Bandra (East), Mumbai-400051. Appellant) : Respondent) I.T.A. No. 1547/Mum/2025 (Assessment Year: 2022-23) Sky High XC Leasing Co. Ltd., The ACIT (IT), Circle-4(2)(1), Room No. 627, 6th Floor, 2, Grand C…

SKY HIGH LXXX LEASING COMPANY LIMITED ,MUMBAI vs. THE ASSISTANT COMMISSIONER OF INCOME TAX (INTERNATIONAL TAX) CIRCLE 4(2)(1), MUMBAI

Bench: Shri Amit Shukla, Jm & Ms Padmavathy S, Am

…IN THE INCOME TAX APPELLATE TRIBUNAL “I” BENCH, MUMBAI BEFORE SHRI AMIT SHUKLA, JM & MS PADMAVATHY S, AM I.T.A. No. 1546/Mum/2025 (Assessment Year: 2022-23) Sky High Lxxix Leasing Co. Ltd., The ACIT (IT), Circle-4(2)(1), Room No. 627, 6th Floor, 2, Grand Canal Square, Grand Canal Harbour, Dublin D02 A342, Vs. Kautalya Bhavan, G. Block, Ireland, State outside India-D02 A342. Bandra Kurla Complex, PAN: ABFCS0570G Bandra (East), Mumbai-400051. Appellant) : Respondent) I.T.A. No. 1547/Mum/2025 (Assessment Year: 2022-23) Sky High XC Leasing Co. Ltd., The ACIT (IT), Circle-4(2)(1), Room No. 627, 6th Floor, 2, Grand C…

SKY HIGH LXXVIII LEASING COMPANY LIMITED ,MUMBAI vs. THE ASSISTANT COMMISSIONER OF INCOME TAX (INTERNATIONAL TAX) CIRCLE 4(2)(1), MUMBAI

Bench: Shri Amit Shukla, Jm & Ms Padmavathy S, Am

…IN THE INCOME TAX APPELLATE TRIBUNAL “I” BENCH, MUMBAI BEFORE SHRI AMIT SHUKLA, JM & MS PADMAVATHY S, AM I.T.A. No. 1546/Mum/2025 (Assessment Year: 2022-23) Sky High Lxxix Leasing Co. Ltd., The ACIT (IT), Circle-4(2)(1), Room No. 627, 6th Floor, 2, Grand Canal Square, Grand Canal Harbour, Dublin D02 A342, Vs. Kautalya Bhavan, G. Block, Ireland, State outside India-D02 A342. Bandra Kurla Complex, PAN: ABFCS0570G Bandra (East), Mumbai-400051. Appellant) : Respondent) I.T.A. No. 1547/Mum/2025 (Assessment Year: 2022-23) Sky High XC Leasing Co. Ltd., The ACIT (IT), Circle-4(2)(1), Room No. 627, 6th Floor, 2, Grand C…

SKY HIGH LXXIX LEASING COMPANY LIMITED ,MUMBAI vs. THE ASSISTANT COMMISSIONER OF INCOME TAX (INTERNATIONAL TAX) CIRCLE 4(2)(1), MUMBAI

Bench: Shri Amit Shukla, Jm & Ms Padmavathy S, Am

…IN THE INCOME TAX APPELLATE TRIBUNAL “I” BENCH, MUMBAI BEFORE SHRI AMIT SHUKLA, JM & MS PADMAVATHY S, AM I.T.A. No. 1546/Mum/2025 (Assessment Year: 2022-23) Sky High Lxxix Leasing Co. Ltd., The ACIT (IT), Circle-4(2)(1), Room No. 627, 6th Floor, 2, Grand Canal Square, Grand Canal Harbour, Dublin D02 A342, Vs. Kautalya Bhavan, G. Block, Ireland, State outside India-D02 A342. Bandra Kurla Complex, PAN: ABFCS0570G Bandra (East), Mumbai-400051. Appellant) : Respondent) I.T.A. No. 1547/Mum/2025 (Assessment Year: 2022-23) Sky High XC Leasing Co. Ltd., The ACIT (IT), Circle-4(2)(1), Room No. 627, 6th Floor, 2, Grand C…

DCIT CC-3(4) MUMBAI, MUMBAI vs. ESSAR PORTS LIMITED, MUMBAI

Appeal are dismissed, being bereft of merit and devoid of substance

Bench: Shri Amit Shukla, Hon’Ble & Shri Arun Khodpia, Hon’Bledcit Cc 3(4), Mumbai Essar Ports Limited 11, Keshavrao Khadye Marg 613, Kautilya Bhawan G Clock Mahalaxmi Vs Bkc Bandra, Mumbai – 400034 Mumbai – 400051, Maharastra Maharastra

…IN THE INCOME TAX APPELLATE TRIBUNAL, MUMBAI BENCH ‘E’, MUMBAI BEFORE SHRI AMIT SHUKLA, HON’BLE JUDICIAL MEMBER AND SHRI ARUN KHODPIA, HON’BLE ACCOUNTANT MEMBER DCIT CC 3(4), Mumbai Essar Ports Limited 11, Keshavrao Khadye Marg 613, Kautilya Bhawan G Clock Mahalaxmi vs BKC Bandra, Mumbai – 400034 Mumbai – 400051, Maharastra Maharastra PAN: AAACE8391D (Appellant) (Respondent) Present for: Assessee by : Shri Tarang Mehta Revenue by : Shri Ritesh Misra, CIT DR Date of Hearing : 13.08.2025 Date of Pronouncement : 18.08.2025 O R D E R PER ARUN KHODPIA, AM: The captioned appeal by the revenue, emerged out of th…

ASSISTANT COMMISSIONER OF INCOME TAX, MUMBAI vs. ESSAR PORTS LTD., MUMBAI

In the result, appeal of the Revenue is dismissed

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

…IN THE INCOME TAX APPELLATE TRIBUNAL, ‘K‘ BENCH MUMBAI BEFORE: SHRI AMIT SHUKLA, JUDICIAL MEMBER & SMT RENU JAUHRI, ACCOUNTANT MEMBER Asst. Commissioner of Vs. M/s. Essar Ports Ltd. Income Tax 11th Floor, Essar House Circle-6(1)(1)Mumbai 11, K.K. Marg Range-6(10 Mahalaxmi Mumbai – 400 034 PAN/GIR No.AAACE8391D (Appellant) .. (Respondent) Assessee by Shri Vijay Mehta Revenue by Shri Heera Ram Choudhary Date of Hearing 07/05/2024 Date of Pronouncement 09/05/2024 आदेश / O R D E R PER AMIT SHUKLA (J.M): The aforesaid appeal has been filed by the Revenue against order dated 07/12/2023 passed by CIT(A)-56, Mumbai…

IL&FS MARITIME INFRASTRUCTURE COMPANY LIMITED,MUMBAI vs. THE DEPUTY COMMISSIONER OF INCOME TAX-14(1)(1), MUMBAI

Bench: Shri Vikas Awasthy & Shri Amarjit Singh

…Page 1 ITA No.3558/Mum/2023 IL & FS Maritime Infrastructure Company Ltd. Vs. The DCIT, 14(1)(1) IN THE INCOME TAX APPELLATE TRIBUNAL “C” BENCH, MUMBAI BEFORE SHRI VIKAS AWASTHY, JUDICIAL MEMBER & SHRI AMARJIT SINGH, ACCOUNTANT MEMBER ITA No.3558/Mum/2023 (A.Y. 2013-14) IL & FS Maritime Infrastructure Company Ltd, Plot, C-22, G Block, the IL & FS Financial Centre, Bandra Kurla Complex, Bandra East, Mumbai – 400051 Vs. The DCIT, 14(1)(1) Room No. 432, 4th Floor, Aayakar Bhawan, M.K. Road, Churchgate, Mumbai - 400020 स्थायी लेखा सं./जीआइआर सं./PAN/GIR No:AABCI7029R Appellant Respondent Appellant by : Ms. Hetal Vora…

STRIDES SHASUN LTD,NAVI MUMBAI vs. DCIT CIR 15(3)(2), MUMBAI

In the result, appeal of assessee is partly allowed

Bench: Shri Vikas Awasthy& Shri Amarjit Singhआअसं.932 /मुं/2017 (िन.व. 2012-13) Strides Pharma Science Limited [Formerly Known As Strides Arcolab Limited/ Strides Shasun Limited] 201, Devavrata, Sector -17, Vashi, Navi Mumbai – 400 703 Pan: Aadcs-8104-P ...... अपीलाथ"/Appellant बनाम Vs. The Deputy Commissioner Of Income Tax Circle – 15(3)(2), Mumbai Room No.451, 4Th Floor, Aaykar Bhavan, M.K.Road, Mumbai – 400 020 ..... "ितवादी/Respondent अपीलाथ" "ारा/ Appellant By : Shri Nitesh Joshi, Advocate With Shri Ninand Patade "ितवादी "ारा/Respondent By : Shri Anoop Hiwase सुनवाई क" ितिथ/ Date Of Hearing : 26/10/2023 घोषणा क" ितिथ/ Date Of Pronouncement : 15 /01/2024 आदेश/Order Per Vikas Awasthy, Jm: This Appeal By The Assessee Is Directed Against The Final Assessment Order Dated 23/01/2017 Passed U/S. 143(3) R.W.S. 144C(13) Of The Income Tax Act, 1961 [In Short ‘The Act’], For The Assessment Year 2012-13. 2. The Assessee In Appeal Has Raised As Many As 12 Grounds. Shri Nitesh Joshi, Advocate Appearing On Behalf Of The Assessee Submitted At The Outset

…ed income going below the returned income. In this regard, we find that the Hon’ble Gujarat High Court in the case of Gujarat Gas Company Ltd., vs. JCIT reported in 245 ITR 84 and also in later decision in the case of Milton Laminates Ltd., vs CIT reported in 37 Taxmann.com 249 had categorically held that the assessed income could go below the returned income if assessee had disclosed certain income which is not supposed to be disclosed as per law. Respectfully following the said decision, we direct the ld. AO to delete the voluntary disallowance of Rs.33,62,493/- made by the assessee u/s.14A of the Act even if u…

STRIDES SHASUN LTD,NAVI MUMBAI vs. DCIT CIR 15(3)(2), MUMBAI

In the result, appeal of the assessee is partly allowed

Bench: Shri Vikas Awasthy& Shri Amarjit Singhआअसं.7400 /मुं/2017 (िन.व. 2013-14) Strides Pharma Science Limited [Formerly Known As Strides Arcolab Limited/ Strides Shasun Limited] 201, Devavrata, Sector -17, Vashi, Navi Mumbai – 400 703 Pan: Aadcs-8104-P ...... अपीलाथ"/Appellant बनाम Vs. The Deputy Commissioner Of Income Tax Circle – 15(3)(2), Mumbai Room No.451, 4Th Floor, Aaykar Bhavan, M.K.Road, Mumbai – 400 020 ..... "ितवादी/Respondent अपीलाथ" "ारा/ Appellant By : Shri Nitesh Joshi, Advocate With Shri Ninand Patade "ितवादी "ारा/Respondent By : Shri Anoop Hiwase & Dr. Samuel Pitta सुनवाई क" ितिथ/ Date Of Hearing : 30/10/2023 घोषणा क" ितिथ/ Date Of Pronouncement : 15/01/2024 /01/2024 आदेश/Order Per Vikas Awasthy, Jm: This Appeal By The Assessee Is Directed Against The Final Assessment Order Dated 30/10/2017 Passed U/S. 143(3) R.W.S. 144C(13) Of The Income Tax Act, 1961 [In Short ‘The Act’], For The Assessment Year 2013-14. 2 2. The Assessee In Appeal Has Raised Ten Grounds Of Appeal. The Assessee Has Also Raised Additional Grounds Of Appeal Vide Application Dated 26/10/2023. 3. The Ground No.1 Of Appeal Is General In Nature, Hence, Require No Separate Adjudication.

…ed income going below the returned income. In this regard, we find that the Hon’ble Gujarat High Court in the case of Gujarat Gas Company Ltd., vs. JCIT reported in 245 ITR 84 and also in later decision in the case of Milton Laminates Ltd., vs CIT reported in 37 Taxmann.com 249 had categorically held that the assessed income could go below the returned income if assessee had disclosed certain income which is not supposed to be disclosed as per law. Respectfully following the said decision, we direct the ld. AO to delete the voluntary disallowance of Rs.33,62,493/- made by the assessee u/s.14A of the Act even if u…

CYQYATOR MEDIA PRIVATE LIMITED ,MUMBAI vs. ASSISTANT COMMISSIONER OF INCOME TAX CENTRAL CIRCLE-6(2)(1), MUMBAI

In the result, appeal of the assessee is partly allowed in the terms aforesaid

Bench: Shri Vikas Awasthy& Shri Amarjit Singh आअसं.2370 /मुं/2023 (िन.व. 2015-16) Cyquator Media Services Private Limited, 18Th Floor, A Wing Marathon Futurex, N.M.Joshi Marg, Lower Parel, Mumbai – 400 013. Pan: Aaecp-0069-P ...... अपीलाथ"/Appellant बनाम Vs. Asstt.Commissioner Of Income Tax Central Circle – 6(2)(1), Mumbai Aaykar Bhavan, M.K.Road, Mumbai – 400 021 ..... "ितवादी/Respondent अपीलाथ" "ारा/ Appellant By : Shri Jay Bhansali "ितवादी "ारा/Respondent By : Shri Prabhat Kumar Gupta सुनवाई क" ितिथ/ Date Of Hearing : 18/10/2023 घोषणा क" ितिथ/ Date Of Pronouncement : 23/10/2023 आदेश/Order Per Vikas Awasthy, Jm: This Appeal By The Assessee Is Directed Against The Order Of Commissioner Of Income Tax (Appeals), National Faceless Appeal Centre, Delhi[ In Short ‘The Cit(A)’] Dated 21/06/2023, For The Assessment Year 2015- 16. 2. The Assessee In Appeal Has Raised As Many As Eight Grounds. All The Grounds Of Appeal Are In Respect Of A Single Issue I.E. Disallowance U/S. 14A Of 2 The Income Tax Act, 1961 [In Short ‘The Act’] R.W. Rule 8D Of The Income Tax Rules, 1962 [In Short ‘The Rules’].

…आयकर अपीलीय अिधकरण मुंबई पीठ “सी ”,मुंबई "ी िवकास अव"थी, "याियक सद"य एवं "ी अमरजीत "सह, लेखाकार सद"य के सम" IN THE INCOME TAX APPELLATE TRIBUNAL MUMBAI BENCH “ C ”, MUMBAI BEFORE SHRI VIKAS AWASTHY, JUDICIAL MEMBER& SHRI AMARJIT SINGH , ACCOUNTANT MEMBER आअसं.2370 /मुं/2023 (िन.व. 2015-16) Cyquator Media Services Private Limited, 18th Floor, A Wing Marathon Futurex, N.M.Joshi Marg, Lower Parel, Mumbai – 400 013. PAN: AAECP-0069-P ...... अपीलाथ"/Appellant बनाम Vs. Asstt.Commissioner of Income Tax Central Circle – 6(2)(1), Mumbai Aaykar Bhavan, M.K.Road, Mumbai – 400 021 ..... "ितवादी/Respondent अपीलाथ" "ारा/ A…

STRIDES SHASUN LTD,NAVI MUMBAI vs. DCIT CIR 15(3)(2), MUMBAI

Bench: Shri Kuldip Singh & Ms. Padmavathy Sassessment Year: 2011-12

…ed income going below the returned income. In this regard, we find that the Hon’ble Gujarat High Court in the case of Gujarat Gas Company Ltd., vs. JCIT reported in 245 ITR 84 and also in later decision in the case of Milton Laminates Ltd., vs CIT reported in 37 Taxmann.com 249 had categorically held that the assessed income could go below the returned income if assessee had disclosed certain income which is not supposed to be disclosed as per law. Respectfully following the said decision, we direct the ld. AO to delete the voluntary disallowance of Rs.33,62,493/- made by the assessee u/s.14A of the Act even if u…

RENAISSANCE SERVICES BV,MUMBAI vs. DCIT (INTERNATIONAL TAX) 4(1) (1), MUMBAI

In the result, appeal filed by assessee is allowed

Bench: Shri Vikas Awasthy & Shri Gagan Goyalrenaissance Services Bv, C/O Marriott Hotels India Pvt. Ltd. 303A, 304, Fulcrum, B-Wing, Hiranandani Business Park, Sahar Road, Andheri (East), Mumbai-400099 Pan: Aaecr4995E ...... Appellant Vs. Dcit (International Taxation)-4(1)(1), 17Th Floor, Room No. 1712, Air India Building, Nariman Point, Mumbai-400021 ..... Respondent

…ned income, still the assessee would be entitled for the relief. Reliance in this regard is made on the decision of the Hon'ble Gujarat High Court in the case of Gujarat Gas Limited vs. JCIT reported in 245 ITR 84 and Milton Laminates Ltd, vs. CIT reported in 37 Taxmann.com 249 (Hon'ble Gujarat High Court). 12.1. On merits, the ld. DR also pointed out that during the year, the ld. AO treated the receipts from computer reservation system as equipment royalty which was not decided by the Tribunal in earlier years and accordingly he argued that the decision of the Tribunal in earlier years would not be applicable fo…

DCIT (IT) -4(1) (1), MUMBAI vs. RENAISSANCE SERVICES BV, MUMBAI

1758/Mum/2021 2013-14

…ed income, still the assessee would be entitled for the relief. Reliance in this regard is made on the decision of the Hon’ble Gujarat High Court in the case of Gujarat Gas Limited vs. JCIT reported in 245 ITR 84 and Milton Laminates Ltd., vs. CIT reported in 37 Taxmann.com 249 (Hon’ble Gujarat High Court). 12.1. On merits, the ld. DR also pointed out that during the year, the ld. AO treated the receipts from computer reservation system as equipment royalty which was not decided by the Tribunal in earlier years and accordingly he argued that the decision of the Tribunal in earlier years would not be applicable fo…

DCIT (IT) -4 (1) (1) , MUMBAI vs. RENAISSANCE SERVICES BV, MUMBAI

1758/Mum/2021 2013-14

…ed income, still the assessee would be entitled for the relief. Reliance in this regard is made on the decision of the Hon’ble Gujarat High Court in the case of Gujarat Gas Limited vs. JCIT reported in 245 ITR 84 and Milton Laminates Ltd., vs. CIT reported in 37 Taxmann.com 249 (Hon’ble Gujarat High Court). 12.1. On merits, the ld. DR also pointed out that during the year, the ld. AO treated the receipts from computer reservation system as equipment royalty which was not decided by the Tribunal in earlier years and accordingly he argued that the decision of the Tribunal in earlier years would not be applicable fo…

RENAISSANCE SERVICES BV,MUMBAI vs. ACIT (INTERNATIONAL TAX) 4(1) (1) , MUMBAI

1758/Mum/2021 2013-14

…ed income, still the assessee would be entitled for the relief. Reliance in this regard is made on the decision of the Hon’ble Gujarat High Court in the case of Gujarat Gas Limited vs. JCIT reported in 245 ITR 84 and Milton Laminates Ltd., vs. CIT reported in 37 Taxmann.com 249 (Hon’ble Gujarat High Court). 12.1. On merits, the ld. DR also pointed out that during the year, the ld. AO treated the receipts from computer reservation system as equipment royalty which was not decided by the Tribunal in earlier years and accordingly he argued that the decision of the Tribunal in earlier years would not be applicable fo…

RENAISSANCE SERVICES BV,MUMBAI vs. DDIT (IT) 2(1), MUMBAI

In the result, appeal of the assessee for A

…ed income, still the assessee would be entitled for the relief. Reliance in this regard is made on the decision of the Hon’ble Gujarat High Court in the case of Gujarat Gas Limited vs. JCIT reported in 245 ITR 84 and Milton Laminates Ltd., vs. CIT reported in 37 Taxmann.com 249 (Hon’ble Gujarat High Court). 12.1. On merits, the ld. DR also pointed out that during the year, the ld. AO treated the receipts from computer reservation system as equipment royalty which was not decided by the Tribunal in earlier years and accordingly he argued that the decision of the Tribunal in earlier years would not be applicable f…