“Section 37(1)”

DCIT, Central Circle-3(2), Mumbai vs. M/S Viraj Profiles Private Limited, Mumbai

In the result, all the appeals filed by the Revenue are

professional fees in its entirety. The Tribunal categorically held that the expenditure was genuine, incurred for business purposes, and was duly allowable under section 37(1). 21. Armed with this decision, the assessee urged before the CIT(A) that the very foundation of the penalty had collapsed, since the addition ... salaries paid to employees were not properly substantiated in his view. He therefore proceeded to disallow such expenses, treating them as inadmissible under section 37(1) of the Act. 36. The assessee carried the matter in appeal. For assessment years 2011-12 and 2013–14, the Tribunal eventually quashed

DCIT, Central Circle-3(2), Mumbai vs. M/S Viraj Profiles Private Limited, Mumbai

In the result, all the appeals filed by the Revenue are dismissed

Bench: SHRI AMIT SHUKLA (Judicial Member), SHRI PRABHASH SHANKAR (Accountant Member)

professional fees in its entirety. The Tribunal categorically held that the expenditure was genuine, incurred for business purposes, and was duly allowable under section 37(1). 21. Armed with this decision, the assessee urged before the CIT(A) that the very foundation of the penalty had collapsed, since the addition ... salaries paid to employees were not properly substantiated in his view. He therefore proceeded to disallow such expenses, treating them as inadmissible under section 37(1) of the Act. 36. The assessee carried the matter in appeal. For assessment years 2011–12 and 2013–14, the Tribunal eventually quashed

DCIT, Central Circle-3(2), Mumbai vs. Viraj Profiles Private Limited, Mumbai

In the result, all the appeals filed by the Revenue are

Bench: Hon'Ble Income Tax Appellate Tribunal, Mumbai 'F' Bench M/S Viraj Profiles Private Limited Summary Of Penalty Appeals Sr. No. Nature Of Addition/ Disallowance Ay 2011-12 U/S 271(1)(C) Ay 2013-14 U/S 271(1)(C) Ay 2015-16 U/S 271(1)(C) Ay 2017-18 U/S 271Aab Ay 2018-19 U/S 271Aab (Amt In Inr) Total Addition Made U/S 143(3)

professional fees in its entirety. The Tribunal categorically held that the expenditure was genuine, incurred for business purposes, and was duly allowable under section 37(1). 21. Armed with this decision, the assessee urged before the CIT(A) that the very foundation of the penalty had collapsed, since the addition ... salaries paid to employees were not properly substantiated in his view. He therefore proceeded to disallow such expenses, treating them as inadmissible under section 37(1) of the Act. 36. The assessee carried the matter in appeal. For assessment years 2011-12 and 2013–14, the Tribunal eventually quashed

DCIT, Central Circle-3(2), Mumbai vs. Viraj Profiles Private Limited, Mumbai

In the result, all the appeals filed by the Revenue are dismissed

Bench: SHRI AMIT SHUKLA (Judicial Member), SHRI PRABHASH SHANKAR (Accountant Member)

professional fees in its entirety. The Tribunal categorically held that the expenditure was genuine, incurred for business purposes, and was duly allowable under section 37(1). 21. Armed with this decision, the assessee urged before the CIT(A) that the very foundation of the penalty had collapsed, since the addition ... salaries paid to employees were not properly substantiated in his view. He therefore proceeded to disallow such expenses, treating them as inadmissible under section 37(1) of the Act. 36. The assessee carried the matter in appeal. For assessment years 2011–12 and 2013–14, the Tribunal eventually quashed

Colgate Palmolive (India) Limited, Mumbai vs. Principal Commissioner of Income Tax -6, Mumbai

In the result, appeal of the assessee is allowed

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

case and in law, the learned PCIT erred in holding that deduction towards Employee Stock Option Plan (ESOP) expenditure claimed under section 37(1) of the Act was erroneously allowed in the assessment order and disregarding the fact that the said amount being actually paid is deductible in accordance with ... Appellant prays that the learned AO be directed to allow claim of ESOP expenditure paid under section 37(1) of the Act.” 2.1. Aforesaid grounds raised by the assessee in the present appeal relate to revisionary proceeding initiated u/s.263 and revisionary order passed thereunder. The issue raised in the revisionary

Arham Star, Mumbai vs. ITO Ward 19(2)(2), Piramal Chamber

In the result, appeal of the assessee is partly allowed

Bench: Shri Saktijit Dey, Hon'Ble & Shri Girish Agrawalassessment Year: 2010-11 Arham Star Income-Tax Officer, Cw-2090, Bharat Diamond Ward - 19(2)(2), Bourse, Bandra Kurla Mumbai Vs. Complex, Mumbai - 400051 (Pan: Aaafs5695M) (Appellant) (Respondent) Present For: Assessee : Shri Rahul Sarda, Advocate Revenue : Shri Surendra Mohan, Sr. Dr Date Of Hearing : 13.08.2025 Date Of Pronouncement : 26.09.2025 O R D E R Per Girish Agrawal: This Appeal Filed By Assessee Is Against The Order Of Cit (A), National Faceless Appeal Centre (Nfac), Delhi Vide Order No. Itba/Nfac/S/250/2024-25/1075308198(1), Dated 30/03/2025 Passed Against The Assessment Order By Income-Tax Officer, 19(1)(1), Mumbai, U/S.144 Of The Income-Tax Act, 1961 (Hereinafter Referred To As The “Act”), Dated 22.12.2017 For Assessment Year 2010-11. 2. Grounds Taken By The Assessee Are Reproduced As Under: 1. The Nfac Failed To Appreciate That The Purchases Made By The Appellant Were Genuine & Supported By Documentary Material Including The Corroboration Of Sales Made From Such Purchases & There Was Not Material To Show That The Purchases Were Not Genuine & Hence, The Same Could Not Have Been Disallowed. 2. The Nfac Erred In Upholding The Addition On The Basis Of Generalized Statements In The Assessment Order Without The Assessing Officer Having Conducted Any Enquiry In The Matter.

IN THE INCOME TAX APPELLATE TRIBUNAL “A” BENCH MUMBAI BEFORE SHRI SAKTIJIT DEY, HON'BLE VICE PRESIDENT AND SHRI GIRISH

Mahindra and Mahindra Limited (As Sucessor to Mahindra Two Wheelers Limited Which in Turn Is Sucessor to Mahindra Trucks and Buses Limited), Mumbai vs. Deputy Commissioner of Income Tax Circle 2(2)(1), Mumbai

taxmann.com 21 (Madras) - Held that expenditure on product advertisement, marketing and brand promotion is revenue in nature and allowable as deduction under section 37(1) of the Act  Indiabuild Villas Development (P.) Ltd. v. DCIT [2018] 98 taxmann.com 187 (Bangalore - Trib.) - Held expenses on brand identity, logo and collateral design ... Holdings (P.) Ltd. Citation: (2012) 21 taxmann.com 165 (Delhi) Relevant Principle: Expenditure incurred on neon signs and glow signs qualifies for deduction under section 37(1) 7. Asian Paints Ltd. Citation: (2012) 102 taxmann.com 375 (Bombay) Relevant Principle: Expenditure incurred on 'Colour Idea Stores' as a part of its advertisement

Hapag Lloyd India Private Limited, Mumbai vs. Principal Commissioner of Income-Tax, Mumbai - 5, Aayakar Bhavan, Mumbai

In the result, the appeal is allowed

Bench: Shri Saktijit Dey & Shri Arun Khodpiahapag Lloyd India Private Limited Pr. Cit Room No. 515, 5Th Floor, 501, Satellite Gazebo, B-Wing, 5Th Floor, Guru Hargovindaji Marg, Aayakar Bhawan, M.K. Road, Vs. Andheri (E), Chakala Mide S.O., Mumbai-400 020 Mumbai-400 093 Pan/Gir No. Aabch 7319 B (Appellant) : (Respondent) : Shri Paras Savla, Adv. A/W Appellant By Shri Pratik Poddar, Adv. & Shri Shreyas Sardesai Respondent By : Shri Ritesh Misra, Cit Dr Date Of Hearing : 23.09.2025 Date Of Pronouncement : 25.09.2025 O R D E R Per Saktijit Dey: The Captioned Appeal Has Been Filed By The Assessee, Assailing The Order Dated 11.03.2025 Passed By Learned Principal Commissioner Of Income Tax (‘Ld. Pcit’ For Short), Mumbai U/S. 263 Of The Income Tax Act, 1961 (‘The Act’ For Short), Pertaining To The Assessment Year (A.Y.) 2020-21. 2. The Grounds Raised By The Assessee Are As Under: Validity Of Revision Proceedings Under Section 263 Of The Act 1. On Facts & Circumstances Of The Case & In Law, The Leamed Pcit Erred In Passing An Order Under Section 263 Of The Act Without Appreciating That The Assessment Order Dated 5 September 2022 Passed By The Learned Assessing Officer ('Ao') Under Section 143(3) Read With Section 144B Of The Act Was Neither Erroneous Nor Prejudicial To The Interest Of The Revenue & Thus, The Order Under Section 263 Of The Act Is Without Jurisdiction & Bad-In-Law.

IN THE INCOME TAX APPELLATE TRIBUNAL “E” BENCH, MUMBAI BEFORE SHRI SAKTIJIT DEY, VICE PRESIDENT AND SHRI ARUN KHODPIA, ACCOUNTANT

Rajnish Wellness Limited, Mumbai vs. ITO, Mumbai

In the result, the appeal of assessee is allowed for statistical purposes

Bench: Shri Vikram Singh Yadav & Shri Rahul Chaudharyassessment Year : 2018-19 Rajnish Wellness Limited, Income Tax Officer, 6Th Floor, Ward-5(3)(1), Navjivan Commercial, Vs. Aayakar Bhavan, Lamington Road, Mumbai-400020. Mumbai Central, Mumbai-400008. Pan : Aahcr3491G (Appellant) (Respondent) For Assessee : None For Revenue : Shri Annavaram Kosuri, Sr.Dr Date Of Hearing : 23-09-2025 Date Of Pronouncement : 24-09-2025 O R D E R Per Vikram Singh Yadav, A.M : This Is An Appeal Filed By The Assessee Against The Order Of The Learned Commissioner Of Income Tax (Appeals)-National Faceless Appeal Centre (Nfac), Delhi [„Ld.Cit(A)‟], Dated 25-03-2025, Pertaining To Assessment Year (Ay) 2018-19. 2. Briefly The Facts Of The Case Are That The Assessee Filed Its Return Of Income Which Was Selected For Limited Scrutiny To Verify The Genuineness Of The Large Scale Promotion Expenses. Notices U/S. 143(2) & 142(1) Of The Income Tax Act, 1961 („The Act‟) Were Issued Calling For The Necessary

IN THE INCOME TAX APPELLATE TRIBUNAL MUMBAI “D” BENCH : MUMBAI BEFORE SHRI VIKRAM SINGH YADAV, ACCOUNTANT MEMBER AND SHRI RAHUL

Dilipkumar Phoolchand Jain, Mumbai vs. DCIT, Circle 20(1), Mumbai

In the result, the appeal of the assessee is allowed for statistical purposes

Bench: Shri Vikram Singh Yadav & Shri Rahul Chaudharyassessment Year : 2020-21 Dilipkumar Phoolchand Jain, Dcit, Circle-20(1), A/1901-1902, Piramal Chambers, Vardhman Heights, Vs. Dr.Ss Rao Marg, Tb Kadam Marg, Parel, Byculla (East), Mumbai-400012. Mumbai-400027. Pan : Aarpj1996K (Appellant) (Respondent) For Assessee : Mr. Dipesh Ruparelia (Virtually Present) For Revenue : Shri Annavaram Kosuri, Sr.Dr Date Of Hearing : 22-09-2025 Date Of Pronouncement : 24-09-2025 O R D E R Per Vikram Singh Yadav, A.M :

Section 57 of the Act without appreciating the fact that the Appellant could have claimed the Interest expense as a business expense under Section 37(1) of the Act, which would in-turn lead to a business loss at which would have been allowed to be duly set off against ... Section 57 of the Act without appreciating the fact that the Appellant could have claimed the interest expense as a business expense under Section 37(1) of the Act and the balance business expense (which is not set off) could have been carried forward by the Appellant for 8 assessment