ASSISTANT COMMISSIONER OF INCOMETAX, MUMBAI vs. VIACOM18 MEDIA PVT LTD, MUMBAI

Appeals of the assessee are allowed partly for statistical purposes whereas appeal of the Revenue is dismissed

Bench: Shri Om Prakash Kant () & Shri Raj Kumar Chauhan ()

additional TDS credit of Rs TDS revised return of income and it claimed an additional TDS credit of Rs TDS

TATA MOTORS LTD,MUMBAI vs. ACIT 2(3), MUMBAI

In the result, appeal of the assessee is partly allowed

Bench: Shri Vikas Awasthy& Shri S.Rifaur Rahmanआअसं.631/मुं/2013 (िन.व. 2008-09) Tata Motors Limited Bombay House, 24,Homi Mody Street, Hutama Chowk, Mumbai – 400001. Pan: Aaact-2727-Q ...... अपीलाथ"/Appellant बनाम Vs. The Addl. Commissioner Of Income Tax Circle -2(3), Mumbai. Aaykar Bhavan, M.K.Road, Mumbai – 400 020 ....."ितवादी/Respondent अपीलाथ" "ारा/ Appellant By : Shri J.D.Mistry, Sr.Advocate With Shri Nikhil Tiwari,Advocate "ितवादी "ारा/Respondent By : Ms. Vatsala Jha, Cit-Dr & Shri Manoj Kumar Singh, Sr.Ar सुनवाई की ितिथ/ Date Of Hearing : 10/11/2023 घोषणा की ितिथ/ Date Of Pronouncement : 05/02/2024 आदेश/Order Per Vikas Awasthy, Jm:

Income Tax (6th Amendment) Rules 2012 with 43 retrospective effect from 01/04/2012 as applicable for Assessment Year 2012- 13. Therefore, the TPO could not have applied ‘Other Method’ at the relevant point of time. Hence, the TPO adopted insured value. 46. We have heard the submissions made by rival sides. The TPO made adjustment in respect of the land

DAIWA CAPITAL MARKETS INDIA PRIVATE LIMITED ,LOWER PAREL vs. ASST COMMISSIONER OF INCOME TAX CIRCLE 4 1 1 MUMBAI , MUMBAI

In the result, appeal filed by the assessee is allowed in above terms

Bench: Shri Om Prakash Kant & Shri Raj Kumar Chauhandaiwa Capital Markets India Acit Circle 4(1)(1), Private Limited Room No. 640, 6Th Floor, Office No. N10 & N11, 9Th Floor, Vs. Aayakar Bhavan, M.K. Road, Dextrus-Peninsula Tower, Peninsula Mumbai-400 020 Corporate Park, G. K. Marg, Lower Parel, Delisle Road, Mumbai-400 013 Pan: Aaccd7178B (Appellant) (Respondent) Assessee Represented By : Ms. Shivali Mhatre, Ld. Ar Department Represented By : Shri Annavaram Kosuri, Ld. Dr Date Of Conclusion Of Hearing : 03.11.2025 Date Of Pronouncement : 20.11.2025

additional TDS credit of Rs. 73,24,074/- and inadvertently missed to claim the genuine TDS credit in the revised return of income

KALYAN DEVELOPMENT CORPORATION,KALYAN vs. ASSISTANT COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-2, THANE, THANE

Bench: Shri Girish Agrawal & Shri Sunil Kumar Singh

Income filed for the Assessment Year 2016-17 by the Lender Company 4 Copy of PAN Card of M/s Annex Tradelink P Ltd having PAN AAICA7688K 5 Copy of Bank Statement of M/s Annex Tradelink P Ltd for A/c No 76694318 with Canara Bank, Bhawanipore, Kolkata 6 Details & Sources of funds available with M/s Annex Tradelink P Ltd while granting

NSE IT LTD,MUMBAI vs. DCIT 8(2), MUMBAI

In the result, the appeal of the assessee is allowed

Bench: Shri Joginder Singh & Shri Ramit Kocharआयकर अपीऱ सं./I.T.A. No.5935/Mum/2014 (नििाारण वर्ा / Assessment Year: 2005-06) बिाम/ M/S. Nse. It Ltd, Dcit 8(2), Mumbai Trade Globe, Ground Floor, Andheri Kurla Road, V. Andheri (E), Mumbai 400059 स्थायी ऱेखा सं./ Pan : Aabcn0159P (अपीऱाथी /Appellant) (प्रत्यथी / Respondent) ..

TDS. Additional income offered while filing revised Return of Income was not agitated. As, assessing officer has initiated penalty proceedings

DY CIT CC 7 (2), MUMBAI vs. M/S MAN GLOBAL LTD., MUMBAI

In the result, all the appeals of the Revenue are dismissed and cross objections of the assessee in CO Nos

Bench: Sri Rajesh Kumar, Am & Sri Amarjit Singh, Jm आयकर आयकर अपील आयकर आयकर अपील अपील संसंसंसं./ Ita No. 7440/Mum/2019 अपील (िनधा"रण वष" / Assessment Year 2011-12) आयकर आयकर अपील आयकर आयकर अपील अपील संसंसंसं./ Ita No. 7533/Mum/2019 अपील (िनधा"रण वष" / Assessment Year 2012-13) आयकर आयकर अपील आयकर आयकर अपील अपील संसंसंसं./ Ita No. 7534/Mum/2019 अपील (िनधा"रण वष" / Assessment Year 2013-14) आयकर अपील आयकर अपील संसंसंसं./ Ita No. 7535/Mum/2019 आयकर आयकर अपील अपील (िनधा"रण वष" / Assessment Year 2014-15) आयकर आयकर अपील आयकर आयकर अपील अपील संसंसंसं./ Ita No. 7536/Mum/2019 अपील (िनधा"रण वष" / Assessment Year 2015-16)

income tax perspective and not by any other authority. Therefore while relying heavily on the order of AO, the ld DR prayed that the order of ld CIT(A) may be set aside by restoring the order of AO on this issue. 90. Having heard both the sides and perusing the material on records including the various evidences filed

RAJU B DOSHI,MUMBAI vs. ASST CIT 19(2)(2), MUMBAI

The appeal is allowed

Bench: Shri R C Sharma & Shri Amit Shukla

income. 49. The Ld. CIT(A), too had confirmed the said addition. 50. After hearing both the parties and on perusal of the impugned orders, it is seen that, the assessee had contended that, assessee’s father late, Shri Banubhai Doshi used to attend marketing activity of the assessee and total commission payable to him as per books of account

RAJU B DOSHI,MUMBAI vs. ASST CIT 19(2)(2), MUMBAI

The appeal is allowed

Bench: Shri R C Sharma & Shri Amit Shukla

income. 49. The Ld. CIT(A), too had confirmed the said addition. 50. After hearing both the parties and on perusal of the impugned orders, it is seen that, the assessee had contended that, assessee’s father late, Shri Banubhai Doshi used to attend marketing activity of the assessee and total commission payable to him as per books of account

RAJU B. DOSHI,MUMBAI vs. ASST CIT 19(2), MUMBAI

The appeal is allowed

Bench: Shri R C Sharma & Shri Amit Shukla

income. 49. The Ld. CIT(A), too had confirmed the said addition. 50. After hearing both the parties and on perusal of the impugned orders, it is seen that, the assessee had contended that, assessee’s father late, Shri Banubhai Doshi used to attend marketing activity of the assessee and total commission payable to him as per books of account

SHRI RAJU B. DOSHI,MUMBAI vs. ACIT 19(2), MUMBAI

The appeal is allowed

Bench: Shri R C Sharma & Shri Amit Shukla

income. 49. The Ld. CIT(A), too had confirmed the said addition. 50. After hearing both the parties and on perusal of the impugned orders, it is seen that, the assessee had contended that, assessee’s father late, Shri Banubhai Doshi used to attend marketing activity of the assessee and total commission payable to him as per books of account

RAJU B. DOSHI,MUMBAI vs. ASST CIT 19(2), MUMBAI

The appeal is allowed

Bench: Shri R C Sharma & Shri Amit Shukla

income. 49. The Ld. CIT(A), too had confirmed the said addition. 50. After hearing both the parties and on perusal of the impugned orders, it is seen that, the assessee had contended that, assessee’s father late, Shri Banubhai Doshi used to attend marketing activity of the assessee and total commission payable to him as per books of account

RAJU B. DOSHI,MUMBAI vs. ASST CIT 19(2), MUMBAI

The appeal is allowed

Bench: Shri R C Sharma & Shri Amit Shukla

income. 49. The Ld. CIT(A), too had confirmed the said addition. 50. After hearing both the parties and on perusal of the impugned orders, it is seen that, the assessee had contended that, assessee’s father late, Shri Banubhai Doshi used to attend marketing activity of the assessee and total commission payable to him as per books of account

MANGESHI ENTERPRISES,KALYAN vs. ASSISTANT COMMISSIONER OF INCOME TAX CENTRAL CIRCLE-2, THANE

Bench: Shri Girish Agrawal & Shri Sunil Kumar Singh

Income filed for the Assessment Year 2016-17 by the Lender Company 4 Copy of PAN Card of M/s Annex Tradelink P Ltd having PAN AAICA7688K 5 Copy of Bank Statement of M/s Annex Tradelink P Ltd for A/c No 76694318 with Canara Bank, Bhawanipore, Kolkata 6 Details & Sources of funds available with M/s Annex Tradelink P Ltd while granting

DY. COMMISSIONER OF INCOME TAX-5(2)(1), MUMBAI, MUMBAI vs. ADITYA BIRLA HOUSING FINANCE LIMITED, MUMBAI

Bench: SHRI OM PRAKASH KANT, ACCOUNTANT MEMBER SHRI RAHUL CHAUDHARY (Judicial Member)

TDS of Rs.27,40,247/-reflected in 26AS but not claimed by the assessee in the return of the income without calling for the remand report on the above issue that the corresponding income to the claimed of aforesaid additional

DY. COMMISSIONER OF INCOME TAX-5(2)(1), MUMBAI, MUMBAI vs. ADITYA BIRLA HOUSING FINANCE LIMITED, MUMBAI

Bench: SHRI OM PRAKASH KANT, ACCOUNTANT MEMBER SHRI RAHUL CHAUDHARY (Judicial Member)

TDS of Rs.27,40,247/-reflected in 26AS but not claimed by the assessee in the return of the income without calling for the remand report on the above issue that the corresponding income to the claimed of aforesaid additional

DY. COMMISSIONER OF INCOME TAX-5(2)(1), MUMBAI, MUMBAI vs. ADITYA BIRLA HOUSING FINANCE LIMITED, MUMBAI

Bench: SHRI OM PRAKASH KANT, ACCOUNTANT MEMBER SHRI RAHUL CHAUDHARY (Judicial Member)

TDS of Rs.27,40,247/-reflected in 26AS but not claimed by the assessee in the return of the income without calling for the remand report on the above issue that the corresponding income to the claimed of aforesaid additional

ANISH DHIRAJ MEHTA,MUMBAI vs. INCOME TAX OFFICER WARD-10(3)(3), MUMBAI

In the result, appeal of the assessee in ITA no

Bench: Shri C.N.Prasad & Shri Ramit Kocharआयकर अपीऱ सं./I.T.A. No.1215/Mum/2018 (नििाारण वर्ा / Assessment Year: (2013-14) बिाम/ Mr. Anish Dhiraj Mehta Income Tax Officer Vrindavan, Ward 10(3)(3) , 55, Nutan Laxmi Society, Aayakar Bhawan, V. 9Th Road, Mumbai-400020 Jvpd Scheme, Vile Parle(W), Mumbai-400049 स्थायी ऱेखा सं./ Pan: Aaefm9616L (अपीऱाथी /Appellant) (प्रत्यथी / Respondent) .. Assessee By: Shri. Ashok Patil Revenue By: Shri. Satishchandra Rajore

additional TDS paid of Rs. 5,00,000/- stood disclosed to Revenue. The assessee never made an attempt to claim entire TDS of Rs. 8,00,000 deducted by Pace while on the other hand declaring initial salary of Rs. 15,00,000/- rather it only claimed credit of TDS of Rs. 3,00,000/- in return of income

FRANKLIN TEMPLETON INTERNATIONAL SERVICES (INDIA) P.LTD,MUMBAI vs. DCIT CIR 6(3)(1), MUMBAI

Income-tax Rules, 1962 ('the Rules').\nInclusion of comparable for Data Processing & Support services segment:\n1.3.1 The learned AO/TPO under the directions of the Hon'ble DRP erred\non facts and in law in applying the filter of diminishing revenue and\npersistent loss as well as different financial year ending and rejecting the\nfollowing comparable companies which were accepted