SMALL INDUSTRIES DEVELOPMENT BANK OF INDIA,MUMBAI vs. DEPUTY COMMISSIONER OF INCOME TAX CIRCLE 3(3)(1),MUMBAI, MUMBAI

Bench: Justice (Retd.) C V Bhadang & Ms Padmavathy S, Am

TDS) held that the amount paid by the assessee to the allottees was in the nature of interest within the meaning of Section 2(28A) and in terms of Section 194A, tax had to be deducted at source. On appeal, the Commissioner (Appeals) allowed the same holding that the amount paid by the Board was not really interest within

DY. COMMISSIONER OF INCOME TAX CIRCLE - 3(3)(1), MUMBAI, MUMBAI vs. SMALL INDUSTRIES DEVELOPMENT BANK OF INDIA, MUMBAI

Bench: Justice (Retd.) C V Bhadang & Ms Padmavathy S, Am

TDS) held that the amount paid by the assessee to the allottees was in the nature of interest within the meaning of Section 2(28A) and in terms of Section 194A, tax had to be deducted at source. On appeal, the Commissioner (Appeals) allowed the same holding that the amount paid by the Board was not really interest within

DY. COMMISSIONER OF INCOME TAX CIRCLE - 3(3)(1), MUMBAI, MUMBAI vs. SMALL INDUSTRIES DEVELOPMENT BANK OF INDIA, MUMBAI

Bench: Justice (Retd.) C V Bhadang & Ms Padmavathy S, Am

TDS) held that the amount paid by the assessee to the allottees was in the nature of interest within the meaning of Section 2(28A) and in terms of Section 194A, tax had to be deducted at source. On appeal, the Commissioner (Appeals) allowed the same holding that the amount paid by the Board was not really interest within

SMALL INDUSTRIES DEVELOPMENT BANK OF INDIA,MUMBAI vs. DEPUTY COMMISSIONER OF INCOME TAX CIRCLE 3(3)(1),MUMBAI, MUMBAI

TDS) held\nthat the amount paid by the assessee to the allottees was in the nature of interest\nwithin the meaning of Section 2(28A) and in terms of Section 194A, tax had to be\ndeducted at source. On appeal, the Commissioner (Appeals) allowed the same\nholding that the amount paid by the Board was not really interest within

DY. COMMISSIONER OF INCOME TAX CIRCLE - 3(3)(1), MUMBAI, MUMBAI vs. SMALL INDUSTRIES DEVELOPMENT BANK OF INDIA, MUMBAI

TDS) held\nthat the amount paid by the assessee to the allottees was in the nature of interest\nwithin the meaning of Section 2(28A) and in terms of Section 194A, tax had to be\ndeducted at source. On appeal, the Commissioner (Appeals) allowed the same\nholding that the amount paid by the Board was not really interest within

DY. COMMISSIONER OF INCOME TAX CIRCLE - 3(3)(1), MUMBAI, MUMBAI vs. SMALL INDUSTRIES DEVELOPMENT BANK OF INDIA, MUMBAI

TDS) held\nthat the amount paid by the assessee to the allottees was in the nature of interest\nwithin the meaning of Section 2(28A) and in terms of Section 194A, tax had to be\ndeducted at source. On appeal, the Commissioner (Appeals) allowed the same\nholding that the amount paid by the Board was not really interest within

ADITYA BIRLA SUN LIFE AMC LIMITED,MAHARASHTRA vs. THE DEPUTY COMMISSIONER OF INCOME TAX-CIRCLE 6(1)(1), MAHARASHTRA

TDS credit, while treating interest\ngrounds as consequential.\n8.\nIn A.Y. 2022-23, no independent addition or disallowance\nwas made in the regular assessment order passed under section\n143(3) read with section 144B of the Act. The CIT(A) recorded that\nonly the income as processed under section 143(1

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 INR.29,30,368/- reflected in updated Form 26AS. 4.3. Being aggrieved, the Revenue has now preferred the present appeal before the Tribunal on the grounds reproduced in paragraph 3 above. 5. On perusal of grounds raised by the Revenue, we find that the Revenue has only referred to addition/adjustment made under Section 43B in Ground No. 1

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 INR.29,30,368/- reflected in updated Form 26AS. 4.3. Being aggrieved, the Revenue has now preferred the present appeal before the Tribunal on the grounds reproduced in paragraph 3 above. 5. On perusal of grounds raised by the Revenue, we find that the Revenue has only referred to addition/adjustment made under Section 43B in Ground No. 1

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 INR.29,30,368/- reflected in updated Form 26AS. 4.3. Being aggrieved, the Revenue has now preferred the present appeal before the Tribunal on the grounds reproduced in paragraph 3 above. 5. On perusal of grounds raised by the Revenue, we find that the Revenue has only referred to addition/adjustment made under Section 43B in Ground No. 1

ADITYA BIRLA SUN LIFE AMC LIMITED,MAHARASHTRA vs. THE DEPUTY COMMISSIONER OF INCOME TAX- CIRCLE 6(1)(1), MAHARASHTRA

Bench: Shri Amit Shukla & Shri Makarand Vasant Mahadeokar1. Ita No. 6663/Mum/2025 (Assessment Year: 2017-18) 2. Ita No. 6701/Mum/2025 (Assessment Year: 2018-19) 3. Ita No. 6702/Mum/2025 (Assessment Year: 2022-23) & 4. Ita No. 6703/Mum/2025 (Assessment Year: 2023-24) Aditya Birla Sun Life Dcitcircle-6(1)(1), Amc Limited, Room No. 502, 5Th 17Th Floor, One World Vs. Floor, Aayakar Centre Tower-1, Jupiter Bhavan, M. K. Mill Compount, 841, Road, Churchgate, Senapati Bapat Marg, Mumbai-400 020 Delisle Road, S.O. Mumbai-400 013 Pan/Gir No. Aaacb6134D (Applicant) (Respondent) Assessee By Shri Ronak Doshi, Shri Shrey Agrawal & Shri Aadish Jain, Ld. Ars Revenue By Shri Surendra Mohan, Ld. Dr Date Of Hearing 27.01.2026 Date Of Pronouncement 06.02.2026

TDS credit, while treating interest grounds as consequential. 8. In A.Y. 2022–23, no independent addition or disallowance was made in the regular assessment order passed under section 143(3) read with section 144B of the Act. The CIT(A) recorded that only the income as processed under section 143(1

BANK OF INDIA,MUMBAI vs. ACIT-2(1)(2), MUMBAI

In the result, the appeal by the Revenue for the assessment year 2018-

Bench: Shri Vikram Singh Yadavshri Sandeep Singh Karhailita No.1452/Mum/2023 Assessment Year : 2016-17 Assessment Year : 2018-19

section 143(3) of the Act, disagreed with the submissions of the assessee and held that perpetual bonds are in the nature of debt instruments with no maturity date. Only the issuing company can buy back the bonds from the investors. Therefore, it was held these bonds are perpetual in nature. Since in the case of perpetual bonds, the investor

ACIT, CIRCLE-2(1)(1), MUMBAI vs. M/S BANK OF INDIA, MUMBAI

In the result, the appeal by the Revenue for the assessment year 2018-

Bench: Shri Vikram Singh Yadavshri Sandeep Singh Karhailita No.1452/Mum/2023 Assessment Year : 2016-17 Assessment Year : 2018-19

section 143(3) of the Act, disagreed with the submissions of the assessee and held that perpetual bonds are in the nature of debt instruments with no maturity date. Only the issuing company can buy back the bonds from the investors. Therefore, it was held these bonds are perpetual in nature. Since in the case of perpetual bonds, the investor

M/S THE MAHARASHTRA STATE CO. OP BANK LTD.,MUMBAI vs. ITO-1(3)(3), MUMBAI

In the result, the appeal of the In the result, the appeal of the assessee is allowed partly assessee is allowed partly whereas the appeal of the Revenue is dismissed

Bench: Shri Om Prakash Kant () & Shri Sandeep Singh Karhail () Assessment Year: 2013-14

1) of section 199 of the Act and Rules made thereunder. However, we direct the assessing officer to verify whether any However, we direct the assessing officer to verify whether any However, we direct the assessing officer to verify whether any credit of the TDS

DY CIT-1(3)(2), MUMBAI vs. MAHARASHTRA STATE CO-OPERATIVE BANK LIMITED, MUMBAI

In the result, the appeal of the In the result, the appeal of the assessee is allowed partly assessee is allowed partly whereas the appeal of the Revenue is dismissed

Bench: Shri Om Prakash Kant () & Shri Sandeep Singh Karhail () Assessment Year: 2013-14

1) of section 199 of the Act and Rules made thereunder. However, we direct the assessing officer to verify whether any However, we direct the assessing officer to verify whether any However, we direct the assessing officer to verify whether any credit of the TDS

STATE BANK OF MYSORE,BANGALORE vs. JCIT, BANGALORE

In the result, the appeal of the Revenue Ground-3 is dismissed

Bench: Shri Narendra Kumar Billaiya, Account Member & Shri Anikesh Banerjeestate Bank Of India Vs Joint Commissioner Of Income-Tax, (Erstwhile State Bank Of Large Tax Payers Unit, Bangalore Mysore Prior To Merger) Local Head Office Compliance Department, 4Th Floor, 65, St. Marks Road, Bangalore-560 001 Pan: Aaccs0155P Appellant Respondent Deputy Commissioner Of Vs State Bank Of Mysore Income-Tax, Ltu, Circle-1, Head Office, Finance & Accounts Bangalore Department, Kg Road, Bangalore- 560 009 Pan: Aaccs0155P Appellant Respondent

section 40(a)(ia) of the Act – Rs.8,10,18,335/- 26. During the year under consideration, the assessee Bank incurred and claimed Advertisement Expenses, Audit Fees and Law charges u/s. 37(1) of the Act since the same were incurred wholly and exclusively for the purpose of the business of the assessee. During the course of the assessment proceedings

JAN SEVA MANDAL ,MUMBAI vs. INCOME TAX OFFICER EXEMPTION WARD -1(4), MUMBAI

In the result, the appeal filed by the assessee is allowed for In the result, the appeal filed by the assessee is allowed for In the result, the appeal filed by the assessee is allowed for statisti...

Bench: Shri Om Prakash Kant () & Ms. Kavitha Rajagopal () Assessment Year: 2023-24 Jan Seva Mandal, Central Processing Centre Income Vinayalaya, Mahakali Caves Tax Deparment, Bengaluru, Vs. Road, Andheri (East), Income Tax Officer Exemption Mumbai-400093. Ward 1(4), Mumbai. 6Th Floor, Mtnl Te Building, Pedder Road, Mumbai-400026. Pan No. Aaatj 4868 K Appellant Respondent

TDS refund of Rs. 1,05,613/- against the Appellant: against the Appellant: 1. A sum of Rs. 17,61,379/ A sum of Rs. 17,61,379/- under section

ACIT (LTU)-1, MUMBAI vs. UNION BANK OF INDIA, MUMBAI

In the result, appeal of the assessee is allowed

1) to Section 129 of the Companies Act is applicable. The said proviso has\nno application to the company because the company, used in\nsection 115JB(2)(b) is to be applied to the company under the Companies\nAct and not to an entity which is deemed by a fiction to be a company for\nthe purpose of the Income