DCIT CEN CIR 8(4), MUMBAI vs. SAVITA OIL TECHNOLOGIES LTD, MUMBAI

Appeal is allowed

Bench: Shri Mahavir Singh & Shri Ramit Kocharआयकर अपीऱ सं./I.T.A. No.7620/Mum/2016 (नििाारण वर्ा / Assessment Year : 2010-11)

11. The further submission of Mr. Pinto that in view of the Explanation to Section 244A(1)(b)of the Act the same would apply only when the amounts are paid consequent to a notice issued under Section 156 of the Act. Not otherwise. This very submission was advanced by the revenue before the Apex Court in the case

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

11,585 Direct Expenditure on TCO 63,677 Proportionate administrative expenditure (disallowed) 17,00,019 Expenses disallowed under section 14A of Income Tax Act, 1961 1,16,75,281 16. We notice that the AO has rejected the above workings of the assessee by holding that “33 The assessee, in the instant case, has not maintained any separate account relevant

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

11,585 Direct Expenditure on TCO 63,677 Proportionate administrative expenditure (disallowed) 17,00,019 Expenses disallowed under section 14A of Income Tax Act, 1961 1,16,75,281 16. We notice that the AO has rejected the above workings of the assessee by holding that “33 The assessee, in the instant case, has not maintained any separate account relevant

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

11,585 Direct Expenditure on TCO 63,677 Proportionate administrative expenditure (disallowed) 17,00,019 Expenses disallowed under section 14A of Income Tax Act, 1961 1,16,75,281 16. We notice that the AO has rejected the above workings of the assessee by holding that “33 The assessee, in the instant case, has not maintained any separate account relevant

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

11,585 Direct Expenditure on TCO 63,677 Proportionate administrative expenditure (disallowed) 17,00,019 Expenses disallowed under section 14A of Income Tax Act, 1961 1,16,75,281 16. We notice that the AO has rejected the above workings of the assessee by holding that “33 The assessee, in the instant case, has not maintained any separate account relevant

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

1,11,29,10,402/-\nclaimed by the assessee in the return of income, thereby granting\nshort credit of Rs. 3,09,621/-.The CIT(A) confirmed the action of\nthe Assessing Officer. He held that the TDS credit was allowed on\nthe basis of Form 26AS and, in absence of reconciliation to his\nsatisfaction, no further credit could

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

11,50,048/- under section 36(1)(vii) of the Act, under section 36(1)(vii) of the Act, M/s The Maharashtra State Co-op. Bank Ltd. M/s The Maharashtra State Co ITA Nos. 3878 & 3916/Mum/2019 (including opening (including opening credit balance of the provision of the bad credit balance of the provision of the bad debts created

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

11,50,048/- under section 36(1)(vii) of the Act, under section 36(1)(vii) of the Act, M/s The Maharashtra State Co-op. Bank Ltd. M/s The Maharashtra State Co ITA Nos. 3878 & 3916/Mum/2019 (including opening (including opening credit balance of the provision of the bad credit balance of the provision of the bad debts created

OBEROI FOUNDATION,MUMBAI vs. CIT (E), MUMBAI

In the result, appeal filed by the assessee is allowed

Bench: Shri Aby T. Varkey, Hon'Ble & Shri S. Rifaur Rahman, Hon'Bleoberoi Foundation V. Cit (Exemptions) Commerz, 3Rd Floor 6Th Floor, Piramal Chambers International Business Park Lalbaug, Mumbai – 400 012 Oberoi Garden City, Off. W.E. Highway Goregaon (E), Mumbai - 400063 Pan: Aaato1684L (Appellant) (Respondent) Assessee Represented By : Shri Vijay Mehta Department Represented By : Shri K.C. Salvamani

1) (URO). In 7 Oberoi Foundation this case, it has been held that Section 13 has no application to Section 10(23C) of the Act. 8. Further submitted that the Ld. CIT(E) has observed that the Assessing Officer ought to have examined the applicability of Section 13 of the Act (referred page no. 9, para (e)(i) ofthe

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)

11. Date of service of Notice under 28/06/2022, ... Section 143(2) of the Income-tax Act AY 2020-2021, 2021-2022 & 2022-2023 12. Date(s) of issue of Notice(s) 12/10/2022, 01/11/2022 under section 142(1) of the Income-tax Act 13. Order passed under section 143(3) read with section 144B of the Income tax Act 14. Returned

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)

11. Date of service of Notice under 28/06/2022, ... Section 143(2) of the Income-tax Act AY 2020-2021, 2021-2022 & 2022-2023 12. Date(s) of issue of Notice(s) 12/10/2022, 01/11/2022 under section 142(1) of the Income-tax Act 13. Order passed under section 143(3) read with section 144B of the Income tax Act 14. Returned

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)

11. Date of service of Notice under 28/06/2022, ... Section 143(2) of the Income-tax Act AY 2020-2021, 2021-2022 & 2022-2023 12. Date(s) of issue of Notice(s) 12/10/2022, 01/11/2022 under section 142(1) of the Income-tax Act 13. Order passed under section 143(3) read with section 144B of the Income tax Act 14. Returned

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

1,11,29,10,402/- claimed by the assessee in the return of income, thereby granting short credit of Rs. 3,09,621/-.The CIT(A) confirmed the action of the Assessing Officer. He held that the TDS credit was allowed on (30) ITA No. 6663, 6701, 6702 & 6703 /Mum/2025 Aditya Birla Sun Life AMC Limited the basis of Form

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

11,585\n63,677\n17,00,019\n1,16,75,281\n16.\nWe notice that the AO has rejected the above workings of the assessee by\nholding that\n“33 The assessee, in the instant case, has not maintained any separate\naccount relevant for exempt income investments and other activities to support\nits claim that they have incurred an expenditure

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

11,585\n63,677\n17,00,019\n1,16,75,281\n16.\nWe notice that the AO has rejected the above workings of the assessee by\nholding that\n“33 The assessee, in the instant case, has not maintained any separate\naccount relevant for exempt income investments and other activities to support\nits claim that they have incurred an expenditure

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

11,585\n63,677\n17,00,019\n1,16,75,281\n\n16.\nWe notice that the AO has rejected the above workings of the assessee by\nholding that\n\n“33 The assessee, in the instant case, has not maintained any separate\naccount relevant for exempt income investments and other activities to support\nits claim that they have incurred

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

In the result, appeal of the assessee is allowed

11 of the Acquisition Act which deals\na corresponding new bank treated as Indian company for the purpose of\nIncome Tax Act, however, Clause (b) in Section 2 to Section 115JB does not\npermit treatment of such bank as a company for the purpose of the said\nclause, because it would be company for which second proviso to sub-section

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