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

115P is consequential to the non-grant of DDT credit, the same shall also be recomputed after giving effect to this direction. Accordingly, these grounds are allowed for statistical purposes. A.Y. 2018–19 - (ITA No. 6701/Mum/2025) Ground No. I: Addition on account of deduction claimed under section 80G amounting to Rs. 2,53,96,666/- 49. We have already adjudicated

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

TDS credit, DDT, and interest levies.", "result": "Partly Allowed", "sections": [ "Sec 250", "Sec 143(1)", "Sec 143(2)", "Sec 142(1)", "Sec 143(3)", "Sec 144B", "Sec 80G", "Sec 36(1)(va)", "Sec 40(a)(ia)", "Sec 43B", "Sec 234B", "Sec 234C", "Sec 270A", "Sec 115P

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

115P is\nconsequential to the non-grant of DDT credit, the same shall also\nbe recomputed after giving effect to this direction. Accordingly,\nthese grounds are allowed for statistical purposes.\nA.Y. 2018–19 - (ITA No. 6701/Mum/2025)\nGround No. I: Addition on account of deduction claimed\nunder section 80G amounting to Rs. 2,53,96,666/-\n49. We have already adjudicated

DEPUTY COMMISSIONER OF INCOME TAX 10(2)(2), MUMBAI vs. MAQUET MEDICAL INDIA PRIVATE LIMITED, MUMBAI

In the result, the appeal of the Revenue is dismissed

Bench: Shri Kuldip Singh () & Ms. Padmavathy S. ()

TDS on 26.03.2014. The case was selected for scrutiny and the statutory notices were duly served on the assessee. The AO completed the assessment by making additions as listsed below: (i) Cessation of liability under section 41(1) – Rs. 7,52,952/- (ii) Unreconciled receipts as per Form 26AS vis-à-vis books of accounts

MAQUET MEDICAL INDIA PRIVATE LIMITED,MUMBAI vs. DEPUTY COMMISSIONER OF INCOME TAX 10(2)(2), MUMBAI

In the result, the appeal of the Revenue is dismissed

Bench: Shri Kuldip Singh () & Ms. Padmavathy S. ()

TDS on 26.03.2014. The case was selected for scrutiny and the statutory notices were duly served on the assessee. The AO completed the assessment by making additions as listsed below: (i) Cessation of liability under section 41(1) – Rs. 7,52,952/- (ii) Unreconciled receipts as per Form 26AS vis-à-vis books of accounts

ACCENTURE SOLUTIONS P LTD (ASOL),MUMBAI vs. ADDL/JT/ DY/CIT/ASSTT/ITO, NATIONAL FACELESS ASSESSMENT CENTRE, DELHI & THE DY CIT,CIRCLE-14(1)(1), MUMBAI

In the result, the appeal of the assessee is partly allowed

Bench: Shri Amit Shukla & Shri Amarjit Singhaccenture Solutions Vs. Additional/Joint/Deputy/ Private Limited (‘Asol’) Assistant Commissioner Plant 3, Godrej & Boyce Of Income Tax/Income- Complex, Phirojshah Tax Officer, National Nagar, Vikhroli West, Facelless Assessment Off L.B.S Marg, Centre, Delhi Mumbai – 400079 The Dcit, Circle 14(1)(1) स्थायी लेखा सं./जीआइआर सं./Pan/Gir No: Aaach3235M Appellant .. Respondent Appellant By : Nishant Thakkar/ Hiten Chande/ Ms. Jasmin Amalsadvala Respondent By : Azhar Zain Vayal Parambath Date Of Hearing 22.05.2023 Date Of Pronouncement 13.07.2023 आदेश / O R D E R Per Amarjit Singh (Am): This Appeal Filed By The Assesse Is Directed Against The Order Passed By The Ao (National Assessment Centre) Mumbai- 2, Dated 18.03.2021 For A.Y. 2016-17 As Per The Direction Of The Drp Issued U/S 144C (5) Of The Act. The Assessee Has Raised The Following Grounds Before Us: “On The Facts & Circumstances Of The Case & In Law, The Learned Ao Transfer Pricing Officer (Tpo), Based On The Directions Of The Hon'Ble Drp Has: General Ground 1. Erred In Assessing The Total Income Of The Appellant At Rs.2888,33,73,016 Against A Total Income Of Rs.2179,39,30,620 As Reported By The Appellant In Its Revised Return Of Income & Determining A Demand Of Rs.2186,98,55,847 Payable By The Appellant.

TDS, advance tax, MAT credit, DDT pertaining to ASPL was reported by the Appellant. The said merger was also noted by the AO in the draft assessment order dated 26 December 2019. However, still the learned ΛΟ: 29. Erred in not granting credit of taxes deducted at source of Rs.198,94,21,730 claimed by the Appellant in its return

M/S. VAN-OORD INDIA PVT. LTD,MUMBAI vs. ACIT CIR 5(3) (2) , MUMBAI

In the result, appeal of the Revenue is dismissed

Bench: Shri Amit Shukla & Shri Gagan Goyalm/S. Van Oord India Pvt. Ltd. 201, 2Nd Floor, Central Plaza, 166 Cst Road, Kalina, Raheja Towers, Opp. Sidbi, Mumbai-400 098 Pan: Aaach5430J ..... Appellant Vs. Acit Circle 5(3) (2) Aayakar Bhavan, M. K. Road, Mumbai- 400 020 ..... Respondent & Acit Circle 5(3) (2) Aayakar Bhavan, M. K. Road, Mumbai- 400 020 ...... Appellant Vs.

Sections 115P and 115Q provide for machinery provisions for recovery. The chapter XII-D is a complete code in itself on DDT. The provisions of TDS

GOLDMAN SACHS (INDIA) SECURITEIS PRIVATE LIMITED,MUMBAI vs. ADD/JT/DY/ASST/CIT/ITO/NFAC, DELHI

115P of the\nAct amounting to Rs. 62,33,79,507.\n10.\nIn levying the additional interest under section 234C of the Act without\nappreciating that the interest under section 234C of the Act is to be calculated\non the returned income filed by the Appellant as per the provisions of the Act.\n11.\nIn computing the consequential interest under

DEUTSCHE INVESTMENTS INDIA PRIVATE LIMITED,MUMBAI vs. DEPUTY COMMISSIONER OF INCOME-TAX CIRCLE- 4(2)(1), MUMBAI, MUMBAI

Bench: Shri Pawan Singh (Jm) & Shri Omkareshwar Chidara (Am) Deutsche Investments India Pvt. Ltd. Dcit, Circle 4(2)(1) Block B1, Nirlon Knowledge Park, Off 6Th Floor, Room No. Western Express Highway, Goregaon Vs. 642, Aayakar East, Mumbai-400 063. Bhavan, M.K. Road Mumbai-400 020. Pan : Aaccd1765E Appellant Respondent

TDS as per law. Similarly, with respect to giving credit to correct payment Dividend Distribution Tax (DDT), the Ld. AO was directed to give credit to DDT after verifying the payment made by appellant company. Since, the levy of interest under section 115P

PIRAMAL GLASS LTD,MUMBAI vs. DCIT 7(3)(2), MUMBAI

The appeal of the assessee stands partly allowed

Bench: Shri Amit Shukla, Jm & Shri Manoj Kumar Aggarwal, Am आयकर अपील सं./I.T.A. No. 157/Mum/2016 ("नधा"रण वष" / Assessment Year : 2011-2012) M/S Piramal Glass Ltd. Deputy Commissioner Of (Earlier Known As ‘Gujarat Glass Pvt. Ltd.’) Income Tax 7(3)(2) बनाम/ Room No. 669A, 6Th Floor Piramal Tower Ganpatrao Kadam Marg Aaykar Bahwan Vs. Lower Parel M.K.Road, Churchgate Mumbai 400013 Mumbai 400020 "थायी लेखा सं./जीआइआर सं./Pan/Gir No. Aabcg-0093-R (अपीलाथ" /Appellant) (""यथ" / Respondent) :

115P and pleaded for deletion of interest on the premises that DDT has been paid by assessee within time. Further, the issue of additional demand does not form subject matter of final assessment order assailed before us. Rather, the demand has been raised in ‘Notice of Demand’ u/s 156 and ‘Income Tax Computation Form’. Therefore, the proper course of action