DCIT TDS 2-1 MUMBAI, MUMBAI vs. PFIZER LIMITED, MUMBAI

In the result, the appeal of the revenue is dismissed

Bench: Shri Narender Kumar Choudhry & Shri Bijayananda Pruseth

TDS on the same and provisions of section 201 being not applicable. The Respondent craves leave to amend, delete, rectify, substitute and modify any of the aforesaid grounds of Cross-Objections or add a new ground or grounds of Cross-Objections at any time before or at the time of hearing the Cross-Objections.” 4. Facts of the case

PIRAMAL CAPITAL AND HOUSING FINANCE LIMITED,MUMBAI vs. ASSISTANT COMMISSIONER OF INCOME TAX TDS - 2 (1),MUMBAI, MUMBAI

Accordingly, in terms of paragraph 13 & 17 above, all the four appeals preferred by the Assessee are allowed

Bench: IN THE INCOME TAX APPELLATE TRIBUNAL "C" BENCH, MUMBAI SHRI AMARJIT SINGH, ACCOUNTANT MEMBER SHRI RAHUL CHAUDHARY (Judicial Member)

TDS as laid under Section 193 and Section 194/A of the Act cannot apply. 2 ITA No. 2351/MUM/2024, ITA No.2348/Mum/2024, ITA No.2347/Mum/2024 and ITA No.2345/Mum/2024 Assessment Year: 2017-2018, 2018-2019, 2019-2020 and 2020-2021 ii. Since, the securities are purchased at the carrying value from the Transferor, the interest element embedded in the cum-interest price should

PIRAMAL CAPITAL AND HOUSING FINANCE LIMITED,MUMBAI vs. ASSISTANT COMMISSIONER OF INCOME TAX TDS - 2 (1), MUMBAI, MUMBAI

Accordingly, in terms of paragraph 13 & 17 above, all the four appeals preferred by the Assessee are allowed

Bench: SHRI AMARJIT SINGH, ACCOUNTANT MEMBER SHRI RAHUL CHAUDHARY (Judicial Member)

TDS as laid under Section 193 and Section 194/A of the Act cannot apply. 2 ITA No. 2351/MUM/2024, ITA No.2348/Mum/2024, ITA No.2347/Mum/2024 and ITA No.2345/Mum/2024 Assessment Year: 2017-2018, 2018-2019, 2019-2020 and 2020-2021 ii. Since, the securities are purchased at the carrying value from the Transferor, the interest element embedded in the cum-interest price should

PIRAMAL CAPITAL AND HOUSING FINANCE LIMITED,MUMBAI vs. ASSISTANT COMMISSIONER OF INCOME TAX TDS - 2 (1), MUMBAI, MUMBAI

Accordingly, in terms of paragraph 13 & 17 above, all the four appeals preferred by the Assessee are allowed

Bench: SHRI AMARJIT SINGH, ACCOUNTANT MEMBER SHRI RAHUL CHAUDHARY (Judicial Member)

TDS as laid under Section 193 and Section 194/A of the Act cannot apply. 2 ITA No. 2351/MUM/2024, ITA No.2348/Mum/2024, ITA No.2347/Mum/2024 and ITA No.2345/Mum/2024 Assessment Year: 2017-2018, 2018-2019, 2019-2020 and 2020-2021 ii. Since, the securities are purchased at the carrying value from the Transferor, the interest element embedded in the cum-interest price should

PIRAMAL CAPITAL AND HOUSING FINANCE LIMITED,MUMBAI vs. ASSISTANT COMMISSIONER OF INCOME TAX TDS - 2 (1), MUMBAI, MUMBAI

Accordingly, in terms of paragraph 13 & 17 above, all the four appeals preferred by the Assessee are allowed

Bench: SHRI AMARJIT SINGH, ACCOUNTANT MEMBER SHRI RAHUL CHAUDHARY (Judicial Member)

TDS as laid under Section 193 and Section 194/A of the Act cannot apply. 2 ITA No. 2351/MUM/2024, ITA No.2348/Mum/2024, ITA No.2347/Mum/2024 and ITA No.2345/Mum/2024 Assessment Year: 2017-2018, 2018-2019, 2019-2020 and 2020-2021 ii. Since, the securities are purchased at the carrying value from the Transferor, the interest element embedded in the cum-interest price should

DCIT(OSD)(TDS)-2(3), MUMBAI, PEDDER ROAD, MUMBAI vs. THE BOMBAY DYEING AND MANUFACTURING COMPANY LIMITED, MUMBAI

In the result, appeal filed by the revenue is dismissed

TDS)2(3), Mumbai being the assessing officer in this\ncase, has committed an error in holding that the assessee was\nliable to deduct tax under section 194C from the payments of\nRs.118,58,98,272/- made to the manufacturers/ suppliers/ vendors\nwho supplied the finished products to the appellant and I also hold\nthat the appellant

SAPPHIRE FOODS INDIA LIMITED,MUMBAI vs. OSD TDS CIRCLE 2(2), MUMBAI

In the result, the appeal of the assessee bearing ITA No

Bench: Shri Om Prakash Kant & Shri Anikesh Banerjee

TDS u/s 194A, 194C, 194I, 194J of the Act at the time of payment to party/parties. The auditor has certified these expenses by ascertaining the amounts and identifying various payees where tax was not deducted. A spot verification was conducted by the Ld. AO U/s 133B(2) of the Act. On verification it was found that the assessee had made

SAPPHIRE FOODS INDIA LIMITED,MUMBAI vs. OSD TDS CIRCLE 2(2), MUMBAI

In the result, the appeal of the assessee bearing ITA No

Bench: Shri Om Prakash Kant & Shri Anikesh Banerjee

TDS u/s 194A, 194C, 194I, 194J of the Act at the time of payment to party/parties. The auditor has certified these expenses by ascertaining the amounts and identifying various payees where tax was not deducted. A spot verification was conducted by the Ld. AO U/s 133B(2) of the Act. On verification it was found that the assessee had made

SAPPHIRE FOODS INDIA LIMITED,MUMBAI vs. OSD TDS CIRCLE 2(2), MUMBAI

In the result, the appeal of the assessee bearing ITA No

Bench: Shri Om Prakash Kant & Shri Anikesh Banerjee

TDS u/s 194A, 194C, 194I, 194J of the Act at the time of payment to party/parties. The auditor has certified these expenses by ascertaining the amounts and identifying various payees where tax was not deducted. A spot verification was conducted by the Ld. AO U/s 133B(2) of the Act. On verification it was found that the assessee had made

SAPPHIRE FOODS INDIA LIMITED,MUMBAI vs. OSD TDS CIRCLE 2(2), MUMBAI

In the result, the appeal of the assessee bearing ITA No

Bench: Shri Om Prakash Kant & Shri Anikesh Banerjee

TDS u/s 194A, 194C, 194I, 194J of the Act at the time of payment to party/parties. The auditor has certified these expenses by ascertaining the amounts and identifying various payees where tax was not deducted. A spot verification was conducted by the Ld. AO U/s 133B(2) of the Act. On verification it was found that the assessee had made

SAPPHIRE FOODS INDIA LIMITED,MUMBAI vs. OSD TDS CIRCLE 2(2), MUMBAI

In the result, the appeal of the assessee bearing ITA No

Bench: Shri Om Prakash Kant & Shri Anikesh Banerjee

TDS u/s 194A, 194C, 194I, 194J of the Act at the time of payment to party/parties. The auditor has certified these expenses by ascertaining the amounts and identifying various payees where tax was not deducted. A spot verification was conducted by the Ld. AO U/s 133B(2) of the Act. On verification it was found that the assessee had made

SAPPHIRE FOODS INDIA LIMITED,MUMBAI vs. OSD TDS CIRCLE 2(2), MUMBAI

In the result, the appeal of the assessee bearing ITA No

Bench: Shri Om Prakash Kant & Shri Anikesh Banerjee

TDS u/s 194A, 194C, 194I, 194J of the Act at the time of payment to party/parties. The auditor has certified these expenses by ascertaining the amounts and identifying various payees where tax was not deducted. A spot verification was conducted by the Ld. AO U/s 133B(2) of the Act. On verification it was found that the assessee had made

SAPPHIRE FOODS INDIA LIMITED,MUMBAI vs. OSD TDS CIRCLE 2(2), MUMBAI

In the result, the appeal of the assessee bearing ITA No

Bench: Shri Om Prakash Kant & Shri Anikesh Banerjee

TDS u/s 194A, 194C, 194I, 194J of the Act at the time of payment to party/parties. The auditor has certified these expenses by ascertaining the amounts and identifying various payees where tax was not deducted. A spot verification was conducted by the Ld. AO U/s 133B(2) of the Act. On verification it was found that the assessee had made

DCIT(TDS) -2(3) MUMBAI, PEDDER ROAD, CUMBALLA HILL, MUMBAI vs. NRB BEARING LIMITED, FORT, MUMBAI

Bench: Justice (Retd.) C V Bhadang, Hon’Ble & Shri B R Baskaran, Hon’Ble

TDS) under Section 194H of the said Act. 2. The brief facts are that the assessee is a company engaged in manufacturing automobile bearings. A spot verification under Section 133B

SYNDICATE BANK,BANDRA WEST vs. INCOME TAX OFFICER, TDS WARD MUMBAI

Bench: Shri Sandeep Gosain (Jm) & Shri Omkareshwar Chidara (Am) Syndicate Bank Ito, 416-4Th Floor Plot No. 342, Syndicate Cumballa Hills, House, 16Th Road, Bandra Vs. Peddar Road West, Mumbai-400 050. Mumbai-400 026. Pan : Mumb1175F Appellant Respondent

section 133B of the Income Tax Act to verify whether TDS was deducted on the interest paid on Fixed Deposits

DCIT(TDS)-2(1), MUMBAI, MUMBAI vs. PIRAMAL ENTERPRISES LIMITED, MUMBAI

In the result, the appeal by the Revenue is dismissed

Bench: Shri Narendra Kumar Billaiyashri Sandeep Singh Karhaildeputy Commissioner Of Income Tax (Tds) – 2(1), Mumbai, ............... Appellant V/S Piramal Enterprises Limited, Piramal Ananta, Agastya Corporate Park Kamini Junction Lbs Marg Opp. Fire Brigade Kurla, ……………… Respondent Mumbai – 400070 Pan : Aaacn5024A

section 133B(2) of the Act was conducted at the premises of the assessee on 19/11/2019. During the survey, on verification of the trial balance and accounts, it was observed that the assessee typically accrues interest in the books based on the period of its holding of the loan and has defaulted in deducting TDS

INCOME TAX OFFICER 8(3)(3), MUMBAI vs. M/S.VIBGYOR TEXOTECH PRIVATE LIMITED, MUMBAI

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

Bench: Shri Amarjit Singh () & Shri Om Prakash Kant () Assessment Year: 2009-10 Income Tax Officer-8(3)(3), M/S Vibgyor Texotech Pvt. Ltd., Room No. 616, 6Th Floor, Aayakar 309, Navyug, T.J. Road, Sewree, Bhavan, M.K. Road, Vs. Mumbai-400015. Mumbai-400020. Pan No. Aaccv 0752 D Appellant Respondent Assessment Year: 2009-10 M/S Vibgyor Texotech Pvt. Ltd., The Asst. Commissioner Of 309, Navyug, T.J. Road, Sewree, Income Tax-8(3)(2), Mumbai-400015. Vs. Mumbai. Pan No. Aaccv 0752 D Appellant Respondent

TDS) also the Assessing Officer disallowed expenditure amounting to Rs.3,97,90,291/-in terms of section 40(a)(ia) of the Act. Additions for unexplained cash credit in terms of section 68 of the Act amounting to Rs.1,46,24,270/- and difference in valuation of fixed asset of Rs.2,50,19,760/- being written off were also made

M/S.VIBGYOR TEXOTECH PRIVATE LIMITED,MUMBAI vs. ACIT-8(3)(2), MUMBAI

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

Bench: Shri Amarjit Singh () & Shri Om Prakash Kant () Assessment Year: 2009-10 Income Tax Officer-8(3)(3), M/S Vibgyor Texotech Pvt. Ltd., Room No. 616, 6Th Floor, Aayakar 309, Navyug, T.J. Road, Sewree, Bhavan, M.K. Road, Vs. Mumbai-400015. Mumbai-400020. Pan No. Aaccv 0752 D Appellant Respondent Assessment Year: 2009-10 M/S Vibgyor Texotech Pvt. Ltd., The Asst. Commissioner Of 309, Navyug, T.J. Road, Sewree, Income Tax-8(3)(2), Mumbai-400015. Vs. Mumbai. Pan No. Aaccv 0752 D Appellant Respondent

TDS) also the Assessing Officer disallowed expenditure amounting to Rs.3,97,90,291/-in terms of section 40(a)(ia) of the Act. Additions for unexplained cash credit in terms of section 68 of the Act amounting to Rs.1,46,24,270/- and difference in valuation of fixed asset of Rs.2,50,19,760/- being written off were also made