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

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

Accordingly, this ground is allowed

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

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

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

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)

Section 143(3) r.w.s. 144B of the Act. Similarly, in Ground No. 2 raised by the Revenue has challenged the action of CIT(A) granting relief to the Assessee without calling for a remand report. Ground No. 3 & 4 are directed against the grant of TDS

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)

Section 143(3) r.w.s. 144B of the Act. Similarly, in Ground No. 2 raised by the Revenue has challenged the action of CIT(A) granting relief to the Assessee without calling for a remand report. Ground No. 3 & 4 are directed against the grant of TDS

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)

Section 143(3) r.w.s. 144B of the Act. Similarly, in Ground No. 2 raised by the Revenue has challenged the action of CIT(A) granting relief to the Assessee without calling for a remand report. Ground No. 3 & 4 are directed against the grant of TDS

DCIT 3.2.1, MUMBAI vs. THE NEW INDIA ASSURANCE CO LIMITED, MUMBAI

Section 115JB of the I.T.Act, 1961 are not \napplicable in the case of the assessee. \n9. Whether on the facts and circumstances of the case and in \nlaw, the Ld. CIT(A) was right in deleting the disallowance \nof Rs.776,13,61,000/- on account of reserve for \nunexpired risk without appreciating the fact the said \nreserved was created

THE NEW INDIA ASSURANCE CO. LTD ,MUMBAI vs. DEPUTY COMMISSIONER OF INCOME TAX, CIRCLE 3(2)(2), MUMBAI

Accordingly, Ground No.1 to 4 raised by the Assessee are allowed

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

Section 37(1) of the Act.We have perused the aforesaid decision of the Tribunal in that case it was stated, during the assessment proceeding, the assessing officer noted that as per material available on record, the Director General of Central Excise Intelligence, Chennai Zone (DGCEI) had carried out investigation in respect of certain auto dealers and intermediaries. In course

DCIT 3.2.1, MUMBAI vs. THE NEW INDIA ASSURANCE CO LIMITED, MUMBAI

Accordingly, Ground No.1 to 4 raised by the Assessee are allowed

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

Section 37(1) of the Act.We have perused the aforesaid decision of the Tribunal in that case it was stated, during the assessment proceeding, the assessing officer noted that as per material available on record, the Director General of Central Excise Intelligence, Chennai Zone (DGCEI) had carried out investigation in respect of certain auto dealers and intermediaries. In course

THE NEW INDIA ASSURANCE CO LTD,MUMBAI vs. DEPUTY COMMISSIONER OF INCOME TAX, CIRCLE 3(2)(2), MUMBAI

Accordingly, Ground No.1 to 4 raised by the Assessee are allowed

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

Section 37(1) of the Act.We have perused the aforesaid decision of the Tribunal in that case it was stated, during the assessment proceeding, the assessing officer noted that as per material available on record, the Director General of Central Excise Intelligence, Chennai Zone (DGCEI) had carried out investigation in respect of certain auto dealers and intermediaries. In course

DCIT 3.2.1, MUMBAI vs. THE NEW INDIA ASSURANCE CO LIMITED, MUMBAI

Accordingly, Ground No.1 to 4 raised by the Assessee are allowed

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

Section 37(1) of the Act.We have perused the aforesaid decision of the Tribunal in that case it was stated, during the assessment proceeding, the assessing officer noted that as per material available on record, the Director General of Central Excise Intelligence, Chennai Zone (DGCEI) had carried out investigation in respect of certain auto dealers and intermediaries. In course

CITIZENCREDIT CO OPERATIVE BANK LIMITED ,DADAR BRANCH vs. ITO (TDS)1(1)(4), MUMBAI

Bench: Shri Narender Kumar Choudhry & Shri Bijayananda Pruseth

143 on the same. 3. not appreciating the fact that- (a) the Appellant is a Co-operative society duly registered under the Multi State Co.operative Societies Act, 1984 and carried on the business of banking in terms of license granted by the Reserve Bank of India. Hence, even though the Appellant was a Co-operative bank

CITIZEN CREDIT CO-OPERATIVE BANK LTD (KALINA BRANCH),MUMBAI vs. ITO (TDS)-1(1)(4), MUMBAI

Bench: Shri Narender Kumar Choudhry & Shri Bijayananda Pruseth

143 on the same. 3. not appreciating the fact that- (a) the Appellant is a Co-operative society duly registered under the Multi State Co.operative Societies Act, 1984 and carried on the business of banking in terms of license granted by the Reserve Bank of India. Hence, even though the Appellant was a Co-operative bank

CITIZENCREDIT CO OPERATIVE BANK LIMITED , CHEMBUR BRANCH,MUMBAI vs. ITO (TDS) 1(1)(4), MUMBAI

Bench: Shri Narender Kumar Choudhry & Shri Bijayananda Pruseth

143 on the same. 3. not appreciating the fact that- (a) the Appellant is a Co-operative society duly registered under the Multi State Co.operative Societies Act, 1984 and carried on the business of banking in terms of license granted by the Reserve Bank of India. Hence, even though the Appellant was a Co-operative bank

CITIZENCREDIT CO OPERATIVE BANK LIMITED (AMBOLI BRANCH),MUMBAI vs. ITO (TDS)1(1)(4), MUMBAI

Bench: Shri Narender Kumar Choudhry & Shri Bijayananda Pruseth

143 on the same. 3. not appreciating the fact that- (a) the Appellant is a Co-operative society duly registered under the Multi State Co.operative Societies Act, 1984 and carried on the business of banking in terms of license granted by the Reserve Bank of India. Hence, even though the Appellant was a Co-operative bank

CITIZENCREDIT CO OPERATIVE BANK LIMITED (MULUND BRANCH),MUMBAI vs. ITO (TDS) 1(1)(4), MUMBAI

Bench: Shri Narender Kumar Choudhry & Shri Bijayananda Pruseth

143 on the same. 3. not appreciating the fact that- (a) the Appellant is a Co-operative society duly registered under the Multi State Co.operative Societies Act, 1984 and carried on the business of banking in terms of license granted by the Reserve Bank of India. Hence, even though the Appellant was a Co-operative bank

CITIZENCREDIT CO-OPERATIVE BANK LIMITED (HILL ROAD BRANCH),MUMBAI vs. ITO (TDS) WARD 1(1)(4), MUMBAI

Bench: Shri Narender Kumar Choudhry & Shri Bijayananda Pruseth

143 on the same. 3. not appreciating the fact that- (a) the Appellant is a Co-operative society duly registered under the Multi State Co.operative Societies Act, 1984 and carried on the business of banking in terms of license granted by the Reserve Bank of India. Hence, even though the Appellant was a Co-operative bank

CITIZEN CREDIT CO.OPERATIVE BANK LTD.,,MUMBAI vs. ITO (TDS)-1(1)(4),, MUMBAI

Bench: Shri Narender Kumar Choudhry & Shri Bijayananda Pruseth

143 on the same. 3. not appreciating the fact that- (a) the Appellant is a Co-operative society duly registered under the Multi State Co.operative Societies Act, 1984 and carried on the business of banking in terms of license granted by the Reserve Bank of India. Hence, even though the Appellant was a Co-operative bank

CITIZEN CREDIT CO-OPERATIVE BANK LTD (SAHAR BRANCH),MUMBAI vs. ITO (TDS)-1(1)(4), MUMBAI

Bench: Shri Narender Kumar Choudhry & Shri Bijayananda Pruseth

143 on the same. 3. not appreciating the fact that- (a) the Appellant is a Co-operative society duly registered under the Multi State Co.operative Societies Act, 1984 and carried on the business of banking in terms of license granted by the Reserve Bank of India. Hence, even though the Appellant was a Co-operative bank