DCIT 2(2)(1), MUMBAI vs. STATE BANK OF INDIA, MUMBAI

The appeal of the Revenue is dismissed

Bench: Shri Joginder Singh & Shri N.K. Pradhanassessment Year: 1995-96 Dcit-2(2)(1), M/S State Bank Of India, R. No.545, Financial Reporting & बनाम/ Aayakar Bhavan Taxation Department, 3Rd Vs. M.K. Road, Floor, Corporate Centre, Mumbai-400020 State Bank Bhavan, Madam Cama Road, Nariman Point, Mumbai-400021 (राज"व /Revenue) ("नधा"रती /Assessee) P.A. No. Aaacs8577K

b) of the sub- section clarifies that the date of payment of tax or penalty would mean the date on and from which the amount of tax or penalty specified in the notice of demand issued under section 156 is paid in excess of such demand. x.The assesses are entitled not only to the refund of tax deposited u/s.195

RAYMOND LTD,MUMBAI vs. DCIT RG 2(3), MUMBAI

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

Bench: Shri Amarjit Singh & Shri Sandeep Singh Karhailita Nos. 8641 & 8642/Mum/2011 (A.Ys. 1999-2000 & 2000-01) Raymond Limited, Vs. The Dcit-2(3) New Hind House, Aayakar Bhavan, Narottam Morarjee Marg, M.K. Road, Ballard Estate, Mumbai – 400 020 Mumbai – 400 001 स्थायी लेखा सं./ जीआइआर सं./ Pan/Gir No: Aaacr4896A Assessee .. Revenue

section 244A(1)(b) of the Income Tax Act, 1961 (the Act) on self-assessment tax paid, by relying on the orders of the Commissioner of Income-tax (Appeals) -6, Mumbai dated 30/09/2011 for assessment years 1994-95, 1995-96 and 1998-99, on the ground that even though the advance tax and TDS

RAYMOND LTD,MUMBAI vs. DCIT RG 2(3), MUMBAI

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

Bench: Shri Amarjit Singh & Shri Sandeep Singh Karhailita Nos. 8641 & 8642/Mum/2011 (A.Ys. 1999-2000 & 2000-01) Raymond Limited, Vs. The Dcit-2(3) New Hind House, Aayakar Bhavan, Narottam Morarjee Marg, M.K. Road, Ballard Estate, Mumbai – 400 020 Mumbai – 400 001 स्थायी लेखा सं./ जीआइआर सं./ Pan/Gir No: Aaacr4896A Assessee .. Revenue

section 244A(1)(b) of the Income Tax Act, 1961 (the Act) on self-assessment tax paid, by relying on the orders of the Commissioner of Income-tax (Appeals) -6, Mumbai dated 30/09/2011 for assessment years 1994-95, 1995-96 and 1998-99, on the ground that even though the advance tax and TDS

KOTAK MAHINDRA BANK LIMITED,MUMBAI vs. DCIT 2(3)(1), MUMBAI

In the result, all the grounds of appeal of assessee is allowed

Bench: Shri Pawan Singh& Smt.Renu Jauhri

TDS and becomes tax paid on regular assessment and thus, the proviso to section 244A(1)(a) is not applicable and interest is payable within the meaning of section 244A(1)(b

KOTAK MAHINDRA BANK LIMITED,MUMBAI vs. DCIT 2 3 1, MUMBAI

In the result, all the grounds of appeal of assessee is allowed

Bench: Shri Pawan Singh& Smt.Renu Jauhri

TDS and becomes tax paid on regular assessment and thus, the proviso to section 244A(1)(a) is not applicable and interest is payable within the meaning of section 244A(1)(b

KOTAK MAHINDRA BANK LIMITED,MUMBAI vs. DCIT 2(3)(1), MUMBAI

In the result, all the grounds of appeal of assessee is allowed

Bench: Shri Pawan Singh& Smt.Renu Jauhri

TDS and becomes tax paid on regular assessment and thus, the proviso to section 244A(1)(a) is not applicable and interest is payable within the meaning of section 244A(1)(b

KOTAK MAHINDRA BANK LIMITED,MUMBAI vs. DCIT 2(3)(1), MUMBAI

In the result, all the grounds of appeal of assessee is allowed

Bench: Shri Pawan Singh& Smt.Renu Jauhri

TDS and becomes tax paid on regular assessment and thus, the proviso to section 244A(1)(a) is not applicable and interest is payable within the meaning of section 244A(1)(b

KOTAK MAHINDRA BANK LIMITED,MUMBAI vs. DCIT 2(3)(1), MUMBAI

In the result, all the grounds of appeal of assessee is allowed

Bench: Shri Pawan Singh& Smt.Renu Jauhri

TDS and becomes tax paid on regular assessment and thus, the proviso to section 244A(1)(a) is not applicable and interest is payable within the meaning of section 244A(1)(b

KOTAK MAHINDRA BANK LIMITED,MUMBAI vs. DCIT 2(3)(1), MUMBAI

In the result, all the grounds of appeal of assessee is allowed

Bench: Shri Pawan Singh& Smt.Renu Jauhri

TDS and becomes tax paid on regular assessment and thus, the proviso to section 244A(1)(a) is not applicable and interest is payable within the meaning of section 244A(1)(b

DCIT 2(2)(1), MUMBAI vs. STATE BANK OF INDIA, MUMBAI

In the result, both the appeals of the revenue are dismissed

Bench: Shri Pawan Singh, Jm & Shri M.Balaganesh, Am

b) of the Act, rather then having provided from the date of payment of the tax. 13. We find support for our view from the decisions rendered by Karnataka High Court in Commissioner of Income-Tax v/s Vijaya Bank [2011] 338 ITR page 489 and Delhi High Court in Commissioner of Income-Tax v/s Sutlej Industries

ACIT 2(2)(1), MUMBAI vs. ICICI PRUDENTIAL AMC LTD, MUMBAI

In the result, appeal of the Revenue is dismissed

Bench: Shri C.N. Prasad, Hon'Ble & Shri G. Manjunatha, Hon'Blea.C.I.T, Circle – 2(2)(1) V. M/S. Icici Prudential Amc Ltd., Room No. 545, 5Th Floor, 8Th Floor, Peninsula Tower, Aayakar Bhavan, M.K. Road, Peninsula Corporate Park, Mumbai-400 020 Lower Parel, Mumbai- 400 013 Pan: Aaaci 1000 K (Appellant) (Respondent) Assessee By : None Department By : Shri Abi Rama Kartikeyan

section 244A(1) of the Act covers interest on refund arising on account of tax paid by way of advance tax, TDS etc. It was further submitted that clause 'b

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

TDS credit was allowed on\nthe basis of Form 26AS and, in absence of reconciliation to his\nsatisfaction, no further credit could be allowed.\nGround No. VII -Levy of interest under section 234D Rs.\n5,26,845/-\n61. The Assessing Officer levied interest under section 234D of\nthe Act on the ground that the refund granted earlier was in\nexcess

UTI MUTUAL FUND,MUMBAI vs. DCIT CENTRALISED PROCESSING CELL-TDS, TRACES, GHAZIABAD

In the result, appeal of the assessee in ITA no

Bench: Shri C.N Prasad & Shri Ramit Kocharआयकर अपीऱ सं./I.T.A. No.2295/Mum/2018 (नििाारण वर्ा / Assessment Year: 2014-15) बिाम/ Uti Mutual Fund, Dcit, Centralised Gn Block, Uti Tower, Processing Cell-Tds, Bandra Complex, Traces, V. Bandra (E), Aayakar Bhawan, Mumbai-400051 Sector-3, Vaishali, Ghaziabad, Up- 201010 स्थायी ऱेखा सं./ Pan: Aaatu1088L (अपीऱाथी /Appellant) .. (प्रत्यथी / Respondent) Assessee By: Ms. Krupa Gandhi Revenue By: Shri. Rajeev Gubgotra (Dr) सुनवाई की तारीख /Date Of Hearing : 13.06.2019 घोषणा की तारीख /Date Of Pronouncement : 01.07.2019 आदेश / O R D E R Per Ramit Kochar: This Appeal, Filed By Assessee, Being

TDS default has been laid out. 2.7 The decision rendered in the case of CIT vs Arvind Mills Limited (supra) was in the context of section 244A and not in the context of 201(1A) of the Act which applies to the case under consideration. It deserves consideration that section 244A(1) refers to month or part of the month

ECONOMIC LAWS PRACTICE,MUMBAI vs. CIT (A)59, MUMBAI

In the result, appeal of the assessee in ITA no

Bench: Hon’Ble Shri C.N. Prasad, Jm & Hon’Ble Shri Manoj Kumar Aggarwal, Am

244A(1) is analogous to provisions of Section 201(1A)(ii) read with Rule 119A of the Act and a month must be given ordinary meaning of the term by taking period of 30 days and not British calendar month as defined u/s 3(35) of the General Clauses Act. In the case of ONGC (supra), the Ahmadabad Bench

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 was allowed on (30) ITA No. 6663, 6701, 6702 & 6703 /Mum/2025 Aditya Birla Sun Life AMC Limited the basis of Form 26AS and, in absence of reconciliation to his satisfaction, no further credit could be allowed. Ground No. VII -Levy of interest under section 234D – Rs. 5,26,845/- 61. The Assessing Officer levied interest under section 234D

GRASIM INDUSTRIES LTD ( CORPORATE FINANCE DIVISION),MUMBAI vs. ADDL CIT RG 6(3), MUMBAI

Bench: the CIT(A). The CIT(A) partly allowed the appeal preferred by the Assessee vide order, dated 18/05/2009. 4. Not being satisfied with the relief granted by the Id. CIT(A), the Assessee has preferred appeal before this Tribunal. The Revenue has also filed cross-appeal challenging the relief granted by the Id. CIT(A).

244A(1) would be assessable in the year in which it is granted and not in the year in which proceedings under section 143(1)(a) attain finality. 16. The matter will now go to the regular Bench for decision on merits.” (Emphasis Supplied) 10.4. We note that the CIT(A) has decided the issue in the following manner

DCIT 8(3)(2), MUMBAI vs. VOLTAS LTD, MUMBAI

In the result, the appeal Revenue is dismissed

Bench: Sri Mahavir Singh, Jm & Sri Rajesh Kumar, Am

TDS. The assessee company also requested for grant of interest on the refund. The AO passed rectification order under section 154 of the Act dated 05.03.2012 and granted refund of ₹ 2,62,32,165/-. But did not grant interest under section 244A(1)(b

ACIT 6(3), MUMBAI vs. GRASIM INDUSTRIES LTD, MUMBAI

244A(1) would be assessable in the\nyear in which it is granted and not in the year in which\nproceedings under section 143(1)(a) attain finality.\n16. The matter will now go to the regular Bench for decision on\nmerits.” (Emphasis Supplied)\n10. 4. We note that the CIT(A) has decided the issue in the following\nmanner