DEEPAK NOVOCHEM TECHNOLOGIES LTD,MUMBAI vs. THE ASSISTANT COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-8(1), MUMBAI

In the result, the appeals filed by the assessee are In the result, the appeals filed by the assessee are In the result, the appeals filed by the assessee are allowed partly for statistical purposes

Bench: Shri Om Prakash Kant () & Shri Rahul Chaudhary () Ita Nos. 2558 To 2562/Mum/2023 Assessment Years: 2014-15 To 2018-19 Deepak Novochem The Acit, Cc-8(1), Technologies Ltd., Aayakar Bhavan, Room No. Vs. 515, 5Th Floor, Citi Point, Boat 656, 6Th Floor, M.K. Road, Club Road, Pune City, Mumbai-400020. Pune-411 001. Pan No. Aaccd 5796 K Appellant Respondent Assessee By : Mr. H.P. Mahajani Revenue By : Mrs. Sanyogita Nagpal, Cit-Dr : Date Of Hearing 16/11/2023 Date Of Pronouncement : 28/11/2023

35(2AB). Further, if the expenses are liable for TDS, then allowability of such expenses if the expenses are liable for TDS, then allowability of such expenses if the expenses are liable for TDS, then allowability of such expenses would be subjected would be subjected to provisions of section

DEEPAK NOVOCHEM TECHNOLOGIES LTD,MUMBAI vs. THE ASSISTANT COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-8(1), MUMBAI

In the result, the appeals filed by the assessee are In the result, the appeals filed by the assessee are In the result, the appeals filed by the assessee are allowed partly for statistical purposes

Bench: Shri Om Prakash Kant () & Shri Rahul Chaudhary () Ita Nos. 2558 To 2562/Mum/2023 Assessment Years: 2014-15 To 2018-19 Deepak Novochem The Acit, Cc-8(1), Technologies Ltd., Aayakar Bhavan, Room No. Vs. 515, 5Th Floor, Citi Point, Boat 656, 6Th Floor, M.K. Road, Club Road, Pune City, Mumbai-400020. Pune-411 001. Pan No. Aaccd 5796 K Appellant Respondent Assessee By : Mr. H.P. Mahajani Revenue By : Mrs. Sanyogita Nagpal, Cit-Dr : Date Of Hearing 16/11/2023 Date Of Pronouncement : 28/11/2023

35(2AB). Further, if the expenses are liable for TDS, then allowability of such expenses if the expenses are liable for TDS, then allowability of such expenses if the expenses are liable for TDS, then allowability of such expenses would be subjected would be subjected to provisions of section

DEEPAK NOVOCHEM TECHNOLOGIES LTD,MUMBAI vs. THE ASSISTANT COMMISSIONER OF INCOME TAX CENTRAL CIRCLE-8(1), MUMBAI

In the result, the appeals filed by the assessee are In the result, the appeals filed by the assessee are In the result, the appeals filed by the assessee are allowed partly for statistical purposes

Bench: Shri Om Prakash Kant () & Shri Rahul Chaudhary () Ita Nos. 2558 To 2562/Mum/2023 Assessment Years: 2014-15 To 2018-19 Deepak Novochem The Acit, Cc-8(1), Technologies Ltd., Aayakar Bhavan, Room No. Vs. 515, 5Th Floor, Citi Point, Boat 656, 6Th Floor, M.K. Road, Club Road, Pune City, Mumbai-400020. Pune-411 001. Pan No. Aaccd 5796 K Appellant Respondent Assessee By : Mr. H.P. Mahajani Revenue By : Mrs. Sanyogita Nagpal, Cit-Dr : Date Of Hearing 16/11/2023 Date Of Pronouncement : 28/11/2023

35(2AB). Further, if the expenses are liable for TDS, then allowability of such expenses if the expenses are liable for TDS, then allowability of such expenses if the expenses are liable for TDS, then allowability of such expenses would be subjected would be subjected to provisions of section

ASIAN PAINTS LIMITED,SANTACRUZ vs. NATIONAL FACELESS ASSESSMENT CENTRE, DELHI

35. Before us, ld. Counsel for the assessee submitted that (i) These expenses in comparison to total expenses (i.e. Rs. 3,636.75 crores) are minuscule, which comes to around only 0.02% of our total expenditure. (ii) That expenses attributable to the earlier years but crystallize in the year under consideration on receipt of invoice/bills ought to be allowed. Even

DY. CIT CIRCLE 3(4), MUMBAI, MUMBAI vs. ASIAN PAINTS LTD, MUMBAI

In the result, appeals filed by assessee and Revenue for A

Bench: IN THE INCOME TAX APPELLATE TRIBUNAL, ‘A‘ BENCH MUMBAI BEFORE: SHRI AMIT SHUKLA (Judicial Member), SMT RENU JAUHRI (Accountant Member)

35. Before us, ld. Counsel for the assessee submitted that - (i) These expenses in comparison to total expenses (i.e. Rs. 3,636.75 crores) are minuscule, which comes to around only 0.02% of our total expenditure. (ii) That expenses attributable to the earlier years but crystallize in the year under consideration on receipt of M/s. Asian Paints invoice/bills ought

ASIAN PAINTS LIMITED,SANTACRUZ vs. ASSISTANT COMMISSIONER OF INCOME TAX, LTU CIRCLE 1, CUFFE PARADE

In the result, appeals filed by assessee and Revenue for\nA

35(2AB), however, the DSIR in its Form 3CL,\nspecifically disallowed \"rent, electricity and maintenance\".\nThe Assessee relied on plethora of decisions in its favour to\ncontend that once facility is approved and other conditions\nare complied with, DSIR cannot quantify expenditure and\nspecifically considering that the amendment to Rule 6(7A)(b)\nwas w.e.f.1.7.2016. The Hon'ble Tribunal took

DY CIT CIRCLE -3(4), MUMBAI, MUMBAI vs. ASIAN PAINTS LIMITED, MUMBAI

35(2AB), however, the DSIR in its Form 3CL,\nspecifically disallowed \"rent, electricity and maintenance\".\nThe Assessee relied on plethora of decisions in its favour to\ncontend that once facility is approved and other conditions\nare complied with, DSIR cannot quantify expenditure and\nspecifically considering that the amendment to Rule 6(7A)(b)\nwas w.e.f.1.7.2016. The Hon'ble Tribunal took

DY CIT CIRCLE 3(4), MUMBAI, MUMBAI vs. ASIAN PAINTS, MUMBAI

In the result, appeals filed by assessee and Revenue for\nA

35(2AB), however, the DSIR in its Form 3CL,\nspecifically disallowed \"rent, electricity and maintenance\".\nThe Assessee relied on plethora of decisions in its favour to\ncontend that once facility is approved and other conditions\nare complied with, DSIR cannot quantify expenditure and\nspecifically considering that the amendment to Rule 6(7A)(b)\nwas w.e.f.1.7.2016. The Hon'ble Tribunal took

ASIAN PAINTS LIMITED,SANTACRUZ vs. DEPUTY COMMISSIONER OF INCOME TAX, LTU CIRCLE 2, CUFFE PARADE

In the result, appeals filed by assessee and Revenue for\nA

35(2AB), however, the DSIR in its Form 3CL,\nspecifically disallowed \"rent, electricity and maintenance\".\nThe Assessee relied on plethora of decisions in its favour to\ncontend that once facility is approved and other conditions\nare complied with, DSIR cannot quantify expenditure and\nspecifically considering that the amendment to Rule 6(7A)(b)\nwas w.e.f.1.7.2016. The Hon'ble Tribunal took

J.B. CHEMICALS AND PHARMACEUTICAL LTD,MUMBAI vs. DCIT CEN CIR 2(1), MUMBAI

The appeals of the assessee are partly allowed

Bench: Shri Aby T. Varkey () & Ms. Padmavathy S. ()

section 35(2AB). Aggrieved, the assessee preferred appeal before the CIT(A), who sustained the order of the Assessing Officer. Aggrieved, he assessee filed appeal before the Tribunal. 4. The assessee vide letters date 07/01/2021, 26/03/2021 and 02/05/2022 raised additional grounds. The issues contended which are common for all the assessment years under consideration through various grounds including the additional

J.B.CHEMICALS & PHARMACEUTICALS LTD.,MUMBAI vs. DCIT -CC -2(1), MUMBAI

The appeals of the assessee are partly allowed

Bench: Shri Aby T. Varkey () & Ms. Padmavathy S. ()

section 35(2AB). Aggrieved, the assessee preferred appeal before the CIT(A), who sustained the order of the Assessing Officer. Aggrieved, he assessee filed appeal before the Tribunal. 4. The assessee vide letters date 07/01/2021, 26/03/2021 and 02/05/2022 raised additional grounds. The issues contended which are common for all the assessment years under consideration through various grounds including the additional

J.B.CHEMICALS & PHARMACEUTICALS LTD.,MUMBAI vs. DCIT -CC -2(1), MUMBAI

The appeals of the assessee are partly allowed

Bench: Shri Aby T. Varkey () & Ms. Padmavathy S. ()

section 35(2AB). Aggrieved, the assessee preferred appeal before the CIT(A), who sustained the order of the Assessing Officer. Aggrieved, he assessee filed appeal before the Tribunal. 4. The assessee vide letters date 07/01/2021, 26/03/2021 and 02/05/2022 raised additional grounds. The issues contended which are common for all the assessment years under consideration through various grounds including the additional

J.B. CHEMICALS AND PHARMACEUTICAL LTD,MUMBAI vs. DCIT CEN CIR 2(1), MUMBAI

The appeals of the assessee are partly allowed

Bench: Shri Aby T. Varkey () & Ms. Padmavathy S. ()

section 35(2AB). Aggrieved, the assessee preferred appeal before the CIT(A), who sustained the order of the Assessing Officer. Aggrieved, he assessee filed appeal before the Tribunal. 4. The assessee vide letters date 07/01/2021, 26/03/2021 and 02/05/2022 raised additional grounds. The issues contended which are common for all the assessment years under consideration through various grounds including the additional

PEOPLE INERACTIVE (I) P. LTD,MUMBAI vs. PR CIT 7, MUMBAI

The appeals of the assessee are allowed

Bench: Shri Joginder Singh & Shri Rajesh Kumar

35 and part of 36 do not separately apply to an eligible unit during the period of tax holiday. During the ITA No. 3558 & 3717/Mum/2016 27 said period the deduction under the aforesaid sections of the Act are deemed to have been made. Similarly, under Section 10A(6)(ii) losses referred to in Section

PEOPLE INERACTIVE (I) P.LTD,MUMBAI vs. PR CIT 7, MUMBAI

The appeals of the assessee are allowed

Bench: Shri Joginder Singh & Shri Rajesh Kumar

35 and part of 36 do not separately apply to an eligible unit during the period of tax holiday. During the ITA No. 3558 & 3717/Mum/2016 27 said period the deduction under the aforesaid sections of the Act are deemed to have been made. Similarly, under Section 10A(6)(ii) losses referred to in Section

ACIT, PIRAMAL CHAMBERS vs. MILESTONE REAL ESTATE FUND, MUMBAI

35) of the\nAct.\n10.\nIn the Appeal, the CIT(A) deleted the additions made by the\nAssessing Officer under Section 10(23FB) of the Act by placing\nreliance upon the decision of the Tribunal in the case of the\nAssessee pertaining to the Assessment Year 2013-14 [ITA No.\n2509/MUM/2018, dated 10/08/2018].\n11.\nWe have given thoughtful consideration

DISHA DISTRIBUTORS,MUMBAI vs. A.O. TDS WD KALYAN, KALYAN

In the result, all the appeals filed by different assessees for different quarters relating to different years are allowed

Bench: Shri Jason P. Boaz & Shri Sanjay Garg

TDS statements under section 200A of the Act. In view of the present set of facts, where the Assessing Officer had charged fees under section 234E of the Act while processing the statements under section 200A of the Act before 01.06.2015, there is no merit in the reliance placed upon by the learned CIT-DR on the said proposition laid

ASIAN PIPES & PROFILES P. LTD,AMBERNATH vs. A.O. TDS WD KALYAN, MUMBAI

In the result, all the appeals filed by different assessees for different quarters relating to different years are allowed

Bench: Shri Jason P. Boaz & Shri Sanjay Garg

TDS statements under section 200A of the Act. In view of the present set of facts, where the Assessing Officer had charged fees under section 234E of the Act while processing the statements under section 200A of the Act before 01.06.2015, there is no merit in the reliance placed upon by the learned CIT-DR on the said proposition laid