DY..C.I.T., BANGALORE vs. M/S STATE BANK OF MYSORE, BANGALORE

In the result, the appeal of the Revenue Ground-3 is dismissed

41(4) is applicable only\nwhen recoveries of bad debts in relation to debts, for which deduction under\nsection 36(1)(vii) is allowed. However, the issue is restored to the file of the Ld.AO\nto verify if the recovery of the amount, in the present case is in respect of write off\nof claim allowed as a deduction under

DCIT CEN CIR 8(4), MUMBAI vs. SAVITA OIL TECHNOLOGIES LTD, MUMBAI

Appeal is allowed

Bench: Shri Mahavir Singh & Shri Ramit Kocharआयकर अपीऱ सं./I.T.A. No.7620/Mum/2016 (नििाारण वर्ा / Assessment Year : 2010-11)

Section 156 to require the assessee to pay such sum by serving a notice (or revised notice) of demand. The notice of demand under Section 156, if issued before the assessment becomes final and binding, is subject to upward revision (or refund) in due course, in accordance with the assessment that comes to be finally made. The stage for refund

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

41,05,801/-\nand made disallowance under section 40(a)(ia) amounting to Rs.\n50,49,586/-. The CIT(A) confirmed all the above disallowances\nfollowing the appellate order for the preceding year and granted\nlimited relief in respect of TDS credit, while treating interest\ngrounds as consequential.\n8.\nIn A.Y. 2022-23, no independent addition or disallowance\nwas made

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)

41,70,860/- filed by the Assessee has been accepted as assessed income. At the same time the Assessing Officer has, while concluding, has stated that the „assessment of income is done as per computation sheet‟. A perusal of the Computation Sheet shows that the adjustment made while processing return of income under Section 143(1) of the Act have

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)

41,70,860/- filed by the Assessee has been accepted as assessed income. At the same time the Assessing Officer has, while concluding, has stated that the „assessment of income is done as per computation sheet‟. A perusal of the Computation Sheet shows that the adjustment made while processing return of income under Section 143(1) of the Act have

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)

41,70,860/- filed by the Assessee has been accepted as assessed income. At the same time the Assessing Officer has, while concluding, has stated that the „assessment of income is done as per computation sheet‟. A perusal of the Computation Sheet shows that the adjustment made while processing return of income under Section 143(1) of the Act have

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

41,05,801/-, and made disallowance under section 40(a)(ia) amounting to Rs. 50,49,586/-. The CIT(A) confirmed all the above disallowances following the appellate order for the preceding year and granted limited relief in respect of TDS credit, while treating interest grounds as consequential. 8. In A.Y. 2022–23, no independent addition or disallowance was made

ACIT, CIRCLE-2(1)(1), MUMBAI vs. M/S BANK OF INDIA, MUMBAI

In the result, the appeal by the Revenue for the assessment year 2018-

Bench: Shri Vikram Singh Yadavshri Sandeep Singh Karhailita No.1452/Mum/2023 Assessment Year : 2016-17 Assessment Year : 2018-19

section 143(3) of the Act, disagreed with the submissions of the assessee and held that perpetual bonds are in the nature of debt instruments with no maturity date. Only the issuing company can buy back the bonds from the investors. Therefore, it was held these bonds are perpetual in nature. Since in the case of perpetual bonds, the investor

BANK OF INDIA,MUMBAI vs. ACIT-2(1)(2), MUMBAI

In the result, the appeal by the Revenue for the assessment year 2018-

Bench: Shri Vikram Singh Yadavshri Sandeep Singh Karhailita No.1452/Mum/2023 Assessment Year : 2016-17 Assessment Year : 2018-19

section 143(3) of the Act, disagreed with the submissions of the assessee and held that perpetual bonds are in the nature of debt instruments with no maturity date. Only the issuing company can buy back the bonds from the investors. Therefore, it was held these bonds are perpetual in nature. Since in the case of perpetual bonds, the investor

ACIT (LTU)-1, MUMBAI vs. UNION BANK OF INDIA, MUMBAI

In the result, appeal of the assessee is allowed

41 of 1999).\n19\nI.T.A. No. 424/Mum/2020\nI.T.A. No. 882/Mum/2020\n(h) in the case of a banking company, any matters which are not required to\nbe disclosed by the Banking Regulation Act, 1949 (10 of 1949),\n(c) in the case of a company engaged in the generation or supply of\nelectricity, any matters which are not required

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

41,05,801/-, and made disallowance under section 40(a)(ia) amounting to Rs. 50,49,586/-. The CIT(A) confirmed all the above disallowances following the appellate order for the preceding year and granted limited relief in respect of TDS credit, while treating interest grounds as consequential.\n8. In A.Y. 2022–23, no independent addition or disallowance was made

DCIT CEN CIR 7(3), MUMBAI vs. GALAXY PREMISES P.LTD, MUMBAI

The appeals of the Revenue are dismissed

Bench: Shri Joginder Singh & Shri G. Manjunatha

41 M/s Galaxy Premises Pvt. Ltd. the recognized modes of recording the loan/deposit. The commercial nature and occurrence of these transactions by way of journal entries is in the normal course of business operation of the group concerns. In this regard, there is no adverse finding by the AO in the regular assessment. AO has not made

DCIT CEN CIR 7(3), MUMBAI vs. GALAXY PREMISES P.LTD, MUMBAI

The appeals of the Revenue are dismissed

Bench: Shri Joginder Singh & Shri G. Manjunatha

41 M/s Galaxy Premises Pvt. Ltd. the recognized modes of recording the loan/deposit. The commercial nature and occurrence of these transactions by way of journal entries is in the normal course of business operation of the group concerns. In this regard, there is no adverse finding by the AO in the regular assessment. AO has not made

DCIT CEN CIR 7(3), MUMBAI vs. GALAXY PREMISES P.LTD, MUMBAI

The appeals of the Revenue are dismissed

Bench: Shri Joginder Singh & Shri G. Manjunatha

41 M/s Galaxy Premises Pvt. Ltd. the recognized modes of recording the loan/deposit. The commercial nature and occurrence of these transactions by way of journal entries is in the normal course of business operation of the group concerns. In this regard, there is no adverse finding by the AO in the regular assessment. AO has not made

DCIT CEN CIR 7(3), MUMBAI vs. GALAXY PREMISES P.LTD, MUMBAI

The appeals of the Revenue are dismissed

Bench: Shri Joginder Singh & Shri G. Manjunatha

41 M/s Galaxy Premises Pvt. Ltd. the recognized modes of recording the loan/deposit. The commercial nature and occurrence of these transactions by way of journal entries is in the normal course of business operation of the group concerns. In this regard, there is no adverse finding by the AO in the regular assessment. AO has not made

DCIT CEN CIR 7(3), MUMBAI vs. GALAXY PREMISES P.LTD, MUMBAI

The appeals of the Revenue are dismissed

Bench: Shri Joginder Singh & Shri G. Manjunatha

41 M/s Galaxy Premises Pvt. Ltd. the recognized modes of recording the loan/deposit. The commercial nature and occurrence of these transactions by way of journal entries is in the normal course of business operation of the group concerns. In this regard, there is no adverse finding by the AO in the regular assessment. AO has not made

DCIT CEN CIR 7(3), MUMBAI vs. GALAXY PREMISES P.LTD, MUMBAI

The appeals of the Revenue are dismissed

Bench: Shri Joginder Singh & Shri G. Manjunatha

41 M/s Galaxy Premises Pvt. Ltd. the recognized modes of recording the loan/deposit. The commercial nature and occurrence of these transactions by way of journal entries is in the normal course of business operation of the group concerns. In this regard, there is no adverse finding by the AO in the regular assessment. AO has not made

BANK OF INDIA,MUMBAI vs. THE NATIONAL FACELESS ASSESSMENT CENTRE, MUMBAI

TDS is deducted on the interest paid and interest is debited to P&L account\n• the bond holders have no right to participate in management of the bank\nThe appellant had submitted that the bonds of Rs. 1,680 Crores outstanding\nas on 31.03.2016 have been redeemed as under:\nPerpetual Bonds – IPDI Series I\n400.00\n24-07-2017\nPerpetual

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

41,05,801/-\nand made disallowance under section 40(a)(ia) amounting to Rs.\n50,49,586/-. The CIT(A) confirmed all the above disallowances\nfollowing the appellate order for the preceding year and granted\nlimited relief in respect of TDS credit, while treating interest\ngrounds as consequential.\n8.\nIn A.Y. 2022–23, no independent addition or disallowance\nwas made