STANDARD CHARTERED BANK,MUMBAI vs. DDIT (IT) 2(1), MUMBAI

In the result, the appeal filed by the assessee is partly allowed and appeal filed by the Revenue is dismissed

Bench: Shri Vikas Awasthy & Shri Gagan Goyalstandard Chartered Bank Taxation Department, 23-25, M. G. Road, 3Rd Floor, Fort, Mumbai-400 001 Pan: Aabcs4681D ..... Appellant Vs. Ddit (Intl. Tax)-2(1) Scindia House, Ballard Estate, N. M. Marg, Mumbai-400 038 ..... Respondent

section, it is clear that it is in the nature of a disabling provision which puts a ceiling on the admissibility of a deduction. It does constitute a restriction-and a restriction which is not similarly placed for a domestic enterprise. The head office expenses, to the extent the same can be fairly allocated to the PE, are admissible

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

482/-\nRs.\n8,45,13,02,470/-\nRs.\n7,49,13,26,247/-\n6. In A.Y. 2017–18, the Assessing Officer disallowed employees' contribution to provident fund amounting to Rs. 82,10,149/- under section 36(1)(va), disallowed deduction claimed under section 80G in respect of CSR related payments amounting to Rs. 92,31,072/-, disallowed interest on delayed

SAPIENS TECHNOLOGIES (1982) INDIA PRIVATE LIMITED,MUMBAI vs. ACIT- 6(3)(1),, MUMBAI

In the result appeals of the revenue are dismissed

Bench: Shri C.N. Prasad, Hon'Ble & Shri M. Balaganesh, Hon'Ble

section 40(a)(ia) of the Act shall not be applicable in case of short deduction of tax at source. 3. Without prejudice to ground no.1 and 2 and on the facts, and in the circumstances of the case, and in law, the learned CIT(A) erred in directing the learned AO to allow the proportionate amount of salary

SAPIENS TECHNOLOGIES(1982) INDIA PRIVATE LIMITED,MUMBAI vs. DCIT - 6(3)(1), MUMBAI

In the result appeals of the revenue are dismissed

Bench: Shri C.N. Prasad, Hon'Ble & Shri M. Balaganesh, Hon'Ble

section 40(a)(ia) of the Act shall not be applicable in case of short deduction of tax at source. 3. Without prejudice to ground no.1 and 2 and on the facts, and in the circumstances of the case, and in law, the learned CIT(A) erred in directing the learned AO to allow the proportionate amount of salary

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

482/-\n8,45,13,02,470/-\n7,49,13,26,247/-\nincome\n6.\nIn A.Y. 2017-18, the Assessing Officer disallowed employees'\ncontribution to provident fund amounting to Rs. 82,10,149/-\nunder section 36(1)(va), disallowed deduction claimed under\nsection 80G in respect of CSR related payments amounting to Rs.\n92,31,072/-, disallowed interest on delayed payment

VASUDEV B. SARDA,MUMBAI vs. ITO 25(2)(4), MUMBAI

In the result, the appeal filed by the assessee is dismissed

Bench: Shri B.R. Baskaran & Shri Pawan Singhshri Vasudev B. Sarda Income Tax Officer-25(2)4 No. 2, Om Chaitnya Tower Pratyakash Kar Bhavan Happy Home Complex Vs. Bandra Kurla Complex Shanti Park, Mira Road (E) Bandra (E), Mumbai 400051 Mumbai 401107 Pan – Aakps0958B Appellant Respondent

482/- and Rs22,472/- for violation of section 194C and section 194J respectively. On appeal before CIT(A) the reopening of assessment as wall as addition under Section 40(a)(ia) were conformed. Further, aggrieved by the order of the CIT(A) assessee is in appeal before us. 4. None appeared on behalf of the assessee despite repeated call

ACIT(IT)-3(2)(2),MUMBAI, MUMBAI vs. MUNCHENER RUCKVERSICHERUNGS-GESELLSCHAFT AKTIENGESELLSCHAFT IN MUNCHEN, MUMBAI

Accordingly, the grounds raised by the assessee are allowed

Bench: Shri Amit Shukla, Jm & Ms Padmavathy S, Am

482 (SC) has held that income of a foreign enterprise can be taxed in India only qua such portion of income Munchener Ruckversicherungs-Gesellschaft Aktiengesellschaft in Munchen accruing and arising to such a foreign enterprise from profits attributable in India and that a method is to be found to ascertain the profits arising in India and only

MUNCHENER RUCKVERSICHERUNGS-GESELLSCHAFT AKTIENGESELLSCHAFT IN MUNCHEN,MUMBAI vs. DEPUTY COMMISSIONER OF INCOME TAX (IT)-3(2)(2), MUMBAI

Accordingly, the grounds raised by the assessee are allowed

Bench: Shri Amit Shukla, Jm & Ms Padmavathy S, Am

482 (SC) has held that income of a foreign enterprise can be taxed in India only qua such portion of income Munchener Ruckversicherungs-Gesellschaft Aktiengesellschaft in Munchen accruing and arising to such a foreign enterprise from profits attributable in India and that a method is to be found to ascertain the profits arising in India and only

MUNCHENER RUCKVERSICHERUNGS -GESELLSCHAFT AKTIENGESELLSCHAFT IN MUNCHEN ,MUMBAI vs. DEPUTY COMMISSIONER OF INCOME TAX (IT)-3(2)(2), MUMBAI

Accordingly, the grounds raised by the assessee are allowed

Bench: Shri Amit Shukla, Jm & Ms Padmavathy S, Am

482 (SC) has held that income of a foreign enterprise can be taxed in India only qua such portion of income Munchener Ruckversicherungs-Gesellschaft Aktiengesellschaft in Munchen accruing and arising to such a foreign enterprise from profits attributable in India and that a method is to be found to ascertain the profits arising in India and only

ACIT(IT)-3(2)(2) MUMBAI, MUMBAI vs. MUNCHENER RUCKVERSICHERUNGS-GESELLSCHAFT AKTIENGESELLSCHAFT IN MUNCHEN, MUMBAI

Accordingly, the grounds raised by the assessee are allowed

Bench: Shri Amit Shukla, Jm & Ms Padmavathy S, Am

482 (SC) has held that income of a foreign enterprise can be taxed in India only qua such portion of income Munchener Ruckversicherungs-Gesellschaft Aktiengesellschaft in Munchen accruing and arising to such a foreign enterprise from profits attributable in India and that a method is to be found to ascertain the profits arising in India and only

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

482/- 8,45,13,02,470/- 7,49,13,26,247/-\nRs.\nRs.\nincome\n6.\nIn A.Y. 2017–18, the Assessing Officer disallowed employees'\ncontribution to provident fund amounting to Rs. 82,10,149/-\nunder section 36(1)(va), disallowed deduction claimed under\nsection 80G in respect of CSR related payments amounting to Rs.\n92,31,072/-, disallowed interest

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

482/- 8,45,13,02,470/- 7,49,13,26,247/- income 6. In A.Y. 2017–18, the Assessing Officer disallowed employees’ contribution to provident fund amounting to Rs. 82,10,149/- under section 36(1)(va), disallowed deduction claimed under section 80G in respect of CSR related payments amounting to Rs. 92,31,072/-, disallowed interest on delayed payment

ABB SWITZERLAND LTD,BANGALORE vs. ADIT 1(1),

In the result, both the appeal of the assessee stands allowed

Bench: Shri G S Pannu & Shri Amit Shukla

TDS’); levy of interest under section 234B and 234C; and initiation of penalty proceedings under section 271(1)(c) by the AO. 3. Before us, the Ld. Senior Counsel Mr. Perci J. Pardiwalla, submitted that in this case the reopening of assessment under section 147 vide notice dated 25.03.2011 u/s 148 is itself is bad in law and accordingly

ABB SWITZERLAND LTD,BANGALORE vs. ADIT 1(1),

In the result, both the appeal of the assessee stands allowed

Bench: Shri G S Pannu & Shri Amit Shukla

TDS’); levy of interest under section 234B and 234C; and initiation of penalty proceedings under section 271(1)(c) by the AO. 3. Before us, the Ld. Senior Counsel Mr. Perci J. Pardiwalla, submitted that in this case the reopening of assessment under section 147 vide notice dated 25.03.2011 u/s 148 is itself is bad in law and accordingly

IDEA CELLULAR LTD,MUMBAI vs. DCIT 3(2), MUMBAI

In the result, appeal of the Revenue in ITA No

TDS) Pune vs Vodafone Cellular Ltd (assessee‟s own case) in Income Tax Appeal Nos. 1152 , 1274, 1995, of 2017 & Income Tax Appeal Nos. 571, 1266 of 2018 dated 27/01/2020 had also taken an identical view in respect of identical issue. 2.8.6. The ld.DR before us placed heavy reliance on the decision of Hon‟ble Supreme Court in the case

DCIT 3(2), MUMBAI vs. IDEA CELLULAR LTD, MUMBAI

In the result, appeal of the Revenue in ITA No

TDS) Pune vs Vodafone Cellular Ltd (assessee‟s own case) in Income Tax Appeal Nos. 1152 , 1274, 1995, of 2017 & Income Tax Appeal Nos. 571, 1266 of 2018 dated 27/01/2020 had also taken an identical view in respect of identical issue. 2.8.6. The ld.DR before us placed heavy reliance on the decision of Hon‟ble Supreme Court in the case

DCIT - 14(2)(1), MUMBAI vs. IDEA CELLULAR LTD., MUMBAI

In the result, the ground no

TDS\nat lower rate, the same is allowable. The ld. AO proceeded to disallow Rs.86,59,127/-\nchallenging which the assessee was in appeal before the first appellate authority.\n60. The ld. CIT(A) allowed this ground of appeal raised by the assessee by relying on\nassessee's own case for A.Y. 2010-11 in assessee's own case, where

THE INDIAN HOTELS COMPANY LTD,MUMBAI vs. ASST CIT CIR 2(2)(1), MUMBAI

In the result, appeal of the Assessee is partly allowed whereas the appeal of the Revenue is dismissed

TDS and TCS as prayed in Ground No. 11 above and after reducing the demand as prayed in Ground No. 12 above.” 31. Ground No. 14 pertains to levying of excess interest under Section 234D of the Act and is therefore disposed off as being consequential in nature. Ground No. 13, and Additional Ground No. 2&3 32. Ground