MUMBAI METROPLITAN REGION DEVELOPMENT AUTHORITY,MUMBAI vs. DDIT (E) -1(1), MUMBAI

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

Bench: Shri S. Rifaur Rahman, Hon'Ble & Shri Pavan Kumar Gadale, Hon'Ble

TDS)-2(3), Mumbai on 10th February, 2011. During the course of the survey it was found that assessee received lease premium against the property from different parties. In this regard assessee was asked to furnish details of lease premium. In response, Ld. AR of the assessee submitted as under: - “The Authority has auctioned land in Bandra Kurla Complex

MUMBAI METROPLITAN REGION DEVELOPMENT AUTHORITY,MUMBAI vs. DDIT (E) -1(1), MUMBAI

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

Bench: Shri S. Rifaur Rahman, Hon'Ble & Shri Pavan Kumar Gadale, Hon'Ble

TDS)-2(3), Mumbai on 10th February, 2011. During the course of the survey it was found that assessee received lease premium against the property from different parties. In this regard assessee was asked to furnish details of lease premium. In response, Ld. AR of the assessee submitted as under: - “The Authority has auctioned land in Bandra Kurla Complex

MUMBAI METROPLITAN REGION DEVELOPMENT AUTHORITY,MUMBAI vs. DDIT (E) -1(1), MUMBAI

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

Bench: Shri S. Rifaur Rahman, Hon'Ble & Shri Pavan Kumar Gadale, Hon'Ble

TDS)-2(3), Mumbai on 10th February, 2011. During the course of the survey it was found that assessee received lease premium against the property from different parties. In this regard assessee was asked to furnish details of lease premium. In response, Ld. AR of the assessee submitted as under: - “The Authority has auctioned land in Bandra Kurla Complex

MUMBAI METROPLITAN REGION DEVELOPMENT AUTHORITY,MUMBAI vs. DDIT (E) -1(1), MUMBAI

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

Bench: Shri S. Rifaur Rahman, Hon'Ble & Shri Pavan Kumar Gadale, Hon'Ble

TDS)-2(3), Mumbai on 10th February, 2011. During the course of the survey it was found that assessee received lease premium against the property from different parties. In this regard assessee was asked to furnish details of lease premium. In response, Ld. AR of the assessee submitted as under: - “The Authority has auctioned land in Bandra Kurla Complex

MUMBAI METROPLITAN REGION DEVELOPMENT AUTHORITY,MUMBAI vs. DDIT (E) -1(1), MUMBAI

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

Bench: Shri S. Rifaur Rahman, Hon'Ble & Shri Pavan Kumar Gadale, Hon'Ble

TDS)-2(3), Mumbai on 10th February, 2011. During the course of the survey it was found that assessee received lease premium against the property from different parties. In this regard assessee was asked to furnish details of lease premium. In response, Ld. AR of the assessee submitted as under: - “The Authority has auctioned land in Bandra Kurla Complex

NETWORTH STOCK BROKING LTD,MUMBAI vs. ACIT CIR 4(2), MUMBAI

In the result, the appeal of assessee in ITA No

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

TDS u/s 194J of the Act by holding that the payments are in the nature of technical services. Now, this issue is covered by the decision of the Hon’ble Supreme Court in the case of Kotak Securities Ltd. (supra) and taking a consistent view this issue is also allowed. 24. The next issue in Revenue’s appeal

ACIT 4(2), MUMBAI vs. NETWORTH STOCK BROKING LTD, MUMBAI

In the result, the appeal of assessee in ITA No

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

TDS u/s 194J of the Act by holding that the payments are in the nature of technical services. Now, this issue is covered by the decision of the Hon’ble Supreme Court in the case of Kotak Securities Ltd. (supra) and taking a consistent view this issue is also allowed. 24. The next issue in Revenue’s appeal

NETWORTH STOCK BROKING LTD,MUMBAI vs. ACIT CIR 4(2), MUMBAI

In the result, the appeal of assessee in ITA No

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

TDS u/s 194J of the Act by holding that the payments are in the nature of technical services. Now, this issue is covered by the decision of the Hon’ble Supreme Court in the case of Kotak Securities Ltd. (supra) and taking a consistent view this issue is also allowed. 24. The next issue in Revenue’s appeal

ACIT 4(2), MUMBAI vs. NETWORTH STOCK BROKING LTD, MUMBAI

In the result, the appeal of assessee in ITA No

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

TDS u/s 194J of the Act by holding that the payments are in the nature of technical services. Now, this issue is covered by the decision of the Hon’ble Supreme Court in the case of Kotak Securities Ltd. (supra) and taking a consistent view this issue is also allowed. 24. The next issue in Revenue’s appeal

INCOME TAX OFFICER 8(3)(3), MUMBAI vs. M/S.VIBGYOR TEXOTECH PRIVATE LIMITED, MUMBAI

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

Bench: Shri Amarjit Singh () & Shri Om Prakash Kant () Assessment Year: 2009-10 Income Tax Officer-8(3)(3), M/S Vibgyor Texotech Pvt. Ltd., Room No. 616, 6Th Floor, Aayakar 309, Navyug, T.J. Road, Sewree, Bhavan, M.K. Road, Vs. Mumbai-400015. Mumbai-400020. Pan No. Aaccv 0752 D Appellant Respondent Assessment Year: 2009-10 M/S Vibgyor Texotech Pvt. Ltd., The Asst. Commissioner Of 309, Navyug, T.J. Road, Sewree, Income Tax-8(3)(2), Mumbai-400015. Vs. Mumbai. Pan No. Aaccv 0752 D Appellant Respondent

TDS) also the Assessing Officer disallowed expenditure amounting to Rs.3,97,90,291/-in terms of section 40(a)(ia) of the Act. Additions for unexplained cash credit in terms of section 68 of the Act amounting to Rs.1,46,24,270/- and difference in valuation of fixed asset of Rs.2,50,19,760/- being written off were also made

M/S.VIBGYOR TEXOTECH PRIVATE LIMITED,MUMBAI vs. ACIT-8(3)(2), MUMBAI

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

Bench: Shri Amarjit Singh () & Shri Om Prakash Kant () Assessment Year: 2009-10 Income Tax Officer-8(3)(3), M/S Vibgyor Texotech Pvt. Ltd., Room No. 616, 6Th Floor, Aayakar 309, Navyug, T.J. Road, Sewree, Bhavan, M.K. Road, Vs. Mumbai-400015. Mumbai-400020. Pan No. Aaccv 0752 D Appellant Respondent Assessment Year: 2009-10 M/S Vibgyor Texotech Pvt. Ltd., The Asst. Commissioner Of 309, Navyug, T.J. Road, Sewree, Income Tax-8(3)(2), Mumbai-400015. Vs. Mumbai. Pan No. Aaccv 0752 D Appellant Respondent

TDS) also the Assessing Officer disallowed expenditure amounting to Rs.3,97,90,291/-in terms of section 40(a)(ia) of the Act. Additions for unexplained cash credit in terms of section 68 of the Act amounting to Rs.1,46,24,270/- and difference in valuation of fixed asset of Rs.2,50,19,760/- being written off were also made

ADDL CIT R G 7(1), MUMBAI vs. NOVARTIS INDIA LTD ( FORMERLY KNOWN AS HINDUSTAN CIBA GIEGY LTD. ), MUMBAI

Bench: Shri Amit Shukla, Hon'Ble & Shri S. Rifaur Rahman, Hon'Blem/S. Novartis India Limited V. Asst. Commissioner Of Income –Tax - 7(2)(2) {Earlier Addl. Commissioner Of Income –Tax – 7(1)} 6Th& 7Th Floor 1St Floor, Aayakar Bhavan Inspire Bkc M.K. Road, Mumbai - 400020 “G” Block, Bkc Main Road Bandra Kurla Complex, Bandra (E) Mumbai – 400051 Pan: Aaach2914F (Appellant) (Respondent) Addl. Commissioner Of Income –Tax – 7(1) V. M/S. Novartis India Limited Room No. 622, Aayakar Bhavan {Earlier Known As Hindustan Ciba Giegy Ltd.,} Sandoz House, Dr. A.B. Road M.K. Road, Mumbai - 400020 Worli, Mumbai – 400018 Pan: Aaach2914F (Appellant) (Respondent) Co No.190/Mum/2011 [Arising Out Of Ita No.6772/Mum/2010 (A.Y. 2002-03)] M/S. Novartis India Limited V. Addl. Commissioner Of Income –Tax – 7(1)} Room No. 622, Aayakar Bhavan {Earlier Known As Hindustan Ciba Giegy Ltd.,} Sandoz House, Dr. A.B. Road M.K. Road, Mumbai - 400020 Worli, Mumbai – 400018 Pan: Aaach2914F (Appellant) (Respondent)

TDS, the Dy. CIT had passed an order under section 154 of the Act (see pages 3-5 of Factual paper book-1). 4 25.08.2003 The Dy. CIT issued a notice under section 143(2) of the Act, selecting the Assessee’s ROI for scrutiny (see page 6 of Factual paper book-1). 5 17.10.2003 The Addl. CIT (Transfer Pricing

DENTSU AEGIS NETWORK INDIA PRIVATE LIMITED(ERSTWHILE VIZEUM MEDIA SERVICE INDIA MERGED IN DAN INDIA),MUMBAI vs. INCOME TAX OFFICER, CIRCLE 8(3)(2), MUMBAI, MUMBAI

In the result, the appeal of the assessee is allowed

Bench: Shri Rahul Chaudhary & Shri Makarand Vasant Mahadeokardentsu Aegis Network Dcit Central India Private Limited Circle-1(1), (Erstwhile Vizeum Media Vs. Aayakar Bhavan, Service India Merged Maharashi Karve With Dentsu Aegis Marg, Mumbai-400 Network India Private 020 Limited W.E.F. 1St April 2017) 2Nd Floor, Devchand House, Dr. A. B. Road, Shiv Sagar Estate Mumbai, Worli So, Mumbai-400 018 Pan/Gir No. Aahca3058N (Applicant) (Respondent) Assessee By Shri Ketan Ved & Shri Abdul Kadir Jawadwala, Ld. Ars Revenue By Shri Annavaram Kosuri, Ld. Dr Date Of Hearing 02.02.2026 Date Of Pronouncement 20.02.2026

2)(b) of the Act. The relevant facts, as emerging from the assessment order, are recorded hereunder. 4. The Assessing Officer observed from the details of expenses claimed under the head “salary and wages” that the assessee had debited an amount of Rs. 46,23,220/- paid to M/s. Aegis Media India Pvt. Ltd. and Rs. 16,27,500/- paid

M. R. CONSTRUCTION,MUMBAI vs. ACIT CEN CIR 22, MUMBAI

In the result, in the case of M

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

TDS Section 194A – Interest on loans 4,12,416 Nil 10,686 Section 194C Contractor 78,06,579 Nil 78,06,579 Section 194J – Supervision Charges 2,55,100 Nil 2,55,100 Section 194H – Brokerage Expenses/ 2,50,000 Nil 2,50,000 commission Section 194J – professional charges 50,000 Nil 50,000 4. Adhoc Disallowance for direct Expenses

JAWAHAR B. PUROHIT,MUMBAI vs. ASST CIT CEN CIR 22XC, MUMBAI

In the result, in the case of M

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

TDS Section 194A – Interest on loans 4,12,416 Nil 10,686 Section 194C Contractor 78,06,579 Nil 78,06,579 Section 194J – Supervision Charges 2,55,100 Nil 2,55,100 Section 194H – Brokerage Expenses/ 2,50,000 Nil 2,50,000 commission Section 194J – professional charges 50,000 Nil 50,000 4. Adhoc Disallowance for direct Expenses

JAWAHAR B. PUROHIT,MUMBAI vs. ASST CIT CEN CIR 22XC, MUMBAI

In the result, in the case of M

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

TDS Section 194A – Interest on loans 4,12,416 Nil 10,686 Section 194C Contractor 78,06,579 Nil 78,06,579 Section 194J – Supervision Charges 2,55,100 Nil 2,55,100 Section 194H – Brokerage Expenses/ 2,50,000 Nil 2,50,000 commission Section 194J – professional charges 50,000 Nil 50,000 4. Adhoc Disallowance for direct Expenses

JAWAHAR B. PUROHIT,MUMBAI vs. ASST CIT CEN CIR 22XC, MUMBAI

In the result, in the case of M

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

TDS Section 194A – Interest on loans 4,12,416 Nil 10,686 Section 194C Contractor 78,06,579 Nil 78,06,579 Section 194J – Supervision Charges 2,55,100 Nil 2,55,100 Section 194H – Brokerage Expenses/ 2,50,000 Nil 2,50,000 commission Section 194J – professional charges 50,000 Nil 50,000 4. Adhoc Disallowance for direct Expenses

JAWAHAR B. PUROHIT,MUMBAI vs. ASST CIT CEN CIR 22XC, MUMBAI

In the result, in the case of M

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

TDS Section 194A – Interest on loans 4,12,416 Nil 10,686 Section 194C Contractor 78,06,579 Nil 78,06,579 Section 194J – Supervision Charges 2,55,100 Nil 2,55,100 Section 194H – Brokerage Expenses/ 2,50,000 Nil 2,50,000 commission Section 194J – professional charges 50,000 Nil 50,000 4. Adhoc Disallowance for direct Expenses