SMALL INDUSTRIES DEVELOPMENT BANK OF INDIA,MUMBAI vs. DEPUTY COMMISSIONER OF INCOME TAX CIRCLE 3(3)(1),MUMBAI, MUMBAI

Bench: Justice (Retd.) C V Bhadang & Ms Padmavathy S, Am

73,55,929/- as provision for doubtful debts under section 36(1)(viia)(c) of the Act at 5% of total income. The AO held that the claim of bad-debts under section 36(1)(vii) is subject to the restriction as per the proviso to the said section where it cannot exceed the credit

DY. COMMISSIONER OF INCOME TAX CIRCLE - 3(3)(1), MUMBAI, MUMBAI vs. SMALL INDUSTRIES DEVELOPMENT BANK OF INDIA, MUMBAI

Bench: Justice (Retd.) C V Bhadang & Ms Padmavathy S, Am

73,55,929/- as provision for doubtful debts under section 36(1)(viia)(c) of the Act at 5% of total income. The AO held that the claim of bad-debts under section 36(1)(vii) is subject to the restriction as per the proviso to the said section where it cannot exceed the credit

SMALL INDUSTRIES DEVELOPMENT BANK OF INDIA,MUMBAI vs. DEPUTY COMMISSIONER OF INCOME TAX CIRCLE 3(3)(1),MUMBAI, MUMBAI

73,55,929/- as provision for\ndoubtful debts under section 36(1)(viia)(c) of the Act at 5% of total income. The\nAO held that the claim of bad-debts under section 36(1)(vii) is subject to the\nrestriction as per the proviso to the said section where it cannot exceed the credit\nbalance in the provision

DY. COMMISSIONER OF INCOME TAX CIRCLE - 3(3)(1), MUMBAI, MUMBAI vs. SMALL INDUSTRIES DEVELOPMENT BANK OF INDIA, MUMBAI

73,55,929/- as provision for\ndoubtful debts under section 36(1)(viia)(c) of the Act at 5% of total income. The\nAO held that the claim of bad-debts under section 36(1)(vii) is subject to the\nrestriction as per the proviso to the said section where it cannot exceed the credit\n5\nITA

DY. COMMISSIONER OF INCOME TAX CIRCLE - 3(3)(1), MUMBAI, MUMBAI vs. SMALL INDUSTRIES DEVELOPMENT BANK OF INDIA, MUMBAI

73,55,929/- as provision for\ndoubtful debts under section 36(1)(viia)(c) of the Act at 5% of total income. The\nAO held that the claim of bad-debts under section 36(1)(vii) is subject to the\nrestriction as per the proviso to the said section where it cannot exceed the credit\nbalance in the provision

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, 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

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

73. While there can be no quarrel with the settled proposition that an intimation under section 143(1) and an assessment order under section 143(3) operate in distinct fields, and that there is no automatic merger of an intimation with a scrutiny assessment unless the issue is examined in the assessment proceedings, the crucial aspect which cannot be lost

M/S THE MAHARASHTRA STATE CO. OP BANK LTD.,MUMBAI vs. ITO-1(3)(3), MUMBAI

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

Bench: Shri Om Prakash Kant () & Shri Sandeep Singh Karhail () Assessment Year: 2013-14

TDS of Rs. 12,23,608/- has been allowed by the has been allowed by the Income-tax Department in the hands of Shri Kapil Ahluwalia or tax Department in the hands of Shri Kapil Ahluwalia or tax Department in the hands of Shri Kapil Ahluwalia or not. If it has been not allowed, then the credit of this amount

DY CIT-1(3)(2), MUMBAI vs. MAHARASHTRA STATE CO-OPERATIVE BANK LIMITED, MUMBAI

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

Bench: Shri Om Prakash Kant () & Shri Sandeep Singh Karhail () Assessment Year: 2013-14

TDS of Rs. 12,23,608/- has been allowed by the has been allowed by the Income-tax Department in the hands of Shri Kapil Ahluwalia or tax Department in the hands of Shri Kapil Ahluwalia or tax Department in the hands of Shri Kapil Ahluwalia or not. If it has been not allowed, then the credit of this amount

DCIT (OSD)(TDS)-2(3), MUMBAI vs. TOTAL ENERGIES MARKETING INDIA PVT LTD, MUMBAI

Appeals are partly allowed

Bench: Shri Prashant Maharishi, Am & Shri Rahul Chaudhary, Jm

1,79,73,114 which TDS on which TDS on which TDS default under default under default under section 201 section

DCIT (OSD)(TDS)-2(3) , MUMBAI vs. TOTAL ENERGIES MARKETING INDIA PVT LTD, MUMBAI

Appeals are partly allowed

Bench: Shri Prashant Maharishi, Am & Shri Rahul Chaudhary, Jm

1,79,73,114 which TDS on which TDS on which TDS default under default under default under section 201 section

DCIT (OSD)(TDS)-2(3) , MUMBAI vs. TOTAL ENERGIES MARKETING INDIA PVT LTD, MUMBAI

Appeals are partly allowed

Bench: Shri Prashant Maharishi, Am & Shri Rahul Chaudhary, Jm

1,79,73,114 which TDS on which TDS on which TDS default under default under default under section 201 section

DCIT (OSD)(TDS)-2(3), MUMBAI vs. TOTAL ENERGIES MARKETING INDIA PVT LTD, MUMBAI

Appeals are partly allowed

Bench: Shri Prashant Maharishi, Am & Shri Rahul Chaudhary, Jm

1,79,73,114 which TDS on which TDS on which TDS default under default under default under section 201 section

DCIT (OSD)(TDS)-2(3), MUMBAI vs. TOTAL ENERGIES MARKETINGS INDIA PVT LTD, MUMBAI

Appeals are partly allowed

Bench: Shri Prashant Maharishi, Am & Shri Rahul Chaudhary, Jm

1,79,73,114 which TDS on which TDS on which TDS default under default under default under section 201 section

DCIT (OSD)(TDS)-2(3), MUMBAI vs. TOTAL ENERGIES MARKETING INDIA PVT LTD, MUMBAI

Appeals are partly allowed

Bench: Shri Prashant Maharishi, Am & Shri Rahul Chaudhary, Jm

1,79,73,114 which TDS on which TDS on which TDS default under default under default under section 201 section

DCIT (OSD)(TDS)-2(3), MUMBAI vs. TOTAL ENERGIES MARKETING INDIA PVT LTD, MUMBAI

Appeals are partly allowed

Bench: Shri Prashant Maharishi, Am & Shri Rahul Chaudhary, Jm

1,79,73,114 which TDS on which TDS on which TDS default under default under default under section 201 section

CITIZENCREDIT CO-OPERATIVE BANK LIMITED (HILL ROAD BRANCH),MUMBAI vs. ITO (TDS)-WARD 1(1)(4), MUMBAI

In the result, the appeal of the assessee is partly allowed for statistical\npurposes

73,066/- (3,60,922 + 12,144) u/s 201(1)/201(1A) of the I.T. Act, 1961,\naggregating to Rs.8,11,969/- deserves to be deleted in toto.\nYour Appellant craves leave, to add, alter, modify or delete all or any of the\ngrounds of the appeal.\"\nITA No.6038/M/2025 (AY 2016-17):\n3.\nThe facts of the case in brief