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

TDS credit by\ndirecting verification. Interest under sections 234B and 234C was\ntreated as consequential.\n7.\nIn A.Y. 2018-19, the Assessing Officer disallowed deduction\nclaimed under section 80G in respect of CSR expenditure\namounting to Rs. 2,53,96,666/-, disallowed employees'\ncontribution to provident fund amounting to Rs. 41,05,801

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

TDS credit by\ndirecting verification. Interest under sections 234B and 234C was\ntreated as consequential.\n7.\nIn A.Y. 2018–19, the Assessing Officer disallowed deduction\nclaimed under section 80G in respect of CSR expenditure\namounting to Rs. 2,53,96,666/-, disallowed employees'\ncontribution to provident fund amounting to Rs. 41,05,801

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

TDS credit by directing verification. Interest under sections 234B and 234C was treated as consequential. 7. In A.Y. 2018–19, the Assessing Officer disallowed deduction claimed under section 80G in respect of CSR expenditure amounting to Rs. 2,53,96,666/-, disallowed employees’ contribution to provident fund amounting to Rs. 41,05,801

BHAGIRATH BEAINGS P.LTD,MUMBAI vs. ADDL CIT (TDS)RG 1, MUMBAI

In the result appeal filed by assessee is allowed

Bench: Shri Shamim Yahaha & Shri Pawan Singhbhagirath Bearings Pvt. Ltd. Addl. Cit (Tds) Range-1, Room No. 801, 8Th Floor, 6, Dr. Bhogilal Bhavan, 5Th Mamlatdar Wadi, Vs. K.G. Mittal Ayurvedic Hospital Malad (W), Mumbai-400064. Building, Charni Road, Mumbai-400002 (Appellant) (Respondent)

TDS) Range-1, Room No. 801, 8th Floor, 6, Dr. Bhogilal Bhavan, 5th Mamlatdar Wadi, Vs. K.G. Mittal Ayurvedic Hospital Malad (W), Mumbai-400064. Building, Charni Road, Mumbai-400002 (Appellant) (Respondent) Assessee by : Sh. P.R. Raiyani (AR) Revenue by : Sh. Suman Kumar-DR Date of hearing : 27.04.2017 Date of Pronouncement : 05.05.2017 Order Under Section

TATA SKY LIMITED,MUMBAI vs. ASST CIT RANGE 16 (1), MUMBAI

In the result, revenue’s appeals are dismissed and assessee’s appeals are allowed for statistical purpose

Bench: Shri Shamim Yahya (Am) & Shri Pavan Kumar Gadale (Jm)

TDS u/s 194H of the IT Act, 1961. This issue of assessee’s appeal is allowed. 8. Since, the issue is covered in favour of the assessee by the decision of ITAT in assessee’s own case and it is not the case that Hon’ble Bombay High Court has 11 Tata Sky Limited reversed the decision of ITAT

ACIT CIRCLE- 16 (1), MUMBAI vs. M/S TATA SKY LTD., MUMBAI

In the result, revenue’s appeals are dismissed and assessee’s appeals are allowed for statistical purpose

Bench: Shri Shamim Yahya (Am) & Shri Pavan Kumar Gadale (Jm)

TDS u/s 194H of the IT Act, 1961. This issue of assessee’s appeal is allowed. 8. Since, the issue is covered in favour of the assessee by the decision of ITAT in assessee’s own case and it is not the case that Hon’ble Bombay High Court has 11 Tata Sky Limited reversed the decision of ITAT

DY. COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-5(1), MUMBAI. , MUMBAI vs. EKJYOT PROPERTIES , MUMBAI

In the result, the appeal of the Revenue is dismissed

Section 194A deals with TDS on interest other than interest on securities. The AO has stated in para 6.5.1. that out of the cash receipts of Rs. 15,00,000/- Rs. 10,00,000/- received on 29.08 from Mrs. Tina Agarwal is not appearing in the ledger and hence, it is reflective of undisclosed transaction. From the ledger

ICICI SECURITIES LTD,MUMBAI vs. DCIT RG 4(1), MUMBAI

In the result, the appeal for the AY 2010-11 is partly allowed

Bench: Shri C.N. Prasad () & Shri N.K. Pradhan () Assessment Year: 2009-10 & Assessment Year: 2010-11 Icici Securities Ltd. Dy. Commissioner Of Icici Centre, H.T. Parekh Income Tax Range Vs. Marg, Churchgate, 4(1), Mumbai-400020. Mumbai. Pan No. Aaaci0996E (Appellant) (Respondent) Assessee By : Mr. Yogesh A. Thar, Ar Revenue By : Mr. M.C. Omi Ningshen, Dr

TDS on payments to ICICI Securities Primary Dealership Ltd. Thus he disallowed a sum of Rs.83,15,712/-. 3.2 In appeal the Ld. CIT(A) followed the order of his predecessor-in- office for AY 2007-08 and AY 2008-09 and held that the provisions of ICICI Securities section 40(a)(ia) do not apply to reimbursement towards rent

DCIT-2(1)(1), MUMBAI, MUMBAI vs. INCRED FINANCIAL SERVICES LIMITED, MUMBAI

In the result, the appeal by the Revenue and the cross-objection by the assessee are dismissed

Bench: Shri Vikram Singh Yadavshri Sandeep Singh Karhaildcit-2(1)(1), Mumbai Room No. 561, 5Th Floor, Aayakar Bhavan, Mumbai- 400021 ............... Appellant

section 143(1) of the Act, whereby TDS credit of only INR 20,61,49,733 was granted to the assessee, resulting in a short grant of TDS credit of INR 1,68,87,801

ASST CIT (LTU) 1, MUMBAI vs. GRASIM INDUSTRIES LIMITED (AS A SUCCESSOR TO ADITYA BIRLA NUVO LTD, MUMBAI

In the result, appeal of the Revenue is dismissed

Bench: Shri Vikas Awasthy, Jm & Ms Padmavathy S, Am

801/- with respect to the corporate and performance guarantee provided by the assessee to its Associated Enterprises (AE) ABMWI Canada and MGI Inc. USA. The TPO has applied a rate of 2.5% and 1.74% respectively while arriving at the TP adjustment. The CIT(A) did not accept the submission of the assessee that providing corporate guarantee is not an international

GRASIM INDUSTRIES LIMITED (AS A SUCCESSOR TO ADITYA BIRLA NUVO LTD),MUMBAI vs. ADDL CIT LTU, MUMBAI

In the result, appeal of the Revenue is dismissed

Bench: Shri Vikas Awasthy, Jm & Ms Padmavathy S, Am

801/- with respect to the corporate and performance guarantee provided by the assessee to its Associated Enterprises (AE) ABMWI Canada and MGI Inc. USA. The TPO has applied a rate of 2.5% and 1.74% respectively while arriving at the TP adjustment. The CIT(A) did not accept the submission of the assessee that providing corporate guarantee is not an international

THERMO FISHER SCIENTIFIC INDIA P. LTD,MUMBAI vs. DCIT 15(3)(1), MUMBAI

section\n32(1) r.w.s. 2(11) of the IT Act.\n3. Ground 3 - Depreciation on contracts - Acquisition from Chemito\nTechnologies Private Limited (CTPL) in AY 2009-10\n3.1 On the facts and in the circumstances of the case and in law, the learned\nDCIT and the Hon'ble DRP erred in not granting depreciation of Rs. 20,59,801

BULLDOG MEDIA AND ENTERTAINMENT PRIVATE LIMITED,MUMBAI vs. COMMISSIONER OF INCOME TAX (APPEALS ), MUMBAI

In the result, appeal filed by the assessee is allowed

Bench: Shri Aby T Varkey & Shri Gagan Goyalbulldog Media & Entertainment Pvt. Ltd. Plot No. C-38-C-39, G-Block, Parinee Crescenzo Building, Behind Mumbai Cricket Association, Bandra Kurla Complex, Mumbai-400051. Pan: Aadcb2393K ...... Appellant Vs. Cit (Appeals), National Faceless Appeal Centre, C.R. Building, Ip Estate, New Delhi-110002 ..... Respondent Appellant By : None Respondent By : Sh. Chetan M. Kacha, Sr.Dr Date Of Hearing : 27/07/2022 Date Of Pronouncement : 20/10/2022 Order Per Gagan Goyal, A.M: This Appeal By The Assessee Is Directed Against The Order Of National Faceless Appeal Centre, Delhi [Hereinafter Referred To As [‘Nfac’] Dated 02.11.2021 Passed Under Section 250 Of The Income Tax Act, 1961 (Hereinafter Referred To As [‘The Act’] For The Assessment Year (Ay) 2018-19. The Assessee Has Raised The Following Grounds Of Appeal:

TDS under section 143(1)(a) and 154 of the Act to the extent of Rs. 4,75,801/- (as reflected

VENUS TRUST MARCH 2015,MUMBAI vs. ITO (TDS) 2(3)(3), MUMBAI

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

Bench: Smt. Kavitha Rajgopal & Shri Gagan Goyalvenus Trust March 2015, Asian Building, Ground Floor, 17, R. Kamani Marg, Ballard Estate, Mumbai – 400 092 Pan: Aabtv9790M ..... Appellant Vs. Ito (Tds) 2 (3)(3) Mtnl Telephone Exchange Building, Cumballa Hills, Peddar Road, Mumbai- 400 026 ..... Respondent

TDS to be deducted worked out to Rs. 52, 74,801/-. 12. Further the AO held that the Assessee was liable to pay simple interest at the rate of 1% per month or part thereof on the amount of such tax from the date on which such tax was deductible to the date on the tax was actually paid under

CMA CGM SA,MUMBAI vs. DCIT (IT) - 2(1)(2), MUMBAI

In the result, assessee’s appeal is partly allowed

Bench: Shri Saktijit Dey & Shrimanoj Kumar Aggarwal

801, and as per the provisions of section 44B r/w section 172 of the Act. In the return of income filed, the assessee claimed benefit under Article– 9 of the India–France Double Taxation Avoidance Agreement (DTAA) 3 CMA CGM SA insofar as it relates to revenue earned from the shipping business in International Waters. The aforesaid benefit claimed

DCIT4(1)(1), MUMBAI vs. ARCADIA SHARE & STOCK BROKERS P. LTD, MUMBAI

In the result, the appeal Revenue is dismissed and the CO of the assessee is allowed

Bench: Sri Mahavir Singh, Jm & Sri Nk Pradhan, Am Aayakr Apila Sam./ Ita No. 5712/Mum/2017 (Inaqa-Arna Baya- / Assessment Year 2008-09) The Dy. Commissioner Of Arcadia Shares & Stock Income Tax, Circle 4(1)(1) Brokers Pvt. Ltd. Room No. 640, 6Th Floor, 328/324, Ninad Chs, 1St Vs. Aayakar Bhavan, M.K. Road, Floor, Bldg No. 7, Service Mumbai-400 020 Road, Near Bhavishya Nidhi Bhavan, Mumbai-400 051 .. (P`%Yaqaai- / Respondent) (Apilaaqai- / Appellant) स्थायी लेखा सं./Pan No. Aaaca4562G प्रत्याक्षेप M./ Co No. 44/Mum/2019 (Arising In Ita No. 5712/Mum/2017 For Ay 2008-09) Arcadia Shares & Stock The Dy. Commissioner Of Brokers Pvt. Ltd. Income Tax, Circle 4(1)(1) 328/324, Ninad Chs, 1St Room No. 640, 6 Th Floor, Vs. Floor, Bldg No. 7, Service Aayakar Bhavan, M.K. Road, Near Bhavishya Nidhi Road, Mumbai-400 020 Bhavan, Mumbai-400 051 .. (P`%Yaqaai- / Respondent) (Apilaaqai- / Appellant) अपीलाथी की ओर से / Appellant By : Shri Satischandra Rajore, Dr प्रत्यथी की ओर से / Respondent By : Shri Dr. K. Shivaram, Ms Neelam Jadhav, Ars सुनवाई की तारीख / Date Of Hearing: 13-05-2019 घोषणा की तारीख / Date Of Pronouncement : 21-05-2019

801/- and tax liability was determined at ₹ 3,42,48,796/- under section 115JB of the IT act. As per the information received from DGIT IV-II, Mumbai, the following transactions have been carried out by the assessee company during the AY 2008-09. Name of the Investor Amount Nature of Transaction Ansh Merchandise P Ltd. (Newplanet

B.K.KHARE & CO. ,MUMBAI vs. ACIT CIR 16(2), MUMBAI

In the result, the appeal of the assessee is allowed for statistical purposes

Bench: Shri Amit Shukla & Shri Amarjit Singhb.K. Khare & Co. Vs. Acit 16(2), 706/708 Sharda 4Th Floor, Chambers, New Marine Aaykar Bhavan, Line, Churchgate, M.K. Road, 400020 Mumbai - 400020 "थायी लेखा सं./जीआइआर सं./Pan/Gir No: Aaafb0265E Appellant .. Respondent

801/- as allowed by the learned AO. 4. The Appellant craves leave to add to, alter, delete or modify any of the above grounds of appeals.” Ground Nos. 1 & 2: 2 . The fact in brief is that the A.O made adjustment in the intimation passed u/s 143(1) of the Act by way of disallowance of delayed remittance of employee

UDAYAN GROVER,MUMBAI vs. NATIONAL FACELESS APPEAL CENTRE(NFAC), DELHI

In the result, appeal filed by the assessee is allowed

Bench: Shri Aby T Varkey, Hon'Ble & Shri S. Rifaur Rahman, Hon'Bleudayan Grover V. National Faceless Appeal Centre Panch Mahal Delhi Panch Sristhi Complex {Acit – 26(3), Bkc, Mumbai} Powai, Mumbai - 400072 Pan: Aclpg0572G (Appellant) (Respondent) Assessee Represented By : Shri Vimal Punmiya Department Represented By : Ms. Kavitha Kaushik

801 the Hon’ble Supreme Court had held that matter had to be considered by applying the test of human probabilities. Having regard to the facts and circumstances as elaborately discussed in this order and inference could reasonably drawn that by all human probabilities, it is very difficult to accept that the assessee has done a genuine transaction with respect

JT CIT RG 24(2), MUMBAI vs. SHAZAD RUSTUMJI, MUMBAI

In the result appeal of the Revenue is partly allowed

Bench: Shri C.N. Prasad & Shri Rajesh Kumarassessment Year: 2007-08

TDS provisions are not attracted for the transport charges as these payments are not made for carrying out any work in pursuance of the contract between the contractor and any specified person (appellant) within the meaning of 194C of the I.T. Act, 1961. Hence, in view of the above the impugned addition of Rs.53,357/- as well as Rs.24.43,801