JCIT(OSD) CIRCLE 2(3)(1), MUMBAI vs. HDFC BANK LIMITED, MUMBAI

In the result, both the above stated appeals of the\nassessee in ITA No

5) of the Companies Act are also\neligible for deduction/s 80G of Ericsson India Global Services Pvt. Ltd. v. DCIT the\nAct subject to satisfying the requisite conditions prescribed for deduction u/s 80G of\nthe Act. For this purpose, the issue is remanded to the file ofAO to examine the same\nwhether the payments satisfy the claim of donation

HDFC BANK LIMITED,MUMBAI vs. DCIT - 2 (3) (1) , MUMBAI

In the result, both the above stated appeals of the\nassessee in ITA No

5) of the Companies Act are also\neligible for deduction/s 80G of Ericsson India Global Services Pvt. Ltd. v. DCIT the\nAct subject to satisfying the requisite conditions prescribed for deduction u/s 80G of\nthe Act. For this purpose, the issue is remanded to the file ofAO to examine the same\nwhether the payments satisfy the claim of donation

JCIT(OSD) CIRCLE 2(3)(1), MUMBAI, MUMBAI vs. HDFC BANK LIMITED, MUMBAI

In the result, both the above stated appeals of the\nassessee in ITA No

5 crores of more have to mandatorily comply with the CSR provisions\nspecified us.135(1) of the Companies Act, 2011. The above mentioned companies are liable to\nspend atleast 25% of its average net profit for the immediately preceding three financial years\non CSR activities. In the present case, the assessee has contributed Rs 30 lacs to various\neducational

JCIT OSD CIRCLE 2(3)(1), MUMBAI, MUMBAI vs. HDFC BANK LIMITED, MUMBAI

In the result, both the above stated appeals of the\nassessee in ITA No

5) of the Companies Act are also\neligible for deduction/s 80G of Ericsson India Global Services Pvt. Ltd. v. DCIT the\nAct subject to satisfying the requisite conditions prescribed for deduction u/s 80G of\nthe Act. For this purpose, the issue is remanded to the file ofAO to examine the same\nwhether the payments satisfy the claim of donation

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

80G in respect of CSR related payments, employees' contribution to provident fund under section 36(1)(va), disallowance under section 40(a)(ia), disallowance under section 43B, computation of capital gains, grant of credit for tax deducted at source, and levy of interest under sections 234B and 234C. Additions and disallowances were made year-wise, and penalty proceedings under section

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

5) ITA No. 6663, 6701, 6702 & 6703 /Mum/2025 Aditya Birla Sun Life AMC Limited limited relief only in respect of short grant of 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

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

Accordingly, this ground is allowed

80G in respect of CSR related payments, employees' contribution to provident fund under section 36(1)(va), disallowance under section 40(a)(ia), disallowance under section 43B, computation of capital gains, grant of credit for tax deducted at source, and levy of interest under sections 234B and 234C. Additions and disallowances were made year-wise, and penalty proceedings under section

PASHUPATI CAPITAL SERVICES PRIVATE LIMITED,MUMBAI vs. PRINCIPAL COMMISSIONER OF INCOME TAX OFFICER, MUMBAI - 4, MUMBAI

In the result, appeal filed by the assessee is allowed in above\nterms

TDS. It is\nrequired to be verified whether the taxable income has been disclosed\ncorrectly\"\n17. It is a settled law that any issue decided by ITAT or the Hon'ble High\nCourt, is binding upon the assessing authorities and in that regard, we are\nsupported bythe decision of the Hon'ble Allahabad High Court in K. N.\nAgarwal

ACIT CC 4 3, MUMBAI, MUMBAI vs. MAERSK LINE INDIA PRIVATE LIMITED, MUMBAI

Bench: Shri Vikram Singh Yadav & Shri Sandeep Singh Karhail

5. "Whether on the facts and in the circumstances of the case and in law, the Ld. CIT (A) has erred in deleting the addition without justifying that the AO had rightly disallowed 100% of provisions made under Section 40(a)(i) (payments to non-residents without TDS); and 30% of the provisions under Section 40(a)(ia) (residents, where

AUGMONT ENTERPRISES PRIVATE LIMITED,MUMBAI vs. ACIT - CIRCLE 6(1)(2), MUMBAI

In the result, appeal filed by the assessee is allowed in above terms

Bench: Shriom Prakash Kant & Shri Raj Kumar Chauhanaugmont Enterprises Pvt. Ltd. Acit Circle-6(1)(2), 201, A/B & 202, 2Nd Floor, Trade Vs. R. No. 506, 5Th Floor, Aayakar World, D-Wing, Kamala Mills Bhavan, Mumbai-400 020 Compound, S. B. Marg, Lower Parel (West), Mumbai-400 003. Pan: Aagcr3007D (Appellant) (Respondent) Assessee Represented By : Ms. Ridhisha Jain, Ld. Ar Department Represented By : Shri Rajesh Kumar Yadav, Ld. Dr Date Of Conclusion Of Hearing : 05.08.2025 Date Of Pronouncement : 12.09.2025

section 80G in respect of CSR expenses of Rs. 10,27,000/- was incorrectly allowed by the Ld. AO and the reasons assigned for doing so are wrong and contrary to the provisions of Income Tax Act and Rules made there under. 3. Your Appellant crave, leave to add, alter, amend or modify any or all grounds of appeal

CHEMICAL PROCESS PIPING PVT LTD ,MUMBAI vs. PRINCIPAL COMMISSIONER OF INCOME TAX -6, MUMBAI

In the result, the appeal filed by the assessee is allowed in above terms

Bench: Shriom Prakash Kant & Shri Raj Kumar Chauhanm/S. Chemical Process Piping Pcit, Mumbai-6, Pvt. Ltd. Vs. R. No. 501, Aayakar Bhavan, Ground Floor, Cpe Plot, B.S.D. Marg, Churchgate, Mumbai-400 Govandi, Mumbai-400 088 020 Pan: Aaccc6212D (Appellant) (Respondent) Assessee Represented By : Shri Nishit Gandhi & Shri Harshad Shah, Ld. Ars Department Represented By : Shri R. A. Dhyani, Ld. Dr Date Of Conclusion Of Hearing : 12.06.2025 Date Of Pronouncement : 12.09.2025

TDS credit carried forward as large deduction is claimed u/s 80G and the donee entity was not approved u/s 80G of the Act. However, in response to the notice, assessee submitted the relevant documents to substantiate the 80G certification which were found in order and the assessment was completed on the return income

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

Accordingly, this ground is allowed

80G in respect of CSR related payments, employees' contribution to provident fund under section 36(1)(va), disallowance under section 40(a)(ia), disallowance under section 43B, computation of capital gains, grant of credit for tax deducted at source, and levy of interest under sections 234B and 234C. Additions and disallowances were made year-wise, and penalty proceedings under section

GOLDMAN SACHS (INDIA) SECURITEIS PRIVATE LIMITED,MUMBAI vs. ADD/JT/DY/ASST/CIT/ITO/NFAC, DELHI

Bench: Shri Amarjit Singhshri Sandeep Singh Karhail

5% of referred business expenditure. AO has nothing to do with the e-TDS returns of the assessee as it covers entire TDS deductions of the assessee for the full year. As discussed above on the issue of TDS and expenses, it was categorically asked to give a detailed note on the TDS deductions as made for each head

ACIT CC 6(2), MUMBAI, MUMBAI vs. OVERSEAS INFRASTRUCTURE ALLIANCE (INDIA) PRIVATE LIMITED, MUMBAI

In the result, appeal by the assessee is allowed

Bench: Shri Sandeep Gosain & Shri Girish Agrawal

5. All the six grounds raised by the Revenue in this appeal are identical to those already dealt by us in the appeal for Assessment Year 2015-16 in the above paragraphs except for variation in the quantum Overseas Infrastructure Alliance (India) Pvt. Ltd. AYs 2011-12, 2015-16 to 2017-18 and 2019-20 to 2022-23 of disallowance/addition

ACIT, CC 6(2), MUMBAI, MUMBAI vs. OVERSEAS INFRASTRUCTURE ALLIANCE (INDIA) PRIVATE LIMITED, MUMBAI

In the result, appeal by the assessee is allowed

Bench: Shri Sandeep Gosain & Shri Girish Agrawal

5. All the six grounds raised by the Revenue in this appeal are identical to those already dealt by us in the appeal for Assessment Year 2015-16 in the above paragraphs except for variation in the quantum Overseas Infrastructure Alliance (India) Pvt. Ltd. AYs 2011-12, 2015-16 to 2017-18 and 2019-20 to 2022-23 of disallowance/addition

ACIT, CC-6(2), MUMBAI, MUMBAI vs. OVERSEAS INFRASTRUCTURE ALLIANCE (INDIA) PRIVATE LIMITED, MUMBAI

In the result, appeal by the assessee is allowed

Bench: Shri Sandeep Gosain & Shri Girish Agrawal

5. All the six grounds raised by the Revenue in this appeal are identical to those already dealt by us in the appeal for Assessment Year 2015-16 in the above paragraphs except for variation in the quantum Overseas Infrastructure Alliance (India) Pvt. Ltd. AYs 2011-12, 2015-16 to 2017-18 and 2019-20 to 2022-23 of disallowance/addition

ACIT, CC-6(2), MUMBAI, MUMBAI vs. OVERSEAS INFRASTRUCTURE ALLIANCE (INDIA) PRIVATE LIMITED, MUMBAI

In the result, appeal by the assessee is allowed

Bench: Shri Sandeep Gosain & Shri Girish Agrawal

5. All the six grounds raised by the Revenue in this appeal are identical to those already dealt by us in the appeal for Assessment Year 2015-16 in the above paragraphs except for variation in the quantum Overseas Infrastructure Alliance (India) Pvt. Ltd. AYs 2011-12, 2015-16 to 2017-18 and 2019-20 to 2022-23 of disallowance/addition

ACIT, CC 6(2), MUMBAI, MUMBAI vs. OVERSEAS INFRASTRUCTURE ALLIANCE (INDIA) PRIVATE LIMITED, MUMBAI

In the result, appeal by the assessee is allowed

Bench: Shri Sandeep Gosain & Shri Girish Agrawal

5. All the six grounds raised by the Revenue in this appeal are identical to those already dealt by us in the appeal for Assessment Year 2015-16 in the above paragraphs except for variation in the quantum Overseas Infrastructure Alliance (India) Pvt. Ltd. AYs 2011-12, 2015-16 to 2017-18 and 2019-20 to 2022-23 of disallowance/addition