ACIT-6(1)(1), MUMBAI, MUMBAI vs. ADITYA BIRLA SUN LIFE AMC LTD., MUMBAI

In the result, the appeal by the Revenue is partly allowed

Bench: Shri Narendra Kumar Billaiyashri Sandeep Singh Karhailaditya Birla Sun Life Amc Ltd., Tower 1, Jupiter Mill Compound, 17Th Floor, One World Center, 841, Senapati Bapat Marg, ............... Appellant Mumbai - 400013 Pan : Aaacb6134D V/S

II, raised in assessee’s appeal, pertains to the disallowance of deduction claimed by the assessee on expenses disallowed under section 40(a) of the Act in previous years. 6. The brief facts of the case pertaining to this issue, as emanating from the record, are: During the year under consideration, the assessee filed its original return of income

FIRMENICH AROMATICS PRODUCTION (INDIA) PRIVATE LIMITED,MUMBAI vs. DEPUTY COMMISSIONER OF INCOME TAX, CIRCLE 1(3)(1), MUMBAI

In the result, both the appeals of the assessee are partly allowed

80G of the Act. Owing to commonality of the issue and facts\nremaining the same, we take up both the appeals together for\nadjudication by passing this consolidated order. We take appeal for\n Assessment Year 2020-21 as the lead year to draw the facts and our\nobservations and findings for this year shall apply mutatis mutandis to\nthe

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

ii)\n| 723,52,81,889\nThus, it is clear from the above that the ground raised by the\nDepartment on the said issue is factually incorrect and ought to be\ndismissed as infructuous.\nआयकर अपीलीय आधकर\nINCOME TAX APPELLATE TRIBU\nIMPARTIAL EASY AND\nSPEEDY JUSTICE (Page 20)\nITA No. 1555, 1573, 2258, 2259 & 2260 Mum 2025\nA.Y

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

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

ii)\n\nThus, it is clear from the above that the ground raised by the\nDepartment on the said issue is factually incorrect and ought to be\ndismissed as infructuous.\n\nPage 20\nITA No. 1555, 1573, 2258, 2259 & 2260 Mum 2025\nΑ.Υ. 2019-20, 2020-21, 2021-22\nHDFC Bank Limited, Mumbai\n\n18. We find merits

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 in respect of CSR expenditure amounting

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

80G amounting to Rs. 2,53,96,666/-.\nGROUND NO. II: NON-GRANT OF DEDUCTION CLAIMED U/S 36(1)(να)\nOF THE ACT AMOUNTING TO RS. 41,05,801/-\n1. On the facts and circumstances of case and in law, CIT(A) erred in\nupholding the action of the AO by disallowing

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

80G amounting to Rs. 2,53,96,666/-.\nGROUND NO. II: NON-GRANT OF DEDUCTION CLAIMED U/S 36(1)(να) OF THE ACT AMOUNTING TO RS. 41,05,801/-\n1. On the facts and circumstances of case and in law, CIT(A) erred in upholding the action of the AO by disallowing

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

ii)\nThus, it is clear from the above that the ground raised by the\nDepartment on the said issue is factually incorrect and ought to be\ndismissed as infructuous.\n18. We find merits in the above submissions as no such directions\nappear to have been given to the AO to restrict the disallowance to\nexempt income.Accordingly,the ground being devoid

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

ii)\nThus, it is clear from the above that the ground raised by the\nDepartment on the said issue is factually incorrect and ought to be\ndismissed as infructuous.\nआयकर अपीलीय आधकर\nINCOME TAX APPELLATE TRIBU\nIMPARTIAL EASY AND\nSPEEDY JUSTICE\n20\nPage 20\nITA

FIRMENICH AROMATICS PRODUCTION (INDIA) PRIVATE LIMITED,MUMBAI vs. ASSESSING OFFICER, NEW DELHI

In the result, both the appeals of the assessee are partly allowed

80G of the Act. Owing to commonality of the issue and facts\nremaining the same, we take up both the appeals together for\nadjudication by passing this consolidated order. We take appeal for\n Assessment Year 2020-21 as the lead year to draw the facts and our\nobservations and findings for this year shall apply mutatis mutandis to\nthe

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

ii) the same\nsuffers from lack of enquiry. Ld. PCIT has concluded in para no. 4.7 and 4.8\nof its order as to how the AO's order is erroneous and prejudicial to the\ninterest of revenue and the said para is extracted below:-\n“4.7 In the current case, it is important to note from the assessment order that

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

80G amounting to Rs. 2,53,96,666/-.\nGROUND NO. II: NON-GRANT OF DEDUCTION CLAIMED_U/S 36(1)(να)\nOF THE ACT AMOUNTING TO RS. 41,05,801/-\n1. On the facts and circumstances of case and in law, CIT(A) erred in\nupholding the action of the AO by disallowing

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

ii) The fixed deposits and interest thereon are business assets and have been accordingly disclosed under the respective heads. Copy of our reply is enclosed as per Annexure-3 for your kind consideration 2.4 Later on, the Ld. Assessing Officer has further raised a specific query on the issue under consideration. In response to which the assessee Company has filed

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

ii) The fixed deposits and interest thereon are business assets and have been accordingly disclosed under the respective heads. Copy of our reply is enclosed as per Annexure-3 for your kind consideration 2.4 Later on, the Ld. Assessing Officer has further raised a specific query on the issue under consideration. In response to which the assessee Company has filed

OVERSEAS INFRASTRUCTURE ALLIANCE (INDIA) PRIVATE LIMTIED ,MUMBAI vs. ASSISTANT COMMISSIONER OF INCOME TAX CENTRAL CIRCLE 6(2), MUMBAI

In the result, appeal by the assessee is allowed

Bench: Shri Sandeep Gosain & Shri Girish Agrawal

ii) The fixed deposits and interest thereon are business assets and have been accordingly disclosed under the respective heads. Copy of our reply is enclosed as per Annexure-3 for your kind consideration 2.4 Later on, the Ld. Assessing Officer has further raised a specific query on the issue under consideration. In response to which the assessee Company has filed

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

ii) The fixed deposits and interest thereon are business assets and have been accordingly disclosed under the respective heads. Copy of our reply is enclosed as per Annexure-3 for your kind consideration 2.4 Later on, the Ld. Assessing Officer has further raised a specific query on the issue under consideration. In response to which the assessee Company has filed