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

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

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

iii) First American (India)\nPvt. Ltd. (ITA No. 1762/Bang/2019) Allegis Services (India) Pvt. Ltd. (ITA No. 1693\n/Bang/2019)\nLd. Counsel further submitted that if the intention was to deny deduction of CSR\nexpenses under section 80G, appropriate amendments on lines of section 37(1) should\nalso have been made under section 80G of the Act. In the absence

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

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

iii) First American (India)\nPvt. Ltd. (ITA No. 1762/Bang/2019) Allegis Services (India) Pvt. Ltd. (ITA No. 1693\n/Bang/2019)\nLd. Counsel further submitted that if the intention was to deny deduction of CSR\nexpenses under section 80G, appropriate amendments on lines of section 37(1) should\nalso have been made under section 80G of the Act. In the absence

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

III: Disallowance under section 40(a) amounting\nto Rs. 50,49,586/-\n51. During the course of assessment, the Assessing Officer\nnoticed that the assessee had created a year-end provision on ad\nhoc basis in respect of certain expenses and had claimed\ndeduction thereof. Since tax was not deducted at source on the\nsaid provision, the Assessing Officer invoked

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

iii) in accordance with the ratio of law laid down by Special\nBench-ITAT, Delhi in the case of Vireet Investment Private Limited\n(supra). This ground is therefore dismissed.\n16. In the ground no.2, it is claimed by the Revenue the Ld.\nCIT(A) erred in restricting the disallowance u/s 14A to the exempt\nincome ignoring the provisions contained

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

iii) First American (India)\nPvt. Ltd. (ITA No. 1762/Bang/2019) Allegis Services (India) Pvt. Ltd. (ITA No. 1693\n/Bang/2019)\nLd. Counsel further submitted that if the intention was to deny deduction of CSR\nexpenses under section 80G, appropriate amendments on lines of section 37(1) should\nalso have been made under section 80G of the Act. In the absence

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

III: Disallowance under section 40(a) amounting\nto Rs. 50,49,586/-\n51. During the course of assessment, the Assessing Officer\nnoticed that the assessee had created a year-end provision on ad\nhoc basis in respect of certain expenses and had claimed\ndeduction thereof. Since tax was not deducted at source on the\nsaid provision, the Assessing Officer invoked

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

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

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

III: Disallowance under section 40(a) amounting\nto Rs. 50,49,586/-\n51. During the course of assessment, the Assessing Officer\nnoticed that the assessee had created a year-end provision on ad\nhoc basis in respect of certain expenses and had claimed\ndeduction thereof. Since tax was not deducted at source on the\nsaid provision, the Assessing Officer invoked

M/S PIRAMAL ENTERPRISES LIMIITED ,MUMBSI vs. DY CIT(APPEAL)-RANGE-8(2)(1), MUMBAI

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

Bench: Shri Vikas Awasthy () & Shri Om Prakash Kant () Assessment Year: 2017-18 M/S Piramal Enterprises Ltd., Dy. Cit, Mumbai-8(1)(2), Or Piramal Tower, Agastya National Facelss Assessment Vs. Corporate Park, Lbs Marg, Centre, Delhi, Kamani Junction, Kurla Room No. 624, 6Th Floor, (West), Aayakar Bhavan, M.K. Road, Mumbai-400070. Mumbai-400020. Pan No. Aaacn 4538 P Appellant Respondent : Assessee By Mr. Ronak Doshi : Revenue By Mr. Rakesh Ranjan, Cit-Dr & Mr. Samuel Pitta, Dr : Date Of Hearing 17/11/2022 : Date Of Pronouncement 28/12/2022

TDS as claimed by the appellant in its return of income. return of income. WITHOUT PREJUDICE TO GROUND I, II, III AND VI AS WITHOUT PREJUDICE TO GROUND I, II, III AND VI AS WITHOUT PREJUDICE TO GROUND I, II, III AND VI AS MENTIONED ABOVE: MENTIONED ABOVE: GROUND NO. VI: DEDUCTION UNDER SECTION 10AA OF GROUND NO. VI: DEDUCTION

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

80G, provided the conditions stipulated therein are satisfied. Contention of the ld. DR that such donations lack voluntariness solely because they form part of CSR obligation is misconceived in law. The choice of recipient of such CSR donations is always with the assessee alone. As long as the donations are made to institutions approved u/s.80G and all the requisite documentary

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

80G, provided the conditions stipulated therein are satisfied. Contention of the ld. DR that such donations lack voluntariness solely because they form part of CSR obligation is misconceived in law. The choice of recipient of such CSR donations is always with the assessee alone. As long as the donations are made to institutions approved u/s.80G and all the requisite documentary

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

In the result, appeal by the assessee is allowed

Bench: Shri Sandeep Gosain & Shri Girish Agrawal

80G, provided the conditions stipulated therein are satisfied. Contention of the ld. DR that such donations lack voluntariness solely because they form part of CSR obligation is misconceived in law. The choice of recipient of such CSR donations is always with the assessee alone. As long as the donations are made to institutions approved u/s.80G and all the requisite documentary