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

In the result, the appeal filed by the Revenue is allowed for statistical\npurposes

5, raised in Revenue's appeal, pertain to the deletion\nof disallowance made under section 40(a)(i) and section 40(a)(ia) of the\nAct.\n4.\nWe have considered the submissions for both sides and perused the\nmaterial available on record. The brief facts of the case are that the\nassessee's primary activity is to provide shipping agency

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

VI-A of the\nAct on account of the donations made under section 80G of the Act and\ndisregarding the donation receipts submitted by the Appellant evidencing the\neligibility for deduction under section 80G of the Act.\nFurther, the learned AO failed to appreciate the fact that voluntary contribution\nis not a mandatory requirement as per the provision of section

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

5% on local sale and 8% on export sale. Royalty\nhas been paid by the assessee for the use of technical know-how of AE's\nsecret formula, manufacturing procedure, etc. The TPO following the order for\n Assessment Year 2016-17 applied CUP and determined the rate of royalty at\n4%. The TPO is applying CUP adopted comparable royalty

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

TDS within the due date. On the other hand, the assessee is claiming the amount in this year. Accordingly, the AO held that the amount of ₹ 65,03,040/- is not allowable as a deduction in the year under consideration. 8. The learned CIT(A), vide impugned order, dismissed the ground raised by the assessee on this issue and held

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

VI: SHORT GRANT OF TAX DEDUCTED AT SOURCE\n(“TDS”) CREDIT AMOUNTING TO RS. 3,09,621/-\n1. On the facts and circumstances of case and in law, CIT(A) erred in\nconfirming the action of the AO in granting a total credit of TDS\namounting to Rs. 1,11,26,00,781/- instead

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

VI: SHORT GRANT OF TAX DEDUCTED AT SOURCE (“TDS”) CREDIT AMOUNTING TO RS. 3,09,621/-\n1. On the facts and circumstances of case and in law, CIT(A) erred in confirming the action of the AO in granting a total credit of TDS amounting to Rs. 1,11,26,00,781/- instead

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

VI-A of the Act which is\nindependent of section 37 of the Act. It is further claimed by the assessee\nthat CSR expenditure is eligible for deduction under section 80G of the Act\neven if the expenditure was disallowed under section 37(1) by virtue of\nExplanation 2 of Section 37 of the Act as the deduction u/s 80G

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

VI: SHORT GRANT OF TAX DEDUCTED AT SOURCE\n(“TDS”) CREDIT AMOUNTING TO RS. 3,09,621/-\n1. On the facts and circumstances of case and in law, CIT(A) erred in\nconfirming the action of the AO in granting a total credit of TDS\namounting to Rs. 1,11,26,00,781/- instead

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

VI-A, including section 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

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

VI-A, including section 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

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

VI-A, including section 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

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

VI-A, including section 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

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

VI-A, including section 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

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

VI-A, including section 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

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

VI-A, including section 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

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

VI-A, including section 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