DCIT (OSD)(TDS)-2(3), MUMBAI vs. TOTAL ENERGIES MARKETING INDIA PVT LTD, MUMBAI

Appeals are partly allowed

Bench: Shri Prashant Maharishi, Am & Shri Rahul Chaudhary, Jm

91 of the paper book wherein identification of the vendor, permanent account number, particulars of the head under which tax is required to be deducted mentioning the section, amount paid or payable, TDS

DCIT (OSD)(TDS)-2(3), MUMBAI vs. TOTAL ENERGIES MARKETINGS INDIA PVT LTD, MUMBAI

Appeals are partly allowed

Bench: Shri Prashant Maharishi, Am & Shri Rahul Chaudhary, Jm

91 of the paper book wherein identification of the vendor, permanent account number, particulars of the head under which tax is required to be deducted mentioning the section, amount paid or payable, TDS

DCIT (OSD)(TDS)-2(3) , MUMBAI vs. TOTAL ENERGIES MARKETING INDIA PVT LTD, MUMBAI

Appeals are partly allowed

Bench: Shri Prashant Maharishi, Am & Shri Rahul Chaudhary, Jm

91 of the paper book wherein identification of the vendor, permanent account number, particulars of the head under which tax is required to be deducted mentioning the section, amount paid or payable, TDS

DCIT (OSD)(TDS)-2(3) , MUMBAI vs. TOTAL ENERGIES MARKETING INDIA PVT LTD, MUMBAI

Appeals are partly allowed

Bench: Shri Prashant Maharishi, Am & Shri Rahul Chaudhary, Jm

91 of the paper book wherein identification of the vendor, permanent account number, particulars of the head under which tax is required to be deducted mentioning the section, amount paid or payable, TDS

DCIT (OSD)(TDS)-2(3), MUMBAI vs. TOTAL ENERGIES MARKETING INDIA PVT LTD, MUMBAI

Appeals are partly allowed

Bench: Shri Prashant Maharishi, Am & Shri Rahul Chaudhary, Jm

91 of the paper book wherein identification of the vendor, permanent account number, particulars of the head under which tax is required to be deducted mentioning the section, amount paid or payable, TDS

DCIT (OSD)(TDS)-2(3), MUMBAI vs. TOTAL ENERGIES MARKETING INDIA PVT LTD, MUMBAI

Appeals are partly allowed

Bench: Shri Prashant Maharishi, Am & Shri Rahul Chaudhary, Jm

91 of the paper book wherein identification of the vendor, permanent account number, particulars of the head under which tax is required to be deducted mentioning the section, amount paid or payable, TDS

DCIT (OSD)(TDS)-2(3), MUMBAI vs. TOTAL ENERGIES MARKETING INDIA PVT LTD, MUMBAI

Appeals are partly allowed

Bench: Shri Prashant Maharishi, Am & Shri Rahul Chaudhary, Jm

91 of the paper book wherein identification of the vendor, permanent account number, particulars of the head under which tax is required to be deducted mentioning the section, amount paid or payable, TDS

ACIT(LTU-1), MUMBAI vs. M/S. TCS LTD, MUMBAI

Bench: Shri Vikas Awasthy () & Ms. Padmavathy S. ()

section 14A read with rule 8D without recording any cogent reasons as to why he is not satisfied with the correctness of the claim of the assessee. Mere recording that the amounts being meager compared to the exempt income earned, cannot be construed as recording of satisfaction. Therefore, respectfully following the ratio laid down by the co- ordinate bench

TATA CONSULTANCY SERRVICES LIMITED,MUMBAI vs. DCIT-1, MUMBAI

Bench: Shri Vikas Awasthy () & Ms. Padmavathy S. ()

section 14A read with rule 8D without recording any cogent reasons as to why he is not satisfied with the correctness of the claim of the assessee. Mere recording that the amounts being meager compared to the exempt income earned, cannot be construed as recording of satisfaction. Therefore, respectfully following the ratio laid down by the co- ordinate bench

TATA CONSULTANCY SERVICES LTD,MUMBAI vs. ADDL CIT LTU -1, MUMBAI

In the result, Revenue’s appeal is dismissed and assessee’s appeal is partly allowed

Bench: Shri Saktijit Dey & Shri N.K. Pradhan

91 read with Explanation–(iv), section 90 does not provide for inclusion of tax levied by any State/ local authority of that country within the expression ‘income tax’. In view of the aforesaid, we direct the Assessing Officer to verify whether the State taxes paid by the assessee overseas are eligible for any relief under section

TATA CONSULTANCY SERVICES LTD,MUMBAI vs. ASST CIT LTU-1, MUMBAI

In the result, appeal by the assessee is partly allowed for statistical purpose

Bench: Shri Prashant Maharishi & Shri Sandeep Singh Karhail

91 read with Explanation–(iv), section 90 does not provide for inclusion of tax levied by any State/ local authority of that country within the expression ‗income tax‘. In view of the aforesaid, we direct the Assessing Officer to verify whether the State taxes paid by the assessee overseas are eligible for any relief under section

ADDL CIT 7(2), MUMBAI vs. RELIANCE COMMUNICATIONS INFRASTRUCTURE LTD, MUMBAI

In the result, appeal filed by the revenue is dismissed

Bench: Shri Amit Shukla & Shri Ramit Kochar

91,62,889/- on account of disallowance under section 40(a)(ia) made by the AO for non-deduction of TDS

BANK OF INDIA,MUMBAI vs. DCIT - 2(1)(1), MUMBAI

In the result, the appeal is partly allowed for statistical purposes in the terms indicated above

section 91 of the Act, amounting to Rs 15,79,80.943; c) TDS, on dividend income received from foreign associates

TATA CONSULTANCY SERVICES LTD,MUMBAI vs. ADDL CIT LARGE TAX PAYER UNIT, MUMBAI

In the result the appeal of the assessee in AY 2008-09 is partly allowed and

Bench: Shri Pawan Singh & Shri Rajesh Kumarvertual Court No. Iii It(Tp)A No. 3263/Mum/2017 For Ay 2008-09 It(Tp) No. 794/Mum/2018 For Ay 201-011 Tata Consultancy Services Vs Dcit Ltd.,9Th Floor, Nirmal Bldg, Large Tax Payer Unit-1, 29Th Floor, Wtc, Nariman Point. Mumbai – 21 Cufee Parade Pan Aaacr4849R Mumbai- 05. Appellant Respondednt

91 of the Act if it is held that the payment of State Taxes is not allowable as deduction. 2. Advertisement expenditure 2.1 On facts and in circumstances of the case and in law, the Id. CIT (A) erred in treating the advertisement expenditure incurred by the Appellant in respect of experience certainly campaign amounting to Rs.1

TATA CONSULTANCY SERVICES LTD,MUMBAI vs. ACIT LARGE TAX PAYER UNIT-1, MUMBAI

797/Mum/2018

91,61,694/- and made an upward adjustment thereon. 12.4. The ld. CIT(A) upheld the action of the ld. TPO in taking AE as the tested party. Further the ld. CIT(A) analysed each of the comparable M/s. Tata Consultancy Services Ltd., companies and provided detailed reasons for either inclusion or exclusion thereon. The ld. TPO was also provided

ACIT CEN CIR 22, MUMBAI vs. M.R. CONSTRUCTION, MUMBAI

In the result, in the case of M

Bench: Sri Mahavir Singh, Jm & Sri Rajesh Kumar, Am

91,2,80,81,82,83,85/2012-13 dated 06-09-13, 12-09-2013,08-11-2012,01- 02-2013. The Assessments were framed by ACIT Centre Circle-22, Mumbai for the A.Ys. 2004-05, 2005-06, 2006-07, 2007-08, 2008-09, 2009-10 & 2010-11 vide different orders dated 21-06-2012 under section 143(3) r.w.s. 153A/C

DCIT CEN CIR 22, MUMBAI vs. M.R. CONSTRUCTION, MUMBAI

In the result, in the case of M

Bench: Sri Mahavir Singh, Jm & Sri Rajesh Kumar, Am

91,2,80,81,82,83,85/2012-13 dated 06-09-13, 12-09-2013,08-11-2012,01- 02-2013. The Assessments were framed by ACIT Centre Circle-22, Mumbai for the A.Ys. 2004-05, 2005-06, 2006-07, 2007-08, 2008-09, 2009-10 & 2010-11 vide different orders dated 21-06-2012 under section 143(3) r.w.s. 153A/C

ASST CIT CC-22, MUMBAI vs. JAWAHAR PUROHIT, MUMBAI

In the result, in the case of M

Bench: Sri Mahavir Singh, Jm & Sri Rajesh Kumar, Am

91,2,80,81,82,83,85/2012-13 dated 06-09-13, 12-09-2013,08-11-2012,01- 02-2013. The Assessments were framed by ACIT Centre Circle-22, Mumbai for the A.Ys. 2004-05, 2005-06, 2006-07, 2007-08, 2008-09, 2009-10 & 2010-11 vide different orders dated 21-06-2012 under section 143(3) r.w.s. 153A/C