BANK OF INDIA,MUMBAI vs. THE NATIONAL FACELESS ASSESSMENT CENTRE, MUMBAI

1 to 160\nof the paper book filed by the assessee. It is noticed that assessing officer has\nspecifically asked the assessee vide notice dated 24.11.2016 to provide the detail\nof income tax reversal on distribution of unsecured perpetual securities. In this\nregard assessee has given detailed submission vide letter dated 16.12.2016\nstating that it has issued 11.4% unsecured perpetual

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

In the result, the appeal by the Revenue for the assessment year 2018-

Bench: Shri Vikram Singh Yadavshri Sandeep Singh Karhailita No.1452/Mum/2023 Assessment Year : 2016-17 Assessment Year : 2018-19

section 143(3) of the Act, disagreed with the submissions of the assessee and held that perpetual bonds are in the nature of debt instruments with no maturity date. Only the issuing company can buy back the bonds from the investors. Therefore, it was held these bonds are perpetual in nature. Since in the case of perpetual bonds, the investor

DY..C.I.T., BANGALORE vs. M/S STATE BANK OF MYSORE, BANGALORE

Bench: Justice (Retd.) C V Bhadang & Ms Padmavathy S, Am

vii) or towards provision for bad and doubtful debts under section 36(1)(viia) and decide the taxability in accordance with law. Disallowance due to re-computation of deduction under section 36(1)(viia) – Ground No.2 in assessee's appeal & Ground No.2 in revenue's appeal 8. The assessee for the year under consideration has debited

STATE BANK OF MYSORE,BANGALORE vs. JCIT, BANGALORE

Bench: Justice (Retd.) C V Bhadang & Ms Padmavathy S, Am

vii) or towards provision for bad and doubtful debts under section 36(1)(viia) and decide the taxability in accordance with law. Disallowance due to re-computation of deduction under section 36(1)(viia) – Ground No.2 in assessee's appeal & Ground No.2 in revenue's appeal 8. The assessee for the year under consideration has debited

DCIT-3(4), MUMBAI vs. M/S UNION OF BANK OF INDIA, MUMBAI

vii) in earlier years is not taxable. Accordingly, the AO is directed to\ndelete the addition made in this regard.\nApplicability of provisions of section 115JB\n13.\nWe notice that the issue of applicability of provisions of section 115JB has\nbeen considered by the Special Bench in assessee's own case for AY 2015-16 (ITA\nNo. 424/Mum/2020 dated

UNION BANK OF INDIA,MUMBAI vs. DCIT, CIR - (LTU)-2, MUMBAI

vii) in earlier years is not taxable. Accordingly, the AO is directed to\ndelete the addition made in this regard.\nApplicability of provisions of section 115JB\n13. We notice that the issue of applicability of provisions of section 115JB has\nbeen considered by the Special Bench in assessee's own case for AY 2015-16 (ITA\nNo. 424/Mum/2020 dated

DCIT-3(4), MUMBAI vs. M/S UNION OF BANK OF INDIA, MUMBAI

vii) in earlier years is not taxable. Accordingly, the AO is directed to\ndelete the addition made in this regard.\nApplicability of provisions of section 115JB\n13.\nWe notice that the issue of applicability of provisions of section 115JB has\nbeen considered by the Special Bench in assessee's own case for AY 2015-16 (ITA\nNo. 424/Mum/2020 dated

UNION BANK OF INDIA,MUMBAI vs. DCIT, CIR - (LTU)-2, MUMBAI

vii) in earlier years is not taxable. Accordingly, the AO is directed to\ndelete the addition made in this regard.\nApplicability of provisions of section 115JB\n13. We notice that the issue of applicability of provisions of section 115JB has\nbeen considered by the Special Bench in assessee's own case for AY 2015-16 (ITA\nNo. 424/Mum/2020 dated

DEPUTY COMMISSIONER OF INCOME TAX, CIRCLE-1(3)(1), MUMBAI, MUMBAI vs. TMF HOLDINGS LIMITED, MUMBAI

In the result, the appeal of the revenue bearing ITA No

Bench: Shri Anikesh Banerjee & Smt. Renu Jauhrideputy Commissioner Of Vs Tmf Holdings Limited 14, 4Th Floor, Sir H C Dinshaw Income Tax, Circle 1(3)(1), Mumbai Building, 16, Horniman Circle, Fort, Room No.535, 5Th Floor, Aaykar Mumbai-400 001 Bhavan, M.K. Road, Mumbai- Pan: Aacct4644A 400 020 Appellant Respondent

bogus transaction, the disclosures made could not be said to be all "true" and "full" Relying upon the said judgment the High Court held that merely because the transaction of convertible bonds was disclosed at the time of original assessment does not mean that there is true and full disclosure of facts. 28. We are unable to agree with this

SUMAN GUPTA,MUMBAI vs. DCIT - CC- 4(2), MUMBAI

In the result, appeal filed by the Revenue is dismissed

Bench: Shri Kuldip Singh, Hon'Ble & Shri S. Rifaur Rahman, Hon'Ble

vii) Sample copies of bills of respective parties. 11. Assessing Officer rejected the submissions of the assessee with the following observations: - • As per section 101, 102 and 106 of the Evidence Act, the onus lies upon the assessee to prove all the expenses including purchases to the satisfaction of the AO, which was not discharged by the assessee

SUMAN GUPTA,MUMBAI vs. DCIT -CC- 4(2), MUMBAI

In the result, appeal filed by the Revenue is dismissed

Bench: Shri Kuldip Singh, Hon'Ble & Shri S. Rifaur Rahman, Hon'Ble

vii) Sample copies of bills of respective parties. 11. Assessing Officer rejected the submissions of the assessee with the following observations: - • As per section 101, 102 and 106 of the Evidence Act, the onus lies upon the assessee to prove all the expenses including purchases to the satisfaction of the AO, which was not discharged by the assessee

TUTOR INVESTMENT AND FINANCE PVT LTD,MUMBAI vs. DCIT, CENTRAL CIRCLE 6(4), MUMBAI

In the result, the orders of the ld

Bench: Shri Narender Kumar Choudhry & Shri Prabhash Shankar

bogus by the AO, Broker memos, Share valuation certificates, Broker memos with respect to F&O losses as well. We have considered the submissions of both the parties and carefully gone through the materials available on record. In our opinion, the new P a g e | 5 ITA No. 287,288,289, 290 &291/Mum/2025

TUTOR INVESTMENT AND FINANCE PVT LTD,MUMBAI vs. DCIT, CENTRAL CIRCLE 6(4), MUMBAI

In the result, the orders of the ld

Bench: Shri Narender Kumar Choudhry & Shri Prabhash Shankar

bogus by the AO, Broker memos, Share valuation certificates, Broker memos with respect to F&O losses as well. We have considered the submissions of both the parties and carefully gone through the materials available on record. In our opinion, the new P a g e | 5 ITA No. 287,288,289, 290 &291/Mum/2025

TUTOR INVESTMENT AND FINANCE PVT LTD,MUMBAI vs. DCIT CENTRAL CIRCLE 6(4), MUMBAI

In the result, the orders of the ld

Bench: Shri Narender Kumar Choudhry & Shri Prabhash Shankar

bogus by the AO, Broker memos, Share valuation certificates, Broker memos with respect to F&O losses as well. We have considered the submissions of both the parties and carefully gone through the materials available on record. In our opinion, the new P a g e | 5 ITA No. 287,288,289, 290 &291/Mum/2025

M/S. PATANJALI FOODS LTD (FORMERLY KNOWN AS RUCHI SOYA INDUSTRIES LTD),MUMBAI vs. DY COMM OF INCOME TAX- CENTRAL CIRCLE-7(2), MUMBAI

In the result, the appeal and cross objections of the assessee are partly allowed and the appeals of the revenue are dismissed

Bench: Shri Aby T. Varkey, Jm & Shri S Rifaur Rahman, Am आयकर अपील सं/ I.T. A. No. 1172/Mum/2023 (निर्धारण वर्ा / Assessment Year: 2010-11) & आयकर अपील सं/ I.T. A. No. 1175/Mum/2023 (निर्धारण वर्ा / Assessment Year: 2012-13) & आयकर अपील सं/ I.T. A. No. 1176/Mum/2023 (निर्धारण वर्ा / Assessment Year: 2012-13)

bogus. Referring to these observations, the AO held that, the assessee, in the present case, had sold a commodity at a price higher than the original purchase price, and then re-purchased it back at a lower price. This according to him implied that the purchases were inflated. The AO accordingly disallowed the inflated payments for purchases quantified at Rs.139

DCIT, CC-7(2), MUMBAI vs. M/S. PATANJALI FOODS LTD.,( FORMERLY KNOWN AS RUCHI SOYA INDUSTRIES LTD,, MUMBAI

In the result, the appeal and cross objections of the assessee are partly allowed and the appeals of the revenue are dismissed

Bench: Shri Aby T. Varkey, Jm & Shri S Rifaur Rahman, Am आयकर अपील सं/ I.T. A. No. 1172/Mum/2023 (निर्धारण वर्ा / Assessment Year: 2010-11) & आयकर अपील सं/ I.T. A. No. 1175/Mum/2023 (निर्धारण वर्ा / Assessment Year: 2012-13) & आयकर अपील सं/ I.T. A. No. 1176/Mum/2023 (निर्धारण वर्ा / Assessment Year: 2012-13)

bogus. Referring to these observations, the AO held that, the assessee, in the present case, had sold a commodity at a price higher than the original purchase price, and then re-purchased it back at a lower price. This according to him implied that the purchases were inflated. The AO accordingly disallowed the inflated payments for purchases quantified at Rs.139

ITO WARD 4(1)(1), MUMBAI, MUMBAI vs. FAIRDEAL INFIN SERVICES PRIVATE LIMITED, MUMBAI

bogus, when the\ndocumentary evidences furnished by the assessee establish genuineness\nof the claim. In the case of PCIT vs. Indravadan Jain (HUF) (ITA\nNo. 454 of 2018) (Bom), the broker through whom the assessee had\ncarried out the transactions have been alleged to have been indulged in\nprice manipulations and the SEBI had also passed an order regarding\nirregularities

DCIT-C-6(2), MUMBAI vs. SAMIRA HABITATS INDIA LIMITED, MUMBAI

In the result, the cross-objection by the assessee for the assessment year 2012-13 is dismissed

Bench: Shri Narendra Kumar Billaiyashri Sandeep Singh Karhailita No.5714/Mum/2024 Assessment Year : 2011-12 Assessment Year : 2012-13 Assessment Year : 2009-10

bogus purchase to 50%. Accordingly, the same is upheld, and Ground No. (i) raised in its Revenue’s appeal is dismissed. 15. The issue arising in Grounds No. (ii) to (iv), raised in Revenue’s appeal, pertains to restricting the addition made on account of on-money received by the assessee. 16. The brief facts of the case pertaining