DEPUTY COMMISSIONER OF INCOME TAX CENTRAL CIRLCE- 5(4), MUMBAI vs. PRITHVI REALTORS AND HOTELS PRIVATE LIMITED, MUMBAI

In the result, the order of the Ld

Bench: Shri Vikram Singh Yadav & Shri Sandeep Singh Karhailassessment Year : 2017-18 Deputy Commissioner Of Prithvi Realtors & Hotels Income Tax, Private Limited, Central Circle-5(4), Vs. 3Rd Floor, Dheeraj Arma, Room No. 427, Anant Kanekar Marg, Kautilya Bhawan, Bandra (East), G Block, Bkc, Mumbai-400051. Bandra (E), Pan : Aaccp6911E Mumbai-400051. (Appellant) (Respondent) For Assessee : None For Revenue : Shri R.A. Dhyani, Cit-Dr Date Of Hearing : 12-02-2026 Date Of Pronouncement : 23-02-2026 O R D E R Per Vikram Singh Yadav, A.M :

section 43B of the Act and has held that interest payable to Punjab and Maharashtra Co-operative Bank is not required to be deducted from value of work-in-progress. In view of the same, we find that the said decisions do not support the case of the assessee. 11 15. Further, we have gone through the decision

IPCA LABORATORIES LTD.,MUMBAI vs. DY CIT -CC-5(2), MUMBAI

bogus purchases to 8% of the value of supplies\nacross all AYs 2009-10, 2010-11, 2011-12 & 2012-13. With these\ndirections, the grounds of the assessee are partly allowed and the\ngrounds raised by the Revenue are dismissed.\n10. Issue 7: Disallowance of professional fees paid\nGround Nos. 8-11 of the Revenue’s appeal

DCIT- CC5(2), MUMBAI vs. IPCA LABORATORIES LTD., MUMBAI

bogus purchases to 8% of the value of supplies \nacross all AYs 2009-10, 2010-11, 2011-12 & 2012-13. With these \ndirections, the grounds of the assessee are partly allowed and the \ngrounds raised by the Revenue are dismissed.\n10. Issue 7: Disallowance of professional fees paid\nGround Nos. 8-11 of the Revenue’s appeal

DY.CIT CC -5(2) CENT. RG. -5, MUMBAI vs. M/S. IPCA LABORATORIES LTD, MUMBAI

bogus purchases to 8% of the value of supplies\nacross all AYs 2009-10, 2010-11, 2011-12 & 2012-13. With these\ndirections, the grounds of the assessee are partly allowed and the\ngrounds raised by the Revenue are dismissed.\n10. Issue 7: Disallowance of professional fees paid\nGround Nos. 8-11 of the Revenue’s appeal

IPCA LABORATORIES LTD.,MUMBAI vs. DY CIT CC-5(2), MUMBAI

Section 37(1)\nof the Act. On facts, qua each of the sub-head of sales & promotion\nexpenses, the AO is noted to have examined the same and made\ndisallowance in the following manner, which is noted to be\nindependent and different from the amounts admitted to be\ndisallowable by Mr. Beli.\nNature of Expenses\nQuantum Disallowed\n- Expenses

CIT -CC5(2) CENTRAL RG., -5,, MUMBAI vs. M/S. IPCA LABORATORIES LTD, MUMBAI

bogus purchases to 8% of the value of supplies\nacross all AYs 2009-10, 2010-11, 2011-12 & 2012-13. With these\ndirections, the grounds of the assessee are partly allowed and the\ngrounds raised by the Revenue are dismissed.\n10. Issue 7: Disallowance of professional fees paid\nGround Nos. 8-11 of the Revenue’s appeal

IPCA LABORATORIES LTD.,MUMBAI vs. DY CIT CC-5(2), MUMBAI

Section 37(1)\nof the Act. On facts, qua each of the sub-head of sales & promotion\nexpenses, the AO is noted to have examined the same and made\ndisallowance in the following manner, which is noted to be\nindependent and different from the amounts admitted to be\ndisallowable by Mr. Beli.\nNature of Expenses Quantum Disallowed\n- Expenses

CIT -CC5(2) CENTRAL RG., -5,, MUMBAI vs. M/S. IPCA LABORATORIES LTD, MUMBAI

Section 37(1) of the Act was unjustified.\n68\nITA No.879 to 883/M/2021\n& Others (Assessee & Revenue)\nA.Y Nos. 2009-10 to AY. 14-15\nIPCA Laboratories Ltd\nThus, the entire disallowance is held to be unsustainable and is\ndirected to be deleted.\n11.13 Now coming to AY 2010-11, as noted above, the CBDT\nCircular No. 5/2012 read with

DCIT -CC5(2) CENTRAL RG., -5,, MUMBAI vs. M/S. IPCA LABORATORIES LTD, MUMBAI

Section 37(1) \nof the Act. On facts, qua each of the sub-head of sales & promotion \nexpenses, the AO is noted to have examined the same and made \ndisallowance in the following manner, which is noted to be \nindependent and different from the amounts admitted to be \ndisallowable by Mr. Beli.\nNature of Expenses\nQuantum Disallowed\n- Expenses

STATE BANK OF MYSORE,BANGALORE vs. JCIT, BANGALORE

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

43B of the Act. The AO disallowed the said claim on the ground that the amount is an appropriation of profit and not expenditure as reported below the net profit in annual accounts and that deduction cannot be allowed by virtue of section 40A(9) of the Act on the ground that it covers deduction under section

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

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

43B of the Act. The AO disallowed the said claim on the ground that the amount is an appropriation of profit and not expenditure as reported below the net profit in annual accounts and that deduction cannot be allowed by virtue of section 40A(9) of the Act on the ground that it covers deduction under section

HERITAGE SAGAR ENTERPRISES,MUMBAI vs. JOINT CIT RANG 22 (1), MUMBAI

Bench: SHRI PRASHANT MAHARISHI, ACCOUNTANT MEMBER SHRI RAHUL CHAUDHARY (Judicial Member)

43B of the Act in respect of FSI Charges & NOC Fee; and the addition of INR 3,00,000/- made by the Assessing Officer under Section 69C of the Act in respect of alleged bogus purchases

DSV AIR & SEA PVT LTD.,,MUM vs. ASST UNIT, INCOME TAX DEPT, ADDL/JT/DY/ACIT/ITO, NFASSC, MUM

In the result, appeal of the assessee is partly allowed

Bench: SHRI AMIT SHUKLA (Judicial Member), SHRI RATNESH NANDAN SAHAY (Accountant Member)

purchases cannot be sustained and same is deleted. 7. With regard to other three parties also the same reasons have been given by the ld. AO. It is seen that assessee had received freight services from Namaste India Aviation Private Limited; road transport services from Lakshmanan Ramchandran; and ocean freight, bunker charges, sea charges, port handling charges from Sea Bridge

DCIT CEN 5 3, MUMBAI, MUMBAI vs. ICICI LOMBARD GENERAL INSURANCE CO. LIMITED, MUMBAI

In the result, appeals of the Revenue are allowed partly

Bench: Shri Om Prakash Kant () & Shri Raj Kumar Chauhan ()

Section 44 of the Incom Under the existing provisions of Section 44 of the Incom Under the existing provisions of Section 44 of the Income Tax Act, the profits and gains of any insurance business is Act, the profits and gains of any insurance business is Act, the profits and gains of any insurance business is computed in accordance with

DCIT CEN 5 3, MUMBAI vs. ICICI LOMBARD GENERAL INSURANCE CO. LIMITED, MUMBAI

In the result, appeals of the Revenue are allowed partly

Bench: Shri Om Prakash Kant () & Shri Raj Kumar Chauhan ()

Section 44 of the Incom Under the existing provisions of Section 44 of the Incom Under the existing provisions of Section 44 of the Income Tax Act, the profits and gains of any insurance business is Act, the profits and gains of any insurance business is Act, the profits and gains of any insurance business is computed in accordance with

DCIT CEN 5 3, MUMBAI, MUMBAI vs. ICICI LOMBARD GENERAL INSURANCE CO. LIMITED, MUMBAI

In the result, appeals of the Revenue are allowed partly

Bench: Shri Om Prakash Kant () & Shri Raj Kumar Chauhan ()

Section 44 of the Incom Under the existing provisions of Section 44 of the Incom Under the existing provisions of Section 44 of the Income Tax Act, the profits and gains of any insurance business is Act, the profits and gains of any insurance business is Act, the profits and gains of any insurance business is computed in accordance with

DCIT CEN 5 3, MUMBAI, MUMBAI vs. ICICI LOMBARD GENERAL INSURANCE CO. LIMITED, MUMBAI

In the result, appeals of the Revenue are allowed partly

Bench: Shri Om Prakash Kant () & Shri Raj Kumar Chauhan ()

Section 44 of the Incom Under the existing provisions of Section 44 of the Incom Under the existing provisions of Section 44 of the Income Tax Act, the profits and gains of any insurance business is Act, the profits and gains of any insurance business is Act, the profits and gains of any insurance business is computed in accordance with

ITO-1(2)(3), MUMBAI vs. MACROCOSM INDUSTRIES PRIVATE LIMITED, MUMBAI

In the result, all the grounds of

Bench: Shri Pawan Singh & Shri Prabhash Shankar(Physical Hearing) Ito – 1(2)(3), Mumbai Macrocosm Industries Private Limited Room No. 527, Aayakar Bhavan Vs 205, Jolly Bhavan No. 2, Near Marine M K Road, Mumbai – 400020. Line, Mumbai – 400020. Pan: Aafcm0249M Appellant / Revenue Respondent / Assessee

bogus purchases shown by the assessee company to 5% only without appreciating the fact that the purchases were not proved to be genuine and the assessee company was not able to produce any evidence or details in support" 2. The Ld. CIT(A) had erred in law by not appreciating the fact that the purchase made as claimed

A.C.I.T. CENTRAL CIRCLE 20, MUMBAI vs. NISSAN COPPER LTD., GUJRAT

43B", "Sec. 40 A(3)", "Sec. 271(1)(c)", "Sec. 80IB" ], "issues": "The primary issue is the dismissal of the appeals due to the assessee company being in liquidation and thus unable to provide representation or compliance. The underlying grounds of appeal involved additions and disallowances made by the Assessing Officer related to alleged over-invoicing, stock shortages, bogus purchases