DCIT 1(1)(2), MUMBAI vs. FORBES & COMPANY LTD, MUMBAI

In the result, the appeal is allowed for statistical purpose

Bench: Shir Pavan Kumar Gadale & Shri Gagan Goyal

capital gain. Under the facts and circumstances and considering the discussions referred above, the addition of Rs. 2.32 crore is not warranted, Ground No. 5 of the appeal is allowed. We find the various new facts and submissions are emerged in the course of hearing and the agreement was filed for the first time. Therefore considering the facts, submissions

DCIT - 1 (1) (2), MUMBAI vs. FORBES & COMPANY LTD., MUMBAI

In the result, the appeal is allowed for statistical purpose

Bench: Shir Pavan Kumar Gadale & Shri Gagan Goyal

capital gain. Under the facts and circumstances and considering the discussions referred above, the addition of Rs. 2.32 crore is not warranted, Ground No. 5 of the appeal is allowed. We find the various new facts and submissions are emerged in the course of hearing and the agreement was filed for the first time. Therefore considering the facts, submissions

PATEL ENGINEERING LIMITED ,MUMBAI vs. DCIT CC-3(4), MUMBAI

In the result, appeals of the Revenue are dismissed, except for one ground no

Bench: SHRI AMIT SHUKLA (Judicial Member), SHRI GIRISH AGRAWAL (Accountant Member)

capital gain, however, the tax rate u/s.112 would be 20%. Thus, following the decision of the Special Bench, the order of the ld. CIT (A) is upheld and the grounds raised by the Revenue are dismissed. 46. Lastly, with regard to ground No.13 raised by the Revenue that the adjustment of Rs.2,46,02,617/- on account of addition made

PATEL ENGINEERING LIMITED ,MUMBAI vs. DCIT-CC-3(4), MUMBAI

In the result, appeals of the Revenue are dismissed,\nexcept for one ground no

capital gain, however, the tax\nrate u/s.112 would be 20%. Thus, following the decision of the\nSpecial Bench, the order of the ld. CIT (A) is upheld and the\ngrounds raised by the Revenue are dismissed.\n46. Lastly, with regard to ground No.13 raised by the Revenue\nthat the adjustment of Rs.2,46,02,617/- on account of addition\nmade

ASST.COMMISSIONER OF INCOME-TAX (TDS)2(1), MUMBAI, MUMBAI vs. PATEL ENGINEERING LIMITED, MUMBAI

capital gain, however, the tax\nrate u/s.112 would be 20%. Thus, following the decision of the\nSpecial Bench, the order of the ld. CIT (A) is upheld and the\ngrounds raised by the Revenue are dismissed.\n46. Lastly, with regard to ground No.13 raised by the Revenue\nthat the adjustment of Rs.2,46,02,617/- on account of addition\nmade

ASST.COMMISSIONER OF INCOME TAX, TDS 2 1, MUMBAI vs. PATEL ENGINEERING LIMITED, MUMBAI

In the result, appeals of the Revenue are dismissed,\nexcept for one ground no

capital gain, however, the tax\nrate u/s.112 would be 20%. Thus, following the decision of the\nSpecial Bench, the order of the ld. CIT (A) is upheld and the\ngrounds raised by the Revenue are dismissed.\n46. Lastly, with regard to ground No.13 raised by the Revenue\nthat the adjustment of Rs.2,46,02,617/- on account of addition\nmade

DCIT CC- 3(4), MUMBAI, MUMBAI vs. PATEL ENGINEERING LIMITED, MUMBAI

capital gain, however, the tax\nrate u/s.112 would be 20%. Thus, following the decision of the\nSpecial Bench, the order of the ld. CIT (A) is upheld and the\ngrounds raised by the Revenue are dismissed.\n46. Lastly, with regard to ground No.13 raised by the Revenue\nthat the adjustment of Rs.2,46,02,617/- on account of addition\nmade

DCIT CC - 3(4), MUMBAI, MUMBAI vs. PATEL ENGINEERING LIMITED, MUMBAI

In the result, appeals of the Revenue are dismissed,\nexcept for one ground no

capital gain, however, the tax\nrate u/s.112 would be 20%. Thus, following the decision of the\nSpecial Bench, the order of the ld. CIT (A) is upheld and the\ngrounds raised by the Revenue are dismissed.\n46. Lastly, with regard to ground No.13 raised by the Revenue\nthat the adjustment of Rs.2,46,02,617/- on account of addition\nmade

ABHYUDAYA CO OPERATIVE BANK LTD , JOGESHWARI EAST BRANCH,MUMBAI vs. INCOME TAX OFFICER (TDS) WARD 1(1)(1), MUMBAI

In the result, all the 20 appeals of the assessee are allowed

Bench: Shri Amit Shukla\Nand\Nshri Girish Agrawal\Nita Nos.2571 To 2590/Mum/2025\N Assessment Year: 2016-17\Nabhyudaya\Nco-Operative\Nbank Ltd.\Nshraddha Shopping Centre,\Nold Nagardas Road, Andheri\N(East), Mumbai 400069.\N(Pan: Aaaaa0300L)\N(Appellant)\Nvs.\Nincome Tax Officer (Tds)\Nward 1(1)(1), Mumbai.\Nroom No. 413, 4Th Floor,\Ncumballa Hill, Mtnl Tele\Nbuilding, Peddar Road, Cumballa\Nhill, Mumbai 400026.\N(Respondent)\Npresent For:\Nassessee\Nrevenue\Ndate Of Hearing\Ndate Of Pronouncement\N: Shri Sharad A. Vaze, Ca\N: Shri. Aditya M. Rai, Sr. Dr\N: 23.06.2025\N: 26.06.2025\Norder\Nper Bench:\Nall These Captioned 20 Appeals Filed By The Assessee Are Against\Nthe Common Order Of Ld. Cit(A) Vide Order No. Itba/Apl/S/250/2024-\N25/1074957920(1) Dated 24.03.2025, Passed Against The Respective\Norders By Income Tax Officer, Tds Ward 1(1)(1), Mumbai For\Nproceedings U/S 201(1)/(1A) Of The Income-Tax Act, 1961 (Hereinafter\Nreferred To As The Act), Dated 28.12.2022 / 29.12.2022, For Assessment\Nyear 2016-17.\N1.

capital fund or 2[infrastructure debt fund or] a public sector\ncompany [or scheduled bank] in relation to a zero coupon bond issued on or\nafter the 1st day of June, 2005 by such company or fund or public sector\ncompany [or scheduled bank];]\n2[(xi)\nto any income by way of interest referred to in clause (23FC) of section

ABHYUDAYA CO OPERATIVE BANK LTD. NERUL BRANCH,MUMBAI vs. INCOME TAX OFFICER , (TDS) TDS WARD 1(1), MUMBAI

In the result, all the 20 appeals of the assessee are allowed

Bench: Shri Amit Shukla\Nand\Nshri Girish Agrawal\Nita Nos.2571 To 2590/Mum/2025\N Assessment Year: 2016-17\Nabhyudaya\Nco-Operative\Nbank Ltd.\Nshraddha Shopping Centre,\Nold Nagardas Road, Andheri\N(East), Mumbai 400069.\Nvs.\Nincome Tax Officer (Tds)\Nward 1(1)(1), Mumbai.\Nroom No. 413, 4Th Floor,\Ncumballa Hill, Mtnl Tele\Nbuilding, Peddar Road, Cumballa\Nhill, Mumbai 400026.\N(Pan: Aaaaa0300L)\N(Appellant)\N(Respondent)\Npresent For:\Nassessee\Nrevenue\Ndate Of Hearing\Ndate Of Pronouncement\N: Shri Sharad A. Vaze, Ca\N: Shri. Aditya M. Rai, Sr. Dr\N: 23.06.2025\N: 26.06.2025\Norder\Nper Bench:\Nall These Captioned 20 Appeals Filed By The Assessee Are Against\Nthe Common Order Of Ld. Cit(A) Vide Order No. Itba/Apl/S/250/2024-\N25/1074957920(1) Dated 24.03.2025, Passed Against The Respective\Norders By Income Tax Officer, Tds Ward 1(1)(1), Mumbai For\Nproceedings U/S 201(1)/(1A) Of The Income-Tax Act, 1961 (Hereinafter\Nreferred To As The Act), Dated 28.12.2022 / 29.12.2022, For Assessment\Nyear 2016-17.\N1.

capital fund or [infrastructure debt fund or] a public sector\ncompany [or scheduled bank] in relation to a zero coupon bond issued on or\nafter the 1st day of June, 2005 by such company or fund or public sector\ncompany [or scheduled bank];]\n[(xi)\nto any income by way of interest referred to in clause (23FC) of section

ABHYUDAYA CO OPERATIVE BANK LTD . KOPARKHAIRANE BRANCH,MUMBAI vs. INCOME TAX OFFICER (TDS)WARD 1(1)(1), MUMBAI

In the result, all the 20 appeals of the assessee are allowed

Bench: Shri Amit Shukla & Shri Girish Agrawal

capital fund or 7[infrastructure debt fund or] a public sector company 8[or scheduled bank] in relation to a zero coupon bond issued on or after the 1st day of June, 2005 by such company or fund or public sector company 8[or scheduled bank];] Abhyudaya Co-operative Bank Ltd. AY 2016-17 9[(xi) to any income

ABHYUDAYA CO OPERATIVE BANK LTD . VIKHROLI WEST BRANCH,MUMBAI vs. INCOME TAX OFFICER TDS WARD 1(1)(1), MUMBAI

In the result, all the 20 appeals of the assessee are allowed

Bench: Shri Amit Shukla & Shri Girish Agrawal

capital fund or 7[infrastructure debt fund or] a public sector company 8[or scheduled bank] in relation to a zero coupon bond issued on or after the 1st day of June, 2005 by such company or fund or public sector company 8[or scheduled bank];] Abhyudaya Co-operative Bank Ltd. AY 2016-17 9[(xi) to any income

ABHYUDAYA CO OPERATIVE BANK LTD TURBHE BRANCH,MUMBAI vs. INCOME TAX OFFICER TDS WARD 1(1)(1), MUMBAI

In the result, all the 20 appeals of the assessee are allowed

Bench: Shri Amit Shukla & Shri Girish Agrawal

capital fund or 7[infrastructure debt fund or] a public sector company 8[or scheduled bank] in relation to a zero coupon bond issued on or after the 1st day of June, 2005 by such company or fund or public sector company 8[or scheduled bank];] Abhyudaya Co-operative Bank Ltd. AY 2016-17 9[(xi) to any income

ABHYUDAYA CO OPERATIVE BANK LTD. ABHYUDAYA NAGAR BRANCH,,MUMBAI vs. INCOME TAX OFFICER (TDS)WARD1(1)(1), MUMBAI

In the result, all the 20 appeals of the assessee are allowed

Bench: Shri Amit Shukla & Shri Girish Agrawal

capital fund or 7[infrastructure debt fund or] a public sector company 8[or scheduled bank] in relation to a zero coupon bond issued on or after the 1st day of June, 2005 by such company or fund or public sector company 8[or scheduled bank];] Abhyudaya Co-operative Bank Ltd. AY 2016-17 9[(xi) to any income

ABHYUDAYA CO OPERATIVE BANK LTD . KANJUR BRANCH ,MUMBAI vs. INCOME TAX OFFICER (TDS) WARD 1(1)(1), MUMBAI

In the result, all the 20 appeals of the assessee are allowed

Bench: Shri Amit Shukla & Shri Girish Agrawal

capital fund or 7[infrastructure debt fund or] a public sector company 8[or scheduled bank] in relation to a zero coupon bond issued on or after the 1st day of June, 2005 by such company or fund or public sector company 8[or scheduled bank];] Abhyudaya Co-operative Bank Ltd. AY 2016-17 9[(xi) to any income

ABHYUDAYA CO-OPERATIVE BANK LTD WORLI BRANCH,MUMBAI vs. ITO TDS, WARD 1(1)(1), MUMBAI

In the result, all the 20 appeals of the assessee are allowed

Bench: Shri Amit Shukla & Shri Girish Agrawal

capital fund or 7[infrastructure debt fund or] a public sector company 8[or scheduled bank] in relation to a zero coupon bond issued on or after the 1st day of June, 2005 by such company or fund or public sector company 8[or scheduled bank];] Abhyudaya Co-operative Bank Ltd. AY 2016-17 9[(xi) to any income

ABHYUDAYA CO OPERATIVE BANK LTD . BORIVALI BRANCH,MUMBAI vs. INCOME TAX OFFICER (TDS) WARD 1(1)(1), MUMBAI

In the result, all the 20 appeals of the assessee are allowed

Bench: Shri Amit Shukla & Shri Girish Agrawal

capital fund or 7[infrastructure debt fund or] a public sector company 8[or scheduled bank] in relation to a zero coupon bond issued on or after the 1st day of June, 2005 by such company or fund or public sector company 8[or scheduled bank];] Abhyudaya Co-operative Bank Ltd. AY 2016-17 9[(xi) to any income

ABHYUDAYA CO OPERATIVE BANK LTD . CBD BELAPUR BRANCH,MUMBAI vs. INCOME TAX OFFICER (TDS) WARD 1(1)(1), MUMBAI

In the result, all the 20 appeals of the assessee are allowed

Bench: Shri Amit Shukla & Shri Girish Agrawal

capital fund or 7[infrastructure debt fund or] a public sector company 8[or scheduled bank] in relation to a zero coupon bond issued on or after the 1st day of June, 2005 by such company or fund or public sector company 8[or scheduled bank];] Abhyudaya Co-operative Bank Ltd. AY 2016-17 9[(xi) to any income