ACIT CIRCLE-2(1)(1), MUMBAI vs. M/S BOMBAY DYEING & MANUFACTURING CO. LTD. , MUMBAI

Bench: Shri Aby T Varkey () & Shri Om Prakash Kant () - A.Y 2014-15 - A.Y 2015-16 Asst. Commissioner Of M/S Bombay Dyeing & Income-Tax 2(1)(1), Mumbai, Manufacturing Co. Ltd Room No.561, 5Th Floor, Vs. Neville House, Jn Herdia Aayakar Bhavan, M.K. Road, Marg, Ballard Estate, Mumbai-400 020 Mumbai-400 001 Pan No. Aaact 2328 K Appellant Respondent - A.Y 2014-15 - A.Y 2015-16 M/S Bombay Dyeing & Dy. Commissioner Of Income- Manufacturing Co. Ltd Tax 2(1), Mumbai, Room Neville House, Jn Herdia No.561, 5Th Floor, Aayakar Vs Marg, Ballard Estate, Bhavan, M.K. Road, Mumbai- Mumbai-400 001 400 020 Pan No. Aaact 2328 K Appellant Respondent

1 to 249 and also a supplementary paper book containing pages 250 to 256. 7. We have heard rival submissions of the parties on the issue We have heard rival submissions of the parties on the issue We have heard rival submissions of the parties on the issues in dispute and perused the relevant materials on record. In ground

THE BOMBAY DYEING & MANUFACTURING COMPANY LTD.,,MUMBAI vs. DCIT, C--2(1), MUMBAI, MUMBAI

Bench: Shri Aby T Varkey () & Shri Om Prakash Kant () - A.Y 2014-15 - A.Y 2015-16 Asst. Commissioner Of M/S Bombay Dyeing & Income-Tax 2(1)(1), Mumbai, Manufacturing Co. Ltd Room No.561, 5Th Floor, Vs. Neville House, Jn Herdia Aayakar Bhavan, M.K. Road, Marg, Ballard Estate, Mumbai-400 020 Mumbai-400 001 Pan No. Aaact 2328 K Appellant Respondent - A.Y 2014-15 - A.Y 2015-16 M/S Bombay Dyeing & Dy. Commissioner Of Income- Manufacturing Co. Ltd Tax 2(1), Mumbai, Room Neville House, Jn Herdia No.561, 5Th Floor, Aayakar Vs Marg, Ballard Estate, Bhavan, M.K. Road, Mumbai- Mumbai-400 001 400 020 Pan No. Aaact 2328 K Appellant Respondent

1 to 249 and also a supplementary paper book containing pages 250 to 256. 7. We have heard rival submissions of the parties on the issue We have heard rival submissions of the parties on the issue We have heard rival submissions of the parties on the issues in dispute and perused the relevant materials on record. In ground

THE BOMBAY DYEING & MANUFACTURING COMPANY LTD.,,MUMBAI vs. DCIT, C--2(1), MUMBAI, MUMBAI

Bench: Shri Aby T Varkey () & Shri Om Prakash Kant () - A.Y 2014-15 - A.Y 2015-16 Asst. Commissioner Of M/S Bombay Dyeing & Income-Tax 2(1)(1), Mumbai, Manufacturing Co. Ltd Room No.561, 5Th Floor, Vs. Neville House, Jn Herdia Aayakar Bhavan, M.K. Road, Marg, Ballard Estate, Mumbai-400 020 Mumbai-400 001 Pan No. Aaact 2328 K Appellant Respondent - A.Y 2014-15 - A.Y 2015-16 M/S Bombay Dyeing & Dy. Commissioner Of Income- Manufacturing Co. Ltd Tax 2(1), Mumbai, Room Neville House, Jn Herdia No.561, 5Th Floor, Aayakar Vs Marg, Ballard Estate, Bhavan, M.K. Road, Mumbai- Mumbai-400 001 400 020 Pan No. Aaact 2328 K Appellant Respondent

1 to 249 and also a supplementary paper book containing pages 250 to 256. 7. We have heard rival submissions of the parties on the issue We have heard rival submissions of the parties on the issue We have heard rival submissions of the parties on the issues in dispute and perused the relevant materials on record. In ground

ACIT CIRCLE-2(1)(1), MUMBAI vs. M/S BOMBAY DYEING & MANUFACTURING CO. LTD. , MUMBAI

Bench: Shri Aby T Varkey () & Shri Om Prakash Kant () - A.Y 2014-15 - A.Y 2015-16 Asst. Commissioner Of M/S Bombay Dyeing & Income-Tax 2(1)(1), Mumbai, Manufacturing Co. Ltd Room No.561, 5Th Floor, Vs. Neville House, Jn Herdia Aayakar Bhavan, M.K. Road, Marg, Ballard Estate, Mumbai-400 020 Mumbai-400 001 Pan No. Aaact 2328 K Appellant Respondent - A.Y 2014-15 - A.Y 2015-16 M/S Bombay Dyeing & Dy. Commissioner Of Income- Manufacturing Co. Ltd Tax 2(1), Mumbai, Room Neville House, Jn Herdia No.561, 5Th Floor, Aayakar Vs Marg, Ballard Estate, Bhavan, M.K. Road, Mumbai- Mumbai-400 001 400 020 Pan No. Aaact 2328 K Appellant Respondent

1 to 249 and also a supplementary paper book containing pages 250 to 256. 7. We have heard rival submissions of the parties on the issue We have heard rival submissions of the parties on the issue We have heard rival submissions of the parties on the issues in dispute and perused the relevant materials on record. In ground

ABBOTT HEALTHCARE PRIVATE LIMITED ,MUMBAI vs. ASSISTANT COMMISSIONER OF INCOME TAX, CIRCLE 2(1)(1), MUMBAI

In the result, Ground No. 3 with its Sub-Grounds is allowed for statistical purposes

Bench: Shri Narender Kumar Choudhry & Shri Gagan Goyalabbott Healthcare Pvt. Ltd. 3, Corporate Park, Sion Trombay Road, Mumbai - 400 071 Pan: Aaack3935D ..... Appellant Vs. Acit 2(1) (1) R. No. 561, 5Th Floor, Aayakar Bhavan, Maharishi Karve Marg, Mumbai- 400 020 ..... Respondent & Acit 2(1) (1) R. No. 561, 5Th Floor, Aayakar Bhavan, Maharishi Karve Marg, Mumbai- 400 020 ...... Appellant Vs.

250 of the Income-tax Act, 1961 ('Act'), disposing of appeal against intimation under section 143(1) of the Act dated 9 March 2021. The following grounds of appeal are alternate and without prejudice to one another: 1. Ground No 1-Validity of the intimation issued under section 143(1) of the Act 1.1 on the facts

ICICI BANK LTD.,MUMBAI vs. THE DY CIT -2(3)(1), MUMBAI

In the result, appeal filed by the assessee is partly allowed

Bench: Shri Prashant Maharishi, Am & Shri Sandeep Singh Karhail, Jm Icici Bank Ltd. The Dy. Commissioner Of Icici Bank Towers, Income-Tax 2(3)(1) Bandra Kurla Complex, Aaykar Bhavan, Vs. 5Th Floor, Room No.552, Badra (East), Mumbai-400 051 M.K. Road, Mumbai-400 020 (Appellant) (Respondent) Pan No. Aaaci1195H

capital gain. viii. Excess allowances of deduction of ₹250,03,69,520/- under Section 36 (1) (vii) of the Act, where

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

250 of the Income-tax Act, 1961 [hereinafter referred to as “the Act”], all dated 25.08.2025, arising out of the assessment orders passed by the Assessing Officer. Since these appeals were heard together and are being disposed of by this consolidated order for the sake of convenience. Facts of the Case 2. The assessee is a resident company engaged

STATE BANK OF MYSORE,BANGALORE vs. JCIT, BANGALORE

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

250 of the Income Tax Act, 1961 (the Act) dated 27.02.2015 for Assessment Year (AY) 2011-12. The issues contended by the assessee and the revenue through various grounds are as under: Assessee's grounds Issues Ground Number Addition on account of recoveries made out of bad-debts written off but 1 not offered as income. Disallowance

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

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

250 of the Income Tax Act, 1961 (the Act) dated 27.02.2015 for Assessment Year (AY) 2011-12. The issues contended by the assessee and the revenue through various grounds are as under: Assessee's grounds Issues Ground Number Addition on account of recoveries made out of bad-debts written off but 1 not offered as income. Disallowance

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

capital\ngains, and the supporting records, and to delete the addition of\nRs. 13,46,813/- made under section 111A of the Act, if it is found\nthat the said income has already been offered to tax as long-term\ncapital gains. Therefore, this ground is allowed for statistical\npurposes.\nGround No. II - Short grant of TDS credit amounting

MATRIX PARTNERS INDIA INVESTMENT HOLDINGS, LLC,MAURITIUS vs. DEPUTY COMMISSIONER OF INCOME TAX, MUMBAI

In the result the appeal filed by the assessee stands partly allowed

Bench: Smt. Beena Pillai () & Ms. Padmavathy S ()

section 90(2), the Ld. A.O. has granted the beneficial option to the applicant at the preference of the Applicant itself. 11. Treaty Provisions are applicable in re/ qua "Income" and not "sources". In this case, there has been one single species of Income, "capital gains" that too, Long Term Capital Gains. 7. To sum up, as per facts

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

250", "Sec 143(1)", "Sec 143(2)", "Sec 142(1)", "Sec 143(3)", "Sec 144B", "Sec 80G", "Sec 36(1)(va)", "Sec 40(a)(ia)", "Sec 43B", "Sec 234B", "Sec 234C", "Sec 270A", "Sec 115P", "Sec 111A", "Sec 112A", "Sec 199", "Rule 37BA", "Sec 234D", "Sec 244A", "Sec 154" ], "issues": "The key issues involved are the allowability of provision

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

capital\ngains, and the supporting records, and to delete the addition of\nRs. 13,46,813/- made under section 111A of the Act, if it is found\nthat the said income has already been offered to tax as long-term\ncapital gains. Therefore, this ground is allowed for statistical\npurposes.\nGround No. II - Short grant of TDS credit amounting

FAROOQ ABDULLA MERCHANT,MUMBAI vs. ITO 23 (1)(4), MUMBAI

In the result, Ground No. V raised by the assessee is partly allowed

Bench: Shri S. Rifaur Rahman, Hon'Ble & Ms. Kavitha Rajagopal, Hon'Blefarooq Abdulla Merchant V. Income Tax Officer- Ward – 23(1)(4) Matru Mandir, Tardev Road A-1401, Poseidon Tower Mumbai – 400 007 Versova, Yari Road Above Indian Bank, Versova Andheri (W), Mumbai - 400061 Pan: Ahupm7426K (Appellant) (Respondent) Assessee Represented By : Shri Vimal Punamiya Department Represented By : Smt. Vranda U. Matkarni

250/- to make the new flat habitable which was purchased at a cost or ₹.1.10 Crores. In order to verify the bills submitted by the assessee, Assessing Officer deputed Inspector to serve a summon u/s. 131 of the Act dated 23.12.2016 to Mr. Laxman Mistry who was given bill of ₹.1,34,17,373, for furnishing his Books of Accounts

DY. COMMISSIONER OF INCOME TAX CIRCLE - 3(3)(1), MUMBAI, MUMBAI vs. SMALL INDUSTRIES DEVELOPMENT BANK OF INDIA, MUMBAI

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

250 of the Income Tax Act, 1961 (the Act) dated 26.06.2023 for (AY) 2014-15, dated 19.06.2023 for AY 2015-16 & 2016-17, dated 11.07.2023 for 2017-18 & 2018-19. The common issues contended by the assessee and revenue in all these appeals are listed as under: Revenue's Appeal – Issues contended (i) Learned Commissioner of come Tax (Appeals) erred

DY. COMMISSIONER OF INCOME TAX CIRCLE - 3(3)(1), MUMBAI, MUMBAI vs. SMALL INDUSTRIES DEVELOPMENT BANK OF INDIA, MUMBAI

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

250 of the Income Tax Act, 1961 (the Act) dated 26.06.2023 for (AY) 2014-15, dated 19.06.2023 for AY 2015-16 & 2016-17, dated 11.07.2023 for 2017-18 & 2018-19. The common issues contended by the assessee and revenue in all these appeals are listed as under: Revenue's Appeal – Issues contended (i) Learned Commissioner of come Tax (Appeals) erred

SMALL INDUSTRIES DEVELOPMENT BANK OF INDIA,MUMBAI vs. DEPUTY COMMISSIONER OF INCOME TAX CIRCLE 3(3)(1),MUMBAI, MUMBAI

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

250 of the Income Tax Act, 1961 (the Act) dated 26.06.2023 for (AY) 2014-15, dated 19.06.2023 for AY 2015-16 & 2016-17, dated 11.07.2023 for 2017-18 & 2018-19. The common issues contended by the assessee and revenue in all these appeals are listed as under: Revenue's Appeal – Issues contended (i) Learned Commissioner of come Tax (Appeals) erred

DY. COMMISSIONER OF INCOME TAX CIRCLE - 3(3)(1), MUMBAI , MUMBAI vs. SMALL INDUSTRIES DEVELOPMENT BANK OF INDIA, MUMBAI

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

250 of the Income Tax Act, 1961 (the Act) dated 26.06.2023 for (AY) 2014-15, dated 19.06.2023 for AY 2015-16 & 2016-17, dated 11.07.2023 for 2017-18 & 2018-19. The common issues contended by the assessee and revenue in all these appeals are listed as under: Revenue's Appeal – Issues contended (i) Learned Commissioner of come Tax (Appeals) erred