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

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

TMF HOLDING LTD.,MUMBAI vs. PR. CIT -1, MUMBAI

Bench: Shri S. Rifaur Rahman, Hon'Ble & Shri Pavan Kumar Gadale, Hon'Bletmf Holdings Ltd., V. Pr.Cit – 1 {Formerly Known As Tata Motors Finance Ltd.,} 3Rd Floor, Room No. 330 10Th Floor, 106 A & B Aayakar Bhavan, M.K. Road Maker Chamber-Iii Mumbai - 400020 Nariman Point, Mumbai Pan: Aacct4644A (Appellant) (Respondent) Shri Nikhil Tiwari Assessee By : Department By : Shri S.N. Kabra

gain earned by the Assessee is in the nature of the capital receipt and the same should be excluded while computing the book profit under section 11 5JB of the Act. 56. Reliance is placed on following decisions wherein it has been held that where a particular receipt is not in the nature of 'income', it cannot also be considered

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

ACIT, CIRCLE 3(1)(2), MUMBAI vs. M/S EUROFINANCE TRAININF & PUBLISHING PVT. LTD., MUMBAI

In the result, appeal by the Revenue is dismissed

Bench: Shri Amarjit Singh & Shri Sandeep Singh Karhail

250 of the Income Tax Act, 1961 (“the Act”) by learned Commissioner of Income Tax (Appeals)– 8, Mumbai, [“learned CIT(A)”], for the assessment year 2013–14. 2. The present appeal has been listed for hearing before us pursuant to the order dated 27/05/2022, passed by the Co–ordinate Bench of the Tribunal in ITO v/s Eurofinance Training & Publishing

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

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

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

ITO 25(2)(5), MUMBAI vs. KIRIT RAOJIBHAI PATEL, MUMBAI

In the result appeal of the learned AO is dismissed

Bench: Sri Prashant Maharishi, Am & Sri Pavan Kumar Gadale, Jm The Income Tax Officer- Kirit Raojibhai Patel 25(2)(5) 5Th Floor Ram Niwas, 34, Room No. 506, C-10, Vallabhnagar, N.S. Road, Vs. Pratyakshakar Bhavan, Bkc, Juhu, Vile Parele(W), Mumbai-400 051 Mumbai-400 049 (Appellant) (Respondent) Pan No. Aabpp3139J Assessee Represented By : Shri Rashmikant Choksey, Ar Department Represented By : Shri K.K. Mishra, Cit Dr Date Of Hearing: 08.12.2021 Date Of Pronouncement : 14.02.2022

1 Sale consideration 6,63,03,000 2 Cost of acquisition of the plot 12,99,450 fair market value as on 1/4/1980 one is ₹ 250,003 and 76/– which is indexed for the relevant assessment year 2,50,367*519/100 3 Cost of improvement Nil Kirit Raojibhai Patel; AY 07-08 4 deduction u/s 54 EC with respect

NETESOFT INDIA LIMITED ,MUMBAI vs. DEPUTY COMMISSIONER OF INCOME TAX -10(3)(1), MUMBAI

The appeal is dismissed for non-prosecution

Bench: Shri Saktijit Dey, Jm & Shri Manoj Kumar Aggarwal, Am आयकरअपील सं./ I.T.A. No.5359/Mum/2017 (िनधा"रण वष" / Assessment Year:2013-14) Netesoft India Limited Dcit-Central Circle-10(3)(1) 602, Maker Bhavan-Iii बनाम/ Room No.212, Aaykar Bhavan New Marin Lines Vs. Mumbai-400 020. Mumbai-400 020. "थायीलेखासं./जीआइआरसं./Pan/Gir No. Aaacn-9543-J (अपीलाथ"/Appellant) : (""थ" / Respondent) अपीलाथ"कीओरसे/ Appellant By : Shri Yogesh Thar-Ld. Ar ""थ"कीओरसे/Respondent By : Ms. Samatha Mullamudi-Ld.Sr.Dr सुनवाईकीतारीख/ : 30/09/2019 Date Of Hearing घोषणाकीतारीख / : 20/12/2019 Date Of Pronouncement आदेश / O R D E R Manoj Kumar Aggarwal (): - 1. Aforesaid Appeal By Assessee For Assessment Year [Ay] 2013-14 Contest The Order Of Ld. Commissioner Of Income-Tax (Appeals)-17, Mumbai, [In Short Referred To As ‘Cit(A)’], Appeal No. Cit(A)-17/It-480/15- 16 Dated 02/05/2017 On Following Sole Ground Of Appeal: -

1-10-2004 then the loss from exempt source would be set off against taxable gain, such set off is contrary to law. (iv)In Mridu Hari Dalmia Parivar Trust v. AO [2016] 68 taxmann.com 376 (Delhi-Trib.), it has been held that - "10. A perusal of sub-section (38) reveals that any income arising from the transfer of long

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

RAVI KANT HUF,MUMBAI vs. ITO WD 23(4), MUMBAI

The appeal of the assessee is dismissed

Bench: Shri Joginder Singh & Shri N.K. Pradhanassessment Year: 2008-09 Shri Ravi Kant Huf, Income Tax Officer, Mohanlal Jain &Co., Ward-23(4), बनाम/ Chartered Accountant, Mumbai Vs. 10, Chartered House, Gr. Floor, Dr.C.H. Street, Marine Lines, Mumbai-400002 ("नधा"रती/Assessee) (राज"व /Revenue) P.A. No. Aabhr0354M

capital gain amount was deposited by the assessee before the due date of furnishing the return u/s 139(1) of the Act, therefore, the assessee is not eligible for the benefit of section 54(2) of the Act and thus, the action taken in the 4 Ravi Kant HUF assessment order was affirmed. The assessee is aggrieved

RANI JAGDISH SAHDEVAN,MUMBAI vs. ITO 25 (3)(3), MUMBAI

In the result, appeal by the assessee is dismissed in terms of our aforesaid findings

Bench: Shri Sandeep Singh Karhail & Shri Gagan Goyal

section 250 of the Income Tax Act, 1961 ("the Act") for the assessment year 2013–14. 2. In this appeal, the assessee has raised following grounds:– ―1. The Learned Assessing Officer and CIT(A) erred in assessing the income of Rs.41,59,952 instead of returned income of Rs.17,41,067. 2. The Learned Assessing Office and CIT(A) erred

BRILLPHARMA PVT. LTD.,MUMBAI vs. ACIT, CPC,BANGALORE, BANGALORE

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

Bench: Shri Pramod Kumar & Shri Sandeep Singh Karhail

250 of the Income Tax Act, 1961 ("the Act") by the learned Commissioner of Income Tax (Appeals), National Faceless Appeal Centre [“learned CIT(A)”], for the assessment year 2019–20. 2. The appeal filed before us is delayed by 47 days. We find that the Hon'ble Supreme Court vide order dated 10.01.2022, in M.A. no.21 of Brillpharma