DCIT (IT) 4(1)(1), MUMBAI, MUMBAI vs. ROBECO QI INSTITUTIONAL EMERGING MARKETS ENHANCED INDEX EQUITIES FUND, MUMBAI

In the result, both the appeals of the Revenue are dismissed

Bench: Shri Om Prakash Kant () & Shri Sunil Kumar Singh () Assessment Year: 2016-17 Dcit (It)-4(1)(1), Robeco Institutioneel Emerging Markets 625, Kautilya Bhavan, G-Block, Fonds, Vs. Bandra Kurla Complex, C/O Ernst & Young Llp, 14Th Floor, Mumbai-400051. The Ruby, 29 Senapati Bapat Marg, Dadar (West), Mumbai-400028. Pan No. Aacts 7682 L Appellant Respondent Assessment Year: 2021-22 Dcit (It)-4(1)(1), Robeco Q1 Institutional Emerging 625, Kautilya Bhavan, G-Block, Markets Enhanced Index Equities Fund, Vs. Bandra Kurla Complex, 14Th Floor, The Rc/O Ernst & Young Mumbai-400051. Llp, 29 Senapati Bapat Marg, Dadar (West), Mumbai-400028. Pan No. Aabtr 2305 L Appellant Respondent

section 74 of the Act as per which any brought forward long term brought forward long term & short term losses have to be set off & short term losses have to be set off Robeco Institutioneel Emerging Robeco Institutioneel Emerging 3 Markets Fonds & Robeco Q1 Markets Fonds & Institutional Emerging Markets Institutional Emerging Markets Enhanced Index Equities Fund Enhanced Index Equities Fund

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

482/- 8,45,13,02,470/- 7,49,13,26,247/- income 6. In A.Y. 2017–18, the Assessing Officer disallowed employees’ contribution to provident fund amounting to Rs. 82,10,149/- under section 36(1)(va), disallowed deduction claimed under section 80G in respect of CSR related payments amounting to Rs. 92,31,072/-, disallowed interest on delayed payment

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

482/-\nRs.\n8,45,13,02,470/-\nRs.\n7,49,13,26,247/-\n6. In A.Y. 2017–18, the Assessing Officer disallowed employees' contribution to provident fund amounting to Rs. 82,10,149/- under section 36(1)(va), disallowed deduction claimed under section 80G in respect of CSR related payments amounting to Rs. 92,31,072/-, disallowed interest on delayed

BRAJ KISHORE SINGH,ANDHERI EAST vs. ASSESSING OFFICER INT. TAX WARD 4(2)(1), INTERNATIONAL TAX, MUMBAI

In the result, the appeal is accordingly partly allowed for statistical

Bench: Ms. Padmavathy S & Shri Raj Kumar Chauhanbraj Kishore Singh Vs. Assessing Officer 604, Lantana, Nahar Amrit Internatinal Tax Ward Shakti, Chandivali, 4(2)91) Maharashtra -400 072. Room No. 632, Kautilya Bhavan, Pan: Bqips8474H C-41 To C-43, G Block, Bandra Kurla Complex, Bandra (East), Mumbai-400051

capital gain as 17,04,264 discussed at para 4 3. Income from other sources 29,602 as per statement Gross total income 17,22,088 Less : Deduction under chapter 29,602 Braj Kishore Singh VIA as per statement Total income 16,92,486 Rounded off to 16,92,490 5. The draft assessment order framed u/s 144C

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

capital gains but directed verification and grant of correct\nTDS credit and treated the interest grounds as consequential.\n5. The year-wise factual matrix emerging from the assessment\norders and the appellate orders of the CIT(A) is summarised in\nthe table below:\nΑ.Υ. 2017-18\nΑ.Υ. 2018-19\nΑ.Υ. 2022-23\nΑ.Υ. 2023-24\nParticulars

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

capital gains but directed verification and grant of correct\nTDS credit and treated the interest grounds as consequential.\n5. The year-wise factual matrix emerging from the assessment\norders and the appellate orders of the CIT(A) is summarised in\nthe table below:\nΑ.Υ. 2017-18\nΑ.Υ. 2018-19\nΑ.Υ. 2022-23\nΑ.Υ. 2023-24\nParticulars

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

482/- was allowed instead of depreciation claimed by the assessee of ₹7,74,20,633/-. iv. Disallowance of club membership expenditure of ₹64,19,440/- holding that such expenditure is capital expenditure, as it is paid for entrance fee. v. Disallowance of Non performing advances provision u/s 43D of Rs 47,05,01481/- vi. Disallowance of provision of expenditure

VINOD K.SHAH,MUMBAI vs. ITO 16(1)(1), MUMBAI

In the result, the assessee’s appeal for A

Bench: Shri Jason P. Boaz & Shri Sandeep Gosain

capital gain and charge tax 10% but denying exemption u/s 54F without assigning any reason. 10. appellant facts are different than what modus appending mention by A.O. 11. notice u/s 148 is not valid it was served before information received at the time of service no information in possession of A.O. 12. confession of broker and gold star is general

VINOD K SHAH,MUMBAI vs. ITO 16(1)(1), MUMBAI

In the result, the assessee’s appeal for A

Bench: Shri Jason P. Boaz & Shri Sandeep Gosain

capital gain and charge tax 10% but denying exemption u/s 54F without assigning any reason. 10. appellant facts are different than what modus appending mention by A.O. 11. notice u/s 148 is not valid it was served before information received at the time of service no information in possession of A.O. 12. confession of broker and gold star is general

GENERAL INSURANCE CORPORATION OF INDIA,MUMBAI vs. ASST CIT 3(1)(2), MUMBAI

In the result, the appeal of the assessee is allowed

482/-. We find that the assessee had claimed exemption u/s 10 as under in the return of income :- Income from LTCG on transfer of shares Exempt u/s 10(38) Rs 588,85,02,720/- Income from VCF as tax is paid by Fund Rs 22,52,211/- Interest on Tax Free Bonds

DCIT 5(3)(1), MUMBAI vs. DEEPAK SHASHI BHUSHAN ROY, MUMBAI

In the result these grounds of appeal raised

Bench: Shri Shamim Yahaha & Shri Pawan Singhdcit 5(3)(1), Deepak Shashi Bhusan Roy, Flat Room No.573, Aayakar Bhavan, No.11, Rambha Chs Ltd, M.K.Road, Nepean Sea Road, Vs. Mumbai 400020 Mumbai-400006 Pan:Aaapr 7703 F

section 54/54F. Thus, the legislature was conscious of the fact while making use of this expression. The expression like ‘owned’ has not been used for the purpose of determining the nature of asset as short-term capital asset or long-term capital asset. The intention of legislature is clear that for the purpose of determining the nature of capital gain

REPRO INDIA LIMITED,MUMBAI vs. ASSISTANT COMMISSIONER OF INCOME TAX, MUMBAI

The appeal is allowed for statistical purposes

Bench: Shri Saktijit Dey & Shri Makarand Vasant Mahadeokarrepro India Limited Acit Circle 11Th Floor, B Wing, Sun 8(1)(1), Paradise Business Plaza, Vs. Aayakar Bhavan, Senapati Bapat Marg, Mumbai-400 020 Lower Parel, Mumbai – 400 013 Pan/Gir No. Aaacr0379J (Applicant) (Respondent) Assessee By Shri Vijay Mehta, Ld. Ar Revenue By Shri Umashankar Prasad, Ld. Dr Date Of Hearing 04.02.2026 Date Of Pronouncement 09.02.2026

section 144B of the Act, determining total loss at Rs. 40,37,373/- as against loss of Rs. 42,94,99,721/- declared by the assessee. 12. Aggrieved by the assessment order the assessee filed an appeal before the CIT(A). Before the CIT(A), the assessee challenged, the adoption of sale consideration

TATA MOTORS LTD,MUMBAI vs. DCIT LTU 2, MUMBAI

Bench: Shri C. N. Prasad, Jm & Shri S. Rifaur Rahman, Am आयकरअपीलसं./ I.T.A. No. 3424/Mum/2019 (निर्धारणवर्ा / Assessment Year: 2013-14)

section (2A) above, Income under any head, say Income from House Property, Income from Capital Gains and Income from Other Sources, such income are. entitled for being set-off against the loss under the head "Profits and Gains of Business or Profession " 4.6. During the year, the Company in its return of income accordingly, set-off the loss

NIKHIL RASHIKLAL VORA ,MUMBAI vs. INCOME TAX OFFICER WARD 34(2)(2), MUMBAI

In the result, the appeal of the assessee is allowed for In the result, the appeal of the assessee is allowed for In the result, the appeal of the assessee is allowed for statistical purposes

Bench: Shri Om Prakash Kant () & Shri Rahul Chaudhary () Assessment Year: 2012-13 Nikhil Rashiklal Vora, Ito Ward 34(2)(2), Flat No. 6, Amit Parnar Ist Kautilya Bhavan, Bandra Kurla Vs. Floor, 205-A, Dixit Road, Vile Complex, Bandra (E), Parle (E), Mumbai-400051. Mumbai-400057. Pan No. Aaopv 0747 R Appellant Respondent

482/- whose maximum allowable deduction is Rs.15,000 / whose maximum allowable deduction is Rs.15,000 / whose maximum allowable deduction is Rs.15,000 /-. It is found that the Appellant has claimed it in the Ret found that the Appellant has claimed it in the Ret found that the Appellant has claimed it in the Return of Income. In the absence

ADITYA BIRLA NUVO LTD (SINCE AMALGAMATED WITH GRASIM INDUSTRIES LIMITED),MUMBAI vs. PRINCIPAL COMMISSIONER OF INCOME TAX CENTRAL 1, MUMBAI

In the result, the appeal of the assessee is allowed

Bench: Us, We Find That The Effective Issue To Be Decided In This Appeal Is As To Whether The Ld Pcit Was Justified In Invoking Revision Jurisdiction U/S 263 Of The Act In The Facts & Circumstances Of The Case.

gain tax. 4.8. Accordingly, your goodself would observe that the provision of Section 47(iv) covers transfer to an Indian subsidiary company which is wholly (100% share capital) owned by the transferer company. In the instant case, the Assessee company does not own whole of the shares capital of ABNL IT & ITES. It only owns 95% share capital of ABNL

DCIT CIR 7(1), MUMBAI vs. PENINSULA LAND LTD, MUMBAI

Section 143(3) of the Act at total income of INR 51,24,75,320/- after making, inter alia, following addition/disallowances: (a) The Assessing Officer rejected the system of accounting followed by the Assessee and re-calculated the business income arising from the project „Ashok Towers‟ by following his own method as opposed to the percentage completion method followed which

ADDL.C.I.T. RG. 7(1), MUMBAI vs. PENINSULA LAND LTD., MUMBAI

Section 143(3) of the Act at total income of INR 51,24,75,320/- after making, inter alia, following addition/disallowances: (a) The Assessing Officer rejected the system of accounting followed by the Assessee and re-calculated the business income arising from the project „Ashok Towers‟ by following his own method as opposed to the percentage completion method followed which

SURAJKUMAR & SONS,MUMBAI vs. ITO 21 (3)(4), MUMBAI

In the result ground no. 2 raised by the assessee is partly allowed for statistical purpose

Bench: Shri O.P. Kant, Accountant, Member & Ms. Kavitha Rajagopalm/S Surajkumar & Sons 302,-C, Shivshakti Chs Ltd., Kashinath Dhuru Marg, Agar Bazar, Prabhadevi, Mumbai-400025. Pan: Aaqfs4464G ...... Appellant Vs. Ito – 21(3)(4), 206, Piramal Chambers, Parel, Lalbaug, Mumbai-400012 ..... Respondent

section 148 was not served to the assessee. On identical facts the Tribunal in the case referred by the ld. DR has held in Ambica Steels Ltd. (supra) that when the requirement of service of notice u/s 148 of the Act was duly complied with by the Ld. AO and when the assessee has no grievance on this the same