VODAFONE WEST LIMITED,(FORMERLY KNOWN AS VODAFONE ESSAR GUJARAT LIMITED),AHMEDABAD vs. THE DY.CIT, CIRCLE-4(1)(2),, AHMEDABAD

In the result, the appeal by the Revenue is partly allowed for statistical\npurposes

gains\nderived by the undertaking from the eligible business, and the business of\nleasing out of assets is not one such business as referred to in section 80-\nIA(4) of the Act. The AO further held that the income relating to such sharing\nof infrastructure with other operators is not related to providing\ntelecommunication services by the assessee

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)

Section 92A of the Act. In such cases the Assessing Officer will decide whether an AOP is formed or not keeping in view the relevant provisions of the Act and judicial jurisprudence on this issue. 6. The above may be brought to the notice of all for necessary compliance" (Emphasis supplied) 18. Thus, in terms of the aforesaid CBDT Circular

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

2(1) /DCIT\n(CC)-3(4)\n(Appellant) Mumbai\n(Respondent)\nPAN/GIR No. AAACP2567L\n2 ITA No. 3068/Mum/2024 and others\nM/s. Patel Engineering Limited\nAssessee by Shri Madhur Agarwal & Shri\nMayur Kisnadwala\nRevenue by Shri Amol Kirtane\nDate of Hearing 23/10/2024\nDate of Pronouncement 31/12/2024\nदेश / ORDER\nPER AMIT SHUKLA (J.M):\nITA NOs. 3068/Mum/2024 & 3065/Mum/2024\nThe aforesaid appeals have

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

2(1)\n/DCIT\n(CC)-3(4)\nMumbai\n(Respondent)\nPAN/GIR No. AAACP2567L\n2\nITA No. 3068/Mum/2024 and others\nM/s. Patel Engineering Limited\nAssessee by\nShri Madhur Agarwal & Shri\nMayur Kisnadwala\nRevenue by\nShri Amol Kirtane\nDate of Hearing\n23/10/2024\nDate of Pronouncement\n31/12/2024\nदेश / ORDER\nPER AMIT SHUKLA (J.M):\nITA NOs. 3068/Mum/2024 & 3065/Mum/2024\nThe aforesaid appeals have been filed

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

2(1)\n/DCIT\n(Appellant)\n(Respondent)\n(CC)-3(4)\nMumbai\nPAN/GIR No. AAACP2567L\n2\nITA No. 3068/Mum/2024 and others\nM/s. Patel Engineering Limited\nAssessee by\nShri Madhur Agarwal & Shri\nMayur Kisnadwala\nRevenue by\nShri Amol Kirtane\nDate of Hearing\n23/10/2024\nDate of Pronouncement\n31/12/2024\nदेश / ORDER\nPER AMIT SHUKLA (J.M):\nITA NOs. 3068/Mum/2024 & 3065/Mum/2024\nThe aforesaid appeals have

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

2(1)\n/DCIT\n(CC)-3(4)\nMumbai\n(Respondent)\nPAN/GIR No. AAACP2567L\n2\nITA No. 3068/Mum/2024 and others\nM/s. Patel Engineering Limited\nAssessee by\nShri Madhur Agarwal & Shri\nMayur Kisnadwala\nRevenue by\nShri Amol Kirtane\nDate of Hearing\n23/10/2024\nDate of Pronouncement\n31/12/2024\nदेश / ORDER\nPER AMIT SHUKLA (J.M):\nITA NOs. 3068/Mum/2024 & 3065/Mum/2024\nThe aforesaid appeals have been filed

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

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

2(1) /DCIT\n(CC)-3(4)\nMumbai\n(Respondent)\nPAN/GIR No. AAACP2567L\n2\nITA No. 3068/Mum/2024 and others\nM/s. Patel Engineering Limited\nAssessee by\nShri Madhur Agarwal & Shri\nMayur Kisnadwala\nRevenue by\nShri Amol Kirtane\nDate of Hearing\n23/10/2024\nDate of Pronouncement\n31/12/2024\nदेश / ORDER\nPER AMIT SHUKLA (J.M):\nITA NOs. 3068/Mum/2024 & 3065/Mum/2024\nThe aforesaid appeals have been filed

DY. COMMISSIONER OF INCOME TAX 5(2)(1), MUMBAI, MUMBAI vs. JSW STEEL COATED PRODUCTS LIMITED, MUMBAI

In the result, appeal of the

Bench: Shri Pawan Singh & Shri Girish Agrawal

gains derived by an undertaking that is engaged in the eligible activity of power generation. b. The SDT for which ALP is required to be determined is the 'supply of power by the eligible power generation unit". c. The method chosen to determine the ALP as well as the choice of tested party should be such as to arrive

DCIT-5(2)(1),MUMBAI, AAYAKAR BHAVAN vs. JSW STEEL COATED PRODUCTS LIMITED, MUMBAI

In the result, C.O. filed by assessee is\ndismissed as infructuous

gains derived by an\nundertaking that is engaged in the eligible activity of power generation.\nb. The SDT for which ALP is required to be determined is the 'supply of power by\nthe eligible power generation unit\".\nc. The method chosen to determine the ALP as well as the choice of tested party\nshould be such as to arrive

TATA CHEMICALS LTD,MUMBAI vs. ADDL CIAT 2(3), MUMBAI

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

Bench: Shri Vikas Awasthy, Hon'Ble & Shri S. Rifaur Rahman, Hon'Ble

section 92A(2) is concerned, SPVs are covered by more than one clause as the entire voting power (clause a) and entire share capital (clause b) of the SPV is held by the owner of that SPV, but loan advanced, if the remittance is to be treated as a loan to the SPV, by the owner

KANSAI NEROLAC PAINTS LIMITED (ERSTWHILE KNOWN AS GOODLASS NEROLAC PAINTS LIMITED),MUMBAI vs. ADDL CIT, RANGE 6 (2), MUMBAI

Accordingly we see no infirmity in the decision of CIT(A) and uphold the decision of the CIT(A). This ground of the revenue is dismissed

Bench: Shri Amit Shukla () & Ms. Padmavathy S. ()

gains of business or profession” or “Income from other sources”, shall be computed in accordance with either cash or mercantile system of accounting regularly employed by the assessee. Further, the Hon’ble Supreme Court, in the case of Rama Bai v. CIT (181 ITR 400) has held that arrears of interest computed on delayed or enhanced compensation shall be taxable

KANSAI NEROLAC PAINTS LTD,MUMBAI vs. DCIT RG 6(2), MUMBAI

Accordingly we see no infirmity in the decision of CIT(A) and uphold the decision of the CIT(A). This ground of the revenue is dismissed

Bench: Shri Amit Shukla () & Ms. Padmavathy S. ()

gains of business or profession” or “Income from other sources”, shall be computed in accordance with either cash or mercantile system of accounting regularly employed by the assessee. Further, the Hon’ble Supreme Court, in the case of Rama Bai v. CIT (181 ITR 400) has held that arrears of interest computed on delayed or enhanced compensation shall be taxable

M/S. KANSAI NEROLAC PAINTS LTD.,MUMBAI vs. DCIT RG. - 6(3), MUMBAI

Accordingly we see no infirmity in the decision of CIT(A) and uphold the decision of the CIT(A). This ground of the revenue is dismissed

Bench: Shri Amit Shukla () & Ms. Padmavathy S. ()

gains of business or profession” or “Income from other sources”, shall be computed in accordance with either cash or mercantile system of accounting regularly employed by the assessee. Further, the Hon’ble Supreme Court, in the case of Rama Bai v. CIT (181 ITR 400) has held that arrears of interest computed on delayed or enhanced compensation shall be taxable

DCIT RG. - 6(3), MUMBAI vs. M/S. KANSAI NEROLAC PAINTS LTD., MUMBAI

Accordingly we see no infirmity in the decision of CIT(A) and uphold the decision of the CIT(A). This ground of the revenue is dismissed

Bench: Shri Amit Shukla () & Ms. Padmavathy S. ()

gains of business or profession” or “Income from other sources”, shall be computed in accordance with either cash or mercantile system of accounting regularly employed by the assessee. Further, the Hon’ble Supreme Court, in the case of Rama Bai v. CIT (181 ITR 400) has held that arrears of interest computed on delayed or enhanced compensation shall be taxable

KANSAI NEROLAC PAINTS LIMITED (ERSTWHILE KNOWN AS GOODLASS NEROLAC PAINTS LIMITED),MUMBAI vs. ADDL. CIT, RANGE 6 (2), MUMBAI

Accordingly we see no infirmity in the decision of CIT(A) and uphold the decision of the CIT(A). This ground of the revenue is dismissed

Bench: Shri Amit Shukla () & Ms. Padmavathy S. ()

gains of business or profession” or “Income from other sources”, shall be computed in accordance with either cash or mercantile system of accounting regularly employed by the assessee. Further, the Hon’ble Supreme Court, in the case of Rama Bai v. CIT (181 ITR 400) has held that arrears of interest computed on delayed or enhanced compensation shall be taxable

TATA CHEMICALS LTD,MUMBAI vs. ACIT 2(3), MUMBAI

Appeal is hereby dismissed as infructuous

section 92A(2) is concerned, SPVs are covered by more than one clause as the entire voting power (clause a) and entire share capital (clause b) of the SPV is held by the owner of that SPV, but loan advanced, if the remittance is to be treated as a loan to the SPV, by the owner

TATA CHEMICALS LTD,MUMBAI vs. DCIT 2(3), MUMBAI

Appeal is hereby dismissed as infructuous

section 92A(2) is concerned, SPVs are covered by more than one clause as the entire voting power (clause a) and entire share capital (clause b) of the SPV is held by the owner of that SPV, but loan advanced, if the remittance is to be treated as a loan to the SPV, by the owner

TATA CHEMICALS LTD,MUMBAI vs. ACIT 2(3), MUMBAI

Appeal is hereby dismissed as infructuous

section 92A(2) is concerned, SPVs are covered by more than one clause as the entire voting power (clause a) and entire share capital (clause b) of the SPV is held by the owner of that SPV, but loan advanced, if the remittance is to be treated as a loan to the SPV, by the owner