MARSH MCLENNAN GLOBAL SERVICES INDIA PRIVATE LIMITED,MUMBAI vs. ASSESSMENT UNIT, INCOME TAX DEPT. NATIONL E- ASSESSMENT CENTRE , DELHI

Appeal is allowed

144C(13) and 144B of the Act on 27.07.2022 after making disallowance of INR 28,72,578/- being entire amount of deduction claimed by the Appellant under Section 80G of the Act. 5. Being aggrieved, the Appellant has filed the present appeal. The Ld. Authorised Representative for the Appellant appearing before us submitted that the Assessing Officer has disregarded

TATA SONS PRIVATE LTD.,MUMBAI vs. PR.CIT-2, MUMBAI

In the result, the appeal of the assessee is allowed

Bench: Shri Rajesh Kumar & Shri Ram Lal Negiassessment Year: 2014-15 M/S. Tata Sons Pvt. Ltd., Pr. Cit 2, 24, Bombay House, Room No.552, Homi Mody Street, Vs. 5Th Floor, Fort, Mumbai – 400 001 Aayakar Bhavan, Pan: Aaact4060A M.K. Road, Mumbai - 400020 (Appellant) (Respondent) Present For: Assessee By : Shri Percy Pardiwala, A.R. Ms. Arati Vissanji, A.R. Revenue By : Shri R. Manjunatha Swamy, D.R. Date Of Hearing : 28.01.2020 Date Of Pronouncement : 20.04.2020 O R D E R

charitable purpose of the satsang was the aspect which was sought to be confined to the facts of the case. The general principle laid down by the Hon’ble Supreme Court on the applicability of the principle of consistency is not something which was in any manner caveated. The Ld. Counsel argued that this is apparent from the statement

DEUTSCHE INDIA PVT. LTD.(EARLIER KNOWN AS 'DBOI GLOBAL SERVICES PVT. LTD.),MUMBAI vs. ACIT-1(3)(1), MUMBAI

In the result, the appeal by the assessee is partly allowed for 16

Bench: Shri Amarjit Singh & Shri Sandeep Singh Karhail

144C(1) of the Act, disagreed with the submissions of the assessee and held that under section 80G the “sums paid” need to be “donation” for the purpose of being eligible for deduction under the said section. It was further held that the amount paid by the assessee should be voluntary to become eligible for deduction under section

ACIT, MUMBAI vs. RELIANCE INDUSTRIES LIMITED, MUMBAI

In the result, the appeal of the Revenue is dismissed whereas the cross-objection of the assessee is allowed

Bench: Shri Om Prakash Kant () & Ms. Kavitha Rajagopal () Assessment Year: 2014-15 Acit, Reliance Industries Ltd., Room No. 559, 5Th Floor, 3Rd Floor Maker Chamber Iv, Aayakar Bhavan, New Marine Vs. Nariman Point, S.O. Lines, Mumbai-400021. Mumbai-400020. Pan No. Aaacr 5055 K Appellant Respondent

144C(3) of the Act on 02.02.2018, wherein certain additions and disallowances were made both under the normal provisions and in the computation of book profit under section 115JB. On appeal, ld first appellate authority granted partial relief to the assessee. 3.2 Subsequently, the assessment records were audited by the office of the Comptroller and Auditor General of India

HERE SOLUTIONS INDIA PRIVATE LIMITED,MUMBAI vs. THE DEPUTY COMMISSIONER OF INCOME TAX (CIRCLE 4(2)(1), MUMBAI), MUMBAI

In the result, appeal of the assessee is allowed

Bench: Smt. Beena Pillai & Shri Girish Agrawalassessment Year: 2022-23

144C(5) of the Income-tax Act, 1961 (hereinafter referred to as the “Act”), for Assessment Year 2022-23. 2. Grounds taken by assessee are reproduced as under: 1. On the facts and circumstances of the case and in law, the learned assessing officer ('Ld. AO')/ Dispute Resolution Panel ('DRP') erred in disallowing the deduction amounting

JSW STEEL LIMITED,MUMBAI vs. ACIT,CC-46, MUMBAI

Appeal of the revenue is partly allowed and appeal of the assessee is dismissed

144C(3) r.w. 153A r.w.s 143(3) of the Income-tax Act, 1961 (hereinafter referred to as 'the Act') on 30.05.2014 is barred by limitation under the provisions of the Act, and the same is void ab initio.” 2. “On facts and circumstances of the case and in law, the Hon'ble CIT(A) has erred in not appreciating that

DCIT CC 8(3)(ERSTWHILE DCIT,CC-46, MUMBAI vs. JSW STEELS LTD, MUMBAI

Appeal of the revenue is partly allowed and appeal of the assessee is dismissed

144C(3) r.w. 153A r.w.s 143(3) of the Income-tax Act, 1961 (hereinafter referred to as 'the Act') on 30.05.2014 is barred by limitation under the provisions of the Act, and the same is void ab initio.” 2. “On facts and circumstances of the case and in law, the Hon'ble CIT(A) has erred in not appreciating that

DCIT CC 8(3), MUMBAI vs. JSW STEELS LTD, MUMBAI

Appeal of the revenue is partly allowed and appeal of the assessee is dismissed

144C(3) r.w. 153A r.w.s 143(3) of the Income-tax Act, 1961 (hereinafter referred to as 'the Act') on 30.05.2014 is barred by limitation under the provisions of the Act, and the same is void ab initio.” 2. “On facts and circumstances of the case and in law, the Hon'ble CIT(A) has erred in not appreciating that

DCIT CC 8(3), MUMBAI vs. JSW STEELS LTD, MUMBAI

Appeal of the revenue is partly allowed and appeal of the assessee is dismissed

144C(3) r.w. 153A r.w.s 143(3) of the Income-tax Act, 1961 (hereinafter referred to as 'the Act') on 30.05.2014 is barred by limitation under the provisions of the Act, and the same is void ab initio.” 2. “On facts and circumstances of the case and in law, the Hon'ble CIT(A) has erred in not appreciating that

JSW STEELS LTD,MUMBAI vs. DCIT CC 8(3), MUMBAI

Appeal of the revenue is partly allowed and appeal of the assessee is dismissed

144C(3) r.w. 153A r.w.s 143(3) of the Income-tax Act, 1961 (hereinafter referred to as 'the Act') on 30.05.2014 is barred by limitation under the provisions of the Act, and the same is void ab initio.” 2. “On facts and circumstances of the case and in law, the Hon'ble CIT(A) has erred in not appreciating that

DCIT CC 8(3)(ERSTWHILE DCIT,CC-46, MUMBAI vs. JSW STEELS LTD, MUMBAI

Appeal of the revenue is partly allowed and appeal of the assessee is dismissed

144C(3) r.w. 153A r.w.s 143(3) of the Income-tax Act, 1961 (hereinafter referred to as 'the Act') on 30.05.2014 is barred by limitation under the provisions of the Act, and the same is void ab initio.” 2. “On facts and circumstances of the case and in law, the Hon'ble CIT(A) has erred in not appreciating that

JSW STEELS LTD,MUMBAI vs. DCIT CC 8(3), MUMBAI

Appeal of the revenue is partly allowed and appeal of the assessee is dismissed

144C(3) r.w. 153A r.w.s 143(3) of the Income-tax Act, 1961 (hereinafter referred to as 'the Act') on 30.05.2014 is barred by limitation under the provisions of the Act, and the same is void ab initio.” 2. “On facts and circumstances of the case and in law, the Hon'ble CIT(A) has erred in not appreciating that

JSW STEELS LTD,MUMBAI vs. DCIT CC 8(3), MUMBAI

Appeal of the revenue is partly allowed and appeal of the assessee is dismissed

144C(3) r.w. 153A r.w.s 143(3) of the Income-tax Act, 1961 (hereinafter referred to as 'the Act') on 30.05.2014 is barred by limitation under the provisions of the Act, and the same is void ab initio.” 2. “On facts and circumstances of the case and in law, the Hon'ble CIT(A) has erred in not appreciating that

COLGATE-PALMOLIVE (INDIA) LIMITED ,MUMBAI vs. PRINCIPLE COMMISSIONER OF INCOME TAX -6, MUMBAI

In the result, appeal of the assessee is allowed

charitable institutions, etc for INR 1 5,042,600/- and under section 80JJAA of the Act for employment of new employees for INR 7,667,132/-. In relation to section 80JJAA we have claimed INR 4,711,690 as deduction carry forward for AY 2016-17 (second year), INR 2,356,117 as deduction carry forward

TATA SONS LTD,MUMBAI vs. ASST CIT CIR 2(3), MUMBAI

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

Bench: Shri Mahavir Singh, Vp & Shri M.Balaganesh, Am Acit-2(3)(1), Vs. M/S. Tata Sons Ltd., Room No.552, 5Th Floor 24, Bombay House Aayakar Bhavan Homi Mody Street M.K.Road, Fort, Mumbai – 400 001 Mumbai – 400 020 Pan/Gir No.Aaact4060A (Appellant) .. (Respondent) M/S. Tata Sons Ltd., Vs. Commissioner Of Income Tax-58 24, Bombay House 344, Aayakar Bhavan Homi Mody Street M.K.Road, Fort, Mumbai – 400 001 Mumbai – 400 020 Pan/Gir No.Aaact4060A (Appellant) .. (Respondent)

144C(3) of the Income Tax Act, 1961 (hereinafter referred to as Act) dated 09/05/2013 by the ld. Asst. Commissioner of Income Tax 2(3), Mumbai (hereinafter referred to as ld. AO). 2. The first issue raised by the assessee to be decided in this regard is with regard to transfer pricing adjustment made in respect of Corporate guarantee

MANUGRAPH INDIA LTD,MUMBAI vs. ASST CIT 3(2)(1), MUMBAI

In the result, this appeal by the assessee is allowed as above

Bench: Shri Shamim Yahya, Am & Shri Ravish Sood, Jm M/S. Manugraph India Limited Asst. Cit-3(2)(1) Room No. 608, 6Th Floor, Sidhwa House, N. A. Sawant Marg, Vs. Colaba, Mumbai-400 005 Aayakar Bhavan, M K Road, Churchgate, Mumbai-400 020 Pan/Gir No. Aaacm 7246 H (Appellant) : (Respondent) Appellant By : Shri Rajan Vora & Shri Pranay Gandhi : Shri V. Jenardhan Respondent By Date Of Hearing : 06.11.2018 : 04.02.2019 Date Of Pronouncement O R D E R Per Shamim Yahya, A. M.:

144C(13) r.w.s. 92CA(3) of the Income Tax Act, 1961 (‘the Act' for short) dated 27.12.2016 pursuant to the direction of the Dispute Resolution Panel-3, Mumbai (‘DRP' for short) dated 23.09.2016 and pertains to the assessment year (A.Y.) 2012-13. 2. The grounds of appeal read as under: PART I —TRANSFER PRICING GROUNDS: 1. Adjustment of Rs.96

MCKINSEY & COMPANY INTERNATIONAL INC.,MUMBAI vs. DCIT (IT) 3(2)(1), MUMBAI

Bench: Sh. Shamim Yahya, Am & Sh. Sandeep Gosain, Jm आयकरअपीलसं./ I.T.A. No. 859/Mum/2015 (निर्धारणवर्ा / Assessment Year: 2011-12)

144C(13) of the I.T. Act for AY 2011- 12 on the grounds mentioned herein below:- 1. The learned AO/ Hon'ble Dispute Resolution Panel ('DRP') has erred in concluding that borrowed services rendered by the Appellant are in the nature of 'fees for included services' under Article 12 of the India-US Double Taxation Avoidance Agreement ('India

JSW STEEL LTD,MUMBAI vs. PR CIT CEN 4, MUMBAI

In the result, appeals of the assessee are allowed

Bench: Shri C.N. Prasad, Hon'Ble & Shri Manoj Kumar Aggarwal, Hon'Ble

144C has been assessed at a loss of Rs 179,40,16,135/-. As there being no positive gross total income for the relevant assessment year, no deduction under chapter VIA has been allowed at all by the Ld AO. As there is no allowance of any deduction u/s 80IA in the relevant assessment year for Rail System, Water

JSW STEEL LTD,MUMBAI vs. PR CIT CEN 4, MUMBAI

In the result, appeals of the assessee are allowed

Bench: Shri C.N. Prasad, Hon'Ble & Shri Manoj Kumar Aggarwal, Hon'Ble

144C has been assessed at a loss of Rs 179,40,16,135/-. As there being no positive gross total income for the relevant assessment year, no deduction under chapter VIA has been allowed at all by the Ld AO. As there is no allowance of any deduction u/s 80IA in the relevant assessment year for Rail System, Water