SIR RATAN TATA TRUST,MUMBAI SUBURBAN vs. ADDITIONAL /JOINT/DEPUTY/ASSISTANT COMMISSIONER OF INCOME TAX, NFAC, MUMBAI

In the result, both the appeals of the assessee in both AY 2014-15 and AY

Bench: Ms Padmavathy S, Am & Shri Rahul Chaudhary, Jm

9 pages- and copies of these details were also furnished before us at pages 216- 223 of the paper book filed before us. All these details were also furnished in the yearend financial statements, which were duly filed with the Assessing Officer. The Assessing Officer categorically notes this and observes that “the assessee has to follow the accumulation provisions

CREDIT GUARANTEE FUND TRUST FOR MICRO AND SMALL ENTERPRISES,MUMBAI vs. DCIT (E) , MUMBAI

Bench: Shri Kuldip Singh & Shri S Rifaur Rahmanassessment Year: 2018-19

charitable organization and accordingly. provisions of section 145 of the Act mandating following of cash or mercantile system of accounting is not applicable in the appellant's case, which is wrong and contrary to the facts of the case, the provisions of the Income Tax Act, 1961, and Rules made thereunder. (iv) CIT(A) erred in observing that: a) there

CREDIT GUARANTEE FUND TRUST FOR MICRO AND SMALL ENTERPRISES ,MUMBAI vs. DEPUTY COMMISSIONER OF INCOME TAX EXEMPTION -1(1), MUMBAI

In the result, the appeal of the assessee is allowed

Bench: Shri Vikram Singh Yadav & Shri Rahul Chaudharyassessment Year : 2018-19 Credit Guarantee Fund Trust Deputy Commissioner Of For Micro & Small Enterprises, Income Tax, Exemption-1(1), 1St Floor, Vs. Mtnl Tel. Exch. Building, Sidbi Swavalamban Bhavan, Cumballa Hills, Pedder Road, Avenue 3, Lane 2, G-Block, Mumbai-400026. Bandra Kurla Complex, Bandra (East), Mumbai-400051. Pan : Aaatc2613D (Appellant) (Respondent) For Assessee : Shri Shailesh Shah & Shri Jay Dharod For Revenue : Shri R.A. Dhyani, Cit-Dr Date Of Hearing : 04-09-2025 Date Of Pronouncement : 15-09-2025 O R D E R Per Vikram Singh Yadav, A.M : This Is An Appeal Filed By The Assessee Against The Order Of The Learned Commissioner Of Income Tax (Appeals)-National Faceless Appeal Centre (Nfac), Delhi [„Ld.Cit(A)‟], Pertaining To Assessment Year (Ay) 2018-19, Wherein The Assessee Has Taken The Following Grounds Of Appeal: “(1) On The Facts & Circumstances Of The Case & In Law, The Learned Commissioner Of Income Tax (Appeals) [Ld. Cit(A)], Nfac Has Erred In Confirming The Order Of Levying Penalty U/S 270A Of The Act Of Rs. 293,63,60,258/- On 2 Disallowances Made In The Assessment Order Passed U/S 143(3) R.W.S 144B Of The Act Without Appreciating The Fact That The Hon'Ble Itat, Mumbai Has Fully Deleted The Said Disallowances & Reasons Assigned By Him For Doing So Are Wrong & Contrary To The Facts & Circumstances Of The Case, Provisions Of The Act & Income Tax Rules, 1962 ("The Rules") Made Thereunder. The Appellant Prays That The Penalty U/S 270A Of The Act Of Rs. 293,63,60,258/- Be Deleted. The Appellant Craves Leave To Add, Amend, Alter, Modify And/Or Delete All Or Any Of The Above Grounds Of Appeal, On Or Before The Date Of Hearing.”

charitable activities, hence not entitled for benefit of section 11 & 12 of the Act”, are not sustainable, hence set aside. Ground No. 2 is determined in favour of the assessee. Ground No.3 21. During the year under consideration the assessee trust has claimed provision for guarantee claims to the tune of Rs.13,14,84,00,000/-. During the year under

NARROTAM MORARJEE INSTITUTE OF SHIPPING,MUMBAI vs. ITO (EXEMPTION)WARD 2(1), MUMBAI

In the result, appeal of the assessee is allowed

Bench: Shri Amit Shukla & Shri Girish Agrawalassessment Year: 2018-19 Narrotam Morarjee Institute Of National Faceless Shipping, Mumbai Assessment Appeal Centre 76 – Jolly Maker, Chambers – 2, (Nfac) Office Of The Vs. Vivek Shah, Mumbai, Nariman Commissioner Of Income Point S.O.-400021 Tax, Appeal, Addl/Jcit(A) Delhi (Pan : Aaatn0042R) (Appellant) (Respondent) Present For: Assessee : Shri Nishit Gandhi, Advocate Revenue : Shri Leyaqat Ali Afaqui, Sr. Dr Date Of Hearing : 18.11.2025 Date Of Pronouncement : 16.02.2026 O R D E R Per Girish Agrawal: This Appeal Filed By The Assessee Is Against The Order Of Commissioner Of Income Tax (Appeal), National Faceless Appeal Centre (Nfac), Delhi Vide Order No. Itba/Nfac/S/250/2025- 26/1078465227(1) Dated 14.07.2025 Passed Against The Penalty Order U/S. 270A Of The Income-Tax Act, 1961 (Hereinafter Referred To As The “Act”), For Ay 2018-19. 2. Grounds Taken By The Assessee Are Reproduced As Under: 1. In The Facts & Circumstances Of The Case & In Law, The Learned Commissioner Of Income Tax (Appeals), National Faceless Appeals Centre, Delhi ["The Cit (A)") U/S 250 Of The Income Tax Act, 1961 ["The Act For Short Erred In Confirming The Penalty U/S 270A Of The Act Passed

charitable trust registered u/s 12A of the Act, assessee had a bona fide belief that the addition of non-utilized set apart fund is similar to the other normal income and deduction u/s 11(1)(a) is allowable. For this bona fide belief, it relied on the decision of Hon’ble High Court of Calcutta in the case

INTERNATIONAL SPECIALTY PRODUCTS (INDIA) PRIVATE LIMITED,MUMBAI vs. THE DEPUTY COMMISSIONER OF INCOME TAX, CIRCLE 15(1)(2), MUMBAI, MUMBAI

In the result, appeal of the assessee is allowed

Bench: Shri Pawan Singh & Smt. Renu Jauhri

section 80G - Held, yes” 7. Respectfully following the above decision of the co-ordinate bench, we hold that the assessee is eligible to claim deduction u/s. 80G of the Act in respect of CSR expenditure made by way of the following donations: Particulars Date of Payment Amount (in INR) Rotary Club of Bombay 19 March 2020 16,05,488 Juhu

WNS GLOBAL SERVICES PRIVATE LIMITED,MUMBAI vs. ASESSMENT UNIT, NATIONAL FACELESS ASSESSMENT CENTRE, NEW DELHI, NEW DELHI

In the result, the appeal of the assessee bearing ITA No

Bench: Shri Anikesh Banerjee & Shri Prabhash Shankarwns Global Services Private Vs Assessment Unit, National Faceless Limited, Mumbai Assessment Centre, New Delhi Pl-10/11, Gate No.4, Godrej- Boyce Complex, Pirojshanagar, L.B.S.Marg, Vikhroli (West), Mumbai-400 079 Pan: Aaacw2598L Appellant Respondent

270A of the Act. The Appellant craves leave to add, alter, omit or substitute at any time before or at the time of the appeal, to enable accordance with law.” 2. The assessee, a company domiciled and incorporated in India, is engaged in providing a range of Business Process Management Services (BPMS), including back-office administration, data management, and contact

M/S. SONATA INFORMATION,MUMBAI vs. CIT CIRCLE 3(4), MUMBAI

Accordingly, disallowance of INR made by the Assessing Officer is deleted and Ground No.1 & 2 raised by the Assessee are allowed

Bench: SHRI PRASHANT MAHARISHI, ACCOUNTANT MEMBER SHRI RAHUL CHAUDHARY (Judicial Member)

270A of the Income Tax Act, 1961 for under reporting the income in its ITR for the year under consideration is initiated separately. (Addition: Rs. 67,15.972/-)” 4. Being aggrieved, the Assessee carried the issue in appeal before the CIT(A). However, the CIT(A) agreed with the Assessing Officer and declined to grant any relief to the Assessee

MAJLIS E KHUDDAMUL MADARI S,MUMBAI vs. ITO EXEM. WARD 2(1), MUMBAI

In the result, the appeal filed by the assessee is allowed for statistical purposes

Bench: Shri Vikram Singh Yadav & Shri Raj Kumar Chauhanassessment Year : 2017-18 Majlis E Khuddamul Madari S, Ito(Exem), Ward-2(1), 14, Uasim Mansion, Room No. 512, 5Th Floor, Koleueheri Village, Vs. Piramal Chambers, Chinchpada, Lal Baug, Parel, Kalina, Mumbai-400012. Mumbai-400098. Pan : Aaaam0694F (Appellant) (Respondent) For Assessee : None For Revenue : Shri Surendra Mohan, Sr.Dr Date Of Hearing : 16-10-2025 Date Of Pronouncement : 27-10-2025 O R D E R Per Vikram Singh Yadav, A.M : This Is An Appeal Filed By The Assessee Against The Order Of The Learned Commissioner Of Income Tax (Appeals)-National Faceless Appeal Centre (Nfac), Delhi [„Ld.Cit(A)‟], Dated 25-06-2025, Pertaining To Assessment Year (Ay) 2017-18, Wherein The Assessee Has Taken The Following Grounds Of Appeal:

Section 68 of the Income-tax Act, 1961, provides that where any sum is found credited in the books of the assessee for any previous year it may be charged to income-tax as the income of the assessee of the previous year if the explanation offered by the assessee about the nature and source of such sums found credited