KPMG ASSURANCE AND CONSULTING SERVICES LLP,MUMBAI vs. ASSISTANT COMMISSIONER OF INCOME TAX-CIRCLE-16(2), MUMBAI

Accordingly, Ground No. 5 & 6 raised by the Revenue are dismissed

Bench: IN THE INCOME TAX APPELLATE TRIBUNAL "I" BENCH, MUMBAI SHRI PRASHANT MAHARISHI, ACCOUNTANT MEMBER SHRI RAHUL CHAUDHARY (Judicial Member)

Permanent Establishment (PE) or fixed base in India, respectively, the same was not liable to tax in India. The Assessee was, therefore, not under obligation to deduct tax from the same and no disallowance under Section 40(a)(i) of the Act was warranted. The CIT(A) also allowed Assessee’s claim for deduction for ITA No.2272-2276/Mum/2023 & CO No.123-128/Mum/2023

KPMG ASSURANCE AND CONSULTING SERVICES LLP,MUMBAI vs. ASSISTANT COMMISSIONER OF INCOME TAX -16(2), MUMBAI

Permanent Establishment (PE) or fixed base in India, respectively, the same was not liable to tax in India. The Assessee was, therefore, not under obligation to deduct tax from the same and no disallowance under Section 40(a)(i) of the Act was warranted. The CIT(A) also allowed Assessee’s claim for deduction for remittance made to KPMG International

KPMG ASSURANCE AND CONSULTING SERVICES LLP,MUMBAI vs. ASSISTANT COMMISSIONER OF INCOME TAX-CIRCLE-16(2), MUMBAI

Accordingly, Ground No. 5 & 6 raised by the Revenue are dismissed

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

Permanent Establishment (PE) or fixed base in India, respectively, the same was not liable to tax in India. The Assessee was, therefore, not under obligation to deduct tax from the same and no disallowance under Section 40(a)(i) of the Act was warranted. The CIT(A) also allowed Assessee’s claim for deduction for ITA No.2272-2276/Mum/2023 & CO No.123-128/Mum/2023

DCIT, CIR 16(2), MUMBAI vs. M/S KPMG ASSURANCE AND CONSULTING SERVICES LLP, MUMBAI

Permanent Establishment (PE) or fixed base in India, respectively, the same was not liable to tax in India. The Assessee was, therefore, not under obligation to deduct tax from the same and no disallowance under Section 40(a)(i) of the Act was warranted. The CIT(A) also allowed Assessee’s claim for deduction for remittance made to KPMG International

DCIT, CIR 16(2), MUMBAI vs. M/S KPMG ASSURANCE AND CONSULTING SERVICES LLP, MUMBAI

Accordingly, Ground No. 5 & 6 raised by the Revenue are dismissed

Bench: IN THE INCOME TAX APPELLATE TRIBUNAL "I" BENCH, MUMBAI SHRI PRASHANT MAHARISHI, ACCOUNTANT MEMBER SHRI RAHUL CHAUDHARY (Judicial Member)

Permanent Establishment (PE) or fixed base in India, respectively, the same was not liable to tax in India. The Assessee was, therefore, not under obligation to deduct tax from the same and no disallowance under Section 40(a)(i) of the Act was warranted. The CIT(A) also allowed Assessee’s claim for deduction for ITA No.2272-2276/Mum/2023 & CO No.123-128/Mum/2023

DCIT, CIR 16(2), MUMBAI vs. M/S KPMG ASSURANCE AND CONSULTING SERVICES LLP, MUMBAI

Permanent Establishment (PE) or fixed base in India, respectively, the same was not liable to tax in India. The Assessee was, therefore, not under obligation to deduct tax from the same and no disallowance under Section 40(a)(i) of the Act was warranted. The CIT(A) also allowed Assessee’s claim for deduction for remittance made to KPMG International

KPMG ASSURANCE AND CONSULTING SERVICES LLP,MUMBAI vs. ASSISTANT COMMISSIONER OF INCOME TAX-CIRCLE-16(2), MUMBAI

Permanent Establishment of\nthe said parties in India, the same was not liable to tax in\nIndia under Article 7 of the corresponding DTAA. [Refer to\nNote 2 at 65 of impugned order passed by the CIT(A)]\n13. Now, both, the Revenue and the Assessee are before us in\nappeal/cross-objection.\n1.4. We note that there is a delay

KPMG ASSURANCE AND CONSULTING SERVICES LLP,MUMBAI vs. ASSISTANT COMMISSIONER OF INCOME TAX -16(2), MUMBAI

Permanent Establishment of\nthe said parties in India, the same was not liable to tax in\nIndia under Article 7 of the corresponding DTAA. [Refer to\nNote 2 at 65 of impugned order passed by the CIT(A)]\n1.3. Now, both, the Revenue and the Assessee are before us in\nappeal/cross-objection.\n1.4. We note that there is a delay

DCIT, CIR 16(2), MUMBAI vs. M/S KPMG ASSURANCE AND CONSULTING SERVICES LLP, MUMBAI

Permanent Establishment of\nthe said parties in India, the same was not liable to tax in\nIndia under Article 7 of the corresponding DTAA. [Refer to\nNote 2 at 65 of impugned order passed by the CIT(A)]\n13. Now, both, the Revenue and the Assessee are before us in\nappeal/cross-objection.\n1.4. We note that there is a delay

DCIT, CIR 16(2), MUMBAI vs. M/S KPMG ASSURANCE AND CONSULTING SERVICES LLP, MUMBAI

Permanent Establishment of\nthe said parties in India, the same was not liable to tax in\nIndia under Article 7 of the corresponding DTAA. [Refer to\nNote 2 at 65 of impugned order passed by the CIT(A)]\n13. Now, both, the Revenue and the Assessee are before us in\nappeal/cross-objection.\n1.4. We note that there is a delay

MSEB HOLDING COMPANY LIMITED,MUMBAI vs. PRINCIPAL COMMISSIONER OF INCOME TAX 1, MUMBAI

In the result, the appeal of the assessee

Bench: Shri Aby T Varkey () & Shri Om Prakash Kant () Assessment Year: 2012-13

Permanent Account Number (PAN] AENPS1459J residing at 29 Account Number (PAN] AENPS1459J residing at 29-Amber, St Floor, Amber, St Floor, Narayan Dabholkar Marg, Malabar Hill, Mumbai Narayan Dabholkar Marg, Malabar Hill, Mumbai- Narayan Dabholkar Marg, Malabar Hill, Mumbai-400006 and working with 'MSEB Holding Company Limited' ['MSEBHCL] having working with 'MSEB Holding Company Limited' ['MSEBHCL] having working with 'MSEB

MSEB HOLDING COMPANY LTD.,MUMBAI vs. ACIT (HQ) (JUDL) TO THE CIT 14, MUMBAI

In the result, the appeal of the assessee

Bench: Shri Aby T Varkey () & Shri Om Prakash Kant () Assessment Year: 2012-13

Permanent Account Number (PAN] AENPS1459J residing at 29 Account Number (PAN] AENPS1459J residing at 29-Amber, St Floor, Amber, St Floor, Narayan Dabholkar Marg, Malabar Hill, Mumbai Narayan Dabholkar Marg, Malabar Hill, Mumbai- Narayan Dabholkar Marg, Malabar Hill, Mumbai-400006 and working with 'MSEB Holding Company Limited' ['MSEBHCL] having working with 'MSEB Holding Company Limited' ['MSEBHCL] having working with 'MSEB

SUNDER NAGAR SATSANG SABHA ,MUMBAI vs. CIT(EXEMPTION), MUMBAI

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

establish that the applicant trust had genuine hardship in\nfiling of the application within the due date. In absence of a reasonable\ncause of delay the request of the applicant for condonation of delay is not\nacceptable.\n5. Since registration under section 12AB is to be granted in terms of the\nprovisions of section 12AB

KPMG ASSURANCE AND CONSULTING SERVICES LLP,MUMBAI vs. ASSISTANT COMMISSIONER OF INCOME TAX-CIRCLE-16(2), MUMBAI

Accordingly,\nGround No. 5 & 6 raised by the Revenue are dismissed

Permanent Establishment (PE) or fixed base in\nIndia, respectively, the same was not liable to tax in India. The\nAssessee was, therefore, not under obligation to deduct tax from\nthe same and no disallowance under Section 40(a)(i) of the Act\nwas warranted.\nThe CIT(A) also allowed Assessee’s claim for deduction for\nremittance made to KPMG International

MISC BERHAD,MUMBAI vs. DDIT (IT) RG 3(2)(2), MUMBAI

In the result, appeal of the assessee is partly allowed

Bench: Shri C.N. Prasad, Hon'Ble & Shri G. Manjunatha, Hon'Ble

permanent establishment' ('PE') of the appellant in India under Article 5 of the Tax Treaty. 3(a) On the facts and in the circumstances of the case and in law, the learned CIT(A) erred in confirming the action of the learned ADIT in holding Crescent as a Fixed Place PE under Article 5(1) of the Tax Treaty

AMRUT PUBLIC CHARITABLE TRUST,MUMBAI vs. ITO, EXEMPTION WARD 1(1), MUMBAI

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

Bench: Shri Amit Shukla & Shri Makarand Vasant Mahadeokaramrut Public Charitable Ito Exemption Trust Ward 1(1), Block 4, Plot No. 578A, Vs. Cumballa Hill, Jitendra Bldg, Pedder Road, Jamejamshed Road, Mumbai-400 026 Matunga, Mumbai- 400 019 Pan/Gir No.Aaata4810A (Applicant) (Respondent) Assessee By Shri P. P. Jayaraman, Ld. Ar Revenue By Shri Rajesh Kumar Yadav, Ld. Dr Date Of Hearing 13.01.2026 Date Of Pronouncement 19.01.2026

establishes that the charitable character, objects and activities of the assessee stood accepted by the Department, and the rejection under section 80G(5) was solely on a procedural ground. 9. The learned AR further submitted that a detailed application for condonation of delay dated 14.01.2026 has been filed before the Bench, wherein the assessee has explained the reasons constituting “reasonable

THE DDIT (IT)-2(1), MUMBAI vs. M/S. TAJ TV LTD, MUMBAI

Bench: Shri G S Pannu & Shri Amit Shukla

Permanent Establishment In India” 28. At the outset, it is noticed that, appeal of the assessee are barred by limitation by several days. In support of its condonation of delay

BLUE SPOT EQUPMENT COMPANY PVT. LTD,MUMBAI vs. TDS CPC, MUMBAI

Bench: Shri Baskaran Br & Shri Kuldip Singh

condonation of delay ITA Nos.163/M/2022 & ors. 7 M/s. Blue Spot Equipment Company Pvt. Ltd. that the assessee has not received any intimation of such outstanding dues and only upon initiation of recovery proceedings, assessee came to know about the outstanding demand. 9. Further, on merits, we find that the issue whether clause (c) of section 200A(1), as substituted