UMMEED FOUNDATION,AL SHAKREEN APT vs. COMMISSIONER OF INCOME TAX (EXEMPTION), PUNE, PMT BUILDING COMMERCIAL COMPLEX

In the result, the grounds of the assessee are allowed for In the result, the grounds of the assessee are allowed for In the result, the grounds of the assessee are allowed for statistical purposes

Bench: Shri Om Prakash Kant () & Ms. Kavitha Rajagopal () Assessment Year: 2023-24 Ummeed Foundation, Cit(E), Pune, Room No. 204, A1 Shakreen Apt, 322, 3Rd Floor, Income Tax Vs. Waf Acomplex Chs, H-104, Office, Pmt Building Sharifa Road, Amrut Nagar, City Commercial Complex, Shankar Convent High School, Thane, Sheth Road, Swargate, Kausa B.O., Maharashtra-400612. Pune-411037. Pan No. Aaatu 4914 H Appellant Respondent

10A and Form No.10AB, under section 119 of the Act, vide above A and Form No.10AB, under section 119 of the Act, vide above A and Form No.10AB, under section 119 of the Act, vide above referred Circulars. As per above referred CBDT Circular No.8/2022, the referred Circulars. As per above referred CBDT Circular No.8/2022, the referred Circulars

SITEL INDIA LTD,MUMBAI vs. DCIT RG 8(3), MUMBAI

In the result, appeal by the Revenue is partly allowed

Bench: Shri Pramod Kumar & Shri Sandeep Singh Karhail

condone the delay in filing the appeal by the assessee and we proceed to decide this appeal on merits. 4. In its appeal, assessee has raised following grounds: “1. The CIT (A) erred in not appreciating that there was no intention of shifting profits outside India by the Appellant and has further failed in not giving any finding/ reasoning

DY.CIT-8(3), MUMBAI vs. SITEL INDIA LTD.,, MUMBAI

In the result, appeal by the Revenue is partly allowed

Bench: Shri Pramod Kumar & Shri Sandeep Singh Karhail

condone the delay in filing the appeal by the assessee and we proceed to decide this appeal on merits. 4. In its appeal, assessee has raised following grounds: “1. The CIT (A) erred in not appreciating that there was no intention of shifting profits outside India by the Appellant and has further failed in not giving any finding/ reasoning

ADVAYA CHARITABLE FOUNDATION (NOW BTG ADVAYA CHARITABLE FOUNDATION),MUMBAI vs. CIT(EXEMPTIONS), MUMBAI , MUMBAI

In the result, both the appeals are allowed for statistical purposes

Bench: Shri Sandeep Gosain & Shri Prabhash Shankar

10A in correct section code and grant registration for balance period as per Section 12AB(1) ie till AY. 2027-2028 7. Per Contra, the learned DR supported the order of the CIT(Exemptions) and submitted that the time limit prescribed under the law is mandatory in nature, and the CIT(E) has no discretion to condone the delay

SHREE DADAR JAIN PAUSHADHSHALA TRUST,MUMBAI vs. ITO (E_ - 1(2), MUMBAI

In the result, the appeal of the assessee in ITA no

Bench: Shri Pawan Singh & Shri Ramit Kocharआयकर अपीऱ सं./I.T.A. No.2061/Mum/2019 (नििाारण वर्ा / Assessment Year: 2014-15) बिाम/ Shree Dadar Jain Ito(E)-1(2) Paushadhshala Trust, Room No. 501, 5 Th Floor, Aaradhana Bhavan, Piramal Chambers, V. 289, S K Bole Road, Lalbaug, Parel, Dadar West, Mumbai-400012 Mumbai-400028 स्थायी ऱेखा सं./ Pan: Aaats7848E (अपीऱाथी /Appellant) .. (प्रत्यथी / Respondent) Assessee By: Shri. Bhadresh Doshi Revenue By: Shri. Abhi Rama Karthikeyn S. सुनवाई की तारीख /Date Of Hearing : 03.06.2019 घोषणा की तारीख /Date Of Pronouncement : 19.08.2019 आदेश / O R D E R Per Ramit Kochar: This Appeal, Filed By Assessee, Being Ita No. 2061/Mum/2019, Is Directed Against Appellate Order Dated 08/02/2019, Passed By Learned Commissioner Of Income Tax (Appeals)-3, Mumbai (Hereinafter Called ―The Cit(A)‖) In Appeal Number Cit(A)-3/It-10394/2017-18, For Assessment Year 2014-15, The Appellate Proceedings Had Arisen Before Learned Cit(A) From Assessment Order Dated 28.12.2006 Passed By Learned Assessing Officer (Hereinafter Called ―The Ao‖) U/S 143(3) Of The Income-Tax Act, 1961 (Hereinafter Called ―The Act‖) For Ay:2014-15. 2. The Grounds Of Appeal Raised By Assessee In Memo Of Appeal Filed With The Income-Tax Appellate Tribunal, Mumbai (Hereinafter Called ―The Tribunal‖) Read As Under:-

10A [, section 10AA], clause (b) of sub-section (1) of section 12A, section 44AB [, section 44DA, section 50B], section 80-1 A, section 80-1B, section 80-IC, section 80-ID, section 80JJAA, section 80LA, section 92E, [section 115JB, [section 115JC] or section 115VW] or to give a notice under clause (a) of sub-section (2) of section

HYDRO PNEUMATIC ACCESSORIES INDIA P.LTD,MUMBAI vs. ITO 10(3)1, MUMBAI

In the result, the appeal is allowed

Bench: Shri C.N. Prasad () & Shri N.K. Pradhan () Assessment Year: 2008-09 Hydro Pneumatic Ito-10(3)(1), Mumbai. Accessories India Pvt. Ltd. Vs. 17, Raja Industrial Estate, P.K. Road, Nahur Village, Mulund (W), Mumbai- 400080. Pan No. Aaach1351A Respondent Appellant Assessee By : Mr. Dharan V. Gandhi, Ar Revenue By : Mr. Abiram Kartikeyan, Dr Date Of Hearing : 31/07/2018 Date Of Pronouncement: 26/10/2018

condone the delay of 569 days in filing this appeal before the Tribunal. 6. The grounds of appeal filed by the assessee read as under: 1. Part disallowance of Deduction u/s 10B-Rs.16,10,585/- a The Ld. CIT(A) erred in confirming the disallowance u/s 10B overlooking and not appreciating the fact that the item of claim received

CARTRADE FOUNDATION ,MUMBAI vs. CIT (EXEMPTION) , MUMBAI

In the result, both the appeals filed by the assessee are allowed for\nstatistical purposes

condone the delay in filing the\napplication if there is reasonable cause for not filing the application within\nthe prescribed time. From the perusal of section 10A

CARTRADE FOUNDATION,MUMBAI vs. CIT (EXEMPTION) , MUMBAI

In the result, both the appeals filed by the assessee are allowed for statistical purposes

Bench: Shri Vikram Singh Yadavshri Sandeep Singh Karhail

condone the delay in filing the application if there is reasonable cause for not filing the application within the prescribed time. From the perusal of section 10A

DY. COMMISSIONER OF INCOME TAX, MUMBAI vs. M/S INFRASOFT TECHNOLOGIES LTD., MUMBAI

In the result, appeal of the Revenue is dismissed

Bench: Shri Amit Shukla & Shri Girish Agrawalassessment Year: 2006-07

section 10A by holding that the new unit was set up by the assessee on 28.03.2000. 2 Infrasoft Technologies Ltd., AY 2006-07 3. At the outset, it is noted that there is a delay of 72 days noted by Registry in filing the present appeal before the Tribunal. In this respect, Revenue has placed on record an application seeking

NITCON SOCIAL FOUNDATION,MUMBAI vs. COMMISSIONER OF INCOME TAX(EXEMPTION),MUMBAI, MUMBAI

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

condone the delay and admit the appeal for\nadjudication.\n7. On merit, Ld. AR argued that vide circular No. 7/2024 dated 25th April\n2024, the CBDT has extended the due date for filing of Form 10AB of\nIncome Tax Act and the same is reproduced below:-\nSub: Extension of due date for filing of Form No. 10A/10AB under the\nIncome

DATTA PRASAD SAHAKARI PATSANSTHA LTD,MUMBAI vs. INCOME TAX OFFICER -26(3)(2), MUMBAI , MUMBAI

In the result, appeal is partly allowed

Bench: Shri Saktijit Dey () & Shri Rajesh Kumar ()

10A or Section 10AA or Section 10B or Section 10BA or under any provision of the said Chapter - VI A under the heading "C.-Deduction in respect of certain incomes", no deduction would be allowed to him under the said provision. In plain terms, this Sub Section (5) of Section 80A of the Act imposes an additional condition for claim

SHRI PARSHWA TILAK SHWETAMBER MURTIPUJAK JAIN ,MUMBAI vs. CIT(EXEMPTION), MUMBAI

Bench: SHRI VIKRAM SINGH YADAV, ACCOUNTANT MEMBER SHRI RAHUL CHAUDHARY (Judicial Member)

condoning the late filing of application in form 10AB by mentioning it is well settled in principle that ignorance of law cannot be pleaded as defective or valid excuse. 4. CIT[E] has erred not into taking in to consideration late application is inadvertent and unintentional without any mala- fide intention and the trust is actively engaged in genuine charitable

PRADEEP SARDA FOUNDATION,MUMBAI vs. CIT (EXEMPTIONS), MUMBAI, MUMBAI

In the result, both the appeals filed by the assessee are allowed for\nstatistical purposes

10A(8) of the Act are mandatory in nature. However, from a plain\nreading of the provisions of section 12A(1)(ac) of the Act, it is evident that\nthe statute authorises the learned CIT(E) to condone the delay

DCIT CC 3(4) CEN RG 3, MUMBAI vs. PATEL ENGINEERING LTD, MUMBAI

In the result, appeal filed by the assessee is dismissed

Bench: Shri Aby T. Varkey, Hon'Ble & Shri S. Rifaur Rahman, Hon’Ble

delay. Both the appeals either cross objection or cross appeal for the respective assessment years have been delayed filed. The reasons given for late filing of appeal does not show sufficient cause on behalf of the Managing Director of the assessee company. The reason provided for the delayed filing does contain in action or negligence on the part

DCIT CC 3(4) CEN RG 3, MUMBAI vs. PATEL ENGINEERING LTD, MUMBAI

In the result, appeal filed by the assessee is dismissed

Bench: Shri Aby T. Varkey, Hon'Ble & Shri S. Rifaur Rahman, Hon’Ble

delay. Both the appeals either cross objection or cross appeal for the respective assessment years have been delayed filed. The reasons given for late filing of appeal does not show sufficient cause on behalf of the Managing Director of the assessee company. The reason provided for the delayed filing does contain in action or negligence on the part

RALLIS INDIA LTD,MUMBAI vs. CIT -3, MUMBAI

The appeal of the Revenue is dismissed,

Bench: Shri Joginder Singh & Shri G. Manjunathaassessment Year: 2008-09 M/S Rallis India Ltd. Cit -3, Mumbai बनाम/ 156/157, Nariman Bhawan, Vs. 15Th Floor, 227, Nariman Point, Mumbai – 400 021. ("नधा"रती /Assessee) (राज"व /Revenue) P.A. No. Aabcr 2657 N & Assessment Year: 2008-09 Dcit -3(3)(1), Mumbai M/S Rallis India Ltd. बनाम/ Room No.609, 6Th Floor, 156/157, Nariman Bhawan, Vs. Aayakar Bhavan, M. K. Road, 15Th Floor, 227, Nariman Mumbai – 400 020. Point, Mumbai – 400 021. (राज"व /Revenue) ("नधा"रती /Assessee) P.A. No. Aabcr 2657 N

section 5 M/s Rallis India Ltd. ITA NO.3680/Mumbai/2016 CO NO.185/Mumbai/2016 145A and stated that as per the principle of stock valuation upheld by the apex court, the method of valuation regularly adopted by the appellant is a recognized method and therefore, the same cannot be rejected. The items written down to the net realizable value are items of raw materials

INVENTURUS KNOWLEDGE SOLUTIONS PVT LTD,MUMBAI vs. PCIT , MUMBAI 6

Bench: Shri Vikas Awasthy & Shri S.Rifaur Rahman आअसं.246/मुं/2022 ("न.व. 2016-17) Inventurus Knowledge Solutions Pvt. Ltd. 801, Mindspace Business Park Pvt. Ltd., Building No.5 & 6, Thane Belapur Road, Airoli East, Navi Mumbai – 400 708. Pan: Aabci-5573-J ...... अपीलाथ" /Appellant बनाम Vs. Pcit,Mumbai -6 Circle 15(1)(2) Aaykar Bhavan, M.K.Road, Mumbai 400 020. ..... ""तवाद"/Respondent अपीलाथ" "वारा/ Appellant By : Shri S.C.Tiwari, Advocate ""तवाद" "वारा/Respondent By : Shri Jayant Jhaveri सुनवाई क" "त"थ/ Date Of Hearing : 09/03/2022 घोषणा क" "त"थ/ Date Of Pronouncement : 03/06/2022 आदेश/ Order Per Vikas Awasthy, Jm:

condonation of delay in filing of the appeal. The delay in filing of appeal has been attributed to the unprecedented situation caused by COVID-19 Pandemic. The Hon'ble Apex Court taking suo- motu cognisance of the hardship caused by COVID-19 Pandemic to the litigants extended the period of limitation under General Law of Limitation and under Special Laws

ASST CIT 12(4), MUMBAI vs. TATA CONSULTANCY SERVICES LTD ( FORMLERY M.S, TCS BUSINESS TRANSFORMATION SOLUTION LTD), BANGALORE

In the result, the plea of assessee under rule 27 of the Tribunal

Bench: Sri Mahavir Singh, Jm & Sri Nk Pradhan, Am Asst. Commissioner Of Tata Consultancy Services Ltd. Income Tax, Large Tax (Formerly M/S Tcs Payer Unit, Business Transformation Centre-1 28Th Floor, World Vs. Solutions Ltd.) Trade Centre, Cuffe Parade, Sjm Towers, 18, Sheshadri Mumbai-400 005 Road, Gandhinagar, Bangalore-560 009 Pan No.Aacp8925G Appellant .. Respondent

delay cannot be condone, against the order of CIT(A), challenging the same on few comparables by invoking the Rule 27 of the Tribunal Rules, which we allow now. 6. Now we will take up the appeal of Revenue and the arguments raised by assessee under rule 27 of the Tribunal Rules. 7. Brief facts are that during the year

LIKEMINDED EDUCATION AND WELFARE SOCIETY ,MUMBAI vs. COMMISSIONER OF INCOME TAX (EXEMPTION) , MUMBAI

In the result, both appeals by the assessee are allowed\nfor statistical purposes

condone the delay.\n5.7\nIt is further stated that non-consideration of the explanations\nsubmitted by the appellant and issuing an adverse order without giving\nan opportunity of being heard is against the principle of Natural Justice\nand shall cause undue hardship to it. The delay in filing of application\nfor registration was on account of genuine medical reasons