MR. SATYA PRAKASH SINGH,MUMBAI vs. ITO, WARD-28(3)(1), VASHI

In the result, the ground so taken by the assessee so far as it relates to challenging the order of the AO as passed beyond the period of limitation is hereby allowed

Bench: Justice (Retd.) Shri C.V. Bhadang & Shri Vikram Singh Yadav

delay is hereby condoned and appeal so filed by the Revenue is admitted for adjudication. 5. Briefly the facts of the case are that the assessee has originally filed his return of income on 28-09-2012, declaring total income of Rs. 5,12,500/-. The assessment proceedings were completed u/s. 143(3) of the Income

TOLANI SHIPPING CO. LTD.,MUMBAI vs. DCIT,CIR-5(3)(2), MUMBAI

In the result, this appeal by the assessee for A

delay had to be condoned. 12 Tolani Shipping Co. Ltd. (ii) That the normal rule of construction is that the intention of the Legislature is primarily to be gathered from the words used in the statute, A careful analysis of section 33AC shows that the deduction contemplated under section 33AC is related not to the asset possessed at the time

HDFC ERGO GENERAL INSURANCE COMPANY LIMITED,MUMBAI vs. THE ASSISTANT COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE 6(2), MUMBAI, MUMBAI

In the result, appeal filed by the assesse bearing ITA No

244A of the Act amounting to Rs. 1,83,48,328 on the refund referred to in ground no. (6) above due to the Appellant. 8. The CIT(A) erred in not directing the AO to allow the claim of Rs.76,27,772 (towards provision for gratuity and leave encashment) under section 43B of the Act (which was added back

DCIT, CC 6(2), MUMBAI, MUMBAI vs. HDFC ERGO GENERAL INSURANCE COMPANY LIMITED, MUMBAI

In the result, appeal filed by the assesse bearing ITA No

Bench: SHRI ANIKESH BANERJEE (Judicial Member), SHRI PRABHASH SHANKAR (Accountant Member)

244A of the Act amounting to Rs. 1,83,48,328 on the refund referred to in ground no. (6) above due to the Appellant. 8. The CIT(A) erred in not directing the AO to allow the claim of Rs.76,27,772 (towards provision for gratuity and leave encashment) under section 43B of the Act (which was added back

RAYMOND LTD,MUMBAI vs. ADDL CIT RG 2(3), MUMBAI

Accordingly, the same are dismissed as not pressed

Bench: Shri Aby T. Varkey, Hon'Ble & Shri S. Rifaur Rahman, Hon'Bleraymond Limited V. The Addl. Cit– 2(3) New Hind House Aayakar Bhavan, M.K. Road Narottam Morarjee Marg Mumbai - 400020 Ballard Estate, Mumbai - 400001 Pan: Aaacr4896A Appellant Respondent C.O. No. 287/Mum/2017 [Arising Out Of Ita No. 2218/Mum/2011 (A.Y. 2007-08)] The Addl. Cit– 2(3) V. Raymond Limited Aayakar Bhavan, M.K. Road New Hind House Mumbai - 400020 Narottam Morarjee Marg Ballard Estate, Mumbai - 400001 Pan: Aaacr4896A Appellant Respondent M/S. Raymond Limited V. The Dcit – Osd- 2(3) New Hind House, Aayakar Bhavan, M.K. Road Narottam Morarjee Marg Mumbai – 400020 Ballard Estate, Mumbai - 400001 Pan: Aaacr4896A Appellant Respondent

condoned, as there is no reasonable cause for the delay. We find that on this issue, the assessee has made the following submissions: In the assesse' s own appeal for A.Y. 1995-96 the CIT (A) has held to determine the annual value of the property @ 27 ITA No. 4322/MUM/2012 (A.Y. 2008-09) C.O. NO. 287& 288/MUM/2017 M/s. Raymond Limited

RAYMOND LTD,MUMBAI vs. DCIT (OSD) RG 2(3), MUMBAI

Accordingly, the same are dismissed as not pressed

Bench: Shri Aby T. Varkey, Hon'Ble & Shri S. Rifaur Rahman, Hon'Bleraymond Limited V. The Addl. Cit– 2(3) New Hind House Aayakar Bhavan, M.K. Road Narottam Morarjee Marg Mumbai - 400020 Ballard Estate, Mumbai - 400001 Pan: Aaacr4896A Appellant Respondent C.O. No. 287/Mum/2017 [Arising Out Of Ita No. 2218/Mum/2011 (A.Y. 2007-08)] The Addl. Cit– 2(3) V. Raymond Limited Aayakar Bhavan, M.K. Road New Hind House Mumbai - 400020 Narottam Morarjee Marg Ballard Estate, Mumbai - 400001 Pan: Aaacr4896A Appellant Respondent M/S. Raymond Limited V. The Dcit – Osd- 2(3) New Hind House, Aayakar Bhavan, M.K. Road Narottam Morarjee Marg Mumbai – 400020 Ballard Estate, Mumbai - 400001 Pan: Aaacr4896A Appellant Respondent

condoned, as there is no reasonable cause for the delay. We find that on this issue, the assessee has made the following submissions: In the assesse' s own appeal for A.Y. 1995-96 the CIT (A) has held to determine the annual value of the property @ 27 ITA No. 4322/MUM/2012 (A.Y. 2008-09) C.O. NO. 287& 288/MUM/2017 M/s. Raymond Limited

IIT INVESTRUST LIMITED ,MUMBAI vs. INCOME TAX OFFICER , 491)(2), , MUMBAI

Condonation of delay in filing the appeal: We refer to the order dated 11.08.2010 of the Assessing Officer framed under section 154 of the Act determining total income 4,46,37,540 for income-tax assessment year 2008-09. In this connection, we would like to inform you that the appeal against the aforesaid assessment order

UNITED HOME ENTERTAINMENT P.LTD,MUMBAI vs. ADIT (IT) 2(2), MUMBAI

The appeals are allowed in terms of our directions as given above

Bench: Shri Amit Shukla () & Shri Ashwani Taneja ()

1. erred in not condoning the delay in filing the appeal before him and accordingly dismissing the appeal as not maintainable; 2. erred in holding that tax is required to be deducted at source on the amount payable by the Appellant to Intelsat Global Sales and Marketing Limited ('Intelsat') [mentioned by the CIT(A) as PanAmSat Corporation] under the Transponder

UNITED HOME ENTERTAINMENT P.LTD,MUMBAI vs. ADIT (IT) 2(2), MUMBAI

The appeals are allowed in terms of our directions as given above

Bench: Shri Amit Shukla () & Shri Ashwani Taneja ()

1. erred in not condoning the delay in filing the appeal before him and accordingly dismissing the appeal as not maintainable; 2. erred in holding that tax is required to be deducted at source on the amount payable by the Appellant to Intelsat Global Sales and Marketing Limited ('Intelsat') [mentioned by the CIT(A) as PanAmSat Corporation] under the Transponder

UNITED HOME ENTERTAINMENT P.LTD,MUMBAI vs. ADIT (IT) 2(2), MUMBAI

The appeals are allowed in terms of our directions as given above

Bench: Shri Amit Shukla () & Shri Ashwani Taneja ()

1. erred in not condoning the delay in filing the appeal before him and accordingly dismissing the appeal as not maintainable; 2. erred in holding that tax is required to be deducted at source on the amount payable by the Appellant to Intelsat Global Sales and Marketing Limited ('Intelsat') [mentioned by the CIT(A) as PanAmSat Corporation] under the Transponder

HDFC BANK LIMITED (AS SUCCESSOR TO HOUSING DEVELOPMENT FINANCE CORPORATION LTD),MUMBAI vs. ADDL CIT RG 1(1), MUMBAI

Bench: Shri Anikesh Banerjee & Shri Girish Agrawal

condone the delay on the ground that there was sufficient cause for the said delay. Accordingly, we take up the appeals for adjudication. Sr. No. ITA No. Assessment Appeal by No. of days year delay 1. 2980/Mum/2024 2014-15 Revenue 18 2. 2979/Mum/2024 2015-16 Revenue 18 3. 2049/Mum/2023 2016-17 Revenue 1 4. 2046/Mum/2023 2017-18 Revenue 1

ADDL CIT RG 1(1), MUMBAI vs. HDFC LTD, MUMBAI

Bench: Shri Anikesh Banerjee & Shri Girish Agrawal

condone the delay on the ground that there was sufficient cause for the said delay. Accordingly, we take up the appeals for adjudication. Sr. No. ITA No. Assessment Appeal by No. of days year delay 1. 2980/Mum/2024 2014-15 Revenue 18 2. 2979/Mum/2024 2015-16 Revenue 18 3. 2049/Mum/2023 2016-17 Revenue 1 4. 2046/Mum/2023 2017-18 Revenue 1

HDFC BANK LIMITED (AS SUCCESSOR TO HOUSING DEVELOPMENT FINANCE CORPORATION LTD),MUMBAI vs. DCIT RG 1(1), MUMBAI

Bench: Shri Anikesh Banerjee & Shri Girish Agrawal

condone the delay on the ground that there was sufficient cause for the said delay. Accordingly, we take up the appeals for adjudication. Sr. No. ITA No. Assessment Appeal by No. of days year delay 1. 2980/Mum/2024 2014-15 Revenue 18 2. 2979/Mum/2024 2015-16 Revenue 18 3. 2049/Mum/2023 2016-17 Revenue 1 4. 2046/Mum/2023 2017-18 Revenue 1

HDFC BANK LIMITED (AS SUCCESSOR TO HOUSING DEVELOPMENT FINANCE CORPORATION LTD),MUMBAI vs. DCIT 1(1), MUMBAI

Bench: Shri Anikesh Banerjee & Shri Girish Agrawal

condone the delay on the ground that there was sufficient cause for the said delay. Accordingly, we take up the appeals for adjudication. Sr. No. ITA No. Assessment Appeal by No. of days year delay 1. 2980/Mum/2024 2014-15 Revenue 18 2. 2979/Mum/2024 2015-16 Revenue 18 3. 2049/Mum/2023 2016-17 Revenue 1 4. 2046/Mum/2023 2017-18 Revenue 1

DAIWA CAPITAL MARKETS INDIA PRIVATE LIMITED ,LOWER PAREL vs. ASST COMMISSIONER OF INCOME TAX CIRCLE 4 1 1 MUMBAI , MUMBAI

In the result, appeal filed by the assessee is allowed in above terms

Bench: Shri Om Prakash Kant & Shri Raj Kumar Chauhandaiwa Capital Markets India Acit Circle 4(1)(1), Private Limited Room No. 640, 6Th Floor, Office No. N10 & N11, 9Th Floor, Vs. Aayakar Bhavan, M.K. Road, Dextrus-Peninsula Tower, Peninsula Mumbai-400 020 Corporate Park, G. K. Marg, Lower Parel, Delisle Road, Mumbai-400 013 Pan: Aaccd7178B (Appellant) (Respondent) Assessee Represented By : Ms. Shivali Mhatre, Ld. Ar Department Represented By : Shri Annavaram Kosuri, Ld. Dr Date Of Conclusion Of Hearing : 03.11.2025 Date Of Pronouncement : 20.11.2025

1 st October, 2024. As per this circular also, the powers to condone delay in filing of return claiming refund has been conferred on the subordinate authorities, namely, CCIT, Pr.CIT and CIT only up to a period of within 5 years from the end of the assessment year concerned. Such powers are not vested with

WESTERN OUTDOOR INTERACTIVE PVT LTD,MUMBAI vs. ASSESSEMENT UNIT, INCOME TAX DEPARTMENT ASSTT COMM. OF INCOME TAX, CIRCLE-16(1), MUMBAI

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

delay being condoned by CBDT whereby the revised return in which such claim is made effective. It is ordered accordingly. 28. Ground No.9 with regard to interest under section 244A is consequential not warranting any separate adjudication. ITA.No.2474/Mum/2022 – AY 2018-19 29. For AY 2018-19, out of the exclusions done by the TPO in the adjustment done towards

WESTERN OUTDOOR INTERACTIVE PRIVATE LIMITED,MUMBAI vs. ASSTT. COMM. OF INCOME TAX, CIRCLE-16(1), MUMBAI

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

delay being condoned by CBDT whereby the revised return in which such claim is made effective. It is ordered accordingly. 28. Ground No.9 with regard to interest under section 244A is consequential not warranting any separate adjudication. ITA.No.2474/Mum/2022 – AY 2018-19 29. For AY 2018-19, out of the exclusions done by the TPO in the adjustment done towards

DCIT-2(1)(1), MUMBAI vs. BANK OF BARODA, MUMBAI

In the result, both the appeals filed by the Revenue and both the cross objections

Bench: Shri Om Prakash Kant, Am & Ms. Kavitha Rajagopal, Jm

delay is condoned. 3. The Revenue has raised the following grounds of appeal and the assessee has raised the following grounds in its cross objection: Grounds raised by the Revenue: "1. On the facts and circumstances of the case and in law, the Ld. CIT (A) erred in holding reopening u/s. 147 of the Act not valid and the quashing