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

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

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

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

244A of\nthe Act amounting to Rs.2,57,25,492 on the refund referred to in ground no. (6)\nabove due to the Appellant.\n8. The CIT(A) erred in confirming the disallowance of Rs.40,074 being sum paid\ntowards profession tax having failed to appreciate that the said sum paid towards\nprofessional tax is not routed through profit

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

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

244A of\nthe Act amounting to Rs.2,57,25,492 on the refund referred to in ground no. (6)\nabove due to the Appellant.\n8. The CIT(A) erred in confirming the disallowance of Rs.40,074 being sum paid\ntowards profession tax having failed to appreciate that the said sum paid towards\nprofessional tax is not routed through profit

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

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

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

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

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

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

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 ()

Section 244A of the Act (on TDS), arising consequent to the above grounds. The above grounds of appeal are without prejudice to each other. 3. During the course of hearing it was stated at the outset by the Ld. Counsel of the assessee that the issue arising in this appeal is identical to the issues which arose in the earlier

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 ()

Section 244A of the Act (on TDS), arising consequent to the above grounds. The above grounds of appeal are without prejudice to each other. 3. During the course of hearing it was stated at the outset by the Ld. Counsel of the assessee that the issue arising in this appeal is identical to the issues which arose in the earlier

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 ()

Section 244A of the Act (on TDS), arising consequent to the above grounds. The above grounds of appeal are without prejudice to each other. 3. During the course of hearing it was stated at the outset by the Ld. Counsel of the assessee that the issue arising in this appeal is identical to the issues which arose in the earlier

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

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

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

244A. Our returned income was accepted without any modifications. 11. 3. Thereafter, the Assessing Officer issued a notice dated 31.03.2017 under section 148 of the Act and our case was re-opened and the Assessing Officer passed an order dated 30.11.2017 under section 143(3) r.w.s.147 of the Act and determined the total income

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

In the result, all the appeals by the assessee are allowed for statistical purpose

Bench: Shri Saktijit Dey, Vp & Shri Prabhash Shankar, Am

section 244A of the Act on the refund arising from the excess DDT paid by the Appellant 3. Briefly, the facts are, the assessee is a resident corporate entity and stated to be engaged in the business of underwriting general insurance policies. The assessments in case of assessee were completed u/s. 143(3) of the Income

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

In the result, all the appeals by the assessee are allowed for statistical purpose

Bench: Shri Saktijit Dey, Vp & Shri Prabhash Shankar, Am

section 244A of the Act on the refund arising from the excess DDT paid by the Appellant 3. Briefly, the facts are, the assessee is a resident corporate entity and stated to be engaged in the business of underwriting general insurance policies. The assessments in case of assessee were completed u/s. 143(3) of the Income

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

In the result, all the appeals by the assessee are allowed for statistical purpose

Bench: Shri Saktijit Dey, Vp & Shri Prabhash Shankar, Am

section 244A of the Act on the refund arising from the excess DDT paid by the Appellant 3. Briefly, the facts are, the assessee is a resident corporate entity and stated to be engaged in the business of underwriting general insurance policies. The assessments in case of assessee were completed u/s. 143(3) of the Income