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

Section 195 of the Act as the same were\nchargeable to tax in India in terms of Section 9(1)(vii) of the Act\nread with either Article 12 or Article 22/23 of the corresponding\nDTAAs as FTS or Other Income, respectively. Since the Assessee\nhad failed to deduct tax from the same in terms of Section

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

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 Co-operative,\nSwitzerland by following, inter alia, the decision of the Mumbai\nBench of the Tribunal, dated 07/04/2017, in the case of\nAssessee for the Assessment Year 2001-2002 [ITA No.\n2493/Mum/2012].\nThe

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

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 Co-operative,\nSwitzerland by following, inter alia, the decision of the Mumbai\nBench of the Tribunal, dated 07/04/2017, in the case of\nAssessee for the Assessment Year 2001-2002 [ITA No.\n2493/Mum/2012].\nThe

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

Section 40(a)(i) of the Act\nwas warranted.\nThe CIT(A) also allowed Assessee’s claim for deduction for\n\nITA No.2272-2276/Mum/2023 & CO No.123-128/Mum/2023\nITA No.2410-2415/Mum/2023 AYs 2012-2013 to 2017-2018\n\n9\n\nremittance made to KPMG International Co-operative,\nSwitzerland by following, inter alia, the decision of the Mumbai\nBench of the Tribunal, dated 07/04/2017

GETINGE MEDICAL INDIA PRIVATE LIMITED ,MUMBAI vs. DCIT 2(2)(1), MUMBAI MAHARASHTRA

In the result, appeal filed by the assessee stands partly allowed

Bench: Smt. Beena Pillai () & Shri Girish Agrawal ()

40 days. He submits that assessee when filed its return of income on 31.03.2021 opted for the 6 Getinge Medical India Private Limited concessional rate u/s 115BAA and also filed Form 10-IC on 01.04.2021. The Ld.AR thus submitted that assessee expressly indicated in its return of income that it was opting for the concessional rate as per Section 115BAA

ITO 22(3)(1), NAVI MUMBAI vs. CRESCENT CONSTRUCTION, NAVI MUMBAI

The appeal of the assessee is allowed and of the Revenue is dismissed

Bench: Shri Joginder Singh & Shri N.K. Pradhanassessment Year: 2005-06

section confines the duty to the disclosure of all primary and material facts necessary for the assessment, fully and truly. As to what are material or primary facts would depend upon the facts and circumstances of each case and no universal formula may be attempted. The legal or factual inferences from those primary or material facts are for the Assessing

CRESCENT CONSTRUCTION CO.,NAVI MUMBAI vs. ASST CIT 22(3), NAVI MUMBAI

The appeal of the assessee is allowed and of the Revenue is dismissed

Bench: Shri Joginder Singh & Shri N.K. Pradhanassessment Year: 2005-06

section confines the duty to the disclosure of all primary and material facts necessary for the assessment, fully and truly. As to what are material or primary facts would depend upon the facts and circumstances of each case and no universal formula may be attempted. The legal or factual inferences from those primary or material facts are for the Assessing

PANKAJ PARASAR,MUMBAI vs. ACIT 11(1), MUMBAI

In the result, the assessee’s appeal for A

Bench: Shri Jason P. Boaz & Shri Sandeep Gosainshri Pankaj Parasar Acit, Circle 11(1) 1St Floor, Plot No. 376 Aayakar Bhavan, M.K. Road Vs. Didee House, 14Th Road Mumbai 400020 Khar (W), Mumbai 400052 Pan – Aaapp9015A Appellant Respondent

condone the delay of 248 days in filing this appeal. This appeal is accordingly admitted for consideration and adjudication. We hold and direct accordingly. 3 Shri Pankaj Parasar 3. The facts of the case, briefly stated, are as under: - 3.1 The assessee, Prop. M/s. Mazaa Films & M/s. Mazaa Productions, engaged in the production and direction of advertisement films, feature films

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

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 Co-operative, Switzerland by following, inter alia, the decision of the Mumbai Bench of the Tribunal, dated 07/04/2017, in the case of Assessee for the Assessment Year 2001-2002 [ITA No. 2493/Mum/2012

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

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 Co-operative, Switzerland by following, inter alia, the decision of the Mumbai Bench of the Tribunal, dated 07/04/2017, in the case of Assessee for the Assessment Year 2001-2002 [ITA No. 2493/Mum/2012

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)

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 ITA No.2410-2415/Mum/2023 AYs 2012-2013 to 2017-2018 remittance made to KPMG International Co-operative, Switzerland by following, inter alia, the decision of the Mumbai Bench of the Tribunal, dated 07/04/2017, in the case of Assessee

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)

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 ITA No.2410-2415/Mum/2023 AYs 2012-2013 to 2017-2018 remittance made to KPMG International Co-operative, Switzerland by following, inter alia, the decision of the Mumbai Bench of the Tribunal, dated 07/04/2017, in the case of Assessee

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)

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 ITA No.2410-2415/Mum/2023 AYs 2012-2013 to 2017-2018 remittance made to KPMG International Co-operative, Switzerland by following, inter alia, the decision of the Mumbai Bench of the Tribunal, dated 07/04/2017, in the case of Assessee

STATE BANK OF INDIA,MUM vs. ACIT-TDS-2(2), MUM

In the result, all the appeals of the assessee are allowed for In the result, all the appeals of the assessee are allowed for In the result, all the appeals of the assessee are allowed for statisti...

Bench: Shri Om Prakash Kant () & Ms. Kavitha Rajagopal () Ita Nos. 3111& 3112/Mum/2022 Assessment Years: 2012-13& 2013-14 State Bank Of India Hrms Acit (Tds) Rg-2(2), Department, Peddar Road, Vs. 4Th Floor, Cidco Tower No. 7, Mumbai-400014. Belapur Railway Station Complex-400614. Tan No. Mums 63193 E Appellant Respondent Assessee By : Mr. Anand Desai & Mr. Sachin Lopes, Ar Revenue By : Mr. Paresh Deshpande, Dr

section assessee to file the said certificate under first prov assessee to file the said certificate under first prov 201(1) of the Act before the Ld. CIT(A) 201(1) of the Act before the Ld. CIT(A), which will be considered by which will be considered by the Ld CIT(A) in accordance with law. in accordance with

STATE BANK OF INDIA-ISB BRANCH,MUMBAI vs. DCIT-TDS-2(2), MUMBAI

In the result, all the appeals of the assessee are allowed for In the result, all the appeals of the assessee are allowed for In the result, all the appeals of the assessee are allowed for statisti...

Bench: Shri Om Prakash Kant () & Ms. Kavitha Rajagopal () Ita Nos. 3111& 3112/Mum/2022 Assessment Years: 2012-13& 2013-14 State Bank Of India Hrms Acit (Tds) Rg-2(2), Department, Peddar Road, Vs. 4Th Floor, Cidco Tower No. 7, Mumbai-400014. Belapur Railway Station Complex-400614. Tan No. Mums 63193 E Appellant Respondent Assessee By : Mr. Anand Desai & Mr. Sachin Lopes, Ar Revenue By : Mr. Paresh Deshpande, Dr

section assessee to file the said certificate under first prov assessee to file the said certificate under first prov 201(1) of the Act before the Ld. CIT(A) 201(1) of the Act before the Ld. CIT(A), which will be considered by which will be considered by the Ld CIT(A) in accordance with law. in accordance with

STATE BANK OF INDIA HRMS DEPARTMENT,MUMBAI vs. ASSTT. COMMISSIONER OF INCOME TAX (TDS)RANGE-2(2), MUMBAI

In the result, all the appeals of the assessee are allowed for In the result, all the appeals of the assessee are allowed for In the result, all the appeals of the assessee are allowed for statisti...

Bench: Shri Om Prakash Kant () & Ms. Kavitha Rajagopal () Ita Nos. 3111& 3112/Mum/2022 Assessment Years: 2012-13& 2013-14 State Bank Of India Hrms Acit (Tds) Rg-2(2), Department, Peddar Road, Vs. 4Th Floor, Cidco Tower No. 7, Mumbai-400014. Belapur Railway Station Complex-400614. Tan No. Mums 63193 E Appellant Respondent Assessee By : Mr. Anand Desai & Mr. Sachin Lopes, Ar Revenue By : Mr. Paresh Deshpande, Dr

section assessee to file the said certificate under first prov assessee to file the said certificate under first prov 201(1) of the Act before the Ld. CIT(A) 201(1) of the Act before the Ld. CIT(A), which will be considered by which will be considered by the Ld CIT(A) in accordance with law. in accordance with

STATE BANK OF INDIA- NRI BRANCH,MUMBAI vs. ACIT-TDS-2(2), MUMBAI

In the result, all the appeals of the assessee are allowed for In the result, all the appeals of the assessee are allowed for In the result, all the appeals of the assessee are allowed for statisti...

Bench: Shri Om Prakash Kant () & Ms. Kavitha Rajagopal () Ita Nos. 3111& 3112/Mum/2022 Assessment Years: 2012-13& 2013-14 State Bank Of India Hrms Acit (Tds) Rg-2(2), Department, Peddar Road, Vs. 4Th Floor, Cidco Tower No. 7, Mumbai-400014. Belapur Railway Station Complex-400614. Tan No. Mums 63193 E Appellant Respondent Assessee By : Mr. Anand Desai & Mr. Sachin Lopes, Ar Revenue By : Mr. Paresh Deshpande, Dr

section assessee to file the said certificate under first prov assessee to file the said certificate under first prov 201(1) of the Act before the Ld. CIT(A) 201(1) of the Act before the Ld. CIT(A), which will be considered by which will be considered by the Ld CIT(A) in accordance with law. in accordance with

STATE BANK OF INDIA,MUM vs. ACIT-TDS-2(2),, MUM

In the result, all the appeals of the assessee are allowed for In the result, all the appeals of the assessee are allowed for In the result, all the appeals of the assessee are allowed for statisti...

Bench: Shri Om Prakash Kant () & Ms. Kavitha Rajagopal () Ita Nos. 3111& 3112/Mum/2022 Assessment Years: 2012-13& 2013-14 State Bank Of India Hrms Acit (Tds) Rg-2(2), Department, Peddar Road, Vs. 4Th Floor, Cidco Tower No. 7, Mumbai-400014. Belapur Railway Station Complex-400614. Tan No. Mums 63193 E Appellant Respondent Assessee By : Mr. Anand Desai & Mr. Sachin Lopes, Ar Revenue By : Mr. Paresh Deshpande, Dr

section assessee to file the said certificate under first prov assessee to file the said certificate under first prov 201(1) of the Act before the Ld. CIT(A) 201(1) of the Act before the Ld. CIT(A), which will be considered by which will be considered by the Ld CIT(A) in accordance with law. in accordance with