M/S. TATA SONS LTD,MUMBAI vs. THE ACIT CIR2(3), MUMBAI

In the result, the appeals filed by the assessee are allowed and that of the Revenue is dismissed

Bench: Shri P K Bansal & Shri Ram Lal Negi

delay, submitted that under section 253 of the Income tax Act, the limitation is provided only for the purpose of filing of appeal and additional grounds can be filed thereafter at any time. He placed his reliance on decision of Hon’ble Rajasthan High Court in the case of Shilpa Associates vs. ITO (263 ITR 317), Madad All vs. DCIT

M/S. TATA SONS LTD.,MUMBAI vs. CIT CIR. 2(3), MUMBAI

In the result, the appeals filed by the assessee are allowed and that of the Revenue is dismissed

Bench: Shri P K Bansal & Shri Ram Lal Negi

delay, submitted that under section 253 of the Income tax Act, the limitation is provided only for the purpose of filing of appeal and additional grounds can be filed thereafter at any time. He placed his reliance on decision of Hon’ble Rajasthan High Court in the case of Shilpa Associates vs. ITO (263 ITR 317), Madad All vs. DCIT

ADDL CIT R G 7(1), MUMBAI vs. NOVARTIS INDIA LTD ( FORMERLY KNOWN AS HINDUSTAN CIBA GIEGY LTD. ), MUMBAI

Bench: Shri Amit Shukla, Hon'Ble & Shri S. Rifaur Rahman, Hon'Blem/S. Novartis India Limited V. Asst. Commissioner Of Income –Tax - 7(2)(2) {Earlier Addl. Commissioner Of Income –Tax – 7(1)} 6Th& 7Th Floor 1St Floor, Aayakar Bhavan Inspire Bkc M.K. Road, Mumbai - 400020 “G” Block, Bkc Main Road Bandra Kurla Complex, Bandra (E) Mumbai – 400051 Pan: Aaach2914F (Appellant) (Respondent) Addl. Commissioner Of Income –Tax – 7(1) V. M/S. Novartis India Limited Room No. 622, Aayakar Bhavan {Earlier Known As Hindustan Ciba Giegy Ltd.,} Sandoz House, Dr. A.B. Road M.K. Road, Mumbai - 400020 Worli, Mumbai – 400018 Pan: Aaach2914F (Appellant) (Respondent) Co No.190/Mum/2011 [Arising Out Of Ita No.6772/Mum/2010 (A.Y. 2002-03)] M/S. Novartis India Limited V. Addl. Commissioner Of Income –Tax – 7(1)} Room No. 622, Aayakar Bhavan {Earlier Known As Hindustan Ciba Giegy Ltd.,} Sandoz House, Dr. A.B. Road M.K. Road, Mumbai - 400020 Worli, Mumbai – 400018 Pan: Aaach2914F (Appellant) (Respondent)

condonation of delay on merit. Hence, this decision is not applicable in the Assessee's case. The facts in the assessee's case are different. The delay in filing of an additional ground is 16 years and no cogent evidence or no explanation has been filed by the assessee to justify the substantial delay of 16 years. In fact

THE DY CIT 3(2), MUMBAI vs. M/S. NUCLEAR POWER CORPORATION OF INDIA LTD, MUMBAI

Bench: Shri Om Prakash Kant () & Ms. Kavitha Rajagopal () Assessment Year: 1998-99 & Assessment Year: 1999-2000 & Assessment Year: 2000-01 & Assessment Year: 2001-02 & Assessment Year: 2002-03 & Assessment Year: 2003-04 & Assessment Year: 2004-05 & Assessment Year: 2005-06 Nuclear Power Corporation Of Acit, Range-3(2), India Ltd., Aayakar Bhavan, M.K. Road, Vikram Sarabhai Bhavan, Vs. Mumbai-400021. Central Avenue, Anushakti Nagar, Mumbai-400094. Pan No. Aaacn 3154 F Appellant Respondent

7A) read with section 120(4)(b) of the Act, no authority had been given by 120(4)(b) of the Act, no authority had been given by 120(4)(b) of the Act, no authority had been given by the CBDT to either the Director General or Chief the CBDT to either the Director General o the CBDT

NUCLEAR POWER CORPORATION OF INDIA LTD,,MUMBAI vs. ADDL. C.I.T,RANGE 3(2), MUMBAI

Bench: Shri Om Prakash Kant () & Ms. Kavitha Rajagopal () Assessment Year: 1998-99 & Assessment Year: 1999-2000 & Assessment Year: 2000-01 & Assessment Year: 2001-02 & Assessment Year: 2002-03 & Assessment Year: 2003-04 & Assessment Year: 2004-05 & Assessment Year: 2005-06 Nuclear Power Corporation Of Acit, Range-3(2), India Ltd., Aayakar Bhavan, M.K. Road, Vikram Sarabhai Bhavan, Vs. Mumbai-400021. Central Avenue, Anushakti Nagar, Mumbai-400094. Pan No. Aaacn 3154 F Appellant Respondent

7A) read with section 120(4)(b) of the Act, no authority had been given by 120(4)(b) of the Act, no authority had been given by 120(4)(b) of the Act, no authority had been given by the CBDT to either the Director General or Chief the CBDT to either the Director General o the CBDT

NUCLEAR POWER CORPORATION OF INDIA LTD,MUMBAI vs. ADDL CIT RG 3(2), MUMBAI

Bench: Shri Om Prakash Kant () & Ms. Kavitha Rajagopal () Assessment Year: 1998-99 & Assessment Year: 1999-2000 & Assessment Year: 2000-01 & Assessment Year: 2001-02 & Assessment Year: 2002-03 & Assessment Year: 2003-04 & Assessment Year: 2004-05 & Assessment Year: 2005-06 Nuclear Power Corporation Of Acit, Range-3(2), India Ltd., Aayakar Bhavan, M.K. Road, Vikram Sarabhai Bhavan, Vs. Mumbai-400021. Central Avenue, Anushakti Nagar, Mumbai-400094. Pan No. Aaacn 3154 F Appellant Respondent

7A) read with section 120(4)(b) of the Act, no authority had been given by 120(4)(b) of the Act, no authority had been given by 120(4)(b) of the Act, no authority had been given by the CBDT to either the Director General or Chief the CBDT to either the Director General o the CBDT

NUCLEAR POWER CORPORATION OF INDIA LTD.,MUMBAI vs. ACIT(OSD) RANGE 3(2), MUMBAI

Bench: Shri Om Prakash Kant () & Ms. Kavitha Rajagopal () Assessment Year: 1998-99 & Assessment Year: 1999-2000 & Assessment Year: 2000-01 & Assessment Year: 2001-02 & Assessment Year: 2002-03 & Assessment Year: 2003-04 & Assessment Year: 2004-05 & Assessment Year: 2005-06 Nuclear Power Corporation Of Acit, Range-3(2), India Ltd., Aayakar Bhavan, M.K. Road, Vikram Sarabhai Bhavan, Vs. Mumbai-400021. Central Avenue, Anushakti Nagar, Mumbai-400094. Pan No. Aaacn 3154 F Appellant Respondent

7A) read with section 120(4)(b) of the Act, no authority had been given by 120(4)(b) of the Act, no authority had been given by 120(4)(b) of the Act, no authority had been given by the CBDT to either the Director General or Chief the CBDT to either the Director General o the CBDT

NUCLEAR POWER CORPORATION OF INDIA LTD.,MUMBAI vs. ADDL.COMMR.OF INCOME TAX, SPL. RG.32, MUMBAI

Bench: Shri Om Prakash Kant () & Ms. Kavitha Rajagopal () Assessment Year: 1998-99 & Assessment Year: 1999-2000 & Assessment Year: 2000-01 & Assessment Year: 2001-02 & Assessment Year: 2002-03 & Assessment Year: 2003-04 & Assessment Year: 2004-05 & Assessment Year: 2005-06 Nuclear Power Corporation Of Acit, Range-3(2), India Ltd., Aayakar Bhavan, M.K. Road, Vikram Sarabhai Bhavan, Vs. Mumbai-400021. Central Avenue, Anushakti Nagar, Mumbai-400094. Pan No. Aaacn 3154 F Appellant Respondent

7A) read with section 120(4)(b) of the Act, no authority had been given by 120(4)(b) of the Act, no authority had been given by 120(4)(b) of the Act, no authority had been given by the CBDT to either the Director General or Chief the CBDT to either the Director General o the CBDT

NUCLEAR POWER CORPORATION OF INDIA LTD.,MUMBAI vs. ACIT RANGE 3(2), MUMBAI

Bench: Shri Om Prakash Kant () & Ms. Kavitha Rajagopal () Assessment Year: 1998-99 & Assessment Year: 1999-2000 & Assessment Year: 2000-01 & Assessment Year: 2001-02 & Assessment Year: 2002-03 & Assessment Year: 2003-04 & Assessment Year: 2004-05 & Assessment Year: 2005-06 Nuclear Power Corporation Of Acit, Range-3(2), India Ltd., Aayakar Bhavan, M.K. Road, Vikram Sarabhai Bhavan, Vs. Mumbai-400021. Central Avenue, Anushakti Nagar, Mumbai-400094. Pan No. Aaacn 3154 F Appellant Respondent

7A) read with section 120(4)(b) of the Act, no authority had been given by 120(4)(b) of the Act, no authority had been given by 120(4)(b) of the Act, no authority had been given by the CBDT to either the Director General or Chief the CBDT to either the Director General o the CBDT

NUCLEAR POWER CORPORATION OF INDIA LTD,,MUMBAI vs. ADDL. C.I.T,RANGE 3(2), MUMBAI

Bench: Shri Om Prakash Kant () & Ms. Kavitha Rajagopal () Assessment Year: 1998-99 & Assessment Year: 1999-2000 & Assessment Year: 2000-01 & Assessment Year: 2001-02 & Assessment Year: 2002-03 & Assessment Year: 2003-04 & Assessment Year: 2004-05 & Assessment Year: 2005-06 Nuclear Power Corporation Of Acit, Range-3(2), India Ltd., Aayakar Bhavan, M.K. Road, Vikram Sarabhai Bhavan, Vs. Mumbai-400021. Central Avenue, Anushakti Nagar, Mumbai-400094. Pan No. Aaacn 3154 F Appellant Respondent

7A) read with section 120(4)(b) of the Act, no authority had been given by 120(4)(b) of the Act, no authority had been given by 120(4)(b) of the Act, no authority had been given by the CBDT to either the Director General or Chief the CBDT to either the Director General o the CBDT

NUCLEAR POWER CORPORATION OF INDIA LTD,,MUMBAI vs. ADDL. C.I.T,RANGE 3(2), MUMBAI

Bench: Shri Om Prakash Kant () & Ms. Kavitha Rajagopal () Assessment Year: 1998-99 & Assessment Year: 1999-2000 & Assessment Year: 2000-01 & Assessment Year: 2001-02 & Assessment Year: 2002-03 & Assessment Year: 2003-04 & Assessment Year: 2004-05 & Assessment Year: 2005-06 Nuclear Power Corporation Of Acit, Range-3(2), India Ltd., Aayakar Bhavan, M.K. Road, Vikram Sarabhai Bhavan, Vs. Mumbai-400021. Central Avenue, Anushakti Nagar, Mumbai-400094. Pan No. Aaacn 3154 F Appellant Respondent

7A) read with section 120(4)(b) of the Act, no authority had been given by 120(4)(b) of the Act, no authority had been given by 120(4)(b) of the Act, no authority had been given by the CBDT to either the Director General or Chief the CBDT to either the Director General o the CBDT

NUCLEAR POWER CORPORATION OF INDIA LTD,MUMBAI vs. ADDL CIT RG 3(2), MUMBAI

Bench: Shri Om Prakash Kant () & Ms. Kavitha Rajagopal () Assessment Year: 1998-99 & Assessment Year: 1999-2000 & Assessment Year: 2000-01 & Assessment Year: 2001-02 & Assessment Year: 2002-03 & Assessment Year: 2003-04 & Assessment Year: 2004-05 & Assessment Year: 2005-06 Nuclear Power Corporation Of Acit, Range-3(2), India Ltd., Aayakar Bhavan, M.K. Road, Vikram Sarabhai Bhavan, Vs. Mumbai-400021. Central Avenue, Anushakti Nagar, Mumbai-400094. Pan No. Aaacn 3154 F Appellant Respondent

7A) read with section 120(4)(b) of the Act, no authority had been given by 120(4)(b) of the Act, no authority had been given by 120(4)(b) of the Act, no authority had been given by the CBDT to either the Director General or Chief the CBDT to either the Director General o the CBDT

NUCLEAR POWER CORPORATION OF INDIA LTD,,MUMBAI vs. ADDL. C.I.T,RANGE 3(2), MUMBAI

Bench: Shri Om Prakash Kant () & Ms. Kavitha Rajagopal () Assessment Year: 1998-99 & Assessment Year: 1999-2000 & Assessment Year: 2000-01 & Assessment Year: 2001-02 & Assessment Year: 2002-03 & Assessment Year: 2003-04 & Assessment Year: 2004-05 & Assessment Year: 2005-06 Nuclear Power Corporation Of Acit, Range-3(2), India Ltd., Aayakar Bhavan, M.K. Road, Vikram Sarabhai Bhavan, Vs. Mumbai-400021. Central Avenue, Anushakti Nagar, Mumbai-400094. Pan No. Aaacn 3154 F Appellant Respondent

7A) read with section 120(4)(b) of the Act, no authority had been given by 120(4)(b) of the Act, no authority had been given by 120(4)(b) of the Act, no authority had been given by the CBDT to either the Director General or Chief the CBDT to either the Director General o the CBDT

M/S. PIK STUDIOS P. LTD (FORMERLY KNOWN AS PIK PEN PRIVATE LIMITED),MUMBAI vs. ITO 8(2)(4), MUMBAI

In the result, these appeals by the assessee stand dismissed

Bench: Shri Shamim Yahya & Shri Amarjit Singh.

condone the said delay. 4. Since the issues are common and connected, the appeals were heard together. These are being consolidated and hence disposed of together by this common order. 5. We note that for assessment years 1999-2000 to 2009-10 (except assessment year 2007-08) are appeals which were already adjudicated by the Tribunal vide order dated

DCIT, CIRCLE-3(4), MUMBAI, MUMBAI vs. GLENMARK PHARMACEUTICALS LIMITED, MUMBAI

In the result, appeal of the Revenue for Assessment Year 2016-17

Bench: Shri Pawan Singh & Shri Girish Agrawal

condone the delay on the ground that there was sufficient cause for the said delay. Accordingly, we take up the matter for adjudication. 3. Brief facts of the case are that assessee is the ultimate holding company of the Glenmark Group. It is research led global, fully integrated pharma company, head quartered in Mumbai, incorporated in 1977, and engaged

DCIT, CIRCLE-3(4), MUMBAI, MUMBAI vs. GLENMARK PHARMACEUTICALS LIMITED, MUMBAI

In the result, appeal of the Revenue for Assessment Year 2016-17

Bench: Shri Pawan Singh & Shri Girish Agrawal

condone the delay on the ground that there was sufficient cause for the said delay. Accordingly, we take up the matter for adjudication. 3. Brief facts of the case are that assessee is the ultimate holding company of the Glenmark Group. It is research led global, fully integrated pharma company, head quartered in Mumbai, incorporated in 1977, and engaged

ITO-26(2)(1), MUMBAI, KAUTILYA BHAVAN BKC, MUMBAI vs. SVADESHI ENTERPRISES (MUMBAI), FORT, MUMBAI

In the result, the appeal of the Revenue is dismissed\nwhile the CO of the assessee is allowed

condone the delay and we\nPage 5\nITA No. 5865/Mum/2024\nCO No. 168/Mum/2025\nΑ.Υ. 2014-15\nSvadeshi Enterprises, Mumbai\ntake up assessee's Cross Objection in C.O. No. 168/Mum/2024\nfirst, as it has a bearing on the very validity of the assessment order.\n5. The brief facts of the case are that the assessee filed its return\nof income

LUPIN LTD.,MUMBAI vs. THE DY CIT, CIRCLE-3(4), MUMBAI

In the result, all the appeals of the assessee and revenue are treated as partly allowed

Bench: Shri B.R. Baskaran (Am) & Shri Pavan Kumar Gadale (Jm)

7A)(b) of the Rules, that the quantification of the weighted deduction u/s.35(2AB) of the Act has significance. 26 M/s. Lupin Limited Asst. year 2010-11, 2011-12 and 2012-13 Further, the date of approval shall not be cut off date for allowing scientific research expenditure u/s. 35(2AB) of the Act.” Following the above said decision

FLAMINGO PHARMACEUTICALS LTD,SION TROMBAY ROAD CHEMBUR vs. DCIT CIRCLE-14(1)(2), MUMBAI , AAYKAR BHAVAN, M.K. ROAD

In the result, the appeal of the assessee is allowed

condone the delay.\n4. It may also be stated here that the instant appeal is part of\nsecond round of litigation. Brief facts of the case are the assessee\nfiled return of income disclosing total income of Rs.15,27,38,623/-. The\nassessment u/s 143(3) of the Act was originally completed by the AO by\nmaking certain addition. During