DCIT 2(2)(1), MUMBAI vs. STATE BANK OF INDIA, MUMBAI

The appeal of the Revenue is dismissed

Bench: Shri Joginder Singh & Shri N.K. Pradhanassessment Year: 1995-96 Dcit-2(2)(1), M/S State Bank Of India, R. No.545, Financial Reporting & बनाम/ Aayakar Bhavan Taxation Department, 3Rd Vs. M.K. Road, Floor, Corporate Centre, Mumbai-400020 State Bank Bhavan, Madam Cama Road, Nariman Point, Mumbai-400021 (राज"व /Revenue) ("नधा"रती /Assessee) P.A. No. Aaacs8577K

9 M/s State Bank of India arising on account of interest accrued but not due on securities.The assessee filed an application before the AO in that regard.He disposed off the application holding that even if the assessee got relief from the appellate authority, it could not get 244A interest,that delay was on part of the assessee for making claim

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

9(1)(vii)(b) of the Act for the reason the same\nwere utilized outside India and/or for earning income from\nsource outside India. [Refer to Note 3 at 65 of impugned\norder passed by the CIT(A)]\n(iii) In respect of balance 16 non-resident parties4\n[at Sl.No. 1

NARIMAN POINT ASSOCIATION,MUMBAI vs. ITO EXEMPTION-2(1), MUMBAI

In the result, both appeals by the assessee are dismissed

Bench: Shri Vikram Singh Yadavshri Sandeep Singh Karhail

vii) of the Act or not is debatable. Further, the above claim for deductions as made by the applicant was by following the decision of the Gujarat High Court in Vithaldas Dhanjibhai (supra). Thus, a debatable issue. Therefore, the same could not have been disallowed by way of an intimation under section 143(I)(a) of the Act.” 9

NARIMAN POINT ASSOCIATION,MUMBAI vs. ITO EXEMPTION-2(1), MUMBAI

In the result, both appeals by the assessee are dismissed

Bench: Shri Vikram Singh Yadavshri Sandeep Singh Karhail

vii) of the Act or not is debatable. Further, the above claim for deductions as made by the applicant was by following the decision of the Gujarat High Court in Vithaldas Dhanjibhai (supra). Thus, a debatable issue. Therefore, the same could not have been disallowed by way of an intimation under section 143(I)(a) of the Act.” 9

DCIT-2(3)(2), MUMBAI vs. KOTAK MAHINDRA BANK LTD., MUMBAI

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

Bench: Sri Mahavir Singh, Jm & Sri Manoj Kumar Aggarwal, Am The Dy. Commissioner Of Kotak Mahindra Bank Ltd. Income Tax, Circle 2(3)(2), 27 Bkc, G Block, Bandra Mumbai R. No. 552, 5Th Floor, Kurla Complex, Bandra Vs. Aayakar Bhavan, M.K. Road, (East), Mumbai-400 023 Mumbai-400 020 Appellant .. Respondent Pan No. Aaack4409J

delay in making such Cross Objection.” 3. When this was pointed out to the learned Sr. Departmental Representative, he objected to condonation but could not give any reason for objection. After hearing both the sides, we feel that this is a fit case for condonation because the assessee inadvertently and under bonafide belief could not file cross objection even though

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

delay in filing cross objections for all the\n assessment years is condoned.\n1.5. During the course of hearing it was submitted that appeals/cross\nobjections for the Assessment Year 2013-14 could be taken as\nlead matters, and that the findings/adjudication on issues raised\nin the appeals/cross objections for Assessment Year 2013-14\nwould apply mutatis mutandis to other appeals/cross

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

9(1)(vii)(b) of the Act for the reason the same\nwere utilized outside India and/or for earning income from\nsource outside India. [Refer to Note 3 at 65 of impugned\norder passed by the CIT(A)]\n(iii) In respect of balance 16 non-resident parties4\n[at Sl.No. 1

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

9(1)(vii)(b) of the Act for the reason the same\nwere utilized outside India and/or for earning income from\nsource outside India. [Refer to Note 3 at 65 of impugned\norder passed by the CIT(A)]\n(iii) In respect of balance 16 non-resident parties4 [at Sl.No. 1

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

9(1)(vii)(b) of the Act for the reason the same\nwere utilized outside India and/or for earning income from\nsource outside India. [Refer to Note 3 at 65 of impugned\norder passed by the CIT(A)]\n(iii) In respect of balance 16 non-resident parties4 [at Sl.No. 1

ACIT, CIRCLE - 3 3 1, MUMBAI vs. JAMNAGAR UTILITIES AND POWER PVT LTD, MUMBAI

In the result, both the appeals of the Revenue are allowed\npartly

delay in filing the appeals is condoned.\n4. Now, we take up the appeal of the Revenue for assessment\nyear 2019-2020. The grounds raised by the Revenue are reproduced\nas under:\n1. \"Whether the contribution or donation made by assessee not\nvoluntarily, but to discharge legal obligation arising from Section 135\nof the Company's Act r.w. schedule VII

ACIT, CIRCLE - 3 3 1, MUMBAI vs. JAMNAGAR UTILITIES AND POWER PVT LTD, MUMBAI

In the result, both the appeals of the Revenue are allowed\npartly

delay in filing the appeals is condoned.\n4. Now, we take up the appeal of the Revenue for assessment\nyear 2019-2020. The grounds raised by the Revenue are reproduced\nas under:\n1. \"Whether the contribution or donation made by assessee not\nvoluntarily, but to discharge legal obligation arising from section 135\nof the Company's Act r.w. schedule VII

ZAHIR KASAM MEMON,MUMBAI vs. ADDL-JCIT (A)-2, , MUMBAI

In the result the appeal filed by the assessee stands dismissed

Bench: Smt Beena Pillai & Shri Prabhash Shankarassessment Year: 2019-20 Zahir Kasam Memon Addl-Jcit (A) -2 Memon Brothers, Chennai, Pinjarwada, Tamil Nadu. Kumbharwada, Vs. Zenda Bazar, Vasai (West).-401201. Pan:Aempm1407R (Appellant) (Respondent)

9 are true to the best of my belief. Nothing material has been concealed.” B. The Ld.AR submitted that in view of the above, the assessee could not file the appeals before this Tribunal well in time and Zahir Kasam Memon; A. Y.2019-20 by the time the appeal papers were prepared for filing, there arose delay of 12 days

SONMRUG CO-OPERATIVE HOUSING SOCIETY LTD,PEDDER ROAD vs. CIT(APPEAL), MUMBAI

In the result the appeal is dismissed in limine

Bench: Hon’Ble Shri Sandeep Gosain & Hon’Ble Shri Prabhash Shankarwith With With Sonmrug Co-Operative Vs. Cit(A) Housing Society Ltd Kautilya Bhavan 62Cc Sunita Apartment Mumbai, Pedder Road, Behind Mount Mumbai - 400012 Unique, Mumbai - 400036 Pan/Gir No. Aabat0916G (Applicant) (Respondent) Assessee By Shri Pawan Choudhary Revenue By Shri Harendra Verma, Sr. Dr Date Of Hearing 16.02.2026 Date Of Pronouncement 19.02.2026 आदेश / Order Per Sandeep Gosain, Jm: Firstly, We Shall Take Ita No. 2794/Mum/2025, A.Y 2012-13 As Lead Case & Facts Narrated Therein.

vii, Delay condonation application has to be decided on the parameters laid down for condoning the delay and condoning the delay for the reason that the conditions have been imposed. tantamount to disregarding the statutory provision. 10 Sonmrug Co-operative Housing Society Ltd Moreover, there are two essential ingredients for 9. condoning delays: (i) the existence of 'sufficient cause

THE SONMRUG CO-OPERATIVE HSG SOCIETY LIMITED,PEDDER ROAD vs. CIT(APPEAL), MUMBAI

In the result the appeal is dismissed in limine

Bench: Hon’Ble Shri Sandeep Gosain & Hon’Ble Shri Prabhash Shankarwith With With Sonmrug Co-Operative Vs. Cit(A) Housing Society Ltd Kautilya Bhavan 62Cc Sunita Apartment Mumbai, Pedder Road, Behind Mount Mumbai - 400012 Unique, Mumbai - 400036 Pan/Gir No. Aabat0916G (Applicant) (Respondent) Assessee By Shri Pawan Choudhary Revenue By Shri Harendra Verma, Sr. Dr Date Of Hearing 16.02.2026 Date Of Pronouncement 19.02.2026 आदेश / Order Per Sandeep Gosain, Jm: Firstly, We Shall Take Ita No. 2794/Mum/2025, A.Y 2012-13 As Lead Case & Facts Narrated Therein.

vii, Delay condonation application has to be decided on the parameters laid down for condoning the delay and condoning the delay for the reason that the conditions have been imposed. tantamount to disregarding the statutory provision. 10 Sonmrug Co-operative Housing Society Ltd Moreover, there are two essential ingredients for 9. condoning delays: (i) the existence of 'sufficient cause

THE SONMRUG CO-OPERATIVE HSG SOCIETY LIMITED,PEDDER ROAD vs. CIT(APPEAL), MUMBAI

In the result the appeal is dismissed in limine

Bench: Hon’Ble Shri Sandeep Gosain & Hon’Ble Shri Prabhash Shankarwith With With Sonmrug Co-Operative Vs. Cit(A) Housing Society Ltd Kautilya Bhavan 62Cc Sunita Apartment Mumbai, Pedder Road, Behind Mount Mumbai - 400012 Unique, Mumbai - 400036 Pan/Gir No. Aabat0916G (Applicant) (Respondent) Assessee By Shri Pawan Choudhary Revenue By Shri Harendra Verma, Sr. Dr Date Of Hearing 16.02.2026 Date Of Pronouncement 19.02.2026 आदेश / Order Per Sandeep Gosain, Jm: Firstly, We Shall Take Ita No. 2794/Mum/2025, A.Y 2012-13 As Lead Case & Facts Narrated Therein.

vii, Delay condonation application has to be decided on the parameters laid down for condoning the delay and condoning the delay for the reason that the conditions have been imposed. tantamount to disregarding the statutory provision. 10 Sonmrug Co-operative Housing Society Ltd Moreover, there are two essential ingredients for 9. condoning delays: (i) the existence of 'sufficient cause

WIN CABLE & DATACOM P.LTD,MUMBAI vs. ASST CIT (TDS) 3(1), MUMBAI

In the result, appeals filed by the assessee are hereby allowed

Bench: S/Shri R.C. Sharma (Am) & Amarjit Singh (Jm) I.T.A. No. 3635/Mum/2016(Assessment Year 2001-02)

condoned the delay. 4. Now, coming to issue No. 1&2 in which the assessee took the plea of limitation. It is the argument of the representative of the assessee that the show-cause notice in all the cases were issued by the Assessing Officer on 23.9.2003, which was served upon the assessee on 24.9.2003 and the proceedings

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

POMEGRANATE MEDIA (PTY) LTD,SOUTH AFRICA vs. DCIT(IT)-3(3)(2), MUMBAI

Bench: Shri Pramod Kumar & Shri Saktijit Dey

condoning the delay in filing the appeals, we admit them for hearing and adjudication on merits. 5. The solitary common issue in dispute arising in these appeals relate to the nature of income received by the assessee from Endemol India Pvt. Ltd., towards line production services, whether is in the nature of fee for technical service, hence, exhigible