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, 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

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

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

DCIT-2(3)(1), MUMBAI, MUMBAI vs. HDFC BANK LIMITED, MUMBAI

In the result, the assessee's appeal for AY 2016-17 to AY 2018-19 is allowed and the Revenue's appeal for AY 2016-17 to 2018-19 is dismissed

Bench: Shri Kuldip Singh, Jm & Ms Padmavathy S, Am

condone the delay of 120 days in filing the appeal and admit the appeal for adjudication. ITA.No.3375/Mum/2023 Disallowance under section 14A – Ground No.1 22. The contention of the Revenue is that the CIT(A) erred in not appreciating that the amendment brought in by Finance Act 2022 to section 14A whereby it has been clarified that the provisions

DCIT 2(3)(1), MUMBAI vs. HDFC BANK LIMITED , MUMBAI

In the result, the assessee's appeal for AY 2016-17 to AY 2018-19 is allowed and the Revenue's appeal for AY 2016-17 to 2018-19 is dismissed

Bench: Shri Kuldip Singh, Jm & Ms Padmavathy S, Am

condone the delay of 120 days in filing the appeal and admit the appeal for adjudication. ITA.No.3375/Mum/2023 Disallowance under section 14A – Ground No.1 22. The contention of the Revenue is that the CIT(A) erred in not appreciating that the amendment brought in by Finance Act 2022 to section 14A whereby it has been clarified that the provisions

HDFC BANK LIMITED,MUMBAI vs. THE DEPUTY COMMISSIONER OF INCOME TAX-2(3)(1), MUMBAI

In the result, the assessee's appeal for AY 2016-17 to AY 2018-19 is allowed and the Revenue's appeal for AY 2016-17 to 2018-19 is dismissed

Bench: Shri Kuldip Singh, Jm & Ms Padmavathy S, Am

condone the delay of 120 days in filing the appeal and admit the appeal for adjudication. ITA.No.3375/Mum/2023 Disallowance under section 14A – Ground No.1 22. The contention of the Revenue is that the CIT(A) erred in not appreciating that the amendment brought in by Finance Act 2022 to section 14A whereby it has been clarified that the provisions

HDFC BANK LIMITED,MUMBAI vs. THE DEPUTY COMMISSIONER OF INCOME TAX-2(3)(1), MUMBAI

In the result, the assessee's appeal for AY 2016-17 to AY 2018-19 is allowed and the Revenue's appeal for AY 2016-17 to 2018-19 is dismissed

Bench: Shri Kuldip Singh, Jm & Ms Padmavathy S, Am

condone the delay of 120 days in filing the appeal and admit the appeal for adjudication. ITA.No.3375/Mum/2023 Disallowance under section 14A – Ground No.1 22. The contention of the Revenue is that the CIT(A) erred in not appreciating that the amendment brought in by Finance Act 2022 to section 14A whereby it has been clarified that the provisions

HDFC BANK LIMITED,MUMBAI vs. THE DEPUTY COMMISSIONER OF INCOME TAX-2(3)(1), MUMBAI

In the result, the assessee's appeal for AY 2016-17 to AY 2018-19 is allowed and the Revenue's appeal for AY 2016-17 to 2018-19 is dismissed

Bench: Shri Kuldip Singh, Jm & Ms Padmavathy S, Am

condone the delay of 120 days in filing the appeal and admit the appeal for adjudication. ITA.No.3375/Mum/2023 Disallowance under section 14A – Ground No.1 22. The contention of the Revenue is that the CIT(A) erred in not appreciating that the amendment brought in by Finance Act 2022 to section 14A whereby it has been clarified that the provisions