ASST CIT CIR 6(1)(2), MUMBAI vs. ASK INVESTMENT MANAGERS P.LTD, MUMBAI

The appeal of the Revenue is allowed for statistical

Bench: Shri Joginder Singh & Shri G. Manjunathaassessment Year 2012-13 Acit M/S Ask Investment Circle-6(1)(2), Managers Pvt. Ltd. बनाम/ R. No.536, 5Th Floor, 1St Floor Bandbox House, Vs. Aayakar Bhavan, Dr. Ab Road, Worli, M. K. Road, Churchgate, Mumbai-400030 Mumbai-400020 (राज"व /Revenue) ("नधा"रती /Assessee) P.A. No. Aafca2302P Shri Nitin Waghmode-Dr राज"व क" ओर से / Revenue By "नधा"रती क" ओर से / Assessee By Shri J.D. Mistri Sr. Advocate

2), as increased by- ------------ (f) the amount or amounts of expenditure relatable to any income to which section 10 (other than provisions contained in clause (38) thereof) or section 11 or section 12 apply; --------------- if any amount referred to in clauses (a) to (i) is debited to the profit and loss account, and as reduced by- (i) the amount

BAJAJ CONSULTANTS PRIVATE LIMITED,MUMBAI vs. DY. COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE - 4(1), MUMBAI

In the result the appeal of the assessee is dismissed

Bench: Shri Om Prakash Kant () & Ms. Kavitha Rajagopal () Assessment Year: 2017-18

2. The core controversy in grounds raised pertains to the The core controversy in grounds raised pertains to the The core controversy in grounds raised pertains to the sustainability of the disallowance under Section 14A Section 14A of the Income sustainability of the Tax Act, 1961 [hereinafter ‘the Act’] read with Rule 8D Rule 8D of the Income

SHAPOORJI PALLANJI AND COMPANY P.LTD,MUMBAI vs. ADDL CIT RG 3(3), MUMBAI

The appeal of the assessee is partly allowed

Bench: Shri Joginder Singh & Shri Manoj Kumar Aggarwalassessment Year: 2011-12 M/S Shapoorji Pallonji & Co. Dcit, Ltd. Circle-3(3), बनाम/ Shapporji Pallonji Centre, Room No.609, 6Th Floor, Vs. 41/44 Minoo Desai Marg, Aayakar Bhavan, M.K.Road, Colaba Mumbai-400020 Mumbai-400005 ("नधा"रती /Assessee) (राज"व /Revenue) Pan. No. Aaacs6994C

14A of the Act r.w.r. 8D(2)(iii), against the claim of the assessee at Rs.1 lakh, consequently, the Ld. Assessing Officer is directed to follow the ratio laid down in order dated 27/03/2015 (Assessment Year 2009-10). Thus, ground no. 2 & 3 are disposed off in terms indicated hereinabove. 4. So far as, ground no.4 is concerned, the assessee

HDFC BANK LIMITED (AS SUCCESSOR TO HDFC LTD),MUMBAI vs. DCIT 2(3)(1), MUMBAI

Bench: Shri Anikesh Banerjee & Shri Girish Agrawal

depreciable assets. X. Disallowance of FCCB issue expenses. XI. Set-off of short-term capital loss. XII. Income from India Value Fund. XIII. Addition on account of receipts as per the ITS details not found recorded in the books of account of assessee. XIV. Capital gains in respect of sale of property. X V. Additional claim of the Assessee with

ACIT-1(1)(1), MUMBAI vs. M/S HOUSING DEVELOPMENT FINANCE CORPORATION LTD, MUMBAI

Bench: Shri Anikesh Banerjee & Shri Girish Agrawal

depreciable assets. X. Disallowance of FCCB issue expenses. XI. Set-off of short-term capital loss. XII. Income from India Value Fund. XIII. Addition on account of receipts as per the ITS details not found recorded in the books of assessee. XIV. Capital gains in respect of sale of property. XV. Additional claim of the Assessee with regard to inadvertent

HINDUSTAN PETROLEUM CORP LTD,MUMBAI vs. DCIT 1(1)(2), MUMBAI

Bench: us. 2.

Section 14A of the Act read with Rule 8D of the Rules. In reply thereto, the Assessee submitted reply letter, dated 13/12/2017, wherein it was, inter alia, contended as under: a. The Assessee had not incurred any direct expenditure for earning the exempt income. b. The Investments were made out of surplus funds generated from time to time. In support

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

depreciable assets. X. Disallowance of FCCB issue expenses. XI. Set-off of short-term capital loss. XII. Income from India Value Fund. 11 HDFC Bank Ltd. ITA No.4315/MUM/2007 and Ors. AYs 2002-03 to 2020-21 XIII. Addition on account of receipts as per the ITS details not found recorded in the books of account of assessee. XIV. Capital gains

HDFC BANK LIMITED (AS SUCCESSOR TO HOUSING DEVELOPMENT FINANCE CORPORATION LTD),MUMBAI vs. THE ADDL CIT RG 1(1), MUMBAI

Bench: Shri Anikesh Banerjee & Shri Girish Agrawal

depreciable assets. X. Disallowance of FCCB issue expenses. XI. Set-off of short-term capital loss. XII. Income from India Value Fund. 11 HDFC Bank Ltd. ITA No.4315/MUM/2007 and Ors. AYs 2002-03 to 2020-21 XIII. Addition on account of receipts as per the ITS details not found recorded in the books of account of assessee. XIV. Capital gains

ADDL CIT RG 1(1), MUMBAI vs. HDFC LTD, MUMBAI

Bench: Shri Anikesh Banerjee & Shri Girish Agrawal

14A of the Act. IV. Discount on grant of stock options (ESOP/ESOS) to employees. V. Computation of amount eligible for deduction u/s. 80M of the Act. VI. Deduction of income by the amount credited to lease equalisation account. VII. Assessment of amount withdrawn from reserve created under section 36(1)(viii). VIII. Disallowance of entrance fees and subscriptions paid

ACIT-1(1)(1), MUMBAI vs. M/S. HOUSING DEVELOPMENT FINANCE CORPORATION LTD., DELHI

Bench: Shri Anikesh Banerjee & Shri Girish Agrawal

14A of the Act. IV. Discount on grant of stock options (ESOP/ESOS) to employees. V. Computation of amount eligible for deduction u/s. 80M of the Act. VI. Deduction of income by the amount credited to lease equalisation account. VII. Assessment of amount withdrawn from reserve created under section 36(1)(viii). VIII. Disallowance of entrance fees and subscriptions paid

HDFC BANK LIMITED (AS SUCCESSOR TO HOUSING DEVELOPMENT FINANCE CORPORATION LTD),MUMBAI vs. DCIT 1(1), MUMBAI

Bench: Shri Anikesh Banerjee & Shri Girish Agrawal

14A of the Act. IV. Discount on grant of stock options (ESOP/ESOS) to employees. V. Computation of amount eligible for deduction u/s. 80M of the Act. VI. Deduction of income by the amount credited to lease equalisation account. VII. Assessment of amount withdrawn from reserve created under section 36(1)(viii). VIII. Disallowance of entrance fees and subscriptions paid

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

14A of the Act. IV. Discount on grant of stock options (ESOP/ESOS) to employees. V. Computation of amount eligible for deduction u/s. 80M of the Act. VI. Deduction of income by the amount credited to lease equalisation account. VII. Assessment of amount withdrawn from reserve created under section 36(1)(viii). VIII. Disallowance of entrance fees and subscriptions paid

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

14A of the Act. IV. Discount on grant of stock options (ESOP/ESOS) to employees. V. Computation of amount eligible for deduction u/s. 80M of the Act. VI. Deduction of income by the amount credited to lease equalisation account. VII. Assessment of amount withdrawn from reserve created under section 36(1)(viii). VIII. Disallowance of entrance fees and subscriptions paid

ASST CIT 19(3), MUMBAI vs. PAHILAJRAI JAIKISHIN, MUMBAI

In the result, the appeal is allowed

Bench: Shri Shailendra Kumar Yadav & Shri Ramit Kocharआयकर अपील सं./I.T.A. No.1562/Mum/2014 ("नधा"रण वष" / Assessment Year: 2010-11)

depreciation is a statutory allowance u/s 32 of the Act relying upon the decision of Hon’ble Supreme Court in the case of Nectar Beverages Private Limited v. DCIT (2009) 314 ITR 314(SC). 5. The AO rejected the contentions of the assessee firm and held that the basic objective of introduction of section 14A into

PAHILAJRAI JAIKISHAN,MUMBAI vs. DCIT 19(3), MUMBAI

In the result, the appeal is allowed

Bench: Shri Shailendra Kumar Yadav & Shri Ramit Kocharआयकर अपील सं./I.T.A. No.1562/Mum/2014 ("नधा"रण वष" / Assessment Year: 2010-11)

depreciation is a statutory allowance u/s 32 of the Act relying upon the decision of Hon’ble Supreme Court in the case of Nectar Beverages Private Limited v. DCIT (2009) 314 ITR 314(SC). 5. The AO rejected the contentions of the assessee firm and held that the basic objective of introduction of section 14A into

ACIT-1(1)(1), MUMBAI vs. M/S. HOUSING DEVELOPMENT FINANCE CORPORATION LTD., DELHI

14A on the interest \ncomponent relating to the investments in shares which yielded dividend \nincome have been made out of owned funds and therefore, no part of \nsuch interest expenditure is allocable on this account. Our observations \nand findings on this aspect are not repeated here as already dealt \nelaborately in the above paragraphs. \n13. 5. With respect to allocation

HDFC BANK LIMITED (AS SUCCESSOR TO HOUSING DEVELOPMENT FINANCE CORPORATION LTD),MUMBAI vs. DCIT RANGE-1(1)(2), MUMBAI

14A on the interest\ncomponent relating to the investments in shares which yielded dividend\nincome have been made out of owned funds and therefore, no part of\nsuch interest expenditure is allocable on this account. Our observations\nand findings on this aspect are not repeated here as already dealt\nelaborately in the above paragraphs.\n\n13. 5. With respect

DCIT CIR 1(1), MUMBAI vs. M/S HOUSING DEVELOPEMENT FINANCE CORPORATION LTD, MUMBAI

In the result, appeals of both, assessee and revenue are decided \nas per the table below: \n\nSr

14A on the interest \ncomponent relating to the investments in shares which yielded dividend \nincome have been made out of owned funds and therefore, no part of \nsuch interest expenditure is allocable on this account. Our observations \nand findings on this aspect are not repeated here as already dealt \nelaborately in the above paragraphs. \n\n13. 5. With respect