MESSE FRANKFURT TRADE FAIRS INDIA PRIVATE LIMITED,MUMBAI vs. DEPUTY COMMISSIONER OF INCOME TAX 2(2)(1), MUMBAI

Bench: Shri Saktijit Dey & Shri Makarand Vasant Mahadeokar1. Ita No. 6498/Mum/2025 (Assessment Year: 2018-19) & 2. Ita No. 6680/Mum/2025 (Assessment Year: 2018-19) Messe Frankfurt Trade Dcit – 2(2)(1), Fairs India Private Income Tax Limited, Vs. Department, 501, 5Th Floor, Gala Mumbai-400 020 Impecca, Mumbai, Chakala Midc S.O, Mumbai-400 093. Pan/Gir No. Aabcm0696G (Applicant) (Respondent) Assessee By Shri Ninad Patade, Ld. Ar Revenue By Shri Annavaram Kosuri, Ld. Dr Date Of Hearing 18.02.2026 Date Of Pronouncement 19.02.2026

depreciation on intangible assets and sustained only the disallowance of deduction under section 80G of Rs. 9,90,000/-, the assessee, considering the quantum of tax involved and with a view to avoid protracted and costly litigation, consciously chose not to pursue further appeal before the Tribunal. 4. It is further stated that subsequently penalty proceedings under section 270A

FAYZ E HUSAYNI TRUST,MUMBAI vs. NATIONAL FACELESS APPEAL CENTRE (NAFC) DELHI , MUMBAI

In the result, appeal filed by the assessee is allowed

depreciation in subsequent years, reinforcing the argument of inadvertence.", "result": "Allowed", "sections": ["Section 11(6)", "Section 143(2)", "Section 142(1)", "Section 270A

TRIG DETECTIVES PVT LTD ,MUMBAI vs. DCIT-CENTRAL CIRCLE 1(2), MUMBAI

In the result, the appeals filed by the assessee bearing ITA Nos

Bench: Shri Anikesh Banerjee & Shri Prabhash Shankar

depreciation is also cancelled. The relevant grounds of the appeal of the assessee are allowed.” 5. With respect to the penalty proceedings for AYs 2017–18 to 2019–20, the penalties were levied under section 270A

TRIG DETECTIVES PVT LTD,MUMBAI vs. DCIT-CENTRAL CIRCLE 1(2), MUMBAI

In the result, the appeals filed by the assessee bearing ITA Nos

Bench: Shri Anikesh Banerjee & Shri Prabhash Shankar

depreciation is also cancelled. The relevant grounds of the appeal of the assessee are allowed.” 5. With respect to the penalty proceedings for AYs 2017–18 to 2019–20, the penalties were levied under section 270A

TRIG DETECTIVES PVT LTD,MUMBAI vs. DCIT-CENTRAL CIRCLE 1(2), MUMBAI

In the result, the appeals filed by the assessee bearing ITA Nos

Bench: Shri Anikesh Banerjee & Shri Prabhash Shankar

depreciation is also cancelled. The relevant grounds of the appeal of the assessee are allowed.” 5. With respect to the penalty proceedings for AYs 2017–18 to 2019–20, the penalties were levied under section 270A

TRIG DETECTIVES PVT LTD,MUMBAI vs. DCIT -CENTRAL CIRCLE -1(2), MUMBAI

In the result, the appeals filed by the assessee bearing ITA Nos

Bench: Shri Anikesh Banerjee & Shri Prabhash Shankar

depreciation is also cancelled. The relevant grounds of the appeal of the assessee are allowed.” 5. With respect to the penalty proceedings for AYs 2017–18 to 2019–20, the penalties were levied under section 270A

TRIG DETECTIVES PVT LTD,MUMBAI vs. DCIT CENTRAL CIRCLE 1(2), MUMBAI

In the result, the appeals filed by the assessee bearing ITA Nos

Bench: Shri Anikesh Banerjee & Shri Prabhash Shankar

depreciation is also cancelled. The relevant grounds of the appeal of the assessee are allowed.” 5. With respect to the penalty proceedings for AYs 2017–18 to 2019–20, the penalties were levied under section 270A

TRIG DETECTIVES PVT LTD,MUMBAI vs. DCIT CENTRAL CIRCLE 1(2), MUMBAI

In the result, the appeals filed by the assessee bearing ITA Nos

Bench: Shri Anikesh Banerjee & Shri Prabhash Shankar

depreciation is also cancelled. The relevant grounds of the appeal of the assessee are allowed.” 5. With respect to the penalty proceedings for AYs 2017–18 to 2019–20, the penalties were levied under section 270A

TRIG DETECTIVES PVT LTD,MUMBAI vs. DCIT-CENTRAL CIRCLE 1(2), MUMBAI

In the result, the appeals filed by the assessee bearing ITA Nos

Bench: Shri Anikesh Banerjee & Shri Prabhash Shankar

depreciation is also cancelled. The relevant grounds of the appeal of the assessee are allowed.” 5. With respect to the penalty proceedings for AYs 2017–18 to 2019–20, the penalties were levied under section 270A

PODAR LITERACY AND EDUCATION TRUST,BANGALORE vs. DCIT CENTRAL CIRCLE - 1(4), MUMBAI, MUMBAI

In the result, the appeal of the assessee is allowed

depreciation was bona\nfide, that there was no concealment or misrepresentation,\nthat its income was otherwise exempt under section 11 of the\nAct, and that no tax advantage had accrued to it.\n7. The Assessing Officer was not convinced with the\nexplanation furnished. He proceeded to pass an order dated\n21.06.2023 under section 270A

TRENT LIMITED ,MUMBAI vs. DEPUTY COMMISSIONER OF INCOME TAX 2(3)(1), MUMBAI

In the result, the appeal filed by the assessee is allowed

depreciation under Section 32(1) read with Explanation 3(b) of the Act. The amendment by the Finance Act, 2021, is not applicable to the assessment year 2018-19.", "result": "Allowed", "sections": [ "Section 2(11)", "Section 2(42C)", "Section 32(1)", "Section 115JB", "Section 143(3)", "Section 144B", "Section 270A

DCIT-14(1)(1), MUMBAI vs. HINDUSTAN DIAMOND COMPANY PVT. LTD., MUMBAI

In the result, appeal of the revenue bearing ITA 166/Mum/2024 is dismissed

Bench: Shriamarjit Singh & Shri Anikesh Banerjee

section 5 Hindustan Diamond Company Pvt Ltd 270A(2); the question that the appellant has under-reported income inconsequence of misreporting of income does not arise. Thus, the AO has erred in levying the penalty u/s 270A of the Act treating that the appellant has under-reported income inconsequence of misreporting of income. Hence, the AO is directed to cancel

NARROTAM MORARJEE INSTITUTE OF SHIPPING,MUMBAI vs. ITO (EXEMPTION)WARD 2(1), MUMBAI

In the result, appeal of the assessee is allowed

Bench: Shri Amit Shukla & Shri Girish Agrawalassessment Year: 2018-19 Narrotam Morarjee Institute Of National Faceless Shipping, Mumbai Assessment Appeal Centre 76 – Jolly Maker, Chambers – 2, (Nfac) Office Of The Vs. Vivek Shah, Mumbai, Nariman Commissioner Of Income Point S.O.-400021 Tax, Appeal, Addl/Jcit(A) Delhi (Pan : Aaatn0042R) (Appellant) (Respondent) Present For: Assessee : Shri Nishit Gandhi, Advocate Revenue : Shri Leyaqat Ali Afaqui, Sr. Dr Date Of Hearing : 18.11.2025 Date Of Pronouncement : 16.02.2026 O R D E R Per Girish Agrawal: This Appeal Filed By The Assessee Is Against The Order Of Commissioner Of Income Tax (Appeal), National Faceless Appeal Centre (Nfac), Delhi Vide Order No. Itba/Nfac/S/250/2025- 26/1078465227(1) Dated 14.07.2025 Passed Against The Penalty Order U/S. 270A Of The Income-Tax Act, 1961 (Hereinafter Referred To As The “Act”), For Ay 2018-19. 2. Grounds Taken By The Assessee Are Reproduced As Under: 1. In The Facts & Circumstances Of The Case & In Law, The Learned Commissioner Of Income Tax (Appeals), National Faceless Appeals Centre, Delhi ["The Cit (A)") U/S 250 Of The Income Tax Act, 1961 ["The Act For Short Erred In Confirming The Penalty U/S 270A Of The Act Passed

Section 11(6), depreciation is not allowable and thus, held it to be disallowed. In this regard also, penalty proceedings u/s 270A

MOUNT MARY NAGARI CO OP CREDIT SOCIETY LIMITED ,MUMBAI vs. INCOME TAX OFFICER WARD 23(2)(3), MUMBAI, MUMBAI

In the result, the appeal preferred by the assessee is allowed for\nstatistical purposes

depreciation claimed of\nRs.3,96,987/- also is not allowed. Penalty proceedings u/s 270A of the Income\ntax Act 1961 are initiated separately for under-reporting of income as the\nassessee has not disclosed the same by filing of the return of income Penalty\nproceedings u/s 271F is initiated separately for not filing the return on time.\nThus the profit

GOLDMAN SACHS (INDIA) FINANCE PRIVATE LIMITED,MUMBAI vs. ASSESSMENT UNIT, INCOME-TAX DEPARTMENT, NEW DELHI

In the result, the appeal by the assessee is partly allowed for statistical\npurposes

depreciation under section 32 of the Act.\n2. Ground No. 2: Disallowance of expense on account of restricted\nstock unit scheme of INR 2,46,38,547\n2.1 The learned AO erred in disallowing the cost in respect of Restricted Stock\nUnits (RSU) granted to its employees of INR 2,46,38,547 on the ground that\nthe same

DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-2(4), MUMBAI, MUMBAI vs. JYOTHY LABS LIMITED, MUMBAI

In the result, both the appeals bearing ITA Nos 515 & 516/Mum/2025 filed by the revenue are dismissed

Bench: Shri Anikesh Banerjee & Shri Omkareshwar Chidara

depreciation which has not been visited with penalty under section 271(1)(c) of the Act for “furnishing of inaccurate particulars”. In this view of the matter and as also bearing in mind the entirety of the case, we deem it fit and proper to delete the impugned penalty. The assessee gets relief accordingly.” The Ld.AR further argued and filed

DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-2(4), MUMBAI , MUMBAI vs. JYOTHY LABS LIMITED, MUMBAI

In the result, both the appeals bearing ITA Nos 515 & 516/Mum/2025 filed by the revenue are dismissed

Bench: Shri Anikesh Banerjee & Shri Omkareshwar Chidara

depreciation which has not been visited with penalty under section 271(1)(c) of the Act for “furnishing of inaccurate particulars”. In this view of the matter and as also bearing in mind the entirety of the case, we deem it fit and proper to delete the impugned penalty. The assessee gets relief accordingly.” The Ld.AR further argued and filed

ANSHUL SPECIALTY MOLECULES PVT LTD,MUMBAI vs. DCIT, CIRCLE 1(1)(1), MUMBAI

In the result, the appeal filed by the assessee is allowed

Bench: Shri Amit Shukla & Shri Makarand Vasant Mahadeokaranshul Speciality Dcit Circle Molecules Private 1(1)(1), Mumbai Limited Vs. Aayakar Bhawani, Flexcel Park, „C‟ Wing, S.V. Mumbai-400 020 Road, Nr. 24 Karat Multiplex, Jogeshwari (W), Mumbai- 400102 Pan/Gir No. Aabca4003H (Applicant) (Respondent) Assessee By Shri H. N. Motiwala, Revenue By Shri Surendra Mohan, Sr. Dr Date Of Hearing 20.01.2026 Date Of Pronouncement 22.01.2026

depreciation of Rs. 1,22,44,409/-, added the same to the income of the assessee, and completed the assessment under section 143(3) read with section 144B of the Act at a total income of Rs. 20,82,99,380/-. Penalty proceedings under section 270A