INNO vs. OURCE SERVICES PRIVATE LIMITED,MUMBAIVS.DCIT, 14(1)(1), MUMBAI

In the result, the appeal of the assessee is dismissed

Bench: Shri Om Prakash Kant () & Shri Raj Kumar Chauhan () Assessment Year: 2021-22 Innovsource Services Pvt. Ltd., Dcit, 14(1)(1), 501, Jolly Board Tower 1, I-Think Aayakar Bhavan, Maharshi Karve Vs. Techno Campus Kanjurmarg-East, Road, New Marine Lines, Mumbai-400042. Churchgate, Mumbai-400020. Pan No. Aaeci 0979 D Appellant Respondent

10B or section 10BA and section 80H to 80VV. The action of CPC restricting the deduction under section 80JJAAto action of CPC restricting the deduction under section 80JJAAto action of CPC restricting the deduction under section 80JJAAto the business income of Rs 6,22,44,207/ s income of Rs 6,22,44,207/- is correct

JAN SEVA MANDAL ,MUMBAI vs. INCOME TAX OFFICER EXEMPTION WARD -1(4), MUMBAI

In the result, the appeal filed by the assessee is allowed for In the result, the appeal filed by the assessee is allowed for In the result, the appeal filed by the assessee is allowed for statisti...

Bench: Shri Om Prakash Kant () & Ms. Kavitha Rajagopal () Assessment Year: 2023-24 Jan Seva Mandal, Central Processing Centre Income Vinayalaya, Mahakali Caves Tax Deparment, Bengaluru, Vs. Road, Andheri (East), Income Tax Officer Exemption Mumbai-400093. Ward 1(4), Mumbai. 6Th Floor, Mtnl Te Building, Pedder Road, Mumbai-400026. Pan No. Aaatj 4868 K Appellant Respondent

disallowing amounts amounts amounts accumulated under Section 11 (1 )(a), Section 11(2), and capital accumulated under Section 11 (1 )(a), Section 11(2), and capital accumulated under Section 11 (1 )(a), Section 11(2), and capital expenditure claimed as income application, due to the late filing expenditure claimed as income application, due to the late filing expenditure claimed

ACIT-23(1), MUMBAI, PIRAMAL CHAMBER, MUMBAI vs. PARISHI DIAMONDS, MUMBAI

In the result, the appeal of the Revenue is dismissed

Bench: Shri Om Prakash Kant () & Shri Raj Kumar Chauhan () Assessment Year: 2012-13 Acit-23(1), Parishi Diamonds, 511, 5Th Floor, Piramal Chamber, Cc2091 To Cc 2093 Tower Central Vs. Lalbaug, Parel, Wings Bharat Diamond Bourse Bandra Mumbai-400012. Kurla Complex, Bandra East, Mumbai-400051. Pan No. Aajfp 2118 B Appellant Respondent

1)(e). If due to t assessee to comply to the requirements of Rule 10(1)(e). If due to t assessee to comply to the requirements of Rule 10(1)(e). If due to the reasonable cause, the assessee could not furnish the relevant reasonable cause, the assessee could not furnish the relevant reasonable cause, the assessee could

DCIT 10(3)(2), MUMBAI vs. PHOENIX MECANO (I) PLTD, MUMBAI

In the result, appeal of the Revenue is allowed

Bench: Shri Joginder Singh, Assessment Year:2011-12

1) applies are for the purposes of determining the quantum of deduction to be computed as if such eligible business were the only source of income of the assessee during the previous year relevant to the initial assessment year and to every subsequent assessment year. A provision akin to sub-section (5) of Section 80- IA or for that matter

VINATI OPRGANICS LTD,MUMBAI vs. ADDL CIT 8(3), MUMBAI

In the result, assessee’s appeal stands partly allowed for the statistical purpose and that of the revenue stands dismissed

Bench: Shri Rajendra & Shri Amit Shukla

1,46,672 China 23. Before us, the Ld. Counsel submitted that in ground No.12, the assessee has taken the plea that, even if such disallowances are upheld then such an enhancement will only go to increase the profit of the undertaking and accordingly, the deduction under section 10B

ASST CIT CIR 1, KALYAN vs. ASB INTERNATIONAL P. LTD, AMBERNATH

In the result, appeals filed by the Revenue in ITA No

Bench: Shri Mahavir Singh & Shri Ramit Kocharआयकर अपील सं./I.T.A. No.7034/Mum/2013 & 7035/Mum/2013 ("नधा"रण वष" / Assessment Years : 2004-05 & 2006-07) Asstt. Commissioner Of M/S Asb International बनाम/ Income Tax – Circle 1, Pvt. Ltd., V. Kalyan, E-9, Addl Ambernath Indl. 1St Floor,, Area, Mohan Plaza, Midc Anand Nagar, Wayale Nagar, Ambernath. Khadakpada, Kalyan. "थायी लेखा सं./Pan :Aaaca8424F .. (अपीलाथ" /Appellant) (""यथ" / Respondent)

disallowance only up to the first day of April, 2001, and granting the benefit, of those provisions even in respect of units to which sections 10A and 10B is applicable. The Finance Act, 2003, amended this subsection with retrospective effect from April 1

HINDUSTAN UNILEVER LTD,MUMBAI vs. ITO CIR 1(1)(4), MUMBAI

In the result, both the appeal of the assessee and the revenue are partly allowed

Bench: Shri Vikas Awasthy () & Ms. Padmavathy S. ()

1) to sub section (9) of section 10B states that the sub-section is not applicable to companies in which public are substantially interested. The assessee and LIEL being companies in which public are substantially interested, the Assessing Officer is not correct in making the disallowance

DEPUTY COMMISSIONER OF INCOME TAX 1(1)(2), MUMBAI vs. HINDUSTAN UNILEVER LIMITED, MUMBAI

disallowance under section 14A in respect of\nexpenditure in relation to tax free income.\nCENVAT on closing stock - Section 145A\n5. erred in confirming adjustment to the value of closing stock of raw materials\nand packing materials by Rs. 43,31,47,338/- representing the unutilised\nbalance of Cenvat as on 31.3.2004.\nReduction in deduction under section

HINDUSTAN UNILEVER LIMITED,MUMBAI vs. DY.CIT-1(1)(2), MUMBAI

disallowance under section 14A in respect of\nexpenditure in relation to tax free income.\nCENVAT on closing stock - Section 145A\n5. erred in confirming adjustment to the value of closing stock of raw materials\nand packing materials by Rs. 43,31,47,338/- representing the unutilised\nbalance of Cenvat as on 31.3.2004.\nReduction in deduction under section

PEOPLE INERACTIVE (I) P.LTD,MUMBAI vs. PR CIT 7, MUMBAI

The appeals of the assessee are allowed

Bench: Shri Joginder Singh & Shri Rajesh Kumar

10B of the Act. Even the Income Tax Return Forms i.e. Form No. 1 dated 17.08.2001 and Form No. 6 for the assessment year 2012-13 are equally contradictory. The appellant Revenue would, however contend that, ex facie, from the language appearing in Section 10A it is crystal clear that the aforesaid provision of the Act, as amended by Finance

PEOPLE INERACTIVE (I) P. LTD,MUMBAI vs. PR CIT 7, MUMBAI

The appeals of the assessee are allowed

Bench: Shri Joginder Singh & Shri Rajesh Kumar

10B of the Act. Even the Income Tax Return Forms i.e. Form No. 1 dated 17.08.2001 and Form No. 6 for the assessment year 2012-13 are equally contradictory. The appellant Revenue would, however contend that, ex facie, from the language appearing in Section 10A it is crystal clear that the aforesaid provision of the Act, as amended by Finance

ITO 2(2)(4), MUMBAI vs. MOBIAPPS INDIA P.LTD, MUMBAI

The appeal of the Revenue is dismissed

Bench: Shri Joginder Singh & Shri Ramit Kocharassessment Year: 2008-09 Income Tax Officer-2(2)(4), M/S Mobiapps India Pvt. Ltd. Room No.542, 5Th Floor, 7/10, Borawala Building, बनाम/ Aayakar Bhavan, Horniman Circle, Fort, Vs. M.K. Road, Mumbai-400001 Mumbai-400020 (राज"व /Revenue) ("नधा"रती /Assessee) Pan. No.Aaccm3613L

10B of the Act. Even the Income Tax Return Forms i.e. Form No. 1 dated 17.08.2001 and Form No. 6 for the assessment year 2012-13 are equally contradictory. The appellant Revenue would, however contend that, ex facie, from the language appearing in Section 10A it is crystal clear that the aforesaid provision of the Act, as amended by Finance

STRIDES ARCOLAB LTD,NAVI MUMBAI vs. DCIT CIR 15(3)(2), MUMBAI

The appeal of the assessee is allowed

Bench: Amit Shukla () & Ms. Padmavathy S. ()

1. Disallowance u/s 10B Rs.11,44,12,969/- 2. Disallowance of weighted deduction u/s 35(2AB) Rs. 5,84,54,070/- 3. Disallowance of premium on FCCB Rs.55,44,94,544/- 4. Disallowance under section

SYSCOM CORPORATION PRIVATE LIMITED,MUMBAI vs. PR.CIT-3, MUMBAI

Bench: Shri S. Rifaur Rahman, Am & Shri Ravish Sood, Jm आयकरअपीलसं./ I.T.A. No. 1608/Mum/2018 (निर्धारणवर्ा / Assessment Year: 2012-13)

disallowed the claim of deduction u/s 43 I.T.A. No. 1608/Mum/2018 M/s Syscom Corporation Pvt. Ltd. 10B with respect to the aforesaid three elements of income on the ground that such incomes do not constitute a first degree profit of the 100% EOU. On appeal, the Hon'ble Mumbai ITAT held that the provisions of section 10B(4) are very clear

HEMAL MAGANLAL SHAH,MUMBAI vs. CIT (A) NFAC, DELHI

In the result, appeal filed by the assessee is dismissed

Bench: Shri Aby T Varkey & Shri Gagan Goyalhemal Maganlal Shah 84, 4Th Floor, Pankaj-B, Lbs Road, Ghatkopar (W), Mumbai-400086. Pan: Amfps8271G ...... Appellant Vs. The Commissioner Of Income Tax (Appeals), National Faceless Appeal Centre (Nfac), Mumbai. ..... Respondent Appellant By : Sh. H.M. Shah Respondent By : Sh. Prasoon Kabra Date Of Hearing : 17/05/2022 Date Of Pronouncement : 10/08/2022 Order Per Gagan Goyal, A.M:

Disallowance of claim, effect of) - Assessment year 2005-06 - Where assessee claimed to have made purchases from some parties but it was not able to produce said parties and summons served to them were returned back un-served, penalty under section 271(1)(c) was leviable [In favour of revenue] The assessee-company claimed exemption under section 10B

STRIDES ARCOLAB LTD,NAVI MUMBAI vs. ASST CIR 10(3), MUMBAI

In the result, the appeals assessee is partly allowed for statistical purposes

Bench: Sri Mahavir Singh, Jm & Sri Rajesh Kumar, Am Strides Shasun Limited The Asst. Commissioner Of (Formerly Known As Strides Income Tax Circle 10(3), Arcolab Limited) 201, Mumbai Vs. Devavrata, Sector 17, Vashi, Navi Mumbai-400 703 Appellant .. Respondent Pan No. Aadcs8104P

disallowing the same from 10B units and non 10B units on the basis of actual rent paid.” 31. Briefly stated facts are that the AO and DRP has considered that the sum of ₹ 1,26,05,528/- being rental expenditure claimed by assessee and rent paid to related parties is unreasonable in term of section

SHREE DADAR JAIN PAUSHADHSHALA TRUST,MUMBAI vs. ITO (E_ - 1(2), MUMBAI

In the result, the appeal of the assessee in ITA no

Bench: Shri Pawan Singh & Shri Ramit Kocharआयकर अपीऱ सं./I.T.A. No.2061/Mum/2019 (नििाारण वर्ा / Assessment Year: 2014-15) बिाम/ Shree Dadar Jain Ito(E)-1(2) Paushadhshala Trust, Room No. 501, 5 Th Floor, Aaradhana Bhavan, Piramal Chambers, V. 289, S K Bole Road, Lalbaug, Parel, Dadar West, Mumbai-400012 Mumbai-400028 स्थायी ऱेखा सं./ Pan: Aaats7848E (अपीऱाथी /Appellant) .. (प्रत्यथी / Respondent) Assessee By: Shri. Bhadresh Doshi Revenue By: Shri. Abhi Rama Karthikeyn S. सुनवाई की तारीख /Date Of Hearing : 03.06.2019 घोषणा की तारीख /Date Of Pronouncement : 19.08.2019 आदेश / O R D E R Per Ramit Kochar: This Appeal, Filed By Assessee, Being Ita No. 2061/Mum/2019, Is Directed Against Appellate Order Dated 08/02/2019, Passed By Learned Commissioner Of Income Tax (Appeals)-3, Mumbai (Hereinafter Called ―The Cit(A)‖) In Appeal Number Cit(A)-3/It-10394/2017-18, For Assessment Year 2014-15, The Appellate Proceedings Had Arisen Before Learned Cit(A) From Assessment Order Dated 28.12.2006 Passed By Learned Assessing Officer (Hereinafter Called ―The Ao‖) U/S 143(3) Of The Income-Tax Act, 1961 (Hereinafter Called ―The Act‖) For Ay:2014-15. 2. The Grounds Of Appeal Raised By Assessee In Memo Of Appeal Filed With The Income-Tax Appellate Tribunal, Mumbai (Hereinafter Called ―The Tribunal‖) Read As Under:-

10B declaring total income at Rs. 1,94,770/-. The return of income was processed u/s 143(1) of the 1961 Act. The case was selected for framing scrutiny assessment and notices u/s. 143(2) and u/s. 142(1) were issued by AO to the assessee, which were duly served on the assessee. 3.3 The AO observed during the course

ITO 1(1)(3), MUMBAI vs. EVERYDAY HEALTH INDIA PVT. LTD., MUMBAI

In the result, the appeal of the Revenue is dismissed

Bench: Shri Saktijit Dey & Shri Ramit Kocharआयकर अपीऱ सं./I.T.A. No.2936/Mum/2016 (नििाारण वर्ा / Assessment Year : 2011-12)

1) dated 29.01.2014 as to why deduction u/s 10B of the 1961 Act should not be disallowed due to reasons cited below:- 'On verification of the documentary evidence filed by you in support of your claim u/s 10B, you are hereby required to show cause as to why the claim u/s 10B should not be disallowed as it is noticed

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

1)", "Section 139(4)", "Section 80A(5)", "Section 80AC", "Section 10A", "Section 10AA", "Section 10B", "Section 10BA", "Section 80-IA", "Section 80-IAB", "Section 80-IB", "Section 80-IC", "Section 80-ID", "Section 80-IE", "Section 80P(2)(d)" ], "issues": "Whether the claim for deduction under Section 80P can be disallowed