SATELLITE TELEVISION ASIAN REGION LTD,MUMBAI vs. DDIT (IT) 2(1), MUMBAI

In the result, appeal of the assessee is treated as allowed

Bench: Shri Amit Shukla & Shri Ashwani Taneja

disallowance. Regarding taxation of service fee and up-linking income, he submitted that, the assessee had offered tax @ 10.45% and 20.91%, respectively in the return of income which is in accordance with section 115A

THE BANK OF NOVA SCOTIA,MUMBAI vs. ADDL DIT (IT) RG 3, MUMBAI

In the result, the appeals of the assessee are partly allowed and\nappeals of the revenue are also partly allowed

115A", "Section 44C", "Section 10(15)"], "issues": "The primary issues revolve around the correct computation of disallowances under Section 14A, the allowability

ITO(IT)1(1)(2), MUMBAI vs. ATOS WORLDWIDE INDIA PVT. LTD., MUMBAI

In the result appeal of the Revenue is dismissed

Bench: Shri Joginder Singh & Shri Ramit Kocharआयकर अपीऱ सं./I.T.A. No. 6424/Mum/2016 (नििाारण वर्ा / Assessment Year: 2015-16) बिाम/ Ito(It)1(1)(2) Atos Worldwide India Pvt. R.No. 113, First Floor, Ltd. Scindia House, N.M. Road, 701, Interface-11, V. Ballard Estate, New Link Road, Mumbai- 400038 Malad(W), Mumbai-400064 स्थायी ऱेखा सं./ Pan : Aaace2403J (अपीऱाथी /Appellant) (प्रत्यथी / Respondent) ..

section 90, 115A, 195 of I.T. Act, 1961 and Finance Act, 2013/2014 will be allowed and if not then the benefit of the rate of 20% will be denied in respect of the balance entities will be disallowed

THOMAS COOK (INDIA) LTD,MUMBAI vs. DY CIT 1 (3)92), MUMBAI

In the result, the appeal filed by the assessee is a In the result, the appeal filed by the assessee is a In the result, the appeal filed by the assessee is allowed for statistical purposes

Bench: Shri Om Prakash Kant () & Ms. Kavitha Rajagopal () Assessment Year: 2015-16 Thomas Cook (India) Ltd., Dy. Cit-1(3)(2), A Wing, 11Th Floor, Marathon Room No. 540, 5Th Floor, Vs. Futurex, N.M. Joshi Marg, Aayakar Bhavan, M.K. Lower Parel (East), Road, Mumbai-400013. Mumbai-400020. Pan No. Aaact 4050 C Appellant Respondent Assessee By : Mr. Ketan Ved Revenue By : Ms. Richa Gulati, Dr : Date Of Hearing 30/05/2023 : Date Of Pronouncement 31/05/2023 Order

disallowing Rs.8,70,45,135/ Rs.8,70,45,135/- pertaining to discount on Employee Stock pertaining to discount on Employee Stock Option Plan (being the difference of market price at the time Option Plan (being the difference of market price at the time Option Plan (being the difference of market price at the time of grant of option and exercise

BANK OF NOVA SCOTIA,MUMBAI vs. ADDL DIT (IT) RG 3, MUMBAI

In the result, the appeals of the assessee are partly allowed and\nappeals of the revenue are also partly allowed

disallowance under Section 14A for earning exempt income, allowing deduction for expatriate salaries in certain conditions, and dismissing revenue appeals related to the applicability of Section 115A

ADIT (IT) 3(2), MUMBAI vs. THE BANK NOVA SCOTIA, MUMBAI

In the result, the appeals of the assessee are partly allowed and\nappeals of the revenue are also partly allowed

disallowances for earning exempt income, and applying TNMM as the most appropriate method for transfer pricing.", "result": "Partly Allowed", "sections": [ "Section 14A", "Section 92C(2)", "Section 44C", "Section 115A

DCIT (IT) -1(2)(1), MUMBAI vs. THE BANK OF NOVA SCOTIA, MUMBAI

disallowance. The applicability of Section 115A to interest income and deduction of interest paid to the head office were decided

ABU DHABI COMMERCIAL BANK PJSC,MUMBAI vs. DCIT (INTERNATIONAL TAXATION)-1(1)(1), MUMBAI

In the result, the appeal is partly allowed

Bench: Shri Saktijit Dey, Vp & Ms. Padmavathy S, Am Abu Dhabi Commercial Bank Pjsc Dcit (International Taxation)- Wework India Management Private 1(1)(1) 5Th Floor, Room No. 517, Limited Vs. 2Nd Floor, Express Towers, Air India Building, Nariman Point, Ranath Goenka Marg, Nariman Point, Mumbai-400 021 Mumbai-400 021 Pan/Gir No. Aaaca 4216 B (Appellant) : (Respondent)

section 115A(1)(a)(iiaa) r.w.s. 194LC of the Act, the interest income is subject to concessional tax rate of 5% with applicable surcharge and cess. He submitted, while negating assessee’s claim and holding that the interest income would be subject to tax @ 20% u/s. 115A(1)(a)(ii), the DRP has completely overlooked the press release dated

THE HONGKONG AND SHANGHAI BANKING CORPORATION LIMITED -INDIA BRANCHES ,MUMBAI vs. THE DEPUTY COMMISSIONER OF INCOME TAX (INTERNATIONAL TAXATION)-2(2)(2), MUMBAI

disallowed owing to non deduction of tax at source. The total interest so\ndisallowed is INR 1,192,078 (see serial # 5 (2) of the computation of total income).\nThe bank has been following the circular no. 740 dated 17-4-1996 issued by Central\nBoard of Direct Taxes (copy attached) in the context of interest paid by the bank

DCIT CEN CIR 4(1), MUMBAI vs. GODAWARI CORPORATION LTD, MUMBAI

In the result, the appeal of Revenue is dismissed

Bench: Sri Mahavir Singh, Jm & Sri Ramit Kochar, Am Dy. Commissioner Of Income Tax, M/S Godavari Corporation Central Circle-4(1), Ltd. R. No. 1916, 19Th Floor, Air Vs. Industry House, 159, Backbay India Building, Nariman Point, Reclamation, Churchgate, Mumbai-400 021 Mumbai-400 020 Appellant .. Respondent Pan No. Aaacg1850D Revenue By .. Shri Sunil Kumar Agarwal, Dr Assessee By .. Miss Aarti Vissanji, Ar Date Of Hearing .. 10-04-2017 Date Of Pronouncement .. 10-04-2017 O R D E R Per Mahavir Singh, Jm:

disallowance u/s 14A to 2% of total exempt income and thereby computing adjusted total income under section 115A on revised

THE HONGKONG AND SHANGHAI BANKING CORPORATION LIMITED INDIA BRANCHES ,MUMBAI vs. THE DEPUTY COMMISSIONER OF INCOME TAX (INTERNATIONAL TAXATION)-2(2)(2), MUMBAI

disallowed owing to non deduction of tax at source. The total interest so\ndisallowed is INR 1,192,078 (see serial # 5 (2) of the computation of total income).\nThe bank has been following the circular no. 740 dated 17-4-1996 issued by Central\nBoard of Direct Taxes (copy attached) in the context of interest paid by the bank

SATELLITE TELEVISION ASIAN REGION LTD,MUMBAI vs. DDIT (IT) 2(1), MUMBAI

In the result, assessee’s appeal is partly allowed

Bench: Shri Saktijit Dey & Shri Manoj Kumar Aggarwal

section 115A of the Act. 19. In grounds no.15 to 19, the assessee has challenged disallowance made under section 40(a)(i) of the Act in respect

ADIT CIR 3(2), MUMBAI vs. THE BANK OF NOVA SCOTIA, MUMBAI

disallowance of expenditure for earning exempt income under Section 14A was not warranted as the assessee had sufficient interest-free funds. Regarding expatriate salary, the Tribunal found that the expenditure was deductible as the employees had offered their global income in India and continuously worked for the Indian branches. The Tribunal also ruled that the applicability of Section 115A

THE BANK OF NOVA SCOTIA,MUMBAI vs. ADIT (IT) 3(2), MUMBAI

In the result, the appeals of the assessee are partly allowed and\nappeals of the revenue are also partly allowed

disallowances, and applicability of Section 115A to foreign currency loan interest income.", "held": "The Tribunal largely followed its own previous

THE HONGKONG AND SHANGHAI BANKING CORPORATION LIMITED ,MUMBAI vs. THE DEPUTY COMMISSIONER OF INCOME TAX (INTERNATIONAL TAXATION)-2(2)(2), MUMBAI

disallowed owing to non deduction of tax at source. The total interest so\ndisallowed is INR 1,192,078 (see serial # 5 (2) of the computation of total income).\nThe bank has been following the circular no. 740 dated 17-4-1996 issued by Central\nBoard of Direct Taxes (copy attached) in the context of interest paid by the bank

CHETAN SHANTIAL SHAH,BARODA vs. ITO (IT) 2(1), MUMBAI

In the result this ground of appeal is allowed for statistical purpose

Bench: Shri G.S. Pannu & Shri Pawan Singhshri Chetan Shantilal Shah Ito (International Taxation)- 36, Lavkush Apartment, 2(1), Mumbai. Pratapganj, Vs. Baroda-390002 Pan: Blnps4745R Appellant Respondent Appellant By : Shri Nirmit Mehta (Ar) Respondent By : Shri Himanshu Sharma (Sr. Dr) Date Of Hearing : 08.08.2018 Date Of Pronouncement : 13.08.2018 Order Under Section 254(1)Of Income Tax Act Per Pawan Singh;

disallowing the tax credit on the addition of Rs. 21,76,154/-. (vi) The learned Commissioner (Appeals) erred in facts and in law in confirming action of assessing officer in charge interest under section 234B of the Act. (vii) The learned Commissioner (Appeals)erred in facts and in law in confirming action of assessing officer in charging interest under section

THE BANK OF NOVA SCOTIA,MUMBAI vs. ADIT (IT) 3(2), MUMBAI

disallowance of expatriate salary, transfer pricing adjustments, and applicability of Section 115A. Several grounds were dismissed as not pressed, while

THE BANK OF NOVA SCOTIA,MUMBAI vs. ADDL CIT (IT) 3, MUMBAI

In the result, the appeals of the assessee are partly allowed and\nappeals of the revenue are also partly allowed

disallowance of expenditure for earning exempt income, allowing expatriate salary deductions, and upholding certain transfer pricing methodologies while allowing others.", "result": "Partly Allowed", "sections": [ "Sec. 14A", "Sec. 10(15)", "Sec. 92C", "Sec. 44C", "Sec. 115A