ADITYA BIRLA SUN LIFE AMC LIMITED,MAHARASHTRA vs. THE DEPUTY COMMISSIONER OF INCOME TAX-CIRCLE 6(1)(1), MAHARASHTRA

143(3)", "Section 144B", "Section 80G", "Section 36(1)(va)", "Section 40(a)(ia)", "Section 43B", "Section 234B", "Section 234C", "Section 270A", "Section 115P", "Section 111A", "Section 112A", "Section 234D", "Section 244A", "Section 199", "Rule 37BA of the Income-tax Rules, 1962"], "issues": "The appeals involve multiple assessment years and grounds, including challenges to disallowances

ADITYA BIRLA SUN LIFE AMC LIMITED,MAHARASHTRA vs. THE DEPUTY COMMISSIONER OF INCOME TAX- CIRCLE 6 (1)(1), MAHARASHTRA

143(3) read with section\n144B of the Act for A.Ys. 2018–19, 2022–23 and 2023–24. In the\ncourse of assessment proceedings, the Assessing Officer\nexamined the allowability of deduction claimed under section 80G\nin respect of CSR related payments, employees' contribution to\nprovident fund under section 36(1)(va), disallowance

ADITYA BIRLA SUN LIFE AMC LIMITED,MAHARASHTRA vs. THE DEPUTY COMMISSIONER OF INCOME TAX- CIRCLE 6(1)(1), MAHARASHTRA

Bench: Shri Amit Shukla & Shri Makarand Vasant Mahadeokar1. Ita No. 6663/Mum/2025 (Assessment Year: 2017-18) 2. Ita No. 6701/Mum/2025 (Assessment Year: 2018-19) 3. Ita No. 6702/Mum/2025 (Assessment Year: 2022-23) & 4. Ita No. 6703/Mum/2025 (Assessment Year: 2023-24) Aditya Birla Sun Life Dcitcircle-6(1)(1), Amc Limited, Room No. 502, 5Th 17Th Floor, One World Vs. Floor, Aayakar Centre Tower-1, Jupiter Bhavan, M. K. Mill Compount, 841, Road, Churchgate, Senapati Bapat Marg, Mumbai-400 020 Delisle Road, S.O. Mumbai-400 013 Pan/Gir No. Aaacb6134D (Applicant) (Respondent) Assessee By Shri Ronak Doshi, Shri Shrey Agrawal & Shri Aadish Jain, Ld. Ars Revenue By Shri Surendra Mohan, Ld. Dr Date Of Hearing 27.01.2026 Date Of Pronouncement 06.02.2026

143(3) read with section 144B of the Act for A.Ys. 2018–19, 2022–23 and 2023–24. In the course of assessment proceedings, the Assessing Officer examined the allowability of deduction claimed under section 80G in respect of CSR related payments, employees’ contribution to provident fund under section 36(1)(va), disallowance

THE NEW INDIA ASSURANCE CO. LTD ,MUMBAI vs. DEPUTY COMMISSIONER OF INCOME TAX, CIRCLE -3(2)(2), MUMBAI

3)\nof section 143 or this section has been made for the\nrelevant assessment year, no action shall be taken under\nthis section after the expiry of four years from the end of\nthe relevant assessment year, unless any income\nchargeable to tax has escaped assessment for such\n assessment year by reason of the failure on the part

DCIT 3.2.1, MUMBAI vs. THE NEW INDIA ASSURANCE CO LIMITED, MUMBAI

3)\nof section 143 or this section has been made for the\nrelevant assessment year, no action shall be taken under\nthis section after the expiry of four years from the end of\nthe relevant assessment year, unless any income\nchargeable to tax has escaped assessment for such\n assessment year by reason of the failure on the part

DCIT 3.2.1, MUMBAI vs. THE NEW INDIA ASSURANCE CO LIMITED, MUMBAI

3)\nof section 143 or this section has been made for the\nrelevant assessment year, no action shall be taken under\nthis section after the expiry of four years from the end of\nthe relevant assessment year, unless any income\nchargeable to tax has escaped assessment for such\n assessment year by reason of the failure on the part

THE NEW INDIA ASSURANCE CO. LTD,MUMBAI vs. ASSISTANT COMMISSIONER OF INCOME TAX , INCOME TAX OFFICER, NFAC, MUMBAI

Accordingly, in terms of the aforesaid, Ground No. 3 to\n7 raised by the Assessee pertaining to merits of such\nadditions/disallowances are dismissed as having been rendered\ninfructuous

Bench: "CLEAN_TEXT": "IN THE INCOME TAX APPELLATE TRIBUNAL\n\"I\" BENCH, MUMBAI\n\nSHRI VIKRAM SINGH YADAV , ACCOUNTANT MEMBER\nSHRI RAHUL CHAUDHARY (Judicial Member)

3)\nof section 143 or this section has been made for the\nrelevant assessment year, no action shall be taken under\nthis section after the expiry of four years from the end of\nthe relevant assessment year, unless any income\nchargeable to tax has escaped assessment for such\n assessment year by reason of the failure on the part

TASKUS INDIA PRIVATE LIMITED,MUMBAI vs. CIRCLE 8(3)(1), MUMBAI

Bench: Shri Sandeep Gosain () & Shri Om Prakash Kant () Assessment Year: 2022-23 M/S Taskus India Pvt. Ltd., 1. Dy. Director Of Income- Ttc Industrial Area, Tower -9, Tax Central Processing Vs. Gigaplex It Park, 18Th & 19Th Centre Unit, Bengaluru, Floor, Midc, Plot No. 1 I.T.5, 1St Floor, Prestige Alpha Airoli Knowledge Park Rd, Airoli, No 48/1, 48/2 Navi Mumbai-400708. Beratenaagrahara Begur Hosur Rd Uttarahali Hobli, Bengaluru- 560100. 2. The Dy. Cit, Circle 8(3)(1), Mumbai. Aayakar Bhavan, M.K. Road, Mumbai-400020. Pan No. Aahct 0980 G Appellant Respondent

disallowance of the deduction, it appears that the tion, it appears that the adjustment was made by invoking clause (v) of Section 143(1)(a), adjustment was made by invoking clause (v) of Section 143(1)(a), adjustment was made by invoking clause (v) of Section 143(1)(a), taking the view that the return was not filed within

DY. COMMISSIONER OF INCOME TAX-5(2)(1), MUMBAI, MUMBAI vs. ADITYA BIRLA HOUSING FINANCE LIMITED, MUMBAI

Bench: SHRI OM PRAKASH KANT, ACCOUNTANT MEMBER SHRI RAHUL CHAUDHARY (Judicial Member)

3) read with Section 144B of the Act. 4.2. In appeal filed against the aforesaid assessment order, the Assessee raised grounds challenging the variation/adjustment made vide intimation, dated 25/10/2022, issued under Section 143(1) of the Act. The CIT(A) vide Order, dated 11/07/2024, allowed aforesaid grounds and granted relief to the Assessee, inter alia, by (a) deleting the disallowance

DY. COMMISSIONER OF INCOME TAX-5(2)(1), MUMBAI, MUMBAI vs. ADITYA BIRLA HOUSING FINANCE LIMITED, MUMBAI

Bench: SHRI OM PRAKASH KANT, ACCOUNTANT MEMBER SHRI RAHUL CHAUDHARY (Judicial Member)

3) read with Section 144B of the Act. 4.2. In appeal filed against the aforesaid assessment order, the Assessee raised grounds challenging the variation/adjustment made vide intimation, dated 25/10/2022, issued under Section 143(1) of the Act. The CIT(A) vide Order, dated 11/07/2024, allowed aforesaid grounds and granted relief to the Assessee, inter alia, by (a) deleting the disallowance

DY. COMMISSIONER OF INCOME TAX-5(2)(1), MUMBAI, MUMBAI vs. ADITYA BIRLA HOUSING FINANCE LIMITED, MUMBAI

Bench: SHRI OM PRAKASH KANT, ACCOUNTANT MEMBER SHRI RAHUL CHAUDHARY (Judicial Member)

3) read with Section 144B of the Act. 4.2. In appeal filed against the aforesaid assessment order, the Assessee raised grounds challenging the variation/adjustment made vide intimation, dated 25/10/2022, issued under Section 143(1) of the Act. The CIT(A) vide Order, dated 11/07/2024, allowed aforesaid grounds and granted relief to the Assessee, inter alia, by (a) deleting the disallowance

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

143(3) order the claim under Section 80JJAA itself is disallowed and a finding is given disallowed and a finding

ESSEL MINING & INDUSTRIES LIMITED,MUMBAI vs. DEPUTY COMMISSIONER OF INCOME TAX - CENTRAL CIRCLE 1(4), MUMBAI

In the result, the appeal of the Revenue for assessment year the result, the appeal of the Revenue for assessment year the result, the appeal of the Revenue for assessment year

Bench: Shri Aby T Varkey () & Shri Om Prakash Kant () Assessment Year: 2011-12 & Assessment Year: 2012-13 Essel Mining & Industries Ltd., Dy. Cit, Central Circle-1(4), Industry House, 18Th Floor, 10, 9Th Floor, Old Cgo Building, Camac Street, Vs. Mk Road, Kolkata-700017. Mumbai-400020. Pan No. Aaace 6607 L Appellant Respondent Assessment Year: 2011-12 & Assessment Year: 2012-13 Jcit, Central Circle-1(4), M/S Essel Mining & Industries Room No. 902, Pratishtha Ltd., Bhavan, 9Th Floor, Old Cgo Vs. Industry House, 18Th Floor, 10, Building Annexe, Camac Street, Mumbai-400020. Kolkata-700017. Pan No. Aaace 6607 L Appellant Respondent Assessment Year: 2011-12 M/S Essel Mining & Industries Dy. Cit, Central Circle-1(4), Ltd., 9Th Floor, Old Cgo Building, Vs. Industry House, 18Th Floor, 10, Mk Road

3, the Revenue is aggrieved with the deletion of In ground No. 3, the Revenue is aggrieved with the deletion of In ground No. 3, the Revenue is aggrieved with the deletion of disallowance of deduction u/s 80IA of the Act amounting to disallowance of deduction u/s 80IA of the Act amounting to disallowance of deduction u/s 80IA

ESSEL MINING & INDUSTRIES LIMITED,MUMBAI vs. DY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-1(4), MUMBAI

In the result, the appeal of the Revenue for assessment year the result, the appeal of the Revenue for assessment year the result, the appeal of the Revenue for assessment year

Bench: Shri Aby T Varkey () & Shri Om Prakash Kant () Assessment Year: 2011-12 & Assessment Year: 2012-13 Essel Mining & Industries Ltd., Dy. Cit, Central Circle-1(4), Industry House, 18Th Floor, 10, 9Th Floor, Old Cgo Building, Camac Street, Vs. Mk Road, Kolkata-700017. Mumbai-400020. Pan No. Aaace 6607 L Appellant Respondent Assessment Year: 2011-12 & Assessment Year: 2012-13 Jcit, Central Circle-1(4), M/S Essel Mining & Industries Room No. 902, Pratishtha Ltd., Bhavan, 9Th Floor, Old Cgo Vs. Industry House, 18Th Floor, 10, Building Annexe, Camac Street, Mumbai-400020. Kolkata-700017. Pan No. Aaace 6607 L Appellant Respondent Assessment Year: 2011-12 M/S Essel Mining & Industries Dy. Cit, Central Circle-1(4), Ltd., 9Th Floor, Old Cgo Building, Vs. Industry House, 18Th Floor, 10, Mk Road

3, the Revenue is aggrieved with the deletion of In ground No. 3, the Revenue is aggrieved with the deletion of In ground No. 3, the Revenue is aggrieved with the deletion of disallowance of deduction u/s 80IA of the Act amounting to disallowance of deduction u/s 80IA of the Act amounting to disallowance of deduction u/s 80IA

MAHARASHTRA STATE ELECTRICITY TRANSMISSION COMPANY LTD.,,MUMBAI vs. THE INCOME TAX OFFICER, WARD-14(2)(3), MUMBAI

In the result, the appeal of the assessee is al

Bench: Shri Vikas Awasthy () & Shri Om Prakash Kant () Assessment Year: 2011-12 Maharashtra State Electricity Income-Tax Officer, Ward Transmission Company Ltd., 14(2)(3), Plot No. C-19 E Block, Vs. Aayakar Bhavan, Maharshi Prakashganga, Bandra-Kurla Karve Road, Complex, Bandra (East), Mumbai-400020. Mumbai-400051. Pan No. Aaecm 2936 N Appellant Respondent Assessee By : Mr. Ketan Ved, Ar Revenue By : Mr. Harishankar Lal, Dr : Date Of Hearing 15/11/2022 Date Of Pronouncement : 29/12/2022

section 143(3) of the Act. The Assessing Officer chose not to disallow the claim of the Petitioner for deductions

DCIT 3.2.1, MUMBAI vs. THE NEW INDIA ASSURANCE CO LIMITED, MUMBAI

Accordingly, in terms of the aforesaid, Ground No. 3 to\n7 raised by the Assessee pertaining to merits of such\nadditions/disallowances are dismissed as having been rendered\ninfructuous

3)\nof section 143 or this section has been made for the\nrelevant assessment year, no action shall be taken under\nthis section after the expiry of four years from the end of\nthe relevant assessment year, unless any income\nchargeable to tax has escaped assessment for such\n assessment year by reason of the failure on the part

MANOHAR MANAK ALLOYS P.LTD,MUMBAI vs. ACIT 4(2), MUMBAI

Appeal is allowed

143(3) of the Act on 30.03.1998. Subsequently, reassessment proceeding were initiated in respect of three issues viz., (i) the expenses claimed for share issue, (ii) bad and doubtful debts and, (iii) excess depreciation on gas cylinders and goods containers. The reassessment order was passed on 28.03.2002. Subsequently, 12 Assessment Years: 2017-18 on 29.03.2004, order under Section

THE NEW INDIA ASSURANCE CO. LTD ,MUMBAI vs. DEPUTY COMMISSIONER OF INCOME TAX, CIRCLE-3(2)(2), MUMBAI

3) \nof section 143 or this section has been made for the \nrelevant assessment year, no action shall be taken under \nthis section after the expiry of four years from the end of \nthe relevant assessment year, unless any income \nchargeable to tax has escaped assessment for such \n assessment year by reason of the failure on the part

DR BATRAS POSITIVE HEALTH CLINIC PRIVATE LIMITED,MUMBAI vs. CIT(A), NATIONAL FACELESS APPEAL CENTRE

In the result, all the appeals of the assessee

Bench: Shri Om Prakash Kant () & Shri Pavan Kumar Gadale () Ita Nos. 2748, 2747 & 2761/Mum/2023 Assessment Year: 2011-12, 2012-13 & 2013-14 Dr Batras Positive Health Clinic Cit(A), National Faceless Pvt. Ltd., Appeal Centre, Delhi. 2Nd Floor, H Kantilal Compound, Vs. Andheri Kurla Road, Sakinaka Andheri East-400072 Pan No. Aabcd 3857 G Appellant Respondent

section 147 of the Act on 28/12/2018, the Assessing Officer disallowed following on on 28/12/2018, the 28/12/2018, the Assessing Officer disallowed Assessing Officer disallowed expenses: (i) Business promotion expenses amounting to Business promotion expenses amounting to ₹3,72,89,606/ 606/- ; (ii) Depreciation on ‘yacht ‘yacht’ amounting to ₹29,62,433/-and (iii) Repair expenses of the yacht amounting