BAJAJ ELECTRICALS LTD,MUMBAI vs. ADDL CIT 2(1), MUMBAI

Accordingly we remit the impugned issue back to the AO with similar directions. The grounds raised by the assessee in this regard are allowed for statistical purposes

Bench: Hon’Ble Justice (Retd.) C V Bhadang & Ms Padmavathy S, Am

145,57,22,635/- respectively. The assessee's case was selected for scrutiny and the statutory notices were duly served on the assessee. The Assessing Officer (AO) completed the assessment by making the following disallowance: (i) Disallowance under section

DCIT 2(1)(1), MUMBAI vs. BAJAJ ELECTRICALS LTD, MUMBAI

Accordingly we remit the impugned issue back to the AO with similar directions. The grounds raised by the assessee in this regard are allowed for statistical purposes

Bench: Hon’Ble Justice (Retd.) C V Bhadang & Ms Padmavathy S, Am

145,57,22,635/- respectively. The assessee's case was selected for scrutiny and the statutory notices were duly served on the assessee. The Assessing Officer (AO) completed the assessment by making the following disallowance: (i) Disallowance under section

ACIT, MUMBAI vs. K RAHEJA CORP PRIVATE LIMITED, MUMBAI

In the result, the appeal of the Revenue is dismissed

Bench: Shri Om Prakash Kant () & Shri Sandeep Singh Karhail () Assessment Year: 2020-21

145 taxmann.com 641) wherein it was held that while calculating disallowance made under Rule 8D @ 0.5% of the held that while calculating disallowance made under Rule 8D @ 0.5% of the held that while calculating disallowance made under Rule 8D @ 0.5% of the average investments, only those investments have to be considered which average investments, only those investments have

SICOM LTD ,MUMBAI vs. DY COMMISSIONER OF INCOME TAX CIRCLE 3(3)(1), MUMBAI

In the result, the appeal filed by the assesee is partly allow for statistical purpose and the appeal filed by the revenue is allowed for statistical purposes

Bench: Shri Om Prakash Kant & Shri Pavan Kumar Gadale, Judicialmember Sicom Ltd, Vs. Dy Commissioner Of Solitaire Corporate Income Tax Circle Park, Bldg No.04, 3(3)(1), Chakala, Andheri(E), 6Th Floor, Room No. Mumbai-400093. 609,Aayakar Bhavan, Maharishi Karve Road, Mumbai- 400020. "थायी लेखा सं./जीआइआर सं.Pan/Gir No. Aaacs5524J (अपीलाथ"/Applicant) (""यथ"/Respondent) Dy Commissioner Of Vs. Sicom Ltd, Income Tax Circle Solitaire Corporate Park, 3(3)(1), Bldg No.04, Chakala, 6Th Floor, Room No. Andheri(E), 609,Aayakar Bhavan, Mumbai-400093. Maharishi Karve Road, Mumbai- 400020. "थायी लेखा सं./जीआइआर सं.Pan/Gir No. Aaacs5524J (अपीलाथ"/Applicant) (""यथ"/Respondent)

145 taxmann.com 219 held when ad-hoc disallowance under section 14A - offered by assessee was rejected and disallowance was computed

DCIT, CIR 16(2), MUMBAI vs. M/S KPMG ASSURANCE AND CONSULTING SERVICES LLP, MUMBAI

Section 195 of the Act as the same were\nchargeable to tax in India in terms of Section 9(1)(vii) of the Act\nread with either Article 12 or Article 22/23 of the corresponding\nDTAAs as FTS or Other Income, respectively. Since the Assessee\nhad failed to deduct tax from the same in terms of Section

SIDDHARTH DEVELOPERS ,MUMBAI vs. ASSTT COMMISSIONER OF INCOME TAX CC-5(3), MUMBAI

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

Bench: Shri S. Rifaur Rahman, Hon'Ble & Shri Sandeep Singh Karhail, Hon'Blesiddharth Developers V. Acit – Central Circle – 5(3) 205 Commerce House Room No. 1906, 19Th Floor 140 N.M. Road, Fort Air India Building Nariman Point, Mumbai – 400 021 Mumbai - 400023 Pan: Abffs4068J (Appellant) (Respondent) Assessee Represented By : Shri Nishit Gandhi Department Represented By : Shri Salil Mishra

section 145(3) were not fulfilled in the present case. 3. In the facts and circumstances of the case and in law, the Ld. CIT(A) erred in confirming the action of the AO in adjusting the Work in Progress (WIP) of the Chhotani Chawl Project of the Appellant by disallowing

DCIT 2(2), MUMBAI vs. STATE BANK OF INDIA, MUMBAI

In the result appeal filed by the assessee for assessment year 2006 – 07 and 2007 – 08 is partly allowed

Bench: Shri Prashant Maharishi, Am & Ms Kavitha Rajagopal , Jm A.Y.2006-07 [ By Assessee] &

disallowance under section 14 A is restricted to the extent of 1% of the exempt income earned by the assessee is also apply to this case. Accordingly ground number 4 of the appeal of the AO and 1 of the appeal of the assessee are decided accordingly. ` 45) Ground number 4 (a) of the appeal is against the broken period

MACROTECH DEVELOPRS LTD,MUMBAI vs. DY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE 7(3), MUMBAI

The appeal is allowed

Bench: Shri Prashant Maharishi, Am & Shri Pavan Kumar Gadale, Jm

Section 143(3) of the Act was passed on 30th July, 2022 determining the total income of the assessee as per normal computation of income at ₹145,67,53,980/- and book profit at ₹107,90,96,962/-. 012. Assessee is aggrieved with that and has preferred this appeal. 013. During the course of hearing, the assessee has raised

MACROTECH DEVELOPERS LTD.(SUCCESSOR TO BELLISSIMO CROWN BUILDMART PVT LTD.,,MUMBAI vs. DCIT CENTRAL CIRCLE 7(3), MUMBAI

The appeal is allowed

Bench: Shri Prashant Maharishi, Am & Shri Pavan Kumar Gadale, Jm

Section 143(3) of the Act was passed on 30th July, 2022 determining the total income of the assessee as per normal computation of income at ₹145,67,53,980/- and book profit at ₹107,90,96,962/-. 012. Assessee is aggrieved with that and has preferred this appeal. 013. During the course of hearing, the assessee has raised

KPMG ASSURANCE AND CONSULTING SERVICES LLP,MUMBAI vs. ASSISTANT COMMISSIONER OF INCOME TAX-CIRCLE-16(2), MUMBAI

disallowance made by the Assessing Officer\nunder Section 40(a)(i) of the Act.\n5. The Assessee claimed deduction for the following fee\npaid/payable to the non-residents aggregating to INR\n11,21,42,029/:-\nSl.No. Name & Country of Tax Residence Status Amount (INR) Note\nRef\n1. Houthoff Buruma, Netherlands Company 8,89,560/-\n2\n2. KPMG AB, Sweden Company

VISHWANATH ACHARAYA,MUMBAI vs. ASST CIT 11(1), MUMBAI

In the result, the appeal filed by the assessee company is partly allowed for statistical purpose

Bench: Shri Joginder Singh & Shri Ramit Kocharआयकर अपील सं./I.T.A. No. 7976/Mum/2011 ("नधा"रण वष" / Assessment Year : 2007-08)

disallowance to 8% of market value of the property after referring to the provisions of section 7(1) of the Wealth Tax Act, 1957 read with Schedule III , from which the assessee will be granted deduction of municipal taxes and the standard deduction @30% as provided under the Act. Similarly, the CIT(A) restricted the claim of interest

DCIT, CIR 16(2), MUMBAI vs. M/S KPMG ASSURANCE AND CONSULTING SERVICES LLP, MUMBAI

disallowance made by the Assessing Officer\nunder Section 40(a)(i) of the Act.\n5. The Assessee claimed deduction for the following fee\npaid/payable to the non-residents aggregating to INR\n11,21,42,029/-:\nSl.No. Name & Country of Tax Residence Status Amount (INR) Note\nRef\n1. Houthoff Buruma, Netherlands Company 8,89,560/- 2\n2. KPMG AB, Sweden Company

DCIT, CIR 16(2), MUMBAI vs. M/S KPMG ASSURANCE AND CONSULTING SERVICES LLP, MUMBAI

disallowance made by the Assessing Officer\nunder Section 40(a)(i) of the Act.\n5. The Assessee claimed deduction for the following fee\npaid/payable to the non-residents aggregating to INR\n11,21,42,029/-\nSl.No. Name & Country of Tax Residence Status Amount (INR) Note\nRef\n1. Houthoff Buruma, Netherlands Company 8,89,560/- 2\n2. KPMG AB, Sweden Company

KPMG ASSURANCE AND CONSULTING SERVICES LLP,MUMBAI vs. ASSISTANT COMMISSIONER OF INCOME TAX -16(2), MUMBAI

disallowance made by the Assessing Officer\nunder Section 40(a)(i) of the Act.\n5. The Assessee claimed deduction for the following fee\npaid/payable to the non-residents aggregating to INR\n11,21,42,029/-:\nSl.No. Name & Country of Tax Residence Status Amount (INR) Note\nRef\n1. Houthoff Buruma, Netherlands Company 8,89,560/- 2\n2. KPMG AB, Sweden Company

ACIT , MUMBAI vs. RELIANCE POWER LTD , MUMBAI

145 taxmann.com 641)\nwherein it has been held that for the purpose of making disallowance of expenses\nunder section 14 A as per rule

M/S EDELWISS RURAL & CORPORATE SERVICES PRIVATE LIMITED,MUMBAI vs. ACIT CENTRAL CIRCLE-1(2), MUMBAI

In the result, the appeal of the assessee is allowed

Bench: Shri Aby T Varkey () & Shri Om Prakash Kant () Assessment Year: 2016-17 M/S Edelweiss Rural & Acit Central Circle-1(2), Corporate Services Pvt. Ltd., R. No. 906, 9Th Floor, Old Vs. Edelweiss House, Off Cst Road, Cgo Building Annexe, Kalina, Santacruz (East), Maharshi Karve Road, Mumbai-400098. Churchgate, Mumbai-400020. Pan No. Aakcs 7311 R Appellant Respondent Assessee By : Mr. Jitendra Jain, Ar Revenue By : Mr. Sanjeev Kashyap, Cit-Dr : Date Of Hearing 09/03/2023 : Date Of Pronouncement ___/03/2023 Order

section 145 (3) of the Act and thus, we set aside the we set aside the finding of the Ld. CIT(A) on the issue in dispute and delete finding of the Ld. CIT(A) on the issue in dispute finding of the Ld. CIT(A) on the issue in dispute disallowance

STATE BANK OF INDIA,MUMBAI vs. ADDL CIT RG 2(2), MUMBAI

In the result, the appeal of the assessee is partly allowed and the appeal of the Revenue is dismissed, as indicated above

Bench: Sri Mahavir Singh, Vp & Sri G Manjunatha, Am आयकर अपील सुं./ Ita No. 3644/Mum/2016 (ननर्ाारण वर्ा / Assessment Year 2008-09) State Bank Of India The Dy. Commissioner Of 3Rd Floor, Corporate Centre Income Tax, Circle -2(2)(1) बनाम/ Madam Cama Road Mumbai Vs. Nariman Point Mumbai-400021 (अपीलार्थी / Appellant) (प्रत्यर्थी/ Respondent) स्र्थायी लेखा सुं./Pan No. Aaacs8577K

disallowance only on the above noted 4 items. He particularly stated the following: - (i) The liability is not for the relevant year rather it relates to earlier year. (ii) If at all it is allowable it falls under Section 40A (4/5) and 40A(7)/(9) of the Act. (iii) Even this provision can be allowed subject to condition of payment

NUVAMA WEALTH MANAGEMENT LIMITED,BANDRA EAST, MUMBAI vs. DEPUTY COMISSIONER OF INCOME TAX, CGO BUILDING, MUMBAI

Bench: Shri Saktijit Dey, Vp & Ms Padmavathy S, Am

section 115JB of the Act. 4. The ld. DR on the other hand submitted that the AO in the assessment order has recorded the dissatisfaction by stating that the disallowance made by assessee is not commensurate with the quantum of exempt income earned by the assessee and therefore the contentions of the assessee in this regard are not sustainable. Accordingly