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

149/- under section 36(1)(va), disallowed deduction claimed under section 80G in respect of CSR related payments amounting to Rs. 92,31,072/-, disallowed

APTIVAA MIDDLE EAST FZE,MUMBAI vs. DEPUTY COMMISSION OF INCOME TAX, CIRCLE 1(1)(2), INTERNATIONAL TAXATION, MUMBAI, MUMBAI

In the result of the file by the assessee stands partly allowed as indicated hereinabove

Bench: Smt. Beena Pillai () & Ms. Padmavathy S. ()

149(1)(b) in the absence of any income escaped assessment represented in the form of "asset" 3. On the facts and circumstances of the case and in law, the notice dated March 17, 2023 issued under section 143(2) of the Act by the Ld. AO is invalid, bad in law and liable to be quashed

APTIVAA MIDDLE EAST FZE,DUBAI, UNITED ARAB EMIRATES vs. DEPUTY COMMISSIONER OF INCOME TAX, CIRCLE 1(1)(2), INTERNATIONAL TAXATION, MUMBAI, MAHARASTRA

In the result of the file by the assessee stands partly allowed as indicated hereinabove

Bench: Smt. Beena Pillai () & Ms. Padmavathy S. ()

149(1)(b) in the absence of any income escaped assessment represented in the form of "asset" 3. On the facts and circumstances of the case and in law, the notice dated March 17, 2023 issued under section 143(2) of the Act by the Ld. AO is invalid, bad in law and liable to be quashed

APTIVAA MIDDLE EAST FZE,DUBAI, UNITED ARAB EMIRATES vs. DEPUTY COMMISSIONER OF INCOME TAX, CIRCLE 1(1)(2), INTERNATIONAL TAXATION, MUMBAI, MAHARASTRA

In the result of the file by the assessee stands partly allowed as indicated hereinabove

Bench: Smt. Beena Pillai () & Ms. Padmavathy S. ()

149(1)(b) in the absence of any income escaped assessment represented in the form of "asset" 3. On the facts and circumstances of the case and in law, the notice dated March 17, 2023 issued under section 143(2) of the Act by the Ld. AO is invalid, bad in law and liable to be quashed

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

disallowed employees'\ncontribution to provident fund amounting to Rs. 82,10,149/-\nunder section 36(1)(va), disallowed deduction claimed

ICICI BANK LTD.,MUMBAI vs. THE DY CIT -2(3)(1), MUMBAI

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

Bench: Shri Prashant Maharishi, Am & Shri Sandeep Singh Karhail, Jm Icici Bank Ltd. The Dy. Commissioner Of Icici Bank Towers, Income-Tax 2(3)(1) Bandra Kurla Complex, Aaykar Bhavan, Vs. 5Th Floor, Room No.552, Badra (East), Mumbai-400 051 M.K. Road, Mumbai-400 020 (Appellant) (Respondent) Pan No. Aaaci1195H

disallow the deduction to 10% of rural advances of ₹122.30 crores which were not rural branches ICICI Bank Ltd; A.Y. 2015-16 vi. Excess deduction allowed under Section 36(1)(viii) of the Act of ₹138,52,06,494/- which should have been restricted to ₹961,47,93,509/- being 20% of allowable deduction. vii. Excess allowances of long-term

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

149/- under section 36(1)(va), disallowed deduction claimed under section 80G in respect of CSR related payments amounting to Rs. 92,31,072/-, disallowed

SHAIRUL IMPEX,MUMBAI vs. ASSESSMENT UNIT INCOME TAX DEPARTMENT (INCOME TAX OFFICER WARD 19(3)(1)), MUMBAI

149(1)(b) of the Act prescribes that escaped home must be represented\nin the fonts of (7) a (1) expenditure in respect of a transaction or in relation to an\nevent; (iii) an entry in the books of Account.\nThe question of a correctness of the claim of deduction under section 801JAA of\nthe Act cannot represent escapement

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)

1)(a) 3. Variation in respect of issue of - disallowance u/s 14A 4. Variation in respect of issue of - disallowance-insurance expense claimed u/s 36 5. Total Income determined as per Rs. 149,11,76,360/- the above proposal The assessment is made u/s 143(3) read with section

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)

1)(a) 3. Variation in respect of issue of - disallowance u/s 14A 4. Variation in respect of issue of - disallowance-insurance expense claimed u/s 36 5. Total Income determined as per Rs. 149,11,76,360/- the above proposal The assessment is made u/s 143(3) read with section

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)

1)(a) 3. Variation in respect of issue of - disallowance u/s 14A 4. Variation in respect of issue of - disallowance-insurance expense claimed u/s 36 5. Total Income determined as per Rs. 149,11,76,360/- the above proposal The assessment is made u/s 143(3) read with section

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

disallowed employees'\ncontribution to provident fund amounting to Rs. 82,10,149/-\nunder section 36(1)(va), disallowed deduction claimed

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

1,05,10,437/- (ii) Disallowance of Prior period expenditure - Rs. 54,83,149/- (iii) Disallowance on account of commission payment - Rs. 3,60,61,410/- 32. Aggrieved the assessee filed further appeal before the CIT(A). The CIT(A) reduced the disallowance under section

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

1,05,10,437/- (ii) Disallowance of Prior period expenditure - Rs. 54,83,149/- (iii) Disallowance on account of commission payment - Rs. 3,60,61,410/- 32. Aggrieved the assessee filed further appeal before the CIT(A). The CIT(A) reduced the 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

1,05,10,437/- (ii) Disallowance of Prior period expenditure - Rs. 54,83,149/- (iii) Disallowance on account of commission payment - Rs. 3,60,61,410/- 32. Aggrieved the assessee filed further appeal before the CIT(A). The CIT(A) reduced the disallowance under section

DCIT-1(2)1, MUMBAI., MUMBAI vs. PATIL CONSTRUCTION AND INFRASTRUCTURE LTD, MUMBAI

In the result In the result, all the three appeals filed by the revenue s filed by the revenue are dismissed

Bench: Shri Sandeep Gosain, Hon’Ble & Ms. Padmavathy S., Hon’Ble

disallowance of claim was made. It was also argued by the revenue that claim was made. It was also argued by the revenue that claim was made. It was also argued by the revenue that I.T.A. No. 4940/Mum/2024 I.T.A. No. 4940/Mum/2024 I.T.A. No. 4942/Mum/2024 I.T.A. No. 4942/Mum/2024 I.T.A. No. I.T.A. No. 4944/Mum/2024 6 the department has filed appeal against

DCIT-1(2)1, MUMBAI, MUMBAI vs. PATIL CONSTRUCTION AND INFRASTRUCTURE LTD, MUMBAI

In the result In the result, all the three appeals filed by the revenue s filed by the revenue are dismissed

Bench: Shri Sandeep Gosain, Hon’Ble & Ms. Padmavathy S., Hon’Ble

disallowance of claim was made. It was also argued by the revenue that claim was made. It was also argued by the revenue that claim was made. It was also argued by the revenue that I.T.A. No. 4940/Mum/2024 I.T.A. No. 4940/Mum/2024 I.T.A. No. 4942/Mum/2024 I.T.A. No. 4942/Mum/2024 I.T.A. No. I.T.A. No. 4944/Mum/2024 6 the department has filed appeal against

DOW CHEMICALS INTERNATIONAL PRIVATE LIMITED ,MUMBAI vs. DEPUTY COMMISSIONER OF INCOME TA-14(1)(2), MUMBAI

In the result, the appeal by the assessee for the

section 143(1) of the Act.\nTherefore, grounds no.6 and 7 are dismissed as not pressed.\n42. Further, ground no.8 raised in assessee's appeal was not pressed\nduring the hearing. Accordingly, the same is dismissed as not pressed.\n43. The issue arising in ground no.9, raised in assessee's appeal, pertains\nto the claim of refund of excess

ACIT, CIRCLE - 3 3 1, MUMBAI vs. JAMNAGAR UTILITIES AND POWER PVT LTD, MUMBAI

In the result, both the appeals of the Revenue are allowed\npartly

149 taxmann.com 286 (Calcutta) has held\nas under:\n\"I. Section 37(1) of the Income-tax Act, 1961 Business expenditure -\nAllowability of (Prior period expenses) - Assessment year 2012-13\nAssessee claimed prior period expenses adjustment in its return of\nincome for relevant year Assessing Officer asked assessee to\nexplain why prior period expenditure should not be disallowed