JEEVANDEEP EDUMEDIA PRIVATE LIMITED,MUMBAI vs. PRINCIPLE CIT-6, MUMBAI

In the result, the a In the result, the appeal of the assessee is stands allowed

Bench: Shri Om Prakash Kant () & Ms. Kavitha Rajagopal () Assessment Year: 2020-21 Jeevandeep Edumedia Pvt. Ltd., Pr. Cit-6, 1St Floor, Sun Paradise Business 501,5Th Floor, Aayakar Bhavan, Plaza, Senapati Bapat Marg, Vs. Maharishi Karve Road, Lower Parel (West), Mumbai-400020. Mumbai-400013. Pan No. Aabcj 0180 G Appellant Respondent

disallowed the CSR expenses u/s 37(1) of the Act while SR expenses u/s 37(1) of the Act while computing the business income and claimed deduction of Rs. 12,49,000 computing the business income and claimed deduction of Rs. 12,49,000 computing the business income and claimed deduction

JASHAN JEWELS PRIVATE LIMITED ,MUMBAI vs. PCIT -5, MUMBAI

In the result, the appeal of the assessee is stands allowed

Bench: Shri Om Prakash Kant () & Ms. Kavitha Rajagopal () Assessment Year: 2020-21 Jashan Jewels Pvt. Ltd., Pcit, Mumbai-5, 301-B Aman Chambers Room No. 515, 5Th Floor, Aayakar Premises Co. Soc. Ltd., Mama Vs. Bhavan, Maharshi Karve Road, Paramand Marg, Opera House, Mumbai-400020. Girgaon, Mumbai-400 004. Pan No. Aabcj 7040 D Appellant Respondent

disallowance under Section 37(1) and result in unintended tax benefits nder Section 37(1) and result in unintended tax benefits nder Section 37(1) and result in unintended tax benefits which would be inconsistent with the legislative framework which would be inconsistent with the legislative framework which would be inconsistent with the legislative framework governing CSR and tax deductions

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

Section 14A of the Act as per Rule 8D by computing the total disallowance of ₹1,182,24,87,180/- and further rejecting suo moto disallowance offered by the assessee of ₹21,89,85,725/- resulting into net disallowance of ₹1,160

STATE BANK OF MYSORE,BANGALORE vs. JCIT, BANGALORE

In the result, the appeal of the Revenue Ground-3 is dismissed

Bench: Shri Narendra Kumar Billaiya, Account Member & Shri Anikesh Banerjeestate Bank Of India Vs Joint Commissioner Of Income-Tax, (Erstwhile State Bank Of Large Tax Payers Unit, Bangalore Mysore Prior To Merger) Local Head Office Compliance Department, 4Th Floor, 65, St. Marks Road, Bangalore-560 001 Pan: Aaccs0155P Appellant Respondent Deputy Commissioner Of Vs State Bank Of Mysore Income-Tax, Ltu, Circle-1, Head Office, Finance & Accounts Bangalore Department, Kg Road, Bangalore- 560 009 Pan: Aaccs0155P Appellant Respondent

disallowance is warranted on this account. In the result, Ground 8 of the assessee’s appeal is allowed. 33. In the result, the appeal of the assessee is allowed in part. ITA No.683/Bang/2015: A.Y. 2010-11 (Revenue’s Appeal) Ground 1 : Deduction under section 36(1)(viia) 34. This ground is identical to ground 2 of assessee’s appeal

BANK OF INDIA,MUMBAI vs. ACIT-2(1)(2), MUMBAI

In the result, the appeal by the Revenue for the assessment year 2018-

Bench: Shri Vikram Singh Yadavshri Sandeep Singh Karhailita No.1452/Mum/2023 Assessment Year : 2016-17 Assessment Year : 2018-19

1)(vii) r.w.s. 36(2)(v) of the Act? (Tax Effect: Rs. 2,71,97,333/- @34.61% Rs. 8,22,59,119/-) 8. Whether on the facts and in the circumstances of the case and in law, the Ld. CIT(A) has erred in deleting the disallowance of interest on Perpetual Bonds as Perpetual Bonds cannot be are not borrowed

ACIT, CIRCLE-2(1)(1), MUMBAI vs. M/S BANK OF INDIA, MUMBAI

In the result, the appeal by the Revenue for the assessment year 2018-

Bench: Shri Vikram Singh Yadavshri Sandeep Singh Karhailita No.1452/Mum/2023 Assessment Year : 2016-17 Assessment Year : 2018-19

1)(vii) r.w.s. 36(2)(v) of the Act? (Tax Effect: Rs. 2,71,97,333/- @34.61% Rs. 8,22,59,119/-) 8. Whether on the facts and in the circumstances of the case and in law, the Ld. CIT(A) has erred in deleting the disallowance of interest on Perpetual Bonds as Perpetual Bonds cannot be are not borrowed

DENA BANK,MUMBAI vs. PRINCIPAL COMMISSIONER OF INCOME TAX 2, MUMBAI

In the result, appeal filed by the assesse is allowed

Bench: Shri G. Manjunatha & Shri Ravish Sooddena Bank Vs. Pcit-2 Room No.344, 3Rd Floor Accounts Department Dena Bank Building Aaykar Bhawan 2Nd Floor M.K.Road 17/B, Horniman Circle Mumbai-400 020 Fort, Mumbai-400 023 Pan/Gir No.Aaacd4249B Appellant) .. Respondent)

section 37(1). The apex court in the context of several cases has held that where penalties are compensatory in nature, the same will not be disallowed u/s, 37(1). Refer; • 201 ITR 684 (SC) Prakash Cotton Mills Pvt. Ltd. • CIT v Dhanlakshmi Bank Ltd./Catholic Syrian Bank Ltd, Kerala High Court order dated 12.11.2002 * [2014] 49 taxmann.com 565 (Punjab

BANK OF INDIA,MUMBAI vs. THE NATIONAL FACELESS ASSESSMENT CENTRE, MUMBAI

section 36(1)(iii) of the\nAct. Accordingly, the AO disallowed the amount of Rs.160,77,00,000 claimed\nas deduction and added the same to the total income of the assessee.\n63. The learned CIT(A), vide impugned order, deleted the addition made by\nthe AO on this issue, by observing as follows:-\n\"10.4.1 It is observed that

DY..C.I.T., BANGALORE vs. M/S STATE BANK OF MYSORE, BANGALORE

In the result, the appeal of the Revenue Ground-3 is dismissed

disallowance\nis warranted on this account.\nIn the result, Ground 8 of the assessee's appeal is allowed.\n33. In the result, the appeal of the assessee is allowed in part.\nITA No.683/Bang/2015: A.Y. 2010-11 (Revenue's Appeal)\nGround 1 : Deduction under section 36(1)(viia)\n34. This ground is identical to ground 2 of assessee's appeal

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

160,06,53,482/- and Rs. 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 14A r.w.r. 8D - Rs. 1

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

160,06,53,482/- and Rs. 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 14A r.w.r. 8D - Rs. 1

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

160,06,53,482/- and Rs. 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 14A r.w.r. 8D - Rs. 1

ACIT, CIRCLE-2(1)(1), MUMBAI vs. M/S BANK OF INDIA, MUMBAI

section 36(1)(iii) of the\nAct. Accordingly, the AO disallowed the amount of Rs.160,77,00,000 claimed\nas deduction and added the same to the total income of the assessee.\n63. The learned CIT(A), vide impugned order, deleted the addition made by\nthe AO on this issue, by observing as follows: -\n\"10.4.1 It is observed that

GEECEE VENTURES LIMITED ,MUMBAI vs. DCIT, CIRCLE 2(1)(1), MUMBAI

The appeal is allowed for statistical purposes

Bench: SHRI VIKRAM SINGH YADAV, ACCOUNTANT MEMBER SHRI RAHUL CHAUDHARY (Judicial Member)

1 assailed the AO in making addition of Rs. 8393835/- u/s 14A r.w.r 8D of the Rules. The AO in Para 3 of the assessment order noted that the assessee had disallowed Rs. 4067450/- under Section 14A r.w.r 8D of the Rules The AO further in the assessment order noted that the assessee had earned exempt income

ACIT-2(1)(1), MUMBAI vs. GEECEE VENTURES LIMITED, MUMBAI

The appeal is allowed for statistical purposes

Bench: SHRI VIKRAM SINGH YADAV, ACCOUNTANT MEMBER SHRI RAHUL CHAUDHARY (Judicial Member)

1 assailed the AO in making addition of Rs. 8393835/- u/s 14A r.w.r 8D of the Rules. The AO in Para 3 of the assessment order noted that the assessee had disallowed Rs. 4067450/- under Section 14A r.w.r 8D of the Rules The AO further in the assessment order noted that the assessee had earned exempt income

ICICI SECURITIES LIMITED,MUMBAI vs. PRINCIPAL COMMISSIONER OF INCOME TAX, MUMBAI -4, MUMBAI

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

Bench: SHRI AMIT SHUKLA (Judicial Member), SMT RENU JAUHRI (Accountant Member)

Disallowance of Interest Expenditure of ₹26,45,160/- under section 36(1)(iii) 43. The last issue which arises for consideration

SWARAN NADHAN SALARIA,MUMBAI vs. DICT CENTRAL CIRCLE 1(2), MUMBAI

In the result all In the result all appeals of the assesses from AY 2014

Bench: Shri Om Prakash Kant () & Shri Raj Kumar Chauhan ()

section 271(1)(c) of the Act are fulfilled. In view of the above, the penalty in respect of interest and the excess the penalty in respect of interest and the excess the penalty in respect of interest and the excess depreciation is also cancelled cancelled. The relevant grounds of the appeal of The relevant grounds of the appeal

SWARAN NADHAN SALARIA,MUMBAI vs. DCIT CENTRAL CIRCLE 1(2), MUMBAI

In the result all In the result all appeals of the assesses from AY 2014

Bench: Shri Om Prakash Kant () & Shri Raj Kumar Chauhan ()

section 271(1)(c) of the Act are fulfilled. In view of the above, the penalty in respect of interest and the excess the penalty in respect of interest and the excess the penalty in respect of interest and the excess depreciation is also cancelled cancelled. The relevant grounds of the appeal of The relevant grounds of the appeal

SWARAN NADHAN SALARIA,MUMBAI vs. DCIT CENTRAL CIRCLE 1(2), MUMBAI

In the result all In the result all appeals of the assesses from AY 2014

Bench: Shri Om Prakash Kant () & Shri Raj Kumar Chauhan ()

section 271(1)(c) of the Act are fulfilled. In view of the above, the penalty in respect of interest and the excess the penalty in respect of interest and the excess the penalty in respect of interest and the excess depreciation is also cancelled cancelled. The relevant grounds of the appeal of The relevant grounds of the appeal