K D LITE DEVELOPERS PRIVATE LIMITED,MUMBAI vs. DY. COMMISSIONER OF INCOME TAX, TDS CIRCLE 1(3), MUMBAI

In the result, all the five appeals filed by the assessee are allowed

Bench: Shri Sandeep Gosain & Shri Prabhash Shankar

disallowance under section 40(a)(ia) would not arise - Held, yes [Para 10] [In favour of assessee] IN THE ITAT Section 194A, read with section 263, of MUMBAI BENCH the Income-tax Act, 1961 - Deduction of 'B' tax at source - Interest other than Neo Sports interest on securities (Reimbursement of Broadcast (P.) commission to holding company) - Ltd. Assessment years

K D LITE DEVELOPERS PRIVATE LIMITED,MUMBAI vs. DY. COMMISSIONER OF INCOME TAX, TDS CIRCLE 1(3), MUMBAI, MUMBAI

In the result, all the five appeals filed by the assessee are allowed

Bench: Shri Sandeep Gosain & Shri Prabhash Shankar

disallowance under section 40(a)(ia) would not arise - Held, yes [Para 10] [In favour of assessee] IN THE ITAT Section 194A, read with section 263, of MUMBAI BENCH the Income-tax Act, 1961 - Deduction of 'B' tax at source - Interest other than Neo Sports interest on securities (Reimbursement of Broadcast (P.) commission to holding company) - Ltd. Assessment years

ROYAL TWINKLE STAR CLUB P.LTD,MUMBAI vs. DCIT CEN CIR 2(4), MUMBAI

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

Bench: Shri G.S. Pannu & Shri Sandeep Singh Karhail

disallowed under section 40(a)(ia) for non-deduction of tax under section 194A of the Act. Royal Twinkle Star Club Pvt. Ltd. A.Y. 2009–10, 2010–11, 2011–12, 2012–13 2013–14, 2014–15 & 2015–16 9. The brief facts of the case pertaining to this issue are: For the year under consideration, the assessee filed its return

ROYAL TWINKLE STAR CLUB P.LTD,MUMBAI vs. DCIT CEN CIR 2(4), MUMBAI

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

Bench: Shri G.S. Pannu & Shri Sandeep Singh Karhail

disallowed under section 40(a)(ia) for non-deduction of tax under section 194A of the Act. Royal Twinkle Star Club Pvt. Ltd. A.Y. 2009–10, 2010–11, 2011–12, 2012–13 2013–14, 2014–15 & 2015–16 9. The brief facts of the case pertaining to this issue are: For the year under consideration, the assessee filed its return

ROYAL TWINKLE STAR CLUB PVT. LTD,MUMBAI vs. DCIT CIRCLE 2 (1), MUMBAI

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

Bench: Shri G.S. Pannu & Shri Sandeep Singh Karhail

disallowed under section 40(a)(ia) for non-deduction of tax under section 194A of the Act. Royal Twinkle Star Club Pvt. Ltd. A.Y. 2009–10, 2010–11, 2011–12, 2012–13 2013–14, 2014–15 & 2015–16 9. The brief facts of the case pertaining to this issue are: For the year under consideration, the assessee filed its return

ROYAL TWINKLE STAR CLUB P.LTD,MUMBAI vs. ACIT CEN CIR 2(4), MUMBAI

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

Bench: Shri G.S. Pannu & Shri Sandeep Singh Karhail

disallowed under section 40(a)(ia) for non-deduction of tax under section 194A of the Act. Royal Twinkle Star Club Pvt. Ltd. A.Y. 2009–10, 2010–11, 2011–12, 2012–13 2013–14, 2014–15 & 2015–16 9. The brief facts of the case pertaining to this issue are: For the year under consideration, the assessee filed its return

ROYAL TWINKLE STAR CLUB P.LTD,MUMBAI vs. ACIT CEN CIR 2(4), MUMBAI

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

Bench: Shri G.S. Pannu & Shri Sandeep Singh Karhail

disallowed under section 40(a)(ia) for non-deduction of tax under section 194A of the Act. Royal Twinkle Star Club Pvt. Ltd. A.Y. 2009–10, 2010–11, 2011–12, 2012–13 2013–14, 2014–15 & 2015–16 9. The brief facts of the case pertaining to this issue are: For the year under consideration, the assessee filed its return

ROYAL TWINKLE STAR CLUB PVT. LTD.,MUMBAI vs. DCIT CENTRAL CIRCLE-2(1), MUMBAI

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

Bench: Shri G.S. Pannu & Shri Sandeep Singh Karhail

disallowed under section 40(a)(ia) for non-deduction of tax under section 194A of the Act. Royal Twinkle Star Club Pvt. Ltd. A.Y. 2009–10, 2010–11, 2011–12, 2012–13 2013–14, 2014–15 & 2015–16 9. The brief facts of the case pertaining to this issue are: For the year under consideration, the assessee filed its return

ROYAL TWINKLE STAR CLUB P.LTD,MUMBAI vs. DCIT CEN CIR 2(4), MUMBAI

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

Bench: Shri G.S. Pannu & Shri Sandeep Singh Karhail

disallowed under section 40(a)(ia) for non-deduction of tax under section 194A of the Act. Royal Twinkle Star Club Pvt. Ltd. A.Y. 2009–10, 2010–11, 2011–12, 2012–13 2013–14, 2014–15 & 2015–16 9. The brief facts of the case pertaining to this issue are: For the year under consideration, the assessee filed its return

ROYAL TWINKLE STAR CLUB PVT. LTD,MUMBAI vs. DCIT CENTRAL CIRCLE-2(1), MUMBAI

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

Bench: Shri G.S. Pannu & Shri Sandeep Singh Karhail

disallowed under section 40(a)(ia) for non-deduction of tax under section 194A of the Act. Royal Twinkle Star Club Pvt. Ltd. A.Y. 2009–10, 2010–11, 2011–12, 2012–13 2013–14, 2014–15 & 2015–16 9. The brief facts of the case pertaining to this issue are: For the year under consideration, the assessee filed its return

K D LITE DEVELOPERS PRIVATE LIMITED,MUMBAI vs. DY. COMMISSIONER OF INCOME TAX, TDS CIRCLE 1(3),, MUMBAI

In the result, all the five appeals filed by the assessee\nare allowed

3), Mumbai the Ld. Assessing Officer is of the view that\nthe assessee has prima facie committed default in\ndeduction of TDS and consequently proceedings u/s 201(1)\n/ 201(1A) of the Income Tax Act, 1961 ('IT Act') were\ninitiated against the various group entities & the assessee.\n5. The AO after serving notices and seeking reply of the\nassessee

K D LITE DEVELOPERS PRIVATE LIMITED,MUMBAI vs. DY. COMMISSIONER OF INCOME TAX, TDS CIRCLE 1(3), MUMBAI, MUMBAI

In the result, all the five appeals filed by the assessee\nare allowed

disallowance could not be\nmade by invoking the provisions of section 40(a)(iii) for\nnon-deduction of tax from reimbursement.\n8. Linklaters LLP Vs ITO (Int.Tax) [2011] 9 ITR (Trib) 217\n(Mum)\nIt was, inter alia, held in this case that reimbursements\nreceived by the assessee were in respect of specific and\nactual expenses incurred by the assessee

ITO-26(2)(1), MUMBAI vs. SAI PRERANA CO-OP CREDIT SOCIETY LTD, MUMBAI

In the result, appeals of the assessee and the Revenue are In the result, appeals of the assessee and the Revenue are In the result, appeals of the assessee and the Revenue are decided as under:

Bench: Shri Kuldip Singh () & Shri Om Prakash Kant () Ita Nos. 217, 220 & 221, 218 & 219, 215, 214/Mum/2023 Assessment Years: 2013-14, 2016-17, 2017-18, 2018-19, 2020-21 Sai Prerana Co-Op Credit Ito-17(3)(2), Society Ltd., Room No. 126, 1St Floor, Vs. 317, Puran Aasha Bldg, Gr. Fl. Kautilya Bhavan, C-41 To C- Narashi Natha Street, Katha 43, G Block Bandra Kurla Bazar Masjid Bunder (W), Complex, Bandra (East), Mumbai-400 009. Mumbai-400051. Pan No. Aadts 5638 M Appellant Respondent

3. On the facts and circumstances of the case in Law, Ld. CIT(A) erred in disallowing CIT(A) erred in disallowing 80P deduction on account of interest re 80P deduction on account of interest received from other than ceived from other than cooperative bank. cooperative bank. 4. The Appellant keep its right reserve to add/modify/ delete 4. The Appellant

INCOME TAX OFFICER-26(2)(1), MUMBAI vs. SAI PRERANA CO-OP CREDIT SOCIETY LTD., MUMBAI

In the result, appeals of the assessee and the Revenue are In the result, appeals of the assessee and the Revenue are In the result, appeals of the assessee and the Revenue are decided as under:

Bench: Shri Kuldip Singh () & Shri Om Prakash Kant () Ita Nos. 217, 220 & 221, 218 & 219, 215, 214/Mum/2023 Assessment Years: 2013-14, 2016-17, 2017-18, 2018-19, 2020-21 Sai Prerana Co-Op Credit Ito-17(3)(2), Society Ltd., Room No. 126, 1St Floor, Vs. 317, Puran Aasha Bldg, Gr. Fl. Kautilya Bhavan, C-41 To C- Narashi Natha Street, Katha 43, G Block Bandra Kurla Bazar Masjid Bunder (W), Complex, Bandra (East), Mumbai-400 009. Mumbai-400051. Pan No. Aadts 5638 M Appellant Respondent

3. On the facts and circumstances of the case in Law, Ld. CIT(A) erred in disallowing CIT(A) erred in disallowing 80P deduction on account of interest re 80P deduction on account of interest received from other than ceived from other than cooperative bank. cooperative bank. 4. The Appellant keep its right reserve to add/modify/ delete 4. The Appellant

INCOME TAX OFFICER-26(2)(1), MUMBAI vs. SAI PRERANA CO-OP CREDIT SOCIETY LTD., MUMBAI

In the result, appeals of the assessee and the Revenue are In the result, appeals of the assessee and the Revenue are In the result, appeals of the assessee and the Revenue are decided as under:

Bench: Shri Kuldip Singh () & Shri Om Prakash Kant () Ita Nos. 217, 220 & 221, 218 & 219, 215, 214/Mum/2023 Assessment Years: 2013-14, 2016-17, 2017-18, 2018-19, 2020-21 Sai Prerana Co-Op Credit Ito-17(3)(2), Society Ltd., Room No. 126, 1St Floor, Vs. 317, Puran Aasha Bldg, Gr. Fl. Kautilya Bhavan, C-41 To C- Narashi Natha Street, Katha 43, G Block Bandra Kurla Bazar Masjid Bunder (W), Complex, Bandra (East), Mumbai-400 009. Mumbai-400051. Pan No. Aadts 5638 M Appellant Respondent

3. On the facts and circumstances of the case in Law, Ld. CIT(A) erred in disallowing CIT(A) erred in disallowing 80P deduction on account of interest re 80P deduction on account of interest received from other than ceived from other than cooperative bank. cooperative bank. 4. The Appellant keep its right reserve to add/modify/ delete 4. The Appellant

ITO-26(2)(1) , MUMBAI vs. SAI PRERANA CO-OP CREDIT SOCIETY LTD, MUMBAI

In the result, appeals of the assessee and the Revenue are In the result, appeals of the assessee and the Revenue are In the result, appeals of the assessee and the Revenue are decided as under:

Bench: Shri Kuldip Singh () & Shri Om Prakash Kant () Ita Nos. 217, 220 & 221, 218 & 219, 215, 214/Mum/2023 Assessment Years: 2013-14, 2016-17, 2017-18, 2018-19, 2020-21 Sai Prerana Co-Op Credit Ito-17(3)(2), Society Ltd., Room No. 126, 1St Floor, Vs. 317, Puran Aasha Bldg, Gr. Fl. Kautilya Bhavan, C-41 To C- Narashi Natha Street, Katha 43, G Block Bandra Kurla Bazar Masjid Bunder (W), Complex, Bandra (East), Mumbai-400 009. Mumbai-400051. Pan No. Aadts 5638 M Appellant Respondent

3. On the facts and circumstances of the case in Law, Ld. CIT(A) erred in disallowing CIT(A) erred in disallowing 80P deduction on account of interest re 80P deduction on account of interest received from other than ceived from other than cooperative bank. cooperative bank. 4. The Appellant keep its right reserve to add/modify/ delete 4. The Appellant

SAI PRERNA CO-OP. CREDIT SOCIETY LTD,MUMBAI vs. ITO WD 17(3) (2) , MUMBAI

In the result, appeals of the assessee and the Revenue are In the result, appeals of the assessee and the Revenue are In the result, appeals of the assessee and the Revenue are decided as under:

Bench: Shri Kuldip Singh () & Shri Om Prakash Kant () Ita Nos. 217, 220 & 221, 218 & 219, 215, 214/Mum/2023 Assessment Years: 2013-14, 2016-17, 2017-18, 2018-19, 2020-21 Sai Prerana Co-Op Credit Ito-17(3)(2), Society Ltd., Room No. 126, 1St Floor, Vs. 317, Puran Aasha Bldg, Gr. Fl. Kautilya Bhavan, C-41 To C- Narashi Natha Street, Katha 43, G Block Bandra Kurla Bazar Masjid Bunder (W), Complex, Bandra (East), Mumbai-400 009. Mumbai-400051. Pan No. Aadts 5638 M Appellant Respondent

3. On the facts and circumstances of the case in Law, Ld. CIT(A) erred in disallowing CIT(A) erred in disallowing 80P deduction on account of interest re 80P deduction on account of interest received from other than ceived from other than cooperative bank. cooperative bank. 4. The Appellant keep its right reserve to add/modify/ delete 4. The Appellant

SAI PRERNA CO-OP. CREDIT SOCIETY LTD,MUMBAI vs. ITO WD 17(3) (2) , MUMBAI

In the result, appeals of the assessee and the Revenue are In the result, appeals of the assessee and the Revenue are In the result, appeals of the assessee and the Revenue are decided as under:

Bench: Shri Kuldip Singh () & Shri Om Prakash Kant () Ita Nos. 217, 220 & 221, 218 & 219, 215, 214/Mum/2023 Assessment Years: 2013-14, 2016-17, 2017-18, 2018-19, 2020-21 Sai Prerana Co-Op Credit Ito-17(3)(2), Society Ltd., Room No. 126, 1St Floor, Vs. 317, Puran Aasha Bldg, Gr. Fl. Kautilya Bhavan, C-41 To C- Narashi Natha Street, Katha 43, G Block Bandra Kurla Bazar Masjid Bunder (W), Complex, Bandra (East), Mumbai-400 009. Mumbai-400051. Pan No. Aadts 5638 M Appellant Respondent

3. On the facts and circumstances of the case in Law, Ld. CIT(A) erred in disallowing CIT(A) erred in disallowing 80P deduction on account of interest re 80P deduction on account of interest received from other than ceived from other than cooperative bank. cooperative bank. 4. The Appellant keep its right reserve to add/modify/ delete 4. The Appellant