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

ASST CIT 19(3), MUMBAI vs. PAHILAJRAI JAIKISHIN, MUMBAI

In the result, the appeal is allowed

Bench: Shri Shailendra Kumar Yadav & Shri Ramit Kocharआयकर अपील सं./I.T.A. No.1562/Mum/2014 ("नधा"रण वष" / Assessment Year: 2010-11)

v) in the form of a percentage of “book profit” [defined in Explanation 3 to section 40(b)]. Up to a “book-profit” of Rs. 1,00,000 or a loss, in the case of a professional firm and Rs. 75,000, in the case of a non-professional firm, the limit is 90% of the “book-profit

PAHILAJRAI JAIKISHAN,MUMBAI vs. DCIT 19(3), MUMBAI

In the result, the appeal is allowed

Bench: Shri Shailendra Kumar Yadav & Shri Ramit Kocharआयकर अपील सं./I.T.A. No.1562/Mum/2014 ("नधा"रण वष" / Assessment Year: 2010-11)

v) in the form of a percentage of “book profit” [defined in Explanation 3 to section 40(b)]. Up to a “book-profit” of Rs. 1,00,000 or a loss, in the case of a professional firm and Rs. 75,000, in the case of a non-professional firm, the limit is 90% of the “book-profit

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

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 'B' BENCH | the Income-tax Act, 1961 - Deduction of Neo Sports | tax at source - Interest other than Broadcast (P.) | interest on securities (Reimbursement of Ltd. commission to holding company) υ. Commissioner

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

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 MUMBAI BENCH 'B' Neo Sports Broadcast (P.) Ltd. IT APPEAL NOS. 4010 & 4011 (MUM.) OF 2014 [ASSESSMENT YEARS 2010-11 AND 2011-12] Section 194A, read with section 263, of the Income-tax Act, 1961 - Deduction of tax at source

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

section 80(P)(2)(d) of the Act provides for deduction in section 80(P)(2)(d) of the Act provides for deduction in section 80(P)(2)(d) of the Act provides for deduction in respect of income of a coop society by way of interest or dividend of income of a coop society by way of interest

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

section 80(P)(2)(d) of the Act provides for deduction in section 80(P)(2)(d) of the Act provides for deduction in section 80(P)(2)(d) of the Act provides for deduction in respect of income of a coop society by way of interest or dividend of income of a coop society by way of interest

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

section 80(P)(2)(d) of the Act provides for deduction in section 80(P)(2)(d) of the Act provides for deduction in section 80(P)(2)(d) of the Act provides for deduction in respect of income of a coop society by way of interest or dividend of income of a coop society by way of interest

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

section 80(P)(2)(d) of the Act provides for deduction in section 80(P)(2)(d) of the Act provides for deduction in section 80(P)(2)(d) of the Act provides for deduction in respect of income of a coop society by way of interest or dividend of income of a coop society by way of interest

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

section 80(P)(2)(d) of the Act provides for deduction in section 80(P)(2)(d) of the Act provides for deduction in section 80(P)(2)(d) of the Act provides for deduction in respect of income of a coop society by way of interest or dividend of income of a coop society by way of interest

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

section 80(P)(2)(d) of the Act provides for deduction in section 80(P)(2)(d) of the Act provides for deduction in section 80(P)(2)(d) of the Act provides for deduction in respect of income of a coop society by way of interest or dividend of income of a coop society by way of interest

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

section 80(P)(2)(d) of the Act provides for deduction in section 80(P)(2)(d) of the Act provides for deduction in section 80(P)(2)(d) of the Act provides for deduction in respect of income of a coop society by way of interest or dividend of income of a coop society by way of interest

DCIT (TDS)(OSD) - 2(3), MUMBAI vs. M/S. WOCKHARDT LTD., MUMBAI

In the result, the appeal filed by the Revenue is dismissed

Bench: Shri Aby T Varkey () & Shri Om Prakash Kant () Assessment Year: 2014-15 Dcit (Tds) (Osd)-2(3), M/S Wockhardt Ltd., Room No. 310, 3Rd Floor, Mtnl Wockhardt Towers, Bandra Building, Cumballa Hill, Vs. Kurla Complex, Mumbai-400026. Mumbai-400051. Pan No. Aaacw 2472 M Appellant Respondent : Assessee By Mr. Pranay Gandhi, Ar : Revenue By Mr. Byomakesh Pradipta Kumar Panda, Cit-Dr : Date Of Hearing 20/12/2022 : Date Of Pronouncement 30/12/2022

194A of the Act. The Learned CIT (Appeals) has rightly reversed the findings of the Assessing (Appeals) has rightly reversed the findings of the Assessing (Appeals) has rightly reversed the findings of the Assessing Officer. Ground raised of the revenue is, therefore, dismissed.” Officer. Ground raised of the revenue is, therefore, dismissed.” Officer. Ground raised of the revenue is, therefore

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

In the result, appeal of the assessee is allowed

disallowed Rs.471,05,05,075/-.\n5. 1. The assessee agitated the matter before ld. CIT(A) and vehemently\ncontended that the assessee had written off bad debts of Rs.923.67 Crore\nafter reducing the opening credit balance in the provision for bad and\ndoubtful debts account u/s 36(1)(viia) of Rs.452.61 Crores and claimed\nthe balance amount of Rs.471.06 Crores

M/S UNION BANK OF INDIA,MUMBAI vs. DEPUTY COMMISSIONER OF INCOME TAX, CIRCLE-(LTU)-2, MUMBAI, MUMBAI

In the result, the appeal of the revenue is dismissed

disallowing exclusion of profits of branches of the Appellant\nBank situated in countries with whom India has entered into a Double\nTaxation Avoidance Agreement (DTAA) namely United Kingdom, France,\nBelgium, Kenya, Japan, United States of America, Singapore, China and\nSouth Africa (herein after referred to as \"foreign branches of the Appellant\nBank\") aggregating to Rs.1408

ACIT CIRCLE ,3(4), MUMBAI, MUMBAI vs. UNION BANK OF INDIA, MUMBAI

In the result, the appeal of the revenue is dismissed

disallowing exclusion of profits of branches of the Appellant\nBank situated in countries with whom India has entered into a Double\nTaxation Avoidance Agreement (DTAA) namely United Kingdom, France,\nBelgium, Kenya, Japan, United States of America, Singapore, China and\nSouth Africa (herein after referred to as \"foreign branches of the Appellant\nBank\") aggregating to Rs.1408

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

Bench: Shri Sandeep Gosain & Shri Prabhash Shankar

v. to give share of the specific projects to the outsiders, wherever applicable. vi. many other reasons depending on case-to-case basis 3. All these entities are engaged in similar business activity of builders and developers. The group is mainly engaged in the business of re-development of slums (SRA Projects) and other old building structures

ACIT, CIRCLE -3(4), MUMBAI, MUMBAI vs. UNION BANK OF INDIA, MUMBAI

In the result, the appeal of the revenue is dismissed

disallowing exclusion of profits of branches of the Appellant\nBank situated in countries with whom India has entered into a Double\nTaxation Avoidance Agreement (DTAA) namely United Kingdom, France,\nBelgium, Kenya, Japan, United States of America, Singapore, China and\nSouth Africa (herein after referred to as \"foreign branches of the Appellant\nBank\") aggregating to Rs.1408