DCIT CIR 5(3)(2), MUMBAI vs. THE GREAT EASTERN SHIPPING CO. LTD, MUMBAI

In the result, appeal of the assessee (ITA number 1597/M/2018) is allowed for statistical purposes

Bench: Shri Prashant Maharishi, Am & Shri Narender Kumar Choudhary , Jm & & The Great Eastern Shipping Co. The Dy. Commissioner Of Ltd. Income-Tax, Kalyaniwalla & Mistry Llp Range-5(3), Esplanade House, 2 Nd Floor, Vs. Room No.525B, 5 Th Floor, M.K. Marg, 29, Hazarimal Somani Marg, Fort, Mumbai-400 001 Mumbai-400 020 (Appellant) (Respondent) Pan No. Aaact1565C The Dy. Commissioner Of Income- The Great Eastern Shipping Co. Tax, Ltd. Range-5(3), Kalyaniwalla & Mistry Llp Vs. Esplanade House, 2 Nd Floor, Room No.525B, 5Th Floor, M.K. Marg, 29, Hazarimal Somani Marg, Mumbai-400 020 Fort, Mumbai-400 001 (Appellant) (Respondent)

198,013 has been claimed as exempt under section 10 (34) of the act. The assessee was asked to furnish the details of the expenditure incurred for earning of the exempt income. Assessee contended that it is not incurred any expenditure for the purpose of earning exempt income and therefore no disallowance

THE GREAT EASTERN SHIPPING CO. LTD,MUMBAI vs. ASST CIT CIR 5(3)(2), MUMBAI

In the result, appeal of the assessee (ITA number 1597/M/2018) is allowed for statistical purposes

Bench: Shri Prashant Maharishi, Am & Shri Narfendrakumar Choudhary , Jm & & The Great Eastern Shipping Co. The Dy. Commissioner Of Ltd. Income-Tax, Kalyaniwalla & Mistry Llp Range-5(3), Esplanade House, 2 N D Floor, Vs. Room No.525B, 5Th Floor, M.K. Marg, 29, Hazarimal Somani Marg, Fort, Mumbai-400 001 Mumbai-400 020 (Appellant) (Respondent) Pan No. Aaact1565C The Dy. Commissioner Of Income- The Great Eastern Shipping Co. Tax, Ltd. Range-5(3), Kalyaniwalla & Mistry Llp Vs. Esplanade House, 2 N D Floor, Room No.525B, 5Th Floor, M.K. Marg, 29, Hazarimal Somani Marg, Mumbai-400 020 Fort, Mumbai-400 001 (Appellant) (Respondent)

198,013 has been claimed as exempt under section 10 (34) of the act. The assessee was asked to furnish the details of the expenditure incurred for earning of the exempt income. Assessee contended that it is not incurred any expenditure for the purpose of earning exempt income and therefore no disallowance

THE GREAT EASTERN SHIPPING CO. LTD,MUMBAI vs. ASST CIT CIR 5(3)(2), MUMBAI

In the result, appeal of the assessee (ITA number 1597/M/2018) is allowed for statistical purposes

Bench: Shri Prashant Maharishi, Am & Shri Narfendrakumar Choudhary , Jm & & The Great Eastern Shipping Co. The Dy. Commissioner Of Ltd. Income-Tax, Kalyaniwalla & Mistry Llp Range-5(3), Esplanade House, 2 N D Floor, Vs. Room No.525B, 5Th Floor, M.K. Marg, 29, Hazarimal Somani Marg, Fort, Mumbai-400 001 Mumbai-400 020 (Appellant) (Respondent) Pan No. Aaact1565C The Dy. Commissioner Of Income- The Great Eastern Shipping Co. Tax, Ltd. Range-5(3), Kalyaniwalla & Mistry Llp Vs. Esplanade House, 2 N D Floor, Room No.525B, 5Th Floor, M.K. Marg, 29, Hazarimal Somani Marg, Mumbai-400 020 Fort, Mumbai-400 001 (Appellant) (Respondent)

198,013 has been claimed as exempt under section 10 (34) of the act. The assessee was asked to furnish the details of the expenditure incurred for earning of the exempt income. Assessee contended that it is not incurred any expenditure for the purpose of earning exempt income and therefore no disallowance

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

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

section\n14A r.w.r 8D and thus the grounds raised by the assessee in this regard are allowed.\n13\nITA 4172/M/13-5749-5750/M/15-110- 111/M/16\nBajaj Electricals Limited\nDisallowance of commission expenses – Ground No.2\n16.\nThe AO during the course of assessment noticed that the assessee has paid\ncommission of Rs.17,06,10,525/- and that the assessee has in the original return

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

disallowance under section 14 A of the income tax act of ₹ 54,199,690/– . The brief of the fact shows that during the year the assessee has earned exempt income of ₹ ITA Nos. 2266 & 2239/Mum/2022 Macrotech Developers Ltd; A.Ys. 17-18 & 18-19 8,303,761/–. Assessee disallowed the same sum under section 14 A of the act. The learned

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

disallowance under section 14 A of the income tax act of ₹ 54,199,690/– . The brief of the fact shows that during the year the assessee has earned exempt income of ₹ ITA Nos. 2266 & 2239/Mum/2022 Macrotech Developers Ltd; A.Ys. 17-18 & 18-19 8,303,761/–. Assessee disallowed the same sum under section 14 A of the act. The learned

ASUS INDIA PVT LTD.,MUMBAI vs. THE LD. ADDL/JOINT/DEPUTY/ACIT/ ITO, DELHI

In the result, appeal of the assessee is partly allowed

Bench: Shri Prashant Maharishi, Am & Ms. Kavitha Rajagopal, Jm Asus India Private Limited The Learned. 402, Supreme Chambers, Addl/Joint/Deputy/Acit/Ito 17-18 Shah Industrial Estate, Room No.305, Ara Centre 2-E Veera Desai Road, Vs. Jhandewalan Extn, New Delhi, Andheri (West), Delhi-110055 Mumbai-400 053 (Appellant) (Respondent) Pan No. Aajca6450C Assessee By : Mr. Vijay Mehta, Adv. Revenue By : Mr. Nihar Ranjan Samal, Sr. Ar Date Of Hearing: 19.05.2023 Date Of Pronouncement : 16.08.2023

section 194H of the act. Accordingly he held that a sum of ₹ 370,175,198 being 30% of ₹ 1,233,917,327 was disallowed

DCIT-15(3)(1), MUMBAI, MUMBAI vs. RELIANCE POWER LTD, NAVI MUMBAI

In the result we do not find any merit in the appeal of the learned assessing officer

Bench: Shri Prashant Maharishi, Am & Shri Rahul Chaudhary, Jm

section 14 A by making the computation under rule 8D (2) of the act. For the indirect interest expenditure under rule 8D (2) (ii) the total disallowance of Rs. 198

DCIT-15(3)(1), MUMBAI , MUMBAI vs. RELIANCE POWER LTD, MUMBAI

In the result we do not find any merit in the appeal of the learned assessing officer

Bench: Shri Prashant Maharishi, Am & Shri Rahul Chaudhary, Jm

section 14 A by making the computation under rule 8D (2) of the act. For the indirect interest expenditure under rule 8D (2) (ii) the total disallowance of Rs. 198

RELIANCE POWER LIMITED,MUMBAI vs. DEPUTY COMMISSIONER OF INCOME TAX CIRCLE, 15(3)(1), MUMBAI

In the result we do not find any merit in the appeal of the learned assessing officer

Bench: Shri Prashant Maharishi, Am & Shri Rahul Chaudhary, Jm

section 14 A by making the computation under rule 8D (2) of the act. For the indirect interest expenditure under rule 8D (2) (ii) the total disallowance of Rs. 198

RELIANCE POWER LIMITED,MUMBAI SUBURBAN vs. DEPUTY COMMISSIONER OF INCOME TAX CIRCLE 15(3)(1), MUMBAI

In the result we do not find any merit in the appeal of the learned assessing officer

Bench: Shri Prashant Maharishi, Am & Shri Rahul Chaudhary, Jm

section 14 A by making the computation under rule 8D (2) of the act. For the indirect interest expenditure under rule 8D (2) (ii) the total disallowance of Rs. 198

MAHARASHTRA STATE ELECTRICITY TRANSMISSION COMPANY LIMITED,MUMBAI vs. ITO CIRCLE 14(1)(1), MUMBAI

Bench: SHRI OM PRAKASH KANT, ACCOUNTANT MEMBER SHRI RAHUL CHAUDHARY (Judicial Member)

Section 37(1) of the Act. The Assessing Officer noted that similar disallowance was made in the Assessee’s own case in earlier years. Therefore, made disallowance of INR.42,69,08,198

JCIT(OSD)-14(1)(1), MUMBAI vs. MAHARASHTRA STATE ELECTRICITY TRANSMISSION CO. LTD., MUMBAI

Bench: SHRI OM PRAKASH KANT, ACCOUNTANT MEMBER SHRI RAHUL CHAUDHARY (Judicial Member)

Section 37(1) of the Act. The Assessing Officer noted that similar disallowance was made in the Assessee’s own case in earlier years. Therefore, made disallowance of INR.42,69,08,198

ADDL CIT 7(2), MUMBAI vs. RELIANCE NATURAL RESOURCES LTD, NAVI MUMBAI

In the result, the appeal is allowed

Bench: Shri Jason P. Boaz & Shri Saktijit Deyreliance Natural Resources Ltd. Addl. Cit, Range 7(2) H Block, 1St Floor, Dhirubhai Room No. 620, 6Th Floor Vs. Ambani Knowledge City Aayakar Bhavan Navi Mumbai 400710 M.K. Road, Mumbai 400020 Pan - Aabcr7656P Appellant Respondent Addl. Cit, Range 7(2) Reliance Natural Resources Ltd. Room No. 620, 6Th Floor H Block, 1St Floor, Dhirubhai Vs. Aayakar Bhavan Ambani Knowledge City M.K. Road, Mumbai 400020 Navi Mumbai 400710 Pan - Aabcr7656P Appellant Respondent

disallowed. On appeal, the learned CIT(A) held that the FCCBs are in the nature of debentures and unsecured loans and hence the expenditure incurred for issue of FCCBs is allowable deduction under section 37(1) of the Act. 11.3 Before us, the learned A.R. for the assessee reiterated the facts of the matter on this issue as laid

RELIANCE NATURAL RESOURCES LTD,NAVI MUMBAI vs. ADDL CIT RG 7(2), MUMBAI

In the result, the appeal is allowed

Bench: Shri Jason P. Boaz & Shri Saktijit Deyreliance Natural Resources Ltd. Addl. Cit, Range 7(2) H Block, 1St Floor, Dhirubhai Room No. 620, 6Th Floor Vs. Ambani Knowledge City Aayakar Bhavan Navi Mumbai 400710 M.K. Road, Mumbai 400020 Pan - Aabcr7656P Appellant Respondent Addl. Cit, Range 7(2) Reliance Natural Resources Ltd. Room No. 620, 6Th Floor H Block, 1St Floor, Dhirubhai Vs. Aayakar Bhavan Ambani Knowledge City M.K. Road, Mumbai 400020 Navi Mumbai 400710 Pan - Aabcr7656P Appellant Respondent

disallowed. On appeal, the learned CIT(A) held that the FCCBs are in the nature of debentures and unsecured loans and hence the expenditure incurred for issue of FCCBs is allowable deduction under section 37(1) of the Act. 11.3 Before us, the learned A.R. for the assessee reiterated the facts of the matter on this issue as laid

CAPRI GLOBAL ADVISORY SERVICES PVT. LTD. (NOW AMALGAMATED WITH CAPRI GLOBAL HOLDINGS PVT. LTD.),MUMBAI vs. DEPUTY COMMISSIONER OF INCOME TAX, CIRCLE - 1(1)(1), MUMBAI

In the result all the appeals of the assessee are allowed

Bench: SHRI AMIT SHUKLA (Judicial Member), SHRI GIRISH AGRAWAL (Accountant Member)

section 14A read with Rule 8D are tabulated below: Sr. Particulars A.Y.2017-18 A.Y.2018- A.Y.2020- No. (Amt) 19(Amt) 21(Amt) 1] Exempt Income earned 12,13,02,344 18,18,51,296 97,14,869 by the Assesses II] Suomoto Disallowance 2,06,263 7,78,768 4,38,366 u/s 14A made by the Assessee III] Disallowance

CAPRI GLOBAL ADVISORY SERVICES PVT. LTD. (NOW AMALGAMATED WITH CAPRI GLOBAL HOLDINGS PVT. LTD.),MUMBAI vs. DEPUTY COMMISSIONER OF INCOME TAX, CIRCLE - 1(1)(1), MUMBAI

In the result all the appeals of the assessee are allowed

Bench: SHRI AMIT SHUKLA (Judicial Member), SHRI GIRISH AGRAWAL (Accountant Member)

section 14A read with Rule 8D are tabulated below: Sr. Particulars A.Y.2017-18 A.Y.2018- A.Y.2020- No. (Amt) 19(Amt) 21(Amt) 1] Exempt Income earned 12,13,02,344 18,18,51,296 97,14,869 by the Assesses II] Suomoto Disallowance 2,06,263 7,78,768 4,38,366 u/s 14A made by the Assessee III] Disallowance

CAPRI GLOBAL ADVISORY SERVICES PVT. LTD. (NOW AMALGAMATED WITH CAPRI GLOBAL HOLDINGS PVT. LTD.),MUMBAI vs. DEPUTY COMMISSIONER OF INCOME TAX, CIRCLE - 1(1)(1), MUMBAI

In the result all the appeals of the assessee are allowed

Bench: SHRI AMIT SHUKLA (Judicial Member), SHRI GIRISH AGRAWAL (Accountant Member)

section 14A read with Rule 8D are tabulated below: Sr. Particulars A.Y.2017-18 A.Y.2018- A.Y.2020- No. (Amt) 19(Amt) 21(Amt) 1] Exempt Income earned 12,13,02,344 18,18,51,296 97,14,869 by the Assesses II] Suomoto Disallowance 2,06,263 7,78,768 4,38,366 u/s 14A made by the Assessee III] Disallowance