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

1)(va)", "Section 40(a)(ia)", "Section 43B", "Section 234B", "Section 234C", "Section 270A", "Section 115P", "Section 111A", "Section 112A", "Section 234D", "Section 244A", "Section 199", "Rule 37BA of the Income-tax Rules, 1962"], "issues": "The appeals involve multiple assessment years and grounds, including challenges to disallowances

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

disallowance of Rs. 54,93,734/- made under section 36(1)(va) of the Act. Thus, Ground No. I raised by the assessee for A.Y. 2022– 23 is allowed. Ground No. II - Short grant of consequential interest under section 244A of the Act 81. This ground relates to the grievance of the assessee that the Assessing Officer has granted short

STRIDES PHARMA SCIENCE LTD.,NAVI MUMBAI vs. THE DY CIT -5(1)(2), MUMBAI

In the result ITA number 1004/M/2021 filed by the assessee for assessment year 2016 – 17 is allowed

Bench: Shri Prashant Maharishi, Am & Shri Sandeep Singh Karhail, Jm Strides Pharma Science Ltd. Dcit 15(1)(2) 201, Devavrata, Sector-17, Aayakar Bhavan, M K Road, Vs. Vashi, Navi Mumbai, 400703 Mumbai 400020 (Appellant) (Respondent) Pan No. Aadcs8104P

disallowance of business promotion expenditure of ₹ 15,199,296/– under section 37 (1) of the act, the learned DRP followed

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

1,16,95,21,997/- as\nagainst the total TDS claimed, resulting in short grant of credit.\n102. The ld. AR submitted that the assessee is legally entitled to\nthe TDS credit under section 199 of the Act read with Rule 37BA\nof the Income-tax Rules, 1962, and prayed that the Assessing\nOfficer be directed to verify the details

M/S. TATA INDUSTRIES LTD,MUMBAI vs. THE ITO 2(3)(3), MUMBAI

In the result, appeal of the assessee is treated as partly allowed

Bench: Shri G. S. Pannu, Accoutant Member & Shri Sanjay Gargtata Industries Ltd., Vs. The Income Tax Officer, Ward- Bombay House,24,Homi 2 (3) (3), Room No.555, Mody Street, Fort, Mumbai Aayakar Bhavan, Maharshi 400 001 Karve Road, Mumbai 400 020 Pan: Aaact 4058 L Appellant .. Respondent Appellant By Shri Dinesh Vyas, Ar Respondent By Shri Alok Johri, Dr Date Of Hearing 22-06-2016 Date Of Pronouncement 20-07-2016

section 37, it is not necessary that the loan amount should be exclusively used in the business of the assessee. However, the requirement is that it should be used for the purpose of the business which need not necessarily be the business of the assessee itself. What is to be seen is that the transfer of borrowed funds

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

sections": [ "250", "143(1)", "143(2)", "142(1)", "143(3)", "144B", "80G", "36(1)(va)", "40(a)(ia)", "43B", "234B", "234C", "270A", "115P", "111A", "112A", "234D", "244A", "199", "37(1)", "40(a)", "43B(f)" ], "issues": "The primary issues revolved around the allowability of various deductions, disallowances

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)

section 40(a)(i) of the Act and tax should have been deducted at source by the assessee firm u/s 195 of the Act or an application should have been made by the assessee firm for no deduction of tax at source u/s 195(2) of the Act . Thus the AO held that these payments to non-resident by assessee

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)

section 40(a)(i) of the Act and tax should have been deducted at source by the assessee firm u/s 195 of the Act or an application should have been made by the assessee firm for no deduction of tax at source u/s 195(2) of the Act . Thus the AO held that these payments to non-resident by assessee

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

Section 43A, assessee was entitled to adjust\nactual cost of imported assets acquired in foreign currency on\naccount of fluctuation in rate of exchange at each balance-sheet\ndate, pending actual payment of varied liability - Held, Income-tax\nAct, 1961 Foreign currency, rate of Assessment year 1998-99\nWhether amendment Finance Act, 2002 with effect from 1

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

section 43A, assessee was entitled to adjust\nactual cost of imported assets acquired in foreign currency on\naccount of fluctuation in rate of exchange at each balance-sheet\ndate, pending actual payment of varied liability - Held, Income-tax\nAct, 1961 Foreign currency, rate of Assessment year 1998-99\nWhether amendment Finance Act, 2002 with effect from 1

VODAFONE INDIA LTD,MUMBAI vs. ASST CIT 8(3)(2), MUMBAI

Section 37(1) 2,05,35,800 TP Adjustment 36,38,25,151 Total Disallowances 659,75,09,200 Taxable income under the head business or profession 474,01,91,199

M/S THE STATE BANK OF PATIALA,PATIALA vs. ACIT, PATIALA

In the result, the appeals of the assessee are partly allowed for In the result, the appeals of the assessee are partly allowed for statistical purposes

Bench: Shri Aby T Varkey () & Shri Om Prakash Kant () Assessment Year: 2013-14 & Assessment Year: 2014-15 & Assessment Year: 2015-16 The State Bank Of India Asst. Cit Circle-Patiala, (Successor To State Bank Of Aayakar Bhavan, Vs. Patiala), Patiala-147001 Dgm & Cfo, Sbi, Local Head Office – Chandigarh, 2Nd Floor, Sector 17A, Chandigarh- 160017. Pan No. Aaccs 0143 D Appellant Respondent Assessee By : Mr. Ketan Ved & Mr. Ninadpatade, Ars Revenue By : Dr. Kishor Dhule, Cit-Dr : Date Of Hearing 09/03/2023 Date Of Pronouncement : 31/03/2023

disallowance of provision before bad debts under Section 36 (1) (viia) of Rs.8.53 before bad debts under Section 36 (1) (viia) of Rs.8.53 before bad debts under Section 36 (1) (viia) of Rs.8.53 crores observing that as per Rule 62ABA of the Income Tax crores observing that as per Rule 62ABA of the Income Tax crores observing that

GRASIM INDUSTRIES LTD ( CORPORATE FINANCE DIVISION),MUMBAI vs. ADDL CIT RG 6(3), MUMBAI

Bench: the CIT(A). The CIT(A) partly allowed the appeal preferred by the Assessee vide order, dated 18/05/2009. 4. Not being satisfied with the relief granted by the Id. CIT(A), the Assessee has preferred appeal before this Tribunal. The Revenue has also filed cross-appeal challenging the relief granted by the Id. CIT(A).

disallowance and held that the provision of section 40(a)(ia) are not applicable in the case.” 8.1. During the course of hearing the Learned Senior Counsel, on instructions, stated that the Assessee does not wish to pursue this ground since relief has been granted to the assessee in relation to this ground in appellate proceedings pertaining to the preceding

LARSEN & TOUBRO LTD,MUMBAI vs. ADDL CIT RG 2(2), MUMBAI

In the result the appeal of the assessee is partly allowed and that of the revenue is dismissed

1 Kovaya Gujarat GCW –CPP 4,37,30,317 TOTAL 4,37,30,317 According to the assessee these expenses were basically revenue in nature and have been incurred wholly and exclusively for the purpose of the company's business. The AO made disallowance of the abovementioned expenditure on ground that, similar expenditure was disallowed by his predecessor relying

ASST CIT CIR 6(1)(2), MUMBAI vs. ASK INVESTMENT MANAGERS P.LTD, MUMBAI

The appeal of the Revenue is allowed for statistical

Bench: Shri Joginder Singh & Shri G. Manjunathaassessment Year 2012-13 Acit M/S Ask Investment Circle-6(1)(2), Managers Pvt. Ltd. बनाम/ R. No.536, 5Th Floor, 1St Floor Bandbox House, Vs. Aayakar Bhavan, Dr. Ab Road, Worli, M. K. Road, Churchgate, Mumbai-400030 Mumbai-400020 (राज"व /Revenue) ("नधा"रती /Assessee) P.A. No. Aafca2302P Shri Nitin Waghmode-Dr राज"व क" ओर से / Revenue By "नधा"रती क" ओर से / Assessee By Shri J.D. Mistri Sr. Advocate

disallowance of expenditure in relation to the exempt income for the first time, but it was always the intention of the Act for not allowing such deduction and this insertion was made only to clarify the intention of the legislature as it was since inception. He pointed out that since section 14A did not provide the method of computing

ACIT 11(3)(1), MUMBAI vs. TOTAL OIL INDIA P.LTD, MUMBAI

Bench: Shri G. S. Pannu, Vp & Shri Amarjit Singh, Jm

disallowing the expenditure u/s 40(a)(i) is upheld and the ground raised by the appellant is dismissed.” 8. On appraisal of the above said finding, we noticed that the matter of controversy has been decided by the CIT(A) on the basis of decision of Bombay High Court in the case of Orient

TOTAL OIL INDIA P.LTD,MUMBAI vs. ADDL CIT RG 8(3), MUMBAI

Bench: Shri G. S. Pannu, Vp & Shri Amarjit Singh, Jm

disallowing the expenditure u/s 40(a)(i) is upheld and the ground raised by the appellant is dismissed.” 8. On appraisal of the above said finding, we noticed that the matter of controversy has been decided by the CIT(A) on the basis of decision of Bombay High Court in the case of Orient

TATA CONSULTANCY SERRVICES LIMITED,MUMBAI vs. DCIT-1, MUMBAI

Bench: Shri Vikas Awasthy () & Ms. Padmavathy S. ()

Disallowance of subscription to Clayton Christensen Institute (CCI) and Royal Hospital for Women Foundation – Ground 1 5. During the course of assessment, the Assessing Officer noticed that assessee has debited a sum of Rs.23,41,64,199/- as donation and in the computation, assessee has added only Rs.20,27,39,220/-. The Assessing Officer called on the assessee to explain