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

In the result, appeals of the assessee are allowed and appeals of the Revenue are dismissed

47,00,310/-, The AO also disallowed a further notional amount of Rs. 12,01,70,250/- as indirect administrative expenditure under clause 2(iii) of Rule 8D, being the amount computed @0.5% of the average value of investments held by the assessee. Hence, the aggregate disallowance under Section

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

In the result, appeals of the assessee are allowed and appeals of the Revenue are dismissed

Bench: SHRI AMIT SHUKLA (Judicial Member), SHRI S.RIFAUR RAHMAN (Accountant Member)

47,00,310/-, The AO also disallowed a further notional amount of Rs. 12,01,70,250/- as indirect administrative expenditure under clause 2(iii) of Rule 8D, being the amount computed @0.5% of the average value of investments held by the assessee. Hence, the aggregate disallowance under Section

ACIT-CIRCLE-5(3)(2), MUMBAI vs. M/S GREAT EASTERN SHIPPING CO. LTD., MUMBAI

In the result, appeals of the assessee are allowed and appeals of the Revenue are dismissed

Bench: SHRI AMIT SHUKLA (Judicial Member), SHRI S.RIFAUR RAHMAN (Accountant Member)

47,00,310/-, The AO also disallowed a further notional amount of Rs. 12,01,70,250/- as indirect administrative expenditure under clause 2(iii) of Rule 8D, being the amount computed @0.5% of the average value of investments held by the assessee. Hence, the aggregate disallowance under Section

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

47,659/- 3. Aggrieved the assessee filed further appeal before the CIT(A). The CIT(A) gave partial relief towards the disallowance made under section 14A r.w.r. 8D and confirmed the other additions/disallowances made by the AO. Aggrieved the assessee is in appeal before us contending the following issues: (i) Additional disallowance under section 14A - Ground

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

47,659/- 3. Aggrieved the assessee filed further appeal before the CIT(A). The CIT(A) gave partial relief towards the disallowance made under section 14A r.w.r. 8D and confirmed the other additions/disallowances made by the AO. Aggrieved the assessee is in appeal before us contending the following issues: (i) Additional disallowance under section 14A - Ground

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

47,659/- 3. Aggrieved the assessee filed further appeal before the CIT(A). The CIT(A) gave partial relief towards the disallowance made under section 14A r.w.r. 8D and confirmed the other additions/disallowances made by the AO. Aggrieved the assessee is in appeal before us contending the following issues: (i) Additional disallowance under section 14A - Ground

BAJAJ INTERNATIONAL REALTY PRIVATE LIMITED ,MUMBAI vs. DCIT, 1(2)1, MUMBAI

In the result both the appeals of the parties are partly allowed for In the result both the appeals of the parties are partly allowed for the statistical purposes

Bench: Shri Om Prakash Kant () & Ms. Kavitha Rajagopal ()

disallowance can be made u/s 14A while computing book profit under the provision of section 115JB of the computing book profit under the provision of section 115JB o computing book profit under the provision of section 115JB o Act. The ground No.12 and 13 of the appeal of the assessee are he ground No.12 and 13 of the appeal

BAJAJ INTERNATIONAL REALTY PRIVATE LIMITED ,MUMBAI vs. DCIT-1(2), MUMBAI

In the result both the appeals of the parties are partly allowed for In the result both the appeals of the parties are partly allowed for the statistical purposes

Bench: Shri Om Prakash Kant () & Ms. Kavitha Rajagopal ()

disallowance can be made u/s 14A while computing book profit under the provision of section 115JB of the computing book profit under the provision of section 115JB o computing book profit under the provision of section 115JB o Act. The ground No.12 and 13 of the appeal of the assessee are he ground No.12 and 13 of the appeal

HINDUSTAN PETROLEUM CORP LTD,MUMBAI vs. DCIT 1(1)(2), MUMBAI

Bench: us. 2.

disallowance under Section 14A of the Act read with Rule 8D(2)(ii) of the Rules. In view of the aforesaid, Ground No. 2 raised by the Revenue is dismissed. Ground No. 3 & 4 30. Ground No. 3 & 4 raised by the Revenue pertains to computation of Book Profits under Section 115JB of the Act. 30.1. Identical ground raised

DCIT-CC-4(2), , MUMBAI vs. BIRLA GROUP HOLDINGS PVT. LTD, MUMBAI

In the result, the appeal of the Revenue is allowed

Bench: Shri Om Prakash Kant () & Shri Rahul Chaudhary () Assessment Year: 2018-19 Dy. Cit, Cc-4(2), Central Birla Group Holdings Pvt. Ltd., Range-4, 1St Floor Industry House, 159 Vs. Room No. 1921, 19Th Floor, Churchgate Reclamation, Air India Building Nariman Churchgate, Mumbai-400020. Point, Mumbai-400021. Pan No. Aaacr 2250 C Appellant Respondent

section 14A r.w.r. 8D(2) which prescribes a methodology for disallowance to be made u/s. 14A." methodology for disallowance to be made u/s. 14A." methodology for disallowance to be made u/s. 14A." 2. Briefly stated, facts of the case are that the assessee a non Briefly stated, facts of the case are that the assessee a non Briefly stated, facts

ACIT-5(1)(1), MUMBAI vs. M/S. ESSAR SHIPPING LTD., MUMBAI

In the result, the appeal of the Revenue is allowed partly for In the result, the appeal of the Revenue is allowed partly for In the result, the appeal of the Revenue is allowed partly for statisti...

Bench: Shri Om Prakash Kant () & Ms. Kavitha Rajagopal () Assessment Year: 2014-15 Acit Circle 5(1)(1), M/S Essar Shipping Ltd., R. No. 568, Aayakar Bhavan, Essar House, 11, K K Marg, Vs. M.K. Road, Mumbai-400020. Mahalaxmi, Mumbai-400034. Pan No. Aacce 3707 D Appellant Respondent

disallowance of Rs.23,69,58,913/- from common interest expenditure by allocating it in the ratio common interest expenditure by allocating it in the ratio common interest expenditure by allocating it in the ratio of assets employed between the tonnage and non of assets employed between the tonnage and non of assets employed between the tonnage and non- tonnage activities

THE GEM & JEWELLERY EXPORT PROMOTION COUNCIL,MUMBAI vs. ASST CIT (E) RG 2(1), MUMBAI

In the result, all the appeals of the assessee are allowed for 10

Bench: Shri Om Prakash Kant () & Shri Rahul Chaudhary () Assessment Year: 2012-13 & Assessment Year: 2013-14 The Gem & Jewellery Export Acit (Exemptions) Range- Promotion Council, 2(1), Vs. Tower-A, Aw-1010, G Block, 5Th Floor, Room No. 519, Bharat Diamond Bourse, Piramal Chambers, Lalbaug, B.K.C., Bandra East, Mumbai-400012. Mumbai-400051. Pan No. Aaatt 3202 H Appellant Respondent Assessment Year: 2014-15 The Gem & Jewellery Export Dcit (Exemptions) Range- Promotion Council, 2(1), Tower-A, Aw-1010, G Block, Vs. 5Th Floor, Piramal Chambers, Bharat Diamond Bourse, Lalbaug, B.K.C., Bandra East, Mumbai-400012. Mumbai-400051. Pan No. Aaatt 3202 H Appellant Respondent

47,543/-. According to the Assessing Officer, the assessee . According to the Assessing Officer, the assessee . According to the Assessing Officer, the assessee was generating huge profit year after year from its activities. The was generating huge profit year after year from its activities was generating huge profit year after year from its activities learned Assessing Officer referred to amendment

TATA INDUSTRIES LIMITED,MUMBAI vs. ADDL.C.I.T., RANGE-2(3), MUMBAI

Section 14A\nof the Act and Rule 8D of the Income Tax Rules, 1962\n(b) Disallowance of brokerage expenses of INR. 1,57,65,808/-\n(c) Disallowance of Debenture Issue Expenses of\nINR.14,82,902/-\n(d) Addition of INR 57,534/- and INR 27,20,110/- in respect of\nthe Guarantee Commission Income\n(e) Disallowance

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

In the result, appeals of the assessee are allowed and\nappeals of the Revenue are dismissed

47,00,310/-, The AO also disallowed a further\nnotional amount of Rs. 12,01,70,250/- as indirect administrative\nexpenditure under clause 2(iii) of Rule 8D, being the amount\ncomputed @0.5% of the average value of investments held by the\nassessee. Hence, the aggregate disallowance under Section

ISC SPECIALITY CHEMICALS LLP ,MUMBAI vs. ITO WARD 19(1)(5), MUMBAI

In the result the appeal filed by the assessee stands partly allowed

Bench: Smt. Beena Pillai () & Shri Girish Agrawal ()

disallow any exemption claimed by the assessee. On the contrary, as the assessee has not offered such capital gain required to be charged u/s. 45 of the Act for taxation as it has failed to satisfy the conditions provided under section 47(xiiib) of the Act, it was proposed to calculate assessee's capital gain on transfer of the assets

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

In the result, appeals of the assessee are allowed and\nappeals of the Revenue are dismissed

47,00,310/-, The AO also disallowed a further\nnotional amount of Rs. 12,01,70,250/- as indirect administrative\nexpenditure under clause 2(iii) of Rule 8D, being the amount\ncomputed @0.5% of the average value of investments held by the\nassessee. Hence, the aggregate disallowance under Section

DCIT-2(3)(1), MUMBAI, MUMBAI vs. HDFC BANK LIMITED, MUMBAI

In the result, the assessee's appeal for AY 2016-17 to AY 2018-19 is allowed and the Revenue's appeal for AY 2016-17 to 2018-19 is dismissed

Bench: Shri Kuldip Singh, Jm & Ms Padmavathy S, Am

Disallowance of bad debts on credit cards – Ground No.3 29. During the year under consideration, the AO noticed that the assessee has claimed Rs. 375,10,36,088/- as write off of bad debts towards credit card. The AO did not allow the claim of the assessee for the reason that the credit card bad debts were never taken into

DCIT 2(3)(1), MUMBAI vs. HDFC BANK LIMITED , MUMBAI

In the result, the assessee's appeal for AY 2016-17 to AY 2018-19 is allowed and the Revenue's appeal for AY 2016-17 to 2018-19 is dismissed

Bench: Shri Kuldip Singh, Jm & Ms Padmavathy S, Am

Disallowance of bad debts on credit cards – Ground No.3 29. During the year under consideration, the AO noticed that the assessee has claimed Rs. 375,10,36,088/- as write off of bad debts towards credit card. The AO did not allow the claim of the assessee for the reason that the credit card bad debts were never taken into