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

3,29,345/-, and disallowed provision for leave encashment amounting to Rs. 57,63,634/-. The CIT(A) upheld all the aforesaid disallowances and granted (5) ITA No. 6663, 6701, 6702 & 6703 /Mum/2025 Aditya Birla Sun Life AMC Limited limited relief only in respect of short grant of TDS credit by directing verification. Interest under sections 234B

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

Accordingly, this ground is allowed

3,29,345/-, and disallowed provision for leave encashment amounting to Rs. 57,63,634/-. The CIT(A) upheld all the aforesaid disallowances and granted limited relief only in respect of short grant of TDS credit by directing verification. Interest under sections 234B

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

Accordingly, this ground is allowed

3,29,345/-, and disallowed provision for leave encashment amounting to Rs. 57,63,634/-. The CIT(A) upheld all the aforesaid disallowances and granted limited relief only in respect of short grant of TDS credit by directing verification. Interest under sections 234B

FRANKLIN TEMPLETON INTERNATIONAL SERVICES (INDIA) P.LTD,MUMBAI vs. DCIT CIR 6(3)(1), MUMBAI

3 - Deduction for repairs and maintenance cost - alternate\nto ground no. 2\n3.1. Without prejudice to Ground 2 above, the learned AO erred on\nfact and in law in not allowing further deduction under section 10A/ 10B\nof the Act from the total income computed by him, particularly on account\nof the disallowance of Rs. 29,47,184, referred

GROWMORE EXPORTS LTD,MUMBAI vs. DCIT CC 31, MUMBAI

In the result, the assessee ‘s appeal for the assessment year 2008-09

Bench: Shri Jason P. Boaz & Shri Ram Lal Negi

3. The Ld. Commissioner of Income-Tax (Appeals) has erred in law and in facts that in confirming the levy of interest u/s. 234A, 234B and 234C of the Act. 4. The Ld. Commissioner of Income-tax (Appeals) has erred in law and in facts in not appreciating that the income assessed. in the hands of the appellant were subjected

APL LOGISTICS P.LTD,MUMBAI vs. DCIT 14(1)(1), MUMBAI

In the result, appeal of the assessee is partly allowed

3) Disallowance under section 14A r.w.r 8D. & 2917 M 15- APL Logistics (India) Pvt. Ltd. The ld. Counsel submitted that the issue raised in the present appeal are identical to the issues adjudicated by the Tribunal in assessee’s appeal for AY 2006-07 & 2007-08. The ld. Counsel pointed that the submissions made while addressing the issue

APL LOGISTICS (INDIA) P. LTD,MUMBAI vs. ASST CIT 10(1), MUMBAI

In the result, appeal of the assessee is partly allowed

3) Disallowance under section 14A r.w.r 8D. & 2917 M 15- APL Logistics (India) Pvt. Ltd. The ld. Counsel submitted that the issue raised in the present appeal are identical to the issues adjudicated by the Tribunal in assessee’s appeal for AY 2006-07 & 2007-08. The ld. Counsel pointed that the submissions made while addressing the issue

DCIT 10(1), MUMBAI vs. APL LOGISTICS (INDIA) P. LTD, MUMBAI

In the result, appeal of the assessee is partly allowed

3) Disallowance under section 14A r.w.r 8D. & 2917 M 15- APL Logistics (India) Pvt. Ltd. The ld. Counsel submitted that the issue raised in the present appeal are identical to the issues adjudicated by the Tribunal in assessee’s appeal for AY 2006-07 & 2007-08. The ld. Counsel pointed that the submissions made while addressing the issue

APL LOGISTICS (INDIA) P.LTD,MUMBAI vs. ASST CIT 10(1), MUMBAI

In the result, appeal of the assessee is partly allowed

3) Disallowance under section 14A r.w.r 8D. & 2917 M 15- APL Logistics (India) Pvt. Ltd. The ld. Counsel submitted that the issue raised in the present appeal are identical to the issues adjudicated by the Tribunal in assessee’s appeal for AY 2006-07 & 2007-08. The ld. Counsel pointed that the submissions made while addressing the issue

DCIT 10(1), MUMBAI vs. APL LOGISTICS (INDIA ) P.LTD, MUMBAI

In the result, appeal of the assessee is partly allowed

3) Disallowance under section 14A r.w.r 8D. & 2917 M 15- APL Logistics (India) Pvt. Ltd. The ld. Counsel submitted that the issue raised in the present appeal are identical to the issues adjudicated by the Tribunal in assessee’s appeal for AY 2006-07 & 2007-08. The ld. Counsel pointed that the submissions made while addressing the issue

APL LOGISTICS (INDIA) P. LTD,MUMBAI vs. ACIT 10(1), MUMBAI

In the result, appeal of the assessee is partly allowed

3) Disallowance under section 14A r.w.r 8D. & 2917 M 15- APL Logistics (India) Pvt. Ltd. The ld. Counsel submitted that the issue raised in the present appeal are identical to the issues adjudicated by the Tribunal in assessee’s appeal for AY 2006-07 & 2007-08. The ld. Counsel pointed that the submissions made while addressing the issue

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

3. The learned assessing officer/DRP has erred in enhancing the book profit of ₹ 54,199,690/– by disallowance under section 14 A of the act while calculating MAT liability under section 115JB of the act 4. The learned assessing officer/DRP has erred in disallowing loan processing fee of ₹ 46,843,401/–. 5. The learned assessing officer/DRP has erred in disallowing

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

3. The learned assessing officer/DRP has erred in enhancing the book profit of ₹ 54,199,690/– by disallowance under section 14 A of the act while calculating MAT liability under section 115JB of the act 4. The learned assessing officer/DRP has erred in disallowing loan processing fee of ₹ 46,843,401/–. 5. The learned assessing officer/DRP has erred in disallowing

SICOM LTD ,MUMBAI vs. DY COMMISSIONER OF INCOME TAX CIRCLE 3(3)(1), MUMBAI

In the result, the appeal filed by the assesee is partly allow for statistical purpose and the appeal filed by the revenue is allowed for statistical purposes

Bench: Shri Om Prakash Kant & Shri Pavan Kumar Gadale, Judicialmember Sicom Ltd, Vs. Dy Commissioner Of Solitaire Corporate Income Tax Circle Park, Bldg No.04, 3(3)(1), Chakala, Andheri(E), 6Th Floor, Room No. Mumbai-400093. 609,Aayakar Bhavan, Maharishi Karve Road, Mumbai- 400020. "थायी लेखा सं./जीआइआर सं.Pan/Gir No. Aaacs5524J (अपीलाथ"/Applicant) (""यथ"/Respondent) Dy Commissioner Of Vs. Sicom Ltd, Income Tax Circle Solitaire Corporate Park, 3(3)(1), Bldg No.04, Chakala, 6Th Floor, Room No. Andheri(E), 609,Aayakar Bhavan, Mumbai-400093. Maharishi Karve Road, Mumbai- 400020. "थायी लेखा सं./जीआइआर सं.Pan/Gir No. Aaacs5524J (अपीलाथ"/Applicant) (""यथ"/Respondent)

3 ITA . No. 1694/MUM/2023 & 2036/MUM/2023 SICOM LTD. 4. erred in not appreciating the fact that the appellant is in the business of project financing and advances were given to subsidiary which was wholly and exclusively for the purpose of business, thereby notional interest cannot be disallowed on such advances, II. Disallowance under section 14A of the Act in respect

ASST CIT (LTU) 1, MUMBAI vs. GRASIM INDUSTRIES LIMITED (AS A SUCCESSOR TO ADITYA BIRLA NUVO LTD, MUMBAI

In the result, appeal of the Revenue is dismissed

Bench: Shri Vikas Awasthy, Jm & Ms Padmavathy S, Am

3,923,46,000/- 8 Upholding the action of the TPO of treating corporate guarantee given to subsidiaries as international transaction and partly confirming the additions made by the TPO. 9 Interest under section 234B, 234C & 234D. 10 Penalty proceedings u/s. 271(1)(c) Revenue Ground No. Issues 1 to 4 Disallowance

GRASIM INDUSTRIES LIMITED (AS A SUCCESSOR TO ADITYA BIRLA NUVO LTD),MUMBAI vs. ADDL CIT LTU, MUMBAI

In the result, appeal of the Revenue is dismissed

Bench: Shri Vikas Awasthy, Jm & Ms Padmavathy S, Am

3,923,46,000/- 8 Upholding the action of the TPO of treating corporate guarantee given to subsidiaries as international transaction and partly confirming the additions made by the TPO. 9 Interest under section 234B, 234C & 234D. 10 Penalty proceedings u/s. 271(1)(c) Revenue Ground No. Issues 1 to 4 Disallowance

GREAVES COTTON LTD,MUMBAI vs. ASST CIT CIR 6(3), MUMBAI

In the result this ground of appeal

Bench: Shri Pradip Kumar Kedia & Shri Pawan Singhgreaves Cotton Ltd. Acit Circle-6(3), Industry Manor, Appasaheb Aayakar Bhavan, M.K. Road, Vs. Marathe Marg, Prabhadevi, Mumbai-400020. Mumbai-400025. Pan: Aaacg2062M Appellant Respondent Greaves Cotton Ltd. Acit Circle-6(3), Industry Manor, Appasaheb Aayakar Bhavan, M.K. Road, Vs. Marathe Marg, Prabhadevi, Mumbai-400020. Mumbai-400025. Pan: Aaacg2062M Appellant Respondent Appellant By : Smt. Arati Vissanji (Advocate) Respondent By : Shri Abbi Rama Karthikey (Dr) Date Of Hearing : 04.06.2019 Date Of Pronouncement : 07.06.2019 Order Under Section 254(1)Of Income Tax Act

3 &4) are partly allowed. 11. Ground No. B (5) relates to adjustment of book profit under section 115JB of disallowance of Rule 14A. The ld. AR of the assessee submits that this ground of appeal is also covered by the decision of Special Bench of Delhi Tribunal in ACIT Vs Vireet Investment (P) Ltd, (82 taxmann.com 415) (Delhi

SIR RATAN TATA TRUST,MUMBAI SUBURBAN vs. ADDITIONAL /JOINT/DEPUTY/ASSISTANT COMMISSIONER OF INCOME TAX, NFAC, MUMBAI

In the result, both the appeals of the assessee in both AY 2014-15 and AY

Bench: Ms Padmavathy S, Am & Shri Rahul Chaudhary, Jm

disallowed exemption of dividend under section 10(34). Learned Commissioner does not dispute these facts but adds that the Assessing Officer did not examine the fundamental question as to whether these shareholdings, as on 1st June 1973, were part of the corpus or not. Unless, according to the learned Commissioner, these shareholdings were held to be part of the corpus

SIR RATAN TATA TRUST,MUMBAI SUBURBAN vs. DEPUTY COMMISSIONER OF INCOME TAX (EXEMPTION)-2(1), MUMBAI

In the result, both the appeals of the assessee in both AY 2014-15 and AY

Bench: Ms Padmavathy S, Am & Shri Rahul Chaudhary, Jm

disallowed exemption of dividend under section 10(34). Learned Commissioner does not dispute these facts but adds that the Assessing Officer did not examine the fundamental question as to whether these shareholdings, as on 1st June 1973, were part of the corpus or not. Unless, according to the learned Commissioner, these shareholdings were held to be part of the corpus