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

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

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

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

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

BENNETT PROPERTY HOLDINGS COMPANY LIMITED,MUMBAI vs. ADDITIONAL -JOINT -DEPUTY-ASST. COMMISSIONER OF INCOME TAX- ITO, DELHI

234B"], "issues": "1. Whether the disallowance under Section 14A and Rule 8D was correctly applied by the Assessing Officer and confirmed by the CIT(A). 2. Whether the Assessee is entitled to set off accumulated loss and unabsorbed depreciation of a demerged undertaking. 3

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

BENNETT PROPERTY HOLDINGS COMPANY LIMITED,MUMBAI vs. DEPUTY COMMISSIONER OF INCOME TAX - 1 (1) (1), MUMBAI, MUMBAI

3) read with Section 144B of the act vide Assessment Order, dated 17/09/2021, assessing the total income of the Assessee under the normal provisions of the Act at INR.58,05,27,113/- and computing Book Profits of the Assessee under Section 115JB of the Act at INR.62,46,98,115/-. Since the tax payable on Book Profits was less than

JAMNADAS VIRJI SHARES AND STOCK BROKERS PRIVATE LIMITED,MUMBAI vs. DEPUTY COMMISSIONER OF INCOME TAX 4(3)(1), MUMBAI

3)", "Section 147", "Section 144B", "Section 133A", "Section 37(1)", "Section 10(34)", "Section 234A", "Section 234B", "Section 234C", "Section 234D"], "issues": "Whether the purchases of gold coins were bogus and disallowable

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

FIDELITY SALEM STREET TRUST FIDELITY SAI EMERGING MARKETS INDEX FUND ,MUMBAI vs. DEPUTY COMMISSIONER OF INCOME TAX (INTERNATIONAL TAXATION)-2(3)(1), MUMBAI

The appeals are partly allowed

Bench: SHRI NARENDRA KUMAR BILLAIYA, ACCOUNTANT MEMBER SHRI RAHUL CHAUDHARY (Judicial Member)

disallowance has been made on presumption. In these circumstances, the order passed by the Commissioner of Income Tax and subsequent thereto, the Commissioner of Income Tax (Appeals) had already considered the case of the department and upheld the order passed by it. We have carefully considered the said question and in our considered opinion, there is no illegality or irregularity

EMPLOYEES RETIREMENT SYSTEM OF TEXAS ,MUMBAI vs. DY CIT (INT. TAX)-2(2)(1), MUMBAI

The appeals are partly allowed

Bench: SHRI NARENDRA KUMAR BILLAIYA, ACCOUNTANT MEMBER SHRI RAHUL CHAUDHARY (Judicial Member)

disallowance has been made on presumption. In these circumstances, the order passed by the Commissioner of Income Tax and subsequent thereto, the Commissioner of Income Tax (Appeals) had already considered the case of the department and upheld the order passed by it. We have carefully considered the said question and in our considered opinion, there is no illegality or irregularity

ACIT-1(1)(1), MUMBAI, MUMBAI vs. BENNETT PROPERTY HOLDINGS COMPANY LIMITED, MUMBAI

Bench: SHRI AMARJIT SINGH, ACCOUNTANT MEMBER SHRI RAHUL CHAUDHARY (Judicial Member)

3) read with Section 144B of the act vide Assessment Order, dated 17/09/2021, assessing the total income of the Assessee under the normal provisions of the Act at INR.58,05,27,113/- and computing Book Profits of the Assessee under Section 115JB of the 24 ITA No. 502/Mum/2024, ITA No.302/Mum/2024 ITA No.556/Mum/2024 & ITA No. 557/Mum/2024 Assessment Year

ACIT-1(1)(1), MUMBAI., MUMBAI vs. BENNETT PROPERTY HOLDINGS COMPANY LIMITED, MUMBAI

disallowance while working of book profit u/s. 115JB\"\n18.\nThe relevant facts in brief that for the Assessment Year 2018–19, the\nAssessee filed original return of income on 31/10/2018 which was\nrevised on 28/03/2019. The case of the Assessee was selected for\nscrutiny. The Assessing Officer completed the assessment under\nSection 143(3) read with Section 144B

EMERSON ELECTRIC COMPANY (INDIA) PRIVATE LIMITED,MUMBAI vs. ADDL/JT/DY/ASSTT/CIT/ITO , DELHI

In the result, the appeal by the assessee is partly allowed for statistical purposes

Bench: Shri S. Rifaur Rahman & Shri Sandeep Singh Karhail

234B as per law. 9. Ground no. 9 - Incorrect computation of interest under Section 234C On the facts and circumstances of the case and in law, the Ld. AO erred in levying interest of Rs. 13.98,175 under Section 234C instead of Rs.11,91,466. The Appellant prays that the Ld. AO be directed to recompute the interest under Section