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).

2 to 2.2 raised the Assessee are allowed. 8. Ground No. 3. “3. Disallowance u/s.40(a)(ia) 3.1. On the facts and circumstances of the case and in law, the CIT (A) erred in upholding the action of AO in disallowing the liability of Rs. 1,74,35,896/- towards year-end expenses applying provision of section

DCIT, CIR-3(3)(1), MUMBAI vs. SICOM LIMITED, MUMBAI CITY

In the result, the appeal filed by the revenue is dismissed

Bench: Shri Pavan Kumar Gadale & Shri Gagan Goyalita Nos. 2034 & 2035/Mum/2023 (A.Y:1999-2000 &1998-99) Dcit, Circle-3(3)(1), Vs. M/S Sicom Limited, Room No.609, Solitaire Corporate Aayakar Bhavan, Park, Building No.4, M.K. Road, Guru Nanak Marg, Mumbai-400020. Chakala, Midc S.O, Mumbai-400093. Pan/Gir No. : Aaacs5524J Appellant .. Respondent

2. Whether on the facts and circumstances of the case, the Ld. CIT(A) is justified in law in directing Assessing officer to allow the short grant of interest u/s 21 of the Interest Tax Act r.w.s 244A(1) of the Act as per law by applying the same principle & rationale as held in decision of Hon'ble Delhi High

HDFC BANK LIMITED (AS SUCCESSOR TO HOUSING DEVELOPMENT FINANCE CORPORATION LTD),MUMBAI vs. DCIT 1(1), MUMBAI

Bench: Shri Anikesh Banerjee & Shri Girish Agrawal

disallowable item and added back to its profit before tax for computing total income in the earlier years. In the year under consideration, balance in the lease equalisation account is a credit balance at the year end. For this credit balance, assessee reduced the same from the profits while computing total income for the year. However, ld. Assessing Officer denied

HDFC BANK LIMITED (AS SUCCESSOR TO HOUSING DEVELOPMENT FINANCE CORPORATION LTD),MUMBAI vs. ADDL CIT RG 1(1), MUMBAI

Bench: Shri Anikesh Banerjee & Shri Girish Agrawal

disallowable item and added back to its profit before tax for computing total income in the earlier years. In the year under consideration, balance in the lease equalisation account is a credit balance at the year end. For this credit balance, assessee reduced the same from the profits while computing total income for the year. However, ld. Assessing Officer denied

ADDL CIT RG 1(1), MUMBAI vs. HDFC LTD, MUMBAI

Bench: Shri Anikesh Banerjee & Shri Girish Agrawal

disallowable item and added back to its profit before tax for computing total income in the earlier years. In the year under consideration, balance in the lease equalisation account is a credit balance at the year end. For this credit balance, assessee reduced the same from the profits while computing total income for the year. However, ld. Assessing Officer denied

HDFC BANK LIMITED (AS SUCCESSOR TO HOUSING DEVELOPMENT FINANCE CORPORATION LTD),MUMBAI vs. DCIT RG 1(1), MUMBAI

Bench: Shri Anikesh Banerjee & Shri Girish Agrawal

disallowable item and added back to its profit before tax for computing total income in the earlier years. In the year under consideration, balance in the lease equalisation account is a credit balance at the year end. For this credit balance, assessee reduced the same from the profits while computing total income for the year. However, ld. Assessing Officer denied

HDFC BANK LIMITED (AS SUCCESSOR TO HDFC LTD),MUMBAI vs. DCIT 2(3)(1), MUMBAI

2 | As at \nMarch 31, 2004 | As at \nMarch 31, 2005 \nRupees | Rupees | Rupees \n---|---|---\nSPECIAL RESERVE No. I | 194,35,94,700 | 934,35,94,700\nLess: Transfer to Provision for Contingencies | 50,00,00,000 | 40,00,00,000 \nSPECIAL RESERVE No. II | 144,35,94,700 | 194,35,94,700 \nOpening Balance

M/S. STANDARD CHARTERED BANK,MUMBAI vs. THE ACIT (IT)1(3), MUMBAI

In the result, appeal filed by the assessee is allowed and appeal filed by the Revenue is dismissed

Bench: Shri Amit Shukla, Hon'Ble & Shri S. Rifaur Rahman, Hon'Blestandard Chartered Bank V. Acit – Range-1(3) Taxation Department, 23-25 Scindia House, Ballard Estate M.G. Road, 3Rd Floor N.M. Marg, Mumbai - 400038 Fort, Mumbai - 400001 Pan: Aabcs4681D (Appellant) (Respondent) Adit (It)– 2(3) V. Standard Chartered Bank Room No. 120, 1St Floor Taxation Department, 23-25 Scindia House, Ballard Estate M.G. Road, 3Rd Floor N.M. Marg, Mumbai - 400038 Fort, Mumbai - 400001 Pan: Aabcs4681D (Appellant) (Respondent) Shri P.J. Pardiwala & Assessee Represented By : Shri Fenil Bhatt Shri Soumendu Kumar Dash Department Represented By :

disallowed: - 9 ITA NO. 803 & 850/MUM/2009 (A.Y. 1999-2000) Standard Chartered Bank Refurbishment: (i). Madras Auto Service Pvt. Ltd., [233 ITR 468 (SC) (ii). R.B Bansilal Abirchand Spg & Weaving Mills vs. CIT 31 ITR 427 (Nagpur- HC) (iii). CIT vs. Rex Talkies (18 Taxman 363 (Karnataka - HC) (iv). CIT vs. Oxford University Press 108 ITR 166 (Bom - HC) (v). ACIT

ACIT- 3(1)(1), MUMBAI vs. MM/S SANOFI INDIA LIMITED (FORMERLY KNOWN AS AVENTIS PHARMA LTD)., MUMBAI

In the result, appeal filed by the Revenue is dismissed

Bench: Shri Vikas Awasthy, Hon’Ble & Shri S. Rifaur Rahman, Hon'Ble

disallow the same during this year and allow the actual claim of the assessee on the basis of actual payment. Accordingly, we allow the ground raised by the assessee for statistical purpose. 49. With regard to, Ground No. 9 which is in respect of interest of ₹.81,83,620 allowed under section

M/S SANOFI INDIA LTD (FORMERLY KNOWN AS AVENTIS PHARMA LTD,MUMBAI vs. THE ACIT RG 8(1), MUMBAI

In the result, appeal filed by the Revenue is dismissed

Bench: Shri Vikas Awasthy, Hon’Ble & Shri S. Rifaur Rahman, Hon'Ble

disallow the same during this year and allow the actual claim of the assessee on the basis of actual payment. Accordingly, we allow the ground raised by the assessee for statistical purpose. 49. With regard to, Ground No. 9 which is in respect of interest of ₹.81,83,620 allowed under section

HDFC BANK LIMITED (AS SUCCESSOR TO HOUSING DEVELOPMENT FINANCE CORPORATION LTD),MUMBAI vs. DCIT 1(1), MUMBAI

section, Assessing Officer has no power to bifurcate on \npro-rata basis and deduct a part of it from the gross dividend income. \nThere is no scope for any estimation of expenditure and hence no scope \n54 \nHDFC Bank Ltd. \nITA No.4315/MUM/2007 and Ors. \nAYs 2002-03 to 2020-21 \nfor allocation of notional expenditure. The deductions contemplated are \nthe

TATA MOTORS LTD,MUMBAI vs. ACIT 2(3), MUMBAI

In the result, appeal of the assessee is partly allowed

Bench: Shri Vikas Awasthy& Shri S.Rifaur Rahmanआअसं.631/मुं/2013 (िन.व. 2008-09) Tata Motors Limited Bombay House, 24,Homi Mody Street, Hutama Chowk, Mumbai – 400001. Pan: Aaact-2727-Q ...... अपीलाथ"/Appellant बनाम Vs. The Addl. Commissioner Of Income Tax Circle -2(3), Mumbai. Aaykar Bhavan, M.K.Road, Mumbai – 400 020 ....."ितवादी/Respondent अपीलाथ" "ारा/ Appellant By : Shri J.D.Mistry, Sr.Advocate With Shri Nikhil Tiwari,Advocate "ितवादी "ारा/Respondent By : Ms. Vatsala Jha, Cit-Dr & Shri Manoj Kumar Singh, Sr.Ar सुनवाई की ितिथ/ Date Of Hearing : 10/11/2023 घोषणा की ितिथ/ Date Of Pronouncement : 05/02/2024 आदेश/Order Per Vikas Awasthy, Jm:

2(28C) includes Additional Commissioner, therefore, in our considered view there is no infirmity or irregularity in appointing officer in the grade of Additional Commissioner to a position designated for Joint Commissioner. Thus, in view of our above findings we find no merit in both 19 the arguments advanced by the ld.Counsel assailing validity of order passed u/s. 92CA

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

2 to 2.2: Disallowance of INR 19,35,01,258/- being interest on Capital Work-in- Progress under Section 36(1)(iii) of the Act. (c) Ground No. 3 to 3.7: Disallowance of INR 30,95,03,786/- in respect of roaming charges under Section 40(a)(ia) of the Act (d) Ground No. 4 to 4.5: Disallowance

THERMO FISHER SCIENTIFIC INDIA PVT LTD. ,MUMBAI vs. DCIT-15(3)(1), MUMBAI

In the result, the appeal of the assessee is allowed for In the result, the appeal of the assessee is allowed for In the result, the appeal of the assessee is allowed for statistical purposes

Bench: Shri Om Prakash Kant () & Ms. Kavitha Rajagopal () Assessment Year: 2009-10 Thermo Fisher Scientific India Dy. Cit-15(3)(1), Pvt. Ltd., Room No. 360, Aayakar Vs. 403-404, ‘B’ Wing, Delphi, Bhavan, New Marine Lines, Hiranandani Business Park, Mumbai-400020. Mumbai-400076. Pan No. Aabct 3207 A Appellant Respondent

section 43(6) of the Act, which reads as under: 2 to section 43(6) of the Act, which reads as under: 2 to section 43(6) of the Act, which reads as under: “Explanation 2.— —Where in any previous year, any block of assets is Where in any previous year, any block of assets is transferred

ACIT 6(3), MUMBAI vs. GRASIM INDUSTRIES LTD, MUMBAI

disallowance and held\nthat the provision of section 40(a)(ia) are not applicable in\nthe case.\"\n8. 1. During the course of hearing the Learned Senior Counsel, on\ninstructions, stated that the Assessee does not wish to pursue this\nground since relief has been granted to the assessee in relation to\nthis ground in appellate proceedings pertaining

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

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

2)", "Section 142(1)", "Section 143(3)", "Section 144B", "Section 80G", "Section 36(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

HDFC BANK LIMITED (AS SUCCESSOR TO HOUSING DEVELOPMENT FINANCE CORPORATION LTD.),MUMBAI vs. ADDL/JT/DY/ACIT/ITO, NFAC , DELHI

Section 57(iii) and find that ld. \nUnder the said section, Assessing Officer has no power to bifurcate on \npro-rata basis and deduct a part of it from the gross dividend income. \nThere is no scope for any estimation of expenditure and hence no scope\n52 \nHDFC Bank Ltd. \nITA No.4315/MUM/2007 and Ors. \nAYs