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

section 14A r.w.r.8D would be reduced to Rs.19,345/-. In that case it is necessary to examine whether the disallowance can be reduced below the suo-motu disallowance at the stage of appeal before the Tribunal. In this regard it is relevant to consider the following observations of the Co-ordinate Bench in the case of Sajjan India Ltd. (supra

BAJAJ ELECTRICALS LTD,MUMBAI vs. ADDL CIT 2(1), MUMBAI

Accordingly we remit the impugned\nissue back to the AO with similar directions. The grounds raised by the assessee in\nthis regard are allowed for statistical purposes

section 14A r.w.r.8D\nwould be reduced to Rs.19,345/-. In that case it is necessary to examine whether the\ndisallowance can be reduced below the suo-motu disallowance at the stage of appeal\nbefore the Tribunal. In this regard it is relevant to consider the following\nobservations of the Co-ordinate Bench in the case of Sajjan India Ltd. (supra

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

In the result, appeal of the assessee (ITA number 1597/M/2018) is allowed for statistical purposes

Bench: Shri Prashant Maharishi, Am & Shri Narfendrakumar Choudhary , Jm & & The Great Eastern Shipping Co. The Dy. Commissioner Of Ltd. Income-Tax, Kalyaniwalla & Mistry Llp Range-5(3), Esplanade House, 2 N D Floor, Vs. Room No.525B, 5Th Floor, M.K. Marg, 29, Hazarimal Somani Marg, Fort, Mumbai-400 001 Mumbai-400 020 (Appellant) (Respondent) Pan No. Aaact1565C The Dy. Commissioner Of Income- The Great Eastern Shipping Co. Tax, Ltd. Range-5(3), Kalyaniwalla & Mistry Llp Vs. Esplanade House, 2 N D Floor, Room No.525B, 5Th Floor, M.K. Marg, 29, Hazarimal Somani Marg, Mumbai-400 020 Fort, Mumbai-400 001 (Appellant) (Respondent)

249,557,343., Was partly allowed. Therefore both the parties are aggrieved and are in appeal. 39. The assessee is aggrieved with the order of the learned CIT – A wherein the disallowance under section

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

In the result, appeal of the assessee (ITA number 1597/M/2018) is allowed for statistical purposes

Bench: Shri Prashant Maharishi, Am & Shri Narfendrakumar Choudhary , Jm & & The Great Eastern Shipping Co. The Dy. Commissioner Of Ltd. Income-Tax, Kalyaniwalla & Mistry Llp Range-5(3), Esplanade House, 2 N D Floor, Vs. Room No.525B, 5Th Floor, M.K. Marg, 29, Hazarimal Somani Marg, Fort, Mumbai-400 001 Mumbai-400 020 (Appellant) (Respondent) Pan No. Aaact1565C The Dy. Commissioner Of Income- The Great Eastern Shipping Co. Tax, Ltd. Range-5(3), Kalyaniwalla & Mistry Llp Vs. Esplanade House, 2 N D Floor, Room No.525B, 5Th Floor, M.K. Marg, 29, Hazarimal Somani Marg, Mumbai-400 020 Fort, Mumbai-400 001 (Appellant) (Respondent)

249,557,343., Was partly allowed. Therefore both the parties are aggrieved and are in appeal. 39. The assessee is aggrieved with the order of the learned CIT – A wherein the disallowance under section

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

In the result, appeal of the assessee (ITA number 1597/M/2018) is allowed for statistical purposes

Bench: Shri Prashant Maharishi, Am & Shri Narender Kumar Choudhary , Jm & & The Great Eastern Shipping Co. The Dy. Commissioner Of Ltd. Income-Tax, Kalyaniwalla & Mistry Llp Range-5(3), Esplanade House, 2 Nd Floor, Vs. Room No.525B, 5 Th Floor, M.K. Marg, 29, Hazarimal Somani Marg, Fort, Mumbai-400 001 Mumbai-400 020 (Appellant) (Respondent) Pan No. Aaact1565C The Dy. Commissioner Of Income- The Great Eastern Shipping Co. Tax, Ltd. Range-5(3), Kalyaniwalla & Mistry Llp Vs. Esplanade House, 2 Nd Floor, Room No.525B, 5Th Floor, M.K. Marg, 29, Hazarimal Somani Marg, Mumbai-400 020 Fort, Mumbai-400 001 (Appellant) (Respondent)

249,557,343., Was partly allowed. Therefore both the parties are aggrieved and are in appeal. 39. The assessee is aggrieved with the order of the learned CIT – A wherein the disallowance under section

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

In the result, appeal of the assessee (ITA number 1597/M/2018) is allowed for statistical purposes

Bench: Shri Prashant Maharishi, Am & Shri Narfendrakumar Choudhary , Jm & & The Great Eastern Shipping Co. The Dy. Commissioner Of Ltd. Income-Tax, Kalyaniwalla & Mistry Llp Range-5(3), Esplanade House, 2 N D Floor, Vs. Room No.525B, 5Th Floor, M.K. Marg, 29, Hazarimal Somani Marg, Fort, Mumbai-400 001 Mumbai-400 020 (Appellant) (Respondent) Pan No. Aaact1565C The Dy. Commissioner Of Income- The Great Eastern Shipping Co. Tax, Ltd. Range-5(3), Kalyaniwalla & Mistry Llp Vs. Esplanade House, 2 N D Floor, Room No.525B, 5Th Floor, M.K. Marg, 29, Hazarimal Somani Marg, Mumbai-400 020 Fort, Mumbai-400 001 (Appellant) (Respondent)

249,557,343., Was partly allowed. Therefore both the parties are aggrieved and are in appeal. 39. The assessee is aggrieved with the order of the learned CIT – A wherein the disallowance under section

DCIT 2(1)(1), MUMBAI vs. BAJAJ ELECTRICALS LTD, MUMBAI

Accordingly we remit the impugned\nissue back to the AO with similar directions. The grounds raised by the assessee in\nthis regard are allowed for statistical purposes

section 14A r.w.r.8D\nwould be reduced to Rs.19,345/-. In that case it is necessary to examine whether the\ndisallowance can be reduced below the suo-motu disallowance at the stage of appeal\nbefore the Tribunal. In this regard it is relevant to consider the following\nobservations of the Co-ordinate Bench in the case of Sajjan India Ltd. (supra

STATE BANK OF INDIA,MUMBAI vs. ADDL CIT RG 2(2), MUMBAI

In the result, the appeal of the assessee is partly allowed and the appeal of the Revenue is dismissed, as indicated above

Bench: Sri Mahavir Singh, Vp & Sri G Manjunatha, Am आयकर अपील सुं./ Ita No. 3644/Mum/2016 (ननर्ाारण वर्ा / Assessment Year 2008-09) State Bank Of India The Dy. Commissioner Of 3Rd Floor, Corporate Centre Income Tax, Circle -2(2)(1) बनाम/ Madam Cama Road Mumbai Vs. Nariman Point Mumbai-400021 (अपीलार्थी / Appellant) (प्रत्यर्थी/ Respondent) स्र्थायी लेखा सुं./Pan No. Aaacs8577K

section 14A of the Act is called for based on the judicial precedents on the subject. Even the suo-moto disallowance made by the assessee in its revised return of income ought to be deleted. With respect to the CIT(A)’s direction that the disallowance u/s 14A of the Act should not go below the amount suo-moto disallowed

FUTURE IDEAS CO LTD.,MUMBAI vs. PR.CIT -9, MUMBAI

In the result, the assessee’s appeal for A

Bench: Shri Jason P. Boaz & Shri Sandeep Gosainfuture Ideas Co. Ltd. Principal Cit – 9 Knowledge House, Shyam Nagar 2Nd Floor, Room No. 214 Vs. Off Jogeshwari Vikroli Link Rd. Aayakar Bhavan, M.K. Road Jogeshwari (E), Mumbai 400060 Mumbai 400020 Pan – Aaacf9519L Appellant Respondent

disallowance was called for, as if it was to 6 Futre Ideas Co. Ltd. be applied automatically without having regard to the particular facts of the case. 4.2.3 It has been contended that the impugned order under section 263 of the Act is bad in law, as the learned Principal CIT has travelled beyond the issue on the basis

DSP FINANCE PRIVATE LIMITED ,MUMBAI vs. THE DEPUTY COMMISSIONER OF INCOME TAX -39(1)(1), MUMBAI

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

Bench: Shri Om Prakash Kant () & Ms. Kavitha Rajagopal () Assessment Year: 2020-21 Dsp Finance Pvt. Ltd., Dy. Director Of Income-Tax, Cpc, 11Th Floor, Mafatlal Centre Nariman Bengaluru-560500. Vs. Point, Nariman Point, Dy. Cit-3(1)(1), Mumbai-400021. Aayakar Bhavan, Mumbai-400020. Pan No. Aaacd 3069 K Appellant Respondent

249 of the Act and therefore the CIT(A) ought to have admitted the said appeal and decided the the CIT(A) ought to have admitted the said appeal and decided the the CIT(A) ought to have admitted the said appeal and decided the case on merits.. case on merits.. 2. Without prejudice to what is stated

FUTURE CORPORATE RESOURCES LTD.(FORMERLY KNOWN AS SIMPLETON INVESTRADE PVT. LTD.),MUMBAI vs. PR.CIT -9, MUMBAI

In the result, the assessee’s appeal for A

Bench: Shri Jason P. Boaz & Shri Sandeep Gosainfuture Corporate Resources Ltd. Principal Cit – 9 (Formerly Simpleton Investrade P. Ltd.) 2Nd Floor, Room No. 214 Knowledge House, Shyam Nagar Vs. Aayakar Bhavan, M.K. Road Off Jogeshwari Vikroli Link Rd. Mumbai 400020 Jogeshwari (E), Mumbai 400060 Pan – Aajcs3979E Appellant Respondent

disallowance was called for, as if it was to be applied automatically without having regard to the particular facts of the case. 6 Futre Corporate Resources Ltd. 4.2.3 It has been contended that the impugned order under section 263 of the Act is bad in law, as the learned Principal CIT has travelled beyond the issue on the basis

IL&FS MARITIME INFRASTRUCTURE COMPANY LIMITED,MUMBAI vs. THE DEPUTY COMMISSIONER OF INCOME TAX-14(1)(1), MUMBAI

In the result, the appeal of the assessee is allowed

disallowed. Further we find\nthat Hon'ble Gujarat High Court in the case of Milton Laminates Ltd.\nVs. CIT (2014) 37 taxmann.com 249 (Gujarat) held that while giving\neffect to order of commissioner of appeal assessing officer can compute\nincome lower than that returned. The Hon'ble Gujarat High Court in the\ncase of Gujarat Gas Co. Ltd. Vs. JCIT

VODAFONE WEST LIMITED,(FORMERLY KNOWN AS VODAFONE ESSAR GUJARAT LIMITED),AHMEDABAD vs. THE DY.CIT, CIRCLE-4(1)(2),, AHMEDABAD

In the result, the appeal by the Revenue is partly allowed for statistical\npurposes

disallowance made u/s.40(a)(ia)\nof the Act in respect of discount offered to pre-paid distributors.\"\n(9). \"The DRP, Ahmedabad has erred in law and on facts in deleting the\naddition of Rs.133,79,00,000/- made on account of receipt for pre-paid\nservices which crystallized during the year itself.\"\n10). \"The DRP, Ahmedabad has erred

THE DY CIT, CIRCLE-4(1)(2),, AHMEDABAD vs. VODAFONE WEST LIMITED,, AHMEDABAD

In the result, the appeal by the Revenue is partly allowed for statistical\npurposes

disallowance made u/s.40(a)(ia)\nof the Act in respect of discount offered to pre-paid distributors.\"\n(9). \"The DRP, Ahmedabad has erred in law and on facts in deleting the\naddition of Rs.133,79,00,000/- made on account of receipt for pre-paid\nservices which crystallized during the year itself.\"\n10). \"The DRP, Ahmedabad has erred

RELIANCE INDUSTRIES LIMITED,MUMBAI vs. ACIT , MUMBAI

In the result, the ITA No

disallowed Rs 8.66 crores for weighted deduction under section 35(2AB) in respect of research and development expenditure by observing as follows: ITA Nos.1645 & 2876/Mum/2019 ITA Nos.2344 & 3945/Mum/2019 Assessment Years: 2014-15 & 2015-16 Page 33 of 105 21.1 On perusal of the computation of income statement, it is seen that during the year under consideration the assesse company

DCIT (LTU)-2, MUMBAI vs. M/S RELIANCE INDUSTRIES LTD., MUMBAI

In the result, the ITA No

disallowed Rs 8.66 crores for weighted deduction under section 35(2AB) in respect of research and development expenditure by observing as follows: ITA Nos.1645 & 2876/Mum/2019 ITA Nos.2344 & 3945/Mum/2019 Assessment Years: 2014-15 & 2015-16 Page 33 of 105 21.1 On perusal of the computation of income statement, it is seen that during the year under consideration the assesse company

RELIANCE INDUSTRIES LTD,MUMBAI vs. DEPUTY COMMISSIONER OF INCOME TAX LARGE TAXPAYER UNIT-2, MUMBAI

In the result, the ITA No

disallowed Rs 8.66 crores for weighted deduction under section 35(2AB) in respect of research and development expenditure by observing as follows: ITA Nos.1645 & 2876/Mum/2019 ITA Nos.2344 & 3945/Mum/2019 Assessment Years: 2014-15 & 2015-16 Page 33 of 105 21.1 On perusal of the computation of income statement, it is seen that during the year under consideration the assesse company

KPMG ASSURANCE AND CONSULTING SERVICES LLP,MUMBAI vs. ASSISTANT COMMISSIONER OF INCOME TAX-CIRCLE-16(2), MUMBAI

Accordingly,\nGround No. 5 & 6 raised by the Revenue are dismissed

disallowance made under\nSection 40(a)(i) of the Act in respect of the aforesaid\npayments.\n32. Saudi Arabia\n32.1. The professional fee paid/payable to firm of individuals, being\ntax residents of Saudi Arabia, are listed at Sl. No. 8 of Table in\nparagraph 26 above.\n32.2. On perusal of Article 14 of the India–Saudi Arabia DTAA it\nbecomes