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

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

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) read with section 144B of the Act for A.Ys. 2018–19, 2022–23 and 2023–24. In the course of assessment proceedings, the Assessing Officer examined the allowability of deduction claimed under section 80G in respect of CSR related payments, employees’ contribution to provident fund under section 36(1)(va), disallowance under section 40(a)(ia), disallowance under section

EXIM TRAC,MUMBAI vs. MUM-C-(431)(91), MUMBAI

In the result the appeal filed by the assessee stands

Bench: Shri Om Prakash Kant () & Shri Sandeep Karhail () Assessment Year: 2019-20

270A(1)(c) of the Act. The issue in dispute in he issue in dispute in said decision was as under: as under: 8. Assessment Order under Section 143(3) of the Act was passed 8. Assessment Order under Section 143(3) of the Act was passed 8. Assessment Order under Section 143(3) of the Act was passed

HI-TECH ENGINEERS,MUMBAI vs. CENTRAL CIRCLE 5(1), BANDRA EAST, MUMBAI,

Bench: SHRI RAHUL CHAUDHARY, JUDICIAL MEMBER SHRI OMKARESHWAR CHIDARA (Accountant Member)

Section 270A of the Act for misreporting of income. 4. The above addition was challenged by the Assessee in appeal before the Commissioner of Income Tax (Appeals) [hereinafter referred to as the ‘First Appellate Authority’ or ‘FAA’]. Vide order, dated 21/07/2022, the First Appellate Authority partly allowed the appeal preferred by the Assessee and restricted the addition on account

HI-TECH ENGINEERS,MUMBAI vs. CENTRAL CIRCLE 5(1), BANDRA MUMBAI

Bench: SHRI RAHUL CHAUDHARY, JUDICIAL MEMBER SHRI OMKARESHWAR CHIDARA (Accountant Member)

Section 270A of the Act for misreporting of income. 4. The above addition was challenged by the Assessee in appeal before the Commissioner of Income Tax (Appeals) [hereinafter referred to as the ‘First Appellate Authority’ or ‘FAA’]. Vide order, dated 21/07/2022, the First Appellate Authority partly allowed the appeal preferred by the Assessee and restricted the addition on account

AAWAGAMAN MERCANTILE LLP ,MUMBAI vs. INCOME TAX OFFICER, WARD, 1(1), KOLKATA

In the result, the appeal by the assessee is allowed

Bench: Shri Amarjit Singhshri Sandeep Singh Karhailaawagaman Mercantile Llp, 204, Anand Estate, Arthur Road 189, Mumbai, Jacob Circle S.O. Mumbai - 400011 ……………. Appellant Maharashtra Pan: Abbfa0328F V/S Ito, Ward – 1(1), Aayakar Bhawan, Kolkata ……………. Respondent P-7, Chowringhee Square, Kolkata. Assessee By : Ms. Dinkle Hariya Revenue By : Shri Manoj Kumar Sinha, Sr.Dr

3,11,06,693. 5. In the meanwhile, penalty proceedings under section 270A were initiated and notice under section 274 read with section 270A of the Act was issued on 12/02/2021 for under-reported income which is in consequence of misreporting. In response to the aforesaid notice, the assessee filed its reply on 08/03/2021 submitting that the assessee while preparing

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

3) read with section 144B of the Act for A.Ys. 2018–19, 2022–23 and 2023–24. In the course of assessment proceedings, the Assessing Officer examined the allowability of deduction claimed under section 80G in respect of CSR related payments, employees' contribution to provident fund under section 36(1)(va), disallowance under section 40(a)(ia), disallowance under section

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

disallowances where facts supported the assessee.", "result": "Partly Allowed", "sections": [ "250", "143(1)", "143(2)", "142(1)", "143(3)", "144B", "80G", "36(1)(va)", "40(a)(ia)", "43B", "234B", "234C", "270A

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

disallowance of ₹ 3 20,92,006/–. Accordingly, we allow ground number 5 of the appeal. 059. Ground number 6 is against initiation of penalty proceedings under section 270A

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

disallowance of ₹ 3 20,92,006/–. Accordingly, we allow ground number 5 of the appeal. 059. Ground number 6 is against initiation of penalty proceedings under section 270A

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)

270A of the Act alleging under reporting of income by the Appellant.” Assessment Year 2022-2023 Ground No.1 to 6: 3. The relevant facts in brief are that the Assessee, a trust organized in the United States of America, is registered with the Securities and Exchange Board of India (SEBI) as a Foreign Portfolio Investor. The Assessee makes portfolio investments

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)

270A of the Act alleging under reporting of income by the Appellant.” Assessment Year 2022-2023 Ground No.1 to 6: 3. The relevant facts in brief are that the Assessee, a trust organized in the United States of America, is registered with the Securities and Exchange Board of India (SEBI) as a Foreign Portfolio Investor. The Assessee makes portfolio investments

BAJAJ AUTO LIMITED,MUMBAI vs. THE PRINCIPAL COMMISSIONER OF INCOME-TAX - 3, MUMBAI, MUMBAI

270A.\"\n7.2 Pursuant to the amendment made in section 155(18), the\nCentral Board of Direct Taxes, vide Notification No. 111 of 2022\ndated 28.09.2022, inserted Rule 132 in the Income-tax Rules, 1962,\nprescribing Form No. 69 for withdrawal of the claim of deduction in\nrespect of surcharge or cess. The said Rule came into effect from\n01.10.2022.\n7.3

MESSE FRANKFURT TRADE FAIRS INDIA PRIVATE LIMITED,MUMBAI vs. DEPUTY COMMISSIONER OF INCOME TAX 2(2)(1), INCOME TAX DEPARTMENT, MUMBAI, MUMBAI

Bench: Shri Saktijit Dey & Shri Makarand Vasant Mahadeokar1. Ita No. 6498/Mum/2025 (Assessment Year: 2018-19) & 2. Ita No. 6680/Mum/2025 (Assessment Year: 2018-19) Messe Frankfurt Trade Dcit – 2(2)(1), Fairs India Private Income Tax Limited, Vs. Department, 501, 5Th Floor, Gala Mumbai-400 020 Impecca, Mumbai, Chakala Midc S.O, Mumbai-400 093. Pan/Gir No. Aabcm0696G (Applicant) (Respondent) Assessee By Shri Ninad Patade, Ld. Ar Revenue By Shri Annavaram Kosuri, Ld. Dr Date Of Hearing 18.02.2026 Date Of Pronouncement 19.02.2026

disallowance has arisen out of a legal inference drawn by the Assessing Officer. In such circumstances, the case would fall within the protective ambit of section 270A(6)(a). 24. In our considered view, the present case does not fall within any of the categories specified in section 270A(9). Consequently, invocation of penalty at 200% under section 270A

MESSE FRANKFURT TRADE FAIRS INDIA PRIVATE LIMITED,MUMBAI vs. DEPUTY COMMISSIONER OF INCOME TAX 2(2)(1), MUMBAI

Bench: Shri Saktijit Dey & Shri Makarand Vasant Mahadeokar1. Ita No. 6498/Mum/2025 (Assessment Year: 2018-19) & 2. Ita No. 6680/Mum/2025 (Assessment Year: 2018-19) Messe Frankfurt Trade Dcit – 2(2)(1), Fairs India Private Income Tax Limited, Vs. Department, 501, 5Th Floor, Gala Mumbai-400 020 Impecca, Mumbai, Chakala Midc S.O, Mumbai-400 093. Pan/Gir No. Aabcm0696G (Applicant) (Respondent) Assessee By Shri Ninad Patade, Ld. Ar Revenue By Shri Annavaram Kosuri, Ld. Dr Date Of Hearing 18.02.2026 Date Of Pronouncement 19.02.2026

disallowance has arisen out of a legal inference drawn by the Assessing Officer. In such circumstances, the case would fall within the protective ambit of section 270A(6)(a). 24. In our considered view, the present case does not fall within any of the categories specified in section 270A(9). Consequently, invocation of penalty at 200% under section 270A

DCIT-3(1)(1), MUMBAI, MUMBAI vs. RELCON INFRAPROJECTS LTD., MUMBAI

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

3) read with Section 153A of the Act the Assessing Officer assessed the income of the Assessee at INR30,65,14,720/- after making the following additions and/or disallowances: Sr. No. Particulars Amount (in INR) 1. Alleged bogus purchases 12,52,40,878 2. Disallowance of unexplained expenditure under 70,80,590 Section 69C of the Act Total additions/disallowance

DCIT-3(1)(1), MUMBAI, MUMBAI vs. RELCON INFRAPROJECTS LTD., MUMBAI

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

3) read with Section 153A of the Act the Assessing Officer assessed the income of the Assessee at INR30,65,14,720/- after making the following additions and/or disallowances: Sr. No. Particulars Amount (in INR) 1. Alleged bogus purchases 12,52,40,878 2. Disallowance of unexplained expenditure under 70,80,590 Section 69C of the Act Total additions/disallowance

DCIT 3(1)(1),MUMBAI, MUMBAI vs. RELCON INFRAPROJECTS LTD, MUMBAI

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

3) read with Section 153A of the Act the Assessing Officer assessed the income of the Assessee at INR30,65,14,720/- after making the following additions and/or disallowances: Sr. No. Particulars Amount (in INR) 1. Alleged bogus purchases 12,52,40,878 2. Disallowance of unexplained expenditure under 70,80,590 Section 69C of the Act Total additions/disallowance