ITO-26(2)(1) , MUMBAI vs. SAI PRERANA CO-OP CREDIT SOCIETY LTD, MUMBAI

In the result, appeals of the assessee and the Revenue are In the result, appeals of the assessee and the Revenue are In the result, appeals of the assessee and the Revenue are decided as under:

Bench: Shri Kuldip Singh () & Shri Om Prakash Kant () Ita Nos. 217, 220 & 221, 218 & 219, 215, 214/Mum/2023 Assessment Years: 2013-14, 2016-17, 2017-18, 2018-19, 2020-21 Sai Prerana Co-Op Credit Ito-17(3)(2), Society Ltd., Room No. 126, 1St Floor, Vs. 317, Puran Aasha Bldg, Gr. Fl. Kautilya Bhavan, C-41 To C- Narashi Natha Street, Katha 43, G Block Bandra Kurla Bazar Masjid Bunder (W), Complex, Bandra (East), Mumbai-400 009. Mumbai-400051. Pan No. Aadts 5638 M Appellant Respondent

2)(a)(i) income from other sources and deduction u/s 80(P)(2)(a)(i) income from other sources and deduction u/s 80(P)(2)(a)(i) would not be available meaning thereby t would not be available meaning thereby that deduction u/s hat deduction u/s 80(P)(2)(a)(i) is available only in respect of income which

ITO-26(2)(1), MUMBAI vs. SAI PRERANA CO-OP CREDIT SOCIETY LTD, MUMBAI

In the result, appeals of the assessee and the Revenue are In the result, appeals of the assessee and the Revenue are In the result, appeals of the assessee and the Revenue are decided as under:

Bench: Shri Kuldip Singh () & Shri Om Prakash Kant () Ita Nos. 217, 220 & 221, 218 & 219, 215, 214/Mum/2023 Assessment Years: 2013-14, 2016-17, 2017-18, 2018-19, 2020-21 Sai Prerana Co-Op Credit Ito-17(3)(2), Society Ltd., Room No. 126, 1St Floor, Vs. 317, Puran Aasha Bldg, Gr. Fl. Kautilya Bhavan, C-41 To C- Narashi Natha Street, Katha 43, G Block Bandra Kurla Bazar Masjid Bunder (W), Complex, Bandra (East), Mumbai-400 009. Mumbai-400051. Pan No. Aadts 5638 M Appellant Respondent

2)(a)(i) income from other sources and deduction u/s 80(P)(2)(a)(i) income from other sources and deduction u/s 80(P)(2)(a)(i) would not be available meaning thereby t would not be available meaning thereby that deduction u/s hat deduction u/s 80(P)(2)(a)(i) is available only in respect of income which

SAI PRERNA CO-OP. CREDIT SOCIETY LTD,MUMBAI vs. ITO WD 17(3) (2) , MUMBAI

In the result, appeals of the assessee and the Revenue are In the result, appeals of the assessee and the Revenue are In the result, appeals of the assessee and the Revenue are decided as under:

Bench: Shri Kuldip Singh () & Shri Om Prakash Kant () Ita Nos. 217, 220 & 221, 218 & 219, 215, 214/Mum/2023 Assessment Years: 2013-14, 2016-17, 2017-18, 2018-19, 2020-21 Sai Prerana Co-Op Credit Ito-17(3)(2), Society Ltd., Room No. 126, 1St Floor, Vs. 317, Puran Aasha Bldg, Gr. Fl. Kautilya Bhavan, C-41 To C- Narashi Natha Street, Katha 43, G Block Bandra Kurla Bazar Masjid Bunder (W), Complex, Bandra (East), Mumbai-400 009. Mumbai-400051. Pan No. Aadts 5638 M Appellant Respondent

2)(a)(i) income from other sources and deduction u/s 80(P)(2)(a)(i) income from other sources and deduction u/s 80(P)(2)(a)(i) would not be available meaning thereby t would not be available meaning thereby that deduction u/s hat deduction u/s 80(P)(2)(a)(i) is available only in respect of income which

INCOME TAX OFFICER-26(2)(1), MUMBAI vs. SAI PRERANA CO-OP CREDIT SOCIETY LTD., MUMBAI

In the result, appeals of the assessee and the Revenue are In the result, appeals of the assessee and the Revenue are In the result, appeals of the assessee and the Revenue are decided as under:

Bench: Shri Kuldip Singh () & Shri Om Prakash Kant () Ita Nos. 217, 220 & 221, 218 & 219, 215, 214/Mum/2023 Assessment Years: 2013-14, 2016-17, 2017-18, 2018-19, 2020-21 Sai Prerana Co-Op Credit Ito-17(3)(2), Society Ltd., Room No. 126, 1St Floor, Vs. 317, Puran Aasha Bldg, Gr. Fl. Kautilya Bhavan, C-41 To C- Narashi Natha Street, Katha 43, G Block Bandra Kurla Bazar Masjid Bunder (W), Complex, Bandra (East), Mumbai-400 009. Mumbai-400051. Pan No. Aadts 5638 M Appellant Respondent

2)(a)(i) income from other sources and deduction u/s 80(P)(2)(a)(i) income from other sources and deduction u/s 80(P)(2)(a)(i) would not be available meaning thereby t would not be available meaning thereby that deduction u/s hat deduction u/s 80(P)(2)(a)(i) is available only in respect of income which

INCOME TAX OFFICER-26(2)(1), MUMBAI vs. SAI PRERANA CO-OP CREDIT SOCIETY LTD., MUMBAI

In the result, appeals of the assessee and the Revenue are In the result, appeals of the assessee and the Revenue are In the result, appeals of the assessee and the Revenue are decided as under:

Bench: Shri Kuldip Singh () & Shri Om Prakash Kant () Ita Nos. 217, 220 & 221, 218 & 219, 215, 214/Mum/2023 Assessment Years: 2013-14, 2016-17, 2017-18, 2018-19, 2020-21 Sai Prerana Co-Op Credit Ito-17(3)(2), Society Ltd., Room No. 126, 1St Floor, Vs. 317, Puran Aasha Bldg, Gr. Fl. Kautilya Bhavan, C-41 To C- Narashi Natha Street, Katha 43, G Block Bandra Kurla Bazar Masjid Bunder (W), Complex, Bandra (East), Mumbai-400 009. Mumbai-400051. Pan No. Aadts 5638 M Appellant Respondent

2)(a)(i) income from other sources and deduction u/s 80(P)(2)(a)(i) income from other sources and deduction u/s 80(P)(2)(a)(i) would not be available meaning thereby t would not be available meaning thereby that deduction u/s hat deduction u/s 80(P)(2)(a)(i) is available only in respect of income which

CREDIT GUARANTEE FUND TRUST FOR MICRO AND SMALL ENTERPRISES,MUMBAI vs. DCIT (E) , MUMBAI

Bench: Shri Kuldip Singh & Shri S Rifaur Rahmanassessment Year: 2018-19

disallowing the sum of Rs. 9,92,75,616/- being 15% of the income derived by the trust under section 11(1)(a) without appreciating the facts that: a) the Hon'ble ITAT has already held in the appellant's own case for AY 2010-11, AY 2011-12 and AY 2014-15 that the proviso to section 2

STRIDES PHARMA SCIENCE LTD.,NAVI MUMBAI vs. THE DY CIT -5(1)(2), MUMBAI

In the result ITA number 1004/M/2021 filed by the assessee for assessment year 2016 – 17 is allowed

Bench: Shri Prashant Maharishi, Am & Shri Sandeep Singh Karhail, Jm Strides Pharma Science Ltd. Dcit 15(1)(2) 201, Devavrata, Sector-17, Aayakar Bhavan, M K Road, Vs. Vashi, Navi Mumbai, 400703 Mumbai 400020 (Appellant) (Respondent) Pan No. Aadcs8104P

2,52,50,670 based on the specific directions given by the Hon'ble ITAT in the order passed for AY 2014-15. 4.4 Without prejudice to the above argument of the Appellant, disallowance, (if any) under Section 14A should be computed based on the methodology provided under Rule 8D of the Rules as amended by Notification

DCIT CC-8(2),MUMBAI, MUMBAI vs. RAKESH S KATHOTIA, MUMBAI

In the result appeal filed by the revenue stands dismissed

Bench: Shri Sandeep Gosain & Shri Prabhash Shankar

274 ITR 122) dated 25.07.2014] has decided the issue in the favour of revenue, stand taken by the assessee in submission is not acceptable at all, therefore, hereby rejected. (The aforesaid, in short, is the summarized version of what has been stated/observed by Ld. AO under para 7.1 and 7.2 of the impugned assessment order dated 27.03.2022) However, while rejecting

DCIT CENTRAL-CIRCLE-2(4), MUMBAI vs. KEYSTONE REALTORS PRIVATE LIMITED, MUMBAI

In the result, appeal of the Revenue is dismissed and the Cross Objection of the assessee is allowed

Bench: Shri Aby T Varkey () & Shri Amarjit Singh ()

Disallowance of claim under section 80G Rs. 50,000/- 4. On account of sale of car parking Rs. 2,82,87,953/- 5. On account of sale of scrap Rs. 27,68,349/- The Assessing Officer levied penalty to the extent of Rs.1,62,50,600 for concealment of income and furnishing of inaccurate particulars of income vide order under

JT.COMMISSIONER OF INCOME TAX (OSD) - CENTRAL CIRCLE 2(4), MUMBAI vs. M/S KEYSTONE REALTORS PRIVATE LIMITED, MUMBAI

In the result, appeal of the Revenue is dismissed and the Cross Objection of the assessee is allowed

Bench: Shri Aby T Varkey () & Shri Amarjit Singh ()

Disallowance of claim under section 80G Rs. 50,000/- 4. On account of sale of car parking Rs. 2,82,87,953/- 5. On account of sale of scrap Rs. 27,68,349/- The Assessing Officer levied penalty to the extent of Rs.1,62,50,600 for concealment of income and furnishing of inaccurate particulars of income vide order under

DCIT CEN CIR 10, MUMBAI vs. KEYSTONE REALTORS P.LTD, MUMBAI

In the result, appeal of the Revenue is dismissed and the Cross Objection of the assessee is allowed

Bench: Shri Aby T Varkey () & Shri Amarjit Singh ()

Disallowance of claim under section 80G Rs. 50,000/- 4. On account of sale of car parking Rs. 2,82,87,953/- 5. On account of sale of scrap Rs. 27,68,349/- The Assessing Officer levied penalty to the extent of Rs.1,62,50,600 for concealment of income and furnishing of inaccurate particulars of income vide order under

KEYSTONE REALTORS PRIVATE LIMITED,MUMBAI vs. DEPUTY COMMISSIONER OF INCOME TAX - CENTRAL CIRCLE 2(4), MUMBAI

In the result, appeal of the Revenue is dismissed and the Cross Objection of the assessee is allowed

Bench: Shri Aby T Varkey () & Shri Amarjit Singh ()

Disallowance of claim under section 80G Rs. 50,000/- 4. On account of sale of car parking Rs. 2,82,87,953/- 5. On account of sale of scrap Rs. 27,68,349/- The Assessing Officer levied penalty to the extent of Rs.1,62,50,600 for concealment of income and furnishing of inaccurate particulars of income vide order under

DSP INVESTMENT MANAGERS PVT LTD,MUMBAI vs. DEPUTY COMMISSIONER OF INCOME TAX 3(1)(1), MUMBAI

2)(iii). The submission of ld. counsel for the assessee is that this\nissue is now covered by the decision of the Hon'ble Delhi High Court in the case of CIT v. Hofcin\nIndia (P.) Ltd. (supra), wherein it has been held that if no dividend income was earned, section\n14A could not be invoked.\nThe Hon'ble Delhi

CREDIT GUARANTEE FUND TRUST FOR MICRO AND SMALL ENTERPRISES ,MUMBAI vs. DEPUTY COMMISSIONER OF INCOME TAX EXEMPTION -1(1), MUMBAI

In the result, the appeal of the assessee is allowed

Bench: Shri Vikram Singh Yadav & Shri Rahul Chaudharyassessment Year : 2018-19 Credit Guarantee Fund Trust Deputy Commissioner Of For Micro & Small Enterprises, Income Tax, Exemption-1(1), 1St Floor, Vs. Mtnl Tel. Exch. Building, Sidbi Swavalamban Bhavan, Cumballa Hills, Pedder Road, Avenue 3, Lane 2, G-Block, Mumbai-400026. Bandra Kurla Complex, Bandra (East), Mumbai-400051. Pan : Aaatc2613D (Appellant) (Respondent) For Assessee : Shri Shailesh Shah & Shri Jay Dharod For Revenue : Shri R.A. Dhyani, Cit-Dr Date Of Hearing : 04-09-2025 Date Of Pronouncement : 15-09-2025 O R D E R Per Vikram Singh Yadav, A.M : This Is An Appeal Filed By The Assessee Against The Order Of The Learned Commissioner Of Income Tax (Appeals)-National Faceless Appeal Centre (Nfac), Delhi [„Ld.Cit(A)‟], Pertaining To Assessment Year (Ay) 2018-19, Wherein The Assessee Has Taken The Following Grounds Of Appeal: “(1) On The Facts & Circumstances Of The Case & In Law, The Learned Commissioner Of Income Tax (Appeals) [Ld. Cit(A)], Nfac Has Erred In Confirming The Order Of Levying Penalty U/S 270A Of The Act Of Rs. 293,63,60,258/- On 2 Disallowances Made In The Assessment Order Passed U/S 143(3) R.W.S 144B Of The Act Without Appreciating The Fact That The Hon'Ble Itat, Mumbai Has Fully Deleted The Said Disallowances & Reasons Assigned By Him For Doing So Are Wrong & Contrary To The Facts & Circumstances Of The Case, Provisions Of The Act & Income Tax Rules, 1962 ("The Rules") Made Thereunder. The Appellant Prays That The Penalty U/S 270A Of The Act Of Rs. 293,63,60,258/- Be Deleted. The Appellant Craves Leave To Add, Amend, Alter, Modify And/Or Delete All Or Any Of The Above Grounds Of Appeal, On Or Before The Date Of Hearing.”

disallowance of the deduction of provision for guarantee claims of Rs.3,47,04,32,777/- and assessed income was determined at Rs 4,13,22,70,216/- vide order dated 14-04-2021 passed under section 143(3) read with section 144(3A) read with section 143(3B) of the Act. The penalty proceedings u/s 270A read with 274 were

BIANCA CO OPERATIVE HOUSING SOCIETY LIMITED,MUMBAI vs. INCOME TAX OFFICER - 24(1)(1), MUMBAI

disallowance of INR\n27,27,524/- made by the Assessing Officer with the direction to\nallow deduction for the same under Section 80(P)(2)(d) of the\nAct.\n5. In view of the above, Ground No. 2 raised by the Appellant is\nallowed; Ground No. 4 raised by the Appellant is disposed off as\nbeing consequential

STRIDES ARCOLAB LTD,NAVI MUMBAI vs. DCIT CIR 15(3)(2), MUMBAI

The appeal of the assessee is allowed

Bench: Amit Shukla () & Ms. Padmavathy S. ()

2. Disallowance of premium payable on redemption of Foreign Currency Convertible Bonds ('FCCB') of Rs. 53,75,81,482/- 2.1. The learned AO erred in disallowing and the Hon'ble DRP erred confirming the disallowance the expenditure of Rs. 53,75,81,482/- being premium payable on redemption of FCCB on the ground that the said expenditure is a mere

DCIT, CC-7(1), MUMBAI vs. M/S MANEESH PHARMACEUTICALS LTD., MUMBAI

2,85,23,354/- under Section 271(1)(c) of the Act. 6. Being aggrieved, the Assessee preferred appeal before CIT(A) and contended that the penalty order, dated 31.03.2022, was bad in law since the Assessing Officer had failed to specify in the notice issued under Section 274 of the Act proposing to levy penalty under Section

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

2 to 8). Copy of the order is placed on record. 68. On the other hand, Ld. DR has fairly accepted the submissions of the Ld.AR. 69. Considered the submissions and material placed on record, we observe from the record that identical issue is decided in favour of the assessee for the A.Y. 2002-03. While deciding the issue