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

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

Bench: Shri Anikesh Banerjee & Shri Girish Agrawal

disallowance under section 144 is Rs 924.78 crore. I.18. We would now like to proceed with the calculation of investments yielding tax free income. It may be noted that the average investments yielding tax free income for the captioned AY amounts to Rs 3,095.11 crore. However, the said amount includes average investment amounting to Rs 1

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

disallowance under section 144 is Rs 924.78 crore. I.18. We would now like to proceed with the calculation of investments yielding tax free income. It may be noted that the average investments yielding tax free income for the captioned AY amounts to Rs 3,095.11 crore. However, the said amount includes average investment amounting to Rs 1

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

3,901.87 | 36.05% | 362.34 | 362.34 \nNot exempt \nSLR | 7,245.38 | 6,598.15 | 6,921.77 | 63.95% | 642.79 | 562.44 \nTotal | 11,278.23 | 10,369.03 | 10,823.63 | | 1,005.13 | 924.78 \nI. 17. On perusal of the aforesaid table it is observed that the interest \nexpenditure to be taken into consideration for computing disallowance \nunder section

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

disallowance under section 144 is Rs 924.78 crore. I.18. We would now like to proceed with the calculation of investments yielding tax free income. It may be noted that the average investments yielding tax free income for the captioned AY amounts to Rs 3,095.11 crore. However, the said amount includes average investment amounting to Rs 1

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

Bench: Shri Anikesh Banerjee & Shri Girish Agrawal

disallowance under section 144 is Rs 924.78 crore. I.18. We would now like to proceed with the calculation of investments yielding tax free income. It may be noted that the average investments yielding tax free income for the captioned AY amounts to Rs 3,095.11 crore. However, the said amount includes average investment amounting to Rs 1

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

disallowance \nunder section 144 is Rs 924.78 crore. \nI. 18. We would now like to proceed with the calculation of investments yielding \ntax free income. It may be noted that the average investments yielding tax \nfree income for the captioned AY amounts to Rs 3,095.11 crore. However, \nthe said amount includes average investment amounting to Rs 1

ABBOTT HEALTHCARE PRIVATE LIMITED ,MUMBAI vs. ASSISTANT COMMISSIONER OF INCOME TAX, CIRCLE 2(1)(1), MUMBAI

In the result, Ground No. 3 with its Sub-Grounds is allowed for statistical purposes

Bench: Shri Narender Kumar Choudhry & Shri Gagan Goyalabbott Healthcare Pvt. Ltd. 3, Corporate Park, Sion Trombay Road, Mumbai - 400 071 Pan: Aaack3935D ..... Appellant Vs. Acit 2(1) (1) R. No. 561, 5Th Floor, Aayakar Bhavan, Maharishi Karve Marg, Mumbai- 400 020 ..... Respondent & Acit 2(1) (1) R. No. 561, 5Th Floor, Aayakar Bhavan, Maharishi Karve Marg, Mumbai- 400 020 ...... Appellant Vs.

disallowance of Rs. 1, 05,193/- on account of delay in making the payment towards the employees' contribution for the provident fund, under section 36(1)(va) r.w.s. 2(24)(x) of the Act. 3

M/S G.L.CONSTRUCTION PVT LTD,MUMBAI vs. ACIT/NATIONAL FACE LESS APPEAL CENTRE, MUMBAI

In the result, the appeal of the assessee is partly allowed for In the result, the appeal of the assessee is partly allowed for In the result, the appeal of the assessee is partly allowed for stati...

Bench: Shri Om Prakash Kant () & Shri Pavan Kumar Gadale () Assessment Year: 2019-20 M/S G.L. Construction Pvt. Ltd, Acit/National Faceless 304, Gokul Arcade B, Subhash Appeal Centre, Road, Near Garware, Vs. 5Th Floor, Aayakar Bhavan, Vile Parle East, Churchgate, Mumbai-400057. Mumbai-400020. Pan No. Aaacg 3438 P Appellant Respondent Assessee By : Mr. N.R. Agrawal, Ar Revenue By : Smt. Sonia Kumar, Dr : Date Of Hearing 16/02/2023 : Date Of Pronouncement 23/02/2023

disallowance of Rs.12,71,250/- u/s 36(1)(va) of the Act u/s 36(1)(va) of the Act invoking section 143(1)(a)(iv) of the Act. The Ld. CIT(A) also on merit invoking section 143(1)(a)(iv) of the Act. The Ld. CIT(A) also on merit invoking section 143(1

DY. COMMISSIONER OF INCOME TAX-5(2)(1), MUMBAI, MUMBAI vs. ADITYA BIRLA HOUSING FINANCE LIMITED, MUMBAI

Bench: SHRI OM PRAKASH KANT, ACCOUNTANT MEMBER SHRI RAHUL CHAUDHARY (Judicial Member)

1)(a) 3. Variation in respect of issue of - disallowance u/s 14A 4. Variation in respect of issue of - disallowance-insurance expense claimed u/s 36 5. Total Income determined as per Rs. 149,11,76,360/- the above proposal The assessment is made u/s 143(3) read with section

DY. COMMISSIONER OF INCOME TAX-5(2)(1), MUMBAI, MUMBAI vs. ADITYA BIRLA HOUSING FINANCE LIMITED, MUMBAI

Bench: SHRI OM PRAKASH KANT, ACCOUNTANT MEMBER SHRI RAHUL CHAUDHARY (Judicial Member)

1)(a) 3. Variation in respect of issue of - disallowance u/s 14A 4. Variation in respect of issue of - disallowance-insurance expense claimed u/s 36 5. Total Income determined as per Rs. 149,11,76,360/- the above proposal The assessment is made u/s 143(3) read with section

DY. COMMISSIONER OF INCOME TAX-5(2)(1), MUMBAI, MUMBAI vs. ADITYA BIRLA HOUSING FINANCE LIMITED, MUMBAI

Bench: SHRI OM PRAKASH KANT, ACCOUNTANT MEMBER SHRI RAHUL CHAUDHARY (Judicial Member)

1)(a) 3. Variation in respect of issue of - disallowance u/s 14A 4. Variation in respect of issue of - disallowance-insurance expense claimed u/s 36 5. Total Income determined as per Rs. 149,11,76,360/- the above proposal The assessment is made u/s 143(3) read with section

DY..C.I.T., BANGALORE vs. M/S STATE BANK OF MYSORE, BANGALORE

Bench: Justice (Retd.) C V Bhadang & Ms Padmavathy S, Am

1)(viia). Disallowance of depreciation on Automated Tailor Machine (ATM) and 3 other computer peripherals by reclassifying as Plant & Machinery Disallowance of certain liabilities by treating as contingent liability 4 Disallowance of deduction under section

STATE BANK OF MYSORE,BANGALORE vs. JCIT, BANGALORE

Bench: Justice (Retd.) C V Bhadang & Ms Padmavathy S, Am

1)(viia). Disallowance of depreciation on Automated Tailor Machine (ATM) and 3 other computer peripherals by reclassifying as Plant & Machinery Disallowance of certain liabilities by treating as contingent liability 4 Disallowance of deduction under section

DCIT RANGE-1(1)(2), MUMBAI vs. HOUSING DEVELOPMENT FINANCE CORPORATION LTD, MUMBAI

disallowance \nunder section 144 is Rs 924.78 crore. \n\nI. 18. We would now like to proceed with the calculation of investments yielding \ntax free income. It may be noted that the average investments yielding tax \nfree income for the captioned AY amounts to Rs 3,095.11 crore. However, \nthe said amount includes average investment amounting to Rs 1

MTITANIUM APARTMENTS PVT LTD,MUMBAI vs. DY. CIT CIRCLE 1(2)(1), MUMBAI

In the result, the appeal of the assessee is dismissed

Bench: Shri Om Prakash Kant () & Ms. Suchitra Raghunath Kamble () Assessment Year: 2024-2025 Mtitanium Apartments Pvt. Ltd., Dy. Cit-Circle 1(2)(1), 2Nd Floor, Shreeniwas House, Range 412, Aayakar Bhawan, Hazarimal Somani Marg, Fort, Vs. M.K. Road, Churchgate, Mumbai-400 001. Mumbai-400020. Pan No. Aafcm 6810 Q Appellant Respondent

disallowed, on the ground that the return for the preceding the return for the preceding year had been furnished belatedly on year had been furnished belatedly on 10.11.2023, beyond the due date prescribed under section 139(1). 10.11.2023, beyond the due date prescribed under section 139(1). 10.11.2023, beyond the due date prescribed under section 139(1). 2.1 Before

TASKUS INDIA PRIVATE LIMITED,MUMBAI vs. CIRCLE 8(3)(1), MUMBAI

Bench: Shri Sandeep Gosain () & Shri Om Prakash Kant () Assessment Year: 2022-23 M/S Taskus India Pvt. Ltd., 1. Dy. Director Of Income- Ttc Industrial Area, Tower -9, Tax Central Processing Vs. Gigaplex It Park, 18Th & 19Th Centre Unit, Bengaluru, Floor, Midc, Plot No. 1 I.T.5, 1St Floor, Prestige Alpha Airoli Knowledge Park Rd, Airoli, No 48/1, 48/2 Navi Mumbai-400708. Beratenaagrahara Begur Hosur Rd Uttarahali Hobli, Bengaluru- 560100. 2. The Dy. Cit, Circle 8(3)(1), Mumbai. Aayakar Bhavan, M.K. Road, Mumbai-400020. Pan No. Aahct 0980 G Appellant Respondent

disallowance of the deduction, it appears that the tion, it appears that the adjustment was made by invoking clause (v) of Section 143(1)(a), adjustment was made by invoking clause (v) of Section 143(1)(a), adjustment was made by invoking clause (v) of Section 143(1)(a), taking the view that the return was not filed within

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

In the result, appeals of both, assessee and revenue are decided \nas per the table below: \n\n| Sr

3,901.87 | 36.05% | 362.34 | 362.34 \n\n| Not exempt \nSLR | 7,245.38 | 6,598.15 | 6,921.77 | 63.95% | 642.79 | 562.44 \n\n| | 11,278.23 | 10,369.03 | 10,823.63 | | 1,005.13 | 924.78 \n\nI. 17. On perusal of the aforesaid table it is observed that the interest \nexpenditure to be taken into consideration for computing disallowance \nunder section

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