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

Accordingly, this ground is allowed

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

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

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 RG 1(1), MUMBAI

Bench: Shri Anikesh Banerjee & Shri Girish Agrawal

3,901.87 6,921.77 36.05% 63.95% 362.34 642.79 362.34 562.44 11,278.23 10,369.03 10,823.63 1,005.13 924.78 I. 17. On perusal of the aforesaid table it is observed that the interest expenditure to be taken into consideration for computing disallowance under section

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

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

Bench: Shri Anikesh Banerjee & Shri Girish Agrawal

3,770.88 Not exempt SLR 7,245.38 6,598.15 6,921.77 63.95% 642.79 562.44 11,278.23 10,369.03 10,823.63 1,005.13 924.78 I. 17. On perusal of the aforesaid table it is observed that the interest expenditure to be taken into consideration for computing disallowance under 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

3,901.87 7,245.38 6,598.15 6,921.77 63.95% 642.79 562.44 Not exempt SLR maintaining 11,278.23 10,369.03 10,823.63 1,005.13 924.78 I. 17. On perusal of the aforesaid table it is observed that the interest expenditure to be taken into consideration for computing disallowance under section

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

ACIT-2(3)(1), MUMBAI vs. HDFC BANK LTD ( MERGED ENTITY HDFC INVESTMENTS LIMITED ), MUMBAI

Bench: Shri Anikesh Banerjee & Shri Girish Agrawal

3,901.87 36.05% 362.34 362.34 Not exempt Tax maintaining SLR 7,245.38 6,598.15 6,921.77 63.95% 642.79 562.44 11,278.23 10,369.03 10,823.63 1,005.13 924.78 I. 17. On perusal of the aforesaid table it is observed that the interest expenditure to be taken into consideration for computing disallowance under section

HDFC BANK LIMITED (AS SUCCESSOR TO HOUSING DEVELOPMENT FINANCE CORPORATION LTD.),MUMBAI vs. DCIT, RANGE-1(1)(2), MUMBAI

Bench: Shri Anikesh Banerjee & Shri Girish Agrawal

3,901.87 10,823.63 36.05% 63.95% 362.34 1,005.13 362.34 924.78 I. 17. On perusal of the aforesaid table it is observed that the interest expenditure to be taken into consideration for computing disallowance under section

HDFC BANK LTD.,(AS SUCCESSOR TO HOUSING DEVELOPMENT FINANCE CORPORATION LTD),MUMBAI vs. DCIT, CIRCLE-2(3)(1), MUMBAI

Bench: Shri Anikesh Banerjee & Shri Girish Agrawal

3 of Section 14A are the procedural provisions for disallowance of the expenditure in relation to income not forming part of the total income. The sub-section provides the procedure for making the disallowance u/s 14A c) The Hon'ble ITAT Special Bench, Mumbai in the case of Daga Capital Management Pvt. Ltd. & Others in 119 TTJ 289/117

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

Bench: Shri Anikesh Banerjee & Shri Girish Agrawal

3,770.88 Not exempt Tax maintaining SLR 7,245.38 6,598.15 6,921.77 63.95% 642.79 562.44 11,278.23 10,369.03 10,823.63 1,005.13 924.78 I. 17. On perusal of the aforesaid table it is observed that the interest expenditure to be taken into consideration for computing disallowance under section

ACIT-1(1)(1), MUMBAI vs. M/S HOUSING DEVELOPMENT FINANCE CORPORATION 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

ACIT-1(1)(1), MUMBAI vs. M/S. HOUSING DEVELOPMENT FINANCE CORPORATION LTD., DELHI

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 HOUSING DEVELOPMENT FINANCE CORPORATION LTD.),MUMBAI vs. ADDL/JT/DY/ACIT/ITO, NFAC, DELHI

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

Bench: Shri Anikesh Banerjee & Shri Girish Agrawal

3,901.87 | 36.05% | 362.34 | 362.34 Not exempt SLR | 7,245.38 | 6,598.15 | 6,921.77 | 63.95% | 642.79 | 562.44 Total | 11,278.23 | 10,369.03 | 10,823.63 | | 1,005.13 | 924.78 I. 17. On perusal of the aforesaid table it is observed that the interest expenditure to be taken into consideration for computing disallowance under 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

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