ELARA CAPITAL (INDIA) PRIVATE LIMITED,MUMBAI vs. ACIT- CIRCLE 6(2)(2), MUMBAI

In the result, the appeal of the assessee is allowed

Bench: Shri Om Prakash Kant () & Ms. Kavitha Rajagopal () Assessment Year: 2017-18 Elara Capital (India) Pvt. Ltd., The Acit-Circle 6(2)(2), Tower 3, 21St Floor, One Room No. 506, 5Th Floor, Vs. International Center, Senapati Aayakar Bhavan, Maharshi Bapat Marg, Elphinstone Karve Road, Mumbai- Road (West), Mumbai-400013. 400020. Pan No. Aabce 6487 B Appellant Respondent

disallowance of Rs. 32,90,000 made under section 14A of the Income Tax Act, 1961 ('Act') by the Assessing

ACIT, MUMBAI vs. K RAHEJA CORP PRIVATE LIMITED, MUMBAI

In the result, the appeal of the Revenue is dismissed

Bench: Shri Om Prakash Kant () & Shri Sandeep Singh Karhail () Assessment Year: 2020-21

disallowance of Rs. 1,45,32,176 under Section 14A r.w. Rule 8D, considering only Rs. 1,45,32,176 under

GATI KINTETSU EXPRESS PRIVATE LIMITED,MUMBAI vs. DY COMMISSIONER OF INCOME TAX, CIRCLE 14(1)(2), MUMBAI, MUMBAI

In the result, In the result, appeal for AY 2013-14 is allowed partly for 14 is allowed partly for statistical purposes, purposes, appeal for AY 2014-15 is partly allowed, is partly allowed, appeal...

Bench: Shri Om Prakash Kant () & Shri Sandeep Singh Karhail ()

disallowed of Rs.53,85,488/ relates to deduction disallowed of Rs.53,85,488/- in respect of two in respect of two items items items (i) (i) (i) amount amount amount of of of receivables/bad receivables/bad receivables/bad debt debt debt written written written off off off of Rs.18,16,695/- (ii) advance and loans written off amounting to (ii) advance

GATI KINTETSU EXPRESS PRIVATE LIMITED ,MAHARASHTRA AND MUMBAI vs. DY. COMMISSIONER OF INCOME TAX, CIRCLE 14(1)(2), MUMBAI, MAHARASHTRA AND MUMBAI

In the result, In the result, appeal for AY 2013-14 is allowed partly for 14 is allowed partly for statistical purposes, purposes, appeal for AY 2014-15 is partly allowed, is partly allowed, appeal...

Bench: Shri Om Prakash Kant () & Shri Sandeep Singh Karhail ()

disallowed of Rs.53,85,488/ relates to deduction disallowed of Rs.53,85,488/- in respect of two in respect of two items items items (i) (i) (i) amount amount amount of of of receivables/bad receivables/bad receivables/bad debt debt debt written written written off off off of Rs.18,16,695/- (ii) advance and loans written off amounting to (ii) advance

GATI KINTETSU EXPRESS PRIVATE LIMITED,MUMBAI vs. DY.COMMISSIONER OF INCOME , CIRLCE 14(1)(2)TAX, MUMBAI

In the result, In the result, appeal for AY 2013-14 is allowed partly for 14 is allowed partly for statistical purposes, purposes, appeal for AY 2014-15 is partly allowed, is partly allowed, appeal...

Bench: Shri Om Prakash Kant () & Shri Sandeep Singh Karhail ()

disallowed of Rs.53,85,488/ relates to deduction disallowed of Rs.53,85,488/- in respect of two in respect of two items items items (i) (i) (i) amount amount amount of of of receivables/bad receivables/bad receivables/bad debt debt debt written written written off off off of Rs.18,16,695/- (ii) advance and loans written off amounting to (ii) advance

GATI KINTETSU EXPRESS PRIVATE LIMITED ,MAHARASHTRA AND MUMBAI vs. DY. COMMISSIONER OF INCOME TAX, CIRCLE 14(1)(2), MUMBAI, MAHARASHTRA AND MUMBAI

In the result, In the result, appeal for AY 2013-14 is allowed partly for 14 is allowed partly for statistical purposes, purposes, appeal for AY 2014-15 is partly allowed, is partly allowed, appeal...

Bench: Shri Om Prakash Kant () & Shri Sandeep Singh Karhail ()

disallowed of Rs.53,85,488/ relates to deduction disallowed of Rs.53,85,488/- in respect of two in respect of two items items items (i) (i) (i) amount amount amount of of of receivables/bad receivables/bad receivables/bad debt debt debt written written written off off off of Rs.18,16,695/- (ii) advance and loans written off amounting to (ii) advance

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 - Rs. 1,05,10,437/- (ii) Disallowance of Prior period expenditure - Rs. 54,83,149/- (iii) Disallowance on account of commission payment - Rs. 3,60,61,410/- 32

DCIT 2(1)(1), MUMBAI vs. BAJAJ ELECTRICALS LTD, 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 - Rs. 1,05,10,437/- (ii) Disallowance of Prior period expenditure - Rs. 54,83,149/- (iii) Disallowance on account of commission payment - Rs. 3,60,61,410/- 32

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 - Rs. 1,05,10,437/- (ii) Disallowance of Prior period expenditure - Rs. 54,83,149/- (iii) Disallowance on account of commission payment - Rs. 3,60,61,410/- 32

ASIA INVESTMENTS PVT.. LTD.,MUMBAI vs. DCIT ,CIRCLE 2 (1)(1), MUMBAI

In the result, all the three appeal

Bench: Shri Om Prakash Kant () & Shri Raj Kumar Chauhan ()

disallowed in full under sub disallowed in full under sub-rule (i); and Asia Investments Pvt. Ltd ITA No. 4529, 6353/MUM/2017, 6209/MUM/2019 (ii) indirect interest expenditure indirect interest expenditure, being interest that cannot be , being interest that cannot be specifically identified or segregated as relating either to taxable specifically identified or segregated as relating either to taxable specifically identified

DCIT 10(1), MUMBAI vs. APL LOGISTICS (INDIA) P. LTD, MUMBAI

In the result, appeal of the assessee is partly allowed

32. The ld. Counsel for the assessee submitted that the assessee in appeal has assailed the order of CIT(A) primarily on three counts i.e. (1) Addition made on account of mismatch in AIR Information (2) Disallowance of interest expenditure under section

APL LOGISTICS (INDIA) P.LTD,MUMBAI vs. ASST CIT 10(1), MUMBAI

In the result, appeal of the assessee is partly allowed

32. The ld. Counsel for the assessee submitted that the assessee in appeal has assailed the order of CIT(A) primarily on three counts i.e. (1) Addition made on account of mismatch in AIR Information (2) Disallowance of interest expenditure under section

APL LOGISTICS P.LTD,MUMBAI vs. DCIT 14(1)(1), MUMBAI

In the result, appeal of the assessee is partly allowed

32. The ld. Counsel for the assessee submitted that the assessee in appeal has assailed the order of CIT(A) primarily on three counts i.e. (1) Addition made on account of mismatch in AIR Information (2) Disallowance of interest expenditure under section

DCIT 10(1), MUMBAI vs. APL LOGISTICS (INDIA ) P.LTD, MUMBAI

In the result, appeal of the assessee is partly allowed

32. The ld. Counsel for the assessee submitted that the assessee in appeal has assailed the order of CIT(A) primarily on three counts i.e. (1) Addition made on account of mismatch in AIR Information (2) Disallowance of interest expenditure under section

APL LOGISTICS (INDIA) P. LTD,MUMBAI vs. ASST CIT 10(1), MUMBAI

In the result, appeal of the assessee is partly allowed

32. The ld. Counsel for the assessee submitted that the assessee in appeal has assailed the order of CIT(A) primarily on three counts i.e. (1) Addition made on account of mismatch in AIR Information (2) Disallowance of interest expenditure under section

APL LOGISTICS (INDIA) P. LTD,MUMBAI vs. ACIT 10(1), MUMBAI

In the result, appeal of the assessee is partly allowed

32. The ld. Counsel for the assessee submitted that the assessee in appeal has assailed the order of CIT(A) primarily on three counts i.e. (1) Addition made on account of mismatch in AIR Information (2) Disallowance of interest expenditure under section

BAJAJ INTERNATIONAL REALTY PRIVATE LIMITED ,MUMBAI vs. DCIT, 1(2)1, MUMBAI

In the result both the appeals of the parties are partly allowed for In the result both the appeals of the parties are partly allowed for the statistical purposes

Bench: Shri Om Prakash Kant () & Ms. Kavitha Rajagopal ()

Section 43CA of the Act, regarding the difference between the sale consideration and the Act, regarding the difference between the sale consideration and the Act, regarding the difference between the sale consideration and the Stamp Duty Valuation (SDV). Stamp Duty Valuation (SDV). Secondly, the disallowance of , the disallowance of Rs. 1,19,32

BAJAJ INTERNATIONAL REALTY PRIVATE LIMITED ,MUMBAI vs. DCIT-1(2), MUMBAI

In the result both the appeals of the parties are partly allowed for In the result both the appeals of the parties are partly allowed for the statistical purposes

Bench: Shri Om Prakash Kant () & Ms. Kavitha Rajagopal ()

Section 43CA of the Act, regarding the difference between the sale consideration and the Act, regarding the difference between the sale consideration and the Act, regarding the difference between the sale consideration and the Stamp Duty Valuation (SDV). Stamp Duty Valuation (SDV). Secondly, the disallowance of , the disallowance of Rs. 1,19,32