TATA INDUSTRIES LIMITED,MUMBAI vs. ADDL.C.I.T., RANGE-2(3), MUMBAI

c' above. the assessee has\ncontended that the amount actually charged to TTSL was\nRs.26,62,576/- and the excess credit by Rs. 57,534/- is\nwrongly given in the books of TTSL. However the assessee\nhas not been able to substantiate the claim with evidences\nand the evidence (in the form of TDS certificate) available

DCIT-2(2)(2), MUMBAI vs. YES BANK LTD., MUMBAI

In the result, both the appeals of the Revenue and assessee he appeals of the Revenue and assessee are allowed partly for statistical purposes

Bench: Shri Om Prakash Kant () & Ms. Kavitha Rajagopal () Assessment Year: 2014-15 Dcit-2(2)(2), M/S Yes Bank Ltd., Room No. 545, 5Th Floor, 9Th Floor, Nehru Centre, Discovery Of Vs. Aayakar Bhavan, India, Dr. Ab Road, Worli, M.K. Road, Churchgate, Mumbai-400018. Mumbai-400020. Pan No. Aaacy 2068 D Appellant Respondent Assessment Year: 2014-15 M/S Yes Bank Ltd., Dcit-2(2)(2), 9Th Floor, Nehru Centre, Room No. 545, 5Th Floor, Aayakar Discovery Of India, Dr. Ab Vs. Bhavan, Road, Worli, M.K. Road, Churchgate, Mumbai-400018. Mumbai-400020. Pan No. Aaacy 2068 D Appellant Respondent

35D of the Act. Act. WITHOUT PRETUDICE TO GROUND NOS. IV AND V: WITHOUT PRETUDICE TO GROUND NOS. IV AND V: WITHOUT PRETUDICE TO GROUND NOS. IV AND V: M/s Yes Bank Ltd. ITA Nos.3501 & 3239/M/2018 GROUND NO. VI: DISALLOWANCE OF QIP EXPENSES BY GROUND NO. VI: DISALLOWANCE OF QIP EXPENSES BY GROUND NO. VI: DISALLOWANCE OF QIP EXPENSES

YES BANK LIMITED,MUMBAI vs. DCIT - 2(2)(2), MUMBAI

In the result, both the appeals of the Revenue and assessee he appeals of the Revenue and assessee are allowed partly for statistical purposes

Bench: Shri Om Prakash Kant () & Ms. Kavitha Rajagopal () Assessment Year: 2014-15 Dcit-2(2)(2), M/S Yes Bank Ltd., Room No. 545, 5Th Floor, 9Th Floor, Nehru Centre, Discovery Of Vs. Aayakar Bhavan, India, Dr. Ab Road, Worli, M.K. Road, Churchgate, Mumbai-400018. Mumbai-400020. Pan No. Aaacy 2068 D Appellant Respondent Assessment Year: 2014-15 M/S Yes Bank Ltd., Dcit-2(2)(2), 9Th Floor, Nehru Centre, Room No. 545, 5Th Floor, Aayakar Discovery Of India, Dr. Ab Vs. Bhavan, Road, Worli, M.K. Road, Churchgate, Mumbai-400018. Mumbai-400020. Pan No. Aaacy 2068 D Appellant Respondent

35D of the Act. Act. WITHOUT PRETUDICE TO GROUND NOS. IV AND V: WITHOUT PRETUDICE TO GROUND NOS. IV AND V: WITHOUT PRETUDICE TO GROUND NOS. IV AND V: M/s Yes Bank Ltd. ITA Nos.3501 & 3239/M/2018 GROUND NO. VI: DISALLOWANCE OF QIP EXPENSES BY GROUND NO. VI: DISALLOWANCE OF QIP EXPENSES BY GROUND NO. VI: DISALLOWANCE OF QIP EXPENSES

ACIT - 2(2)(2), MUMBAI vs. YES BANK LIMITED, MUMBAI

2)iii) to the suo moto disallowance\nmade by the Appellant.\n4. The Appellant prays that the AO be directed to restrict the\ndisallowance u/s. 14A of the Act, to the suo-moto disallowance made\nby the Appellant.\nGROUND NO. VII: ORDER MADE ON THE BASIS OF SURMISES AND\nASSUMPTIONS WHILE CONFIRMING DISALLOWANCE U/S. 35D OF\nTHE

DCIT-14(1)(1), MUMBAI vs. BNP PARIBAS SECURITIES INDIA PVT. LTD., MUMBAI

In the result, the appeal of the Revenue is dismissed

Bench: Shri Om Prakash Kant () & Shri Sandeep Singh Karhail () Assessment Year: 2009-10 Dcit, Circle-14(1)(1), M/S Bnp Paribas Securities India Room No. 432, 4Th Floor, Pvt. Ltd., Aayakar Bhavan, M.K. Road, Vs. 8Th Floor, 1 North Avenue, Maker Mumbai-400020. Maxity Bandra Kurla Complex, Bandra (East)- Mumbai-400051. Pan No. Aadcb 4690 F Appellant Respondent

2 of section 35D of the Act, I do not find any merit in of section 35D of the Act, I do not find any merit in disallowing the whole disallowing the whole expenditure of expenditure of 20,80,75,902 under section35D of the Act and 20,80,75,902 under section35D of the Act and hereby delete

YES BANK LTD.,,MUMBAI vs. DCIT(2)(2)(2), MUMBAI

2)iii) to the suo moto disallowance\nmade by the Appellant.\n4. The Appellant prays that the AO be directed to restrict the\ndisallowance u/s. 14A of the Act, to the suo-moto disallowance made\nby the Appellant.\nGROUND NO. VII: ORDER MADE ON THE BASIS OF SURMISES AND\nASSUMPTIONS WHILE CONFIRMING DISALLOWANCE U/S. 35D OF\nTHE

BAJAJ HOLDINGS & INVESTMENTS LTD ( FORMERLY KNOWN AS BAJAJ AUTO LTD),MUMBAI vs. ADDL CIT RG 3(1), MUMBAI

The appeals are partly allowed

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

c) Whether, on the facts and in the circumstances of the case, the Tribunal is right in law in saying that unabsorbed depreciation of earlier years before the first year of claim, which has already been absorbed, could be notionally carried forward and taken into consideration for computation of deduction under section 80-IA ? 12.6. Answering the above question

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

2 is against disallowance under section 14 A of the income tax act of ₹ 54,199,690/– . The brief of the fact shows that during the year the assessee has earned exempt income of ₹ ITA Nos. 2266 & 2239/Mum/2022 Macrotech Developers Ltd; A.Ys. 17-18 & 18-19 8,303,761/–. Assessee disallowed the same sum under section

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

2 is against disallowance under section 14 A of the income tax act of ₹ 54,199,690/– . The brief of the fact shows that during the year the assessee has earned exempt income of ₹ ITA Nos. 2266 & 2239/Mum/2022 Macrotech Developers Ltd; A.Ys. 17-18 & 18-19 8,303,761/–. Assessee disallowed the same sum under section

BAJAJ HOLDINGS & INVESTMENT LTD ( FORMERLY BAJAJ AUTO LTD),MUMBAI vs. ACIT LTU, MUMBAI

2. For the Assessment Year 2005-06, in the return of income the \nAssessee had claimed deduction of INR.1,17,19,960/- under \nSection 35D of the Act in respect of 1/10th of the GDR issue \nexpenses which was disallowed by the Assessing Officer. However, \nin appeal, the CIT(A) accepted Assessee’s claim and allowed \ndeduction for the aforesaid

DCIT-2(2)(1), MUMBAI vs. YES BANK LIMITED, MUMBAI

In the result, appeals of the revenue for AY 2011-12 to 2013-14 are dismissed

Bench: Shri Saktijit Dey & Ms Padmavathy S, Am

c) of the I. T. Act 1961. The present appeal is against this penalty. 9.2 It is seen that in A.Y. 2010-11, the Hon'ble ITAT allowed the claim u/s 35D vide order number ITA No. 3497/MUM/2018 dated 14.07.2020. The relevant portion of the order is as under: - 2. The grounds of appeal filed by the assessee read

DCIT-2(2)(1), MUMBAI vs. YES BANK LIMITED, MUMBAI

In the result, appeals of the revenue for AY 2011-12 to 2013-14 are dismissed

Bench: Shri Saktijit Dey & Ms Padmavathy S, Am

c) of the I. T. Act 1961. The present appeal is against this penalty. 9.2 It is seen that in A.Y. 2010-11, the Hon'ble ITAT allowed the claim u/s 35D vide order number ITA No. 3497/MUM/2018 dated 14.07.2020. The relevant portion of the order is as under: - 2. The grounds of appeal filed by the assessee read

DCIT-2(2)(1), MUMBAI vs. YES BANK LIMITED, MUMBAI

In the result, appeals of the revenue for AY 2011-12 to 2013-14 are dismissed

Bench: Shri Saktijit Dey & Ms Padmavathy S, Am

c) of the I. T. Act 1961. The present appeal is against this penalty. 9.2 It is seen that in A.Y. 2010-11, the Hon'ble ITAT allowed the claim u/s 35D vide order number ITA No. 3497/MUM/2018 dated 14.07.2020. The relevant portion of the order is as under: - 2. The grounds of appeal filed by the assessee read

CONCENTRIX SERVICES INDIA PRIVATE LIMITED (FORMERLY KNOWN AS MINACS PRIVATE LIMITED, MINACS LIMITED & ADITY BIRLA MINACS WORLDWIDE LIMITED ),MUMBAI vs. JOINT COMMISSIONER OF IT (OSD)10(2)(2)ASSISTANT COMMISSIONER OF INCOME TAX-9(2)(2), MUMBAI

C-10, 7th Floor, Pratyakshakar Bhavan, Bandra Kurla Complex, Bandra (East), Mumbai – 400051 ……………. Respondent & ITA No. 5940/MUM/2017 (Assessment Year: 2011-12) (Assessment Year: 2012-13) Deputy Commissioner of Income Tax 10(2)(2), Mumbai, Room No. 216-A, 2nd Floor, Aayakar Bhavan, M.K. Road, Mumbai - 400020 …………… Appellant Concentrix Services India Private Vs Limited, [Formerly known as Minacs Private Limited, Minacs

CONCENTRIX SERVICES INDIA PRIVATE LIMITED (FORMERLY KNOWN AS MINACS PRIVATE LIMITED, MINACS LIMITED & ADITY BIRLA MINACS WORLDWIDE LIMITED ),MUMBAI vs. DEPUTY COMMISSIONER OF INCOME TAX-10(2)(2), MUMBAI

C-10, 7th Floor, Pratyakshakar Bhavan, Bandra Kurla Complex, Bandra (East), Mumbai – 400051 ……………. Respondent & ITA No. 5940/MUM/2017 (Assessment Year: 2011-12) (Assessment Year: 2012-13) Deputy Commissioner of Income Tax 10(2)(2), Mumbai, Room No. 216-A, 2nd Floor, Aayakar Bhavan, M.K. Road, Mumbai - 400020 …………… Appellant Concentrix Services India Private Vs Limited, [Formerly known as Minacs Private Limited, Minacs

TRENT LIMITED,MUMBAI vs. DEPUTY COMMISSIONER OF INCOME TAX 2(3)(1), MUMBAI

In the result, these grounds of appeal are

Bench: Shri Pawan Singh& Shri Girish Agrawal(Physical Hearing) Trent Limited Dcit-2(3)(1), Mumbai 552, 5Th Floor, Aayakar Bhavan, Bombay House, Mumbai, Vs Maharashtra – 400001. Maharishi Karve Road, [Pan: Aaacl1838J] Mumbai-400020. Appellant / Assessee Respondent / Revenue Dcit-2(3)(1), Mumbai Trent Limited 552, 5Th Floor, Aayakar Bhavan, Vs G Block, Plot No. C 60, Trent House, Maharishi Karve Road, Beside City Bank, Bandra K Complex, Mumbai-400020. Bandra E Mumbai – 400051. [Pan: Aaacl1838J] Appellant / Revenue Respondent / Assessee

C 60, Trent House, Maharishi Karve Road, Beside City Bank, Bandra K Complex, Mumbai-400020. Bandra E Mumbai – 400051. [PAN: AAACL1838J] Appellant / Revenue Respondent / Assessee Assessee by Shri Nikhil Tiwari a/w Mr. Charul Mittal, CA Revenue by Shri Ajay Chandra, CIT-DR Date of hearing 23.01.2026 Date of pronouncement 30.01.2026 Order under section 254(1) of Income

DCIT, MUMBAI vs. TRENT LIMITED, MUMBAI

In the result, these grounds of appeal are

Bench: Shri Pawan Singh& Shri Girish Agrawal(Physical Hearing) Trent Limited Dcit-2(3)(1), Mumbai 552, 5Th Floor, Aayakar Bhavan, Bombay House, Mumbai, Vs Maharashtra – 400001. Maharishi Karve Road, [Pan: Aaacl1838J] Mumbai-400020. Appellant / Assessee Respondent / Revenue Dcit-2(3)(1), Mumbai Trent Limited 552, 5Th Floor, Aayakar Bhavan, Vs G Block, Plot No. C 60, Trent House, Maharishi Karve Road, Beside City Bank, Bandra K Complex, Mumbai-400020. Bandra E Mumbai – 400051. [Pan: Aaacl1838J] Appellant / Revenue Respondent / Assessee

C 60, Trent House, Maharishi Karve Road, Beside City Bank, Bandra K Complex, Mumbai-400020. Bandra E Mumbai – 400051. [PAN: AAACL1838J] Appellant / Revenue Respondent / Assessee Assessee by Shri Nikhil Tiwari a/w Mr. Charul Mittal, CA Revenue by Shri Ajay Chandra, CIT-DR Date of hearing 23.01.2026 Date of pronouncement 30.01.2026 Order under section 254(1) of Income

M/S. BAJAJ AUTO LTD.,MUMBAI vs. ADDL. CIT. RG. - 3(1), MUMBAI

Appeal of the revenue is dismissed

2 Crores provided was written back in F.Y. 2003-04\nrelevant to A.Y. 2004-05. The said provision written back to the Profit and Loss\nAccount was accordingly offered to tax in A.Y. 2004-05.\n59.\nIn the Assessment Order, the Assessing Officer disallowed merely on the\nground that the provision created is a contingent liability. On appeal