STATE BANK OF INDIA,MUMBAI vs. ADDL CIT CIR 2(2), MUMBAI

In the result appeal filed by the assessee for assessment

Bench: Shri Prashant Maharishi, Am & Ms Kavitha Rajagopal , Jm

section 143(3) of the Act held that claim of the assessee was required to be disallowed in the light of the decision of the Supreme Court in Vijaya Bank Ltd. v. Addl CIT [1991] 57 Taxman 152/187 ITR 541 wherein it was held that such an expenditure is required to be capitalized and cannot be allowed as a deduction

DCIT 2(2), MUMBAI vs. STATE BANK OF INDIA, MUMBAI

In the result appeal filed by the assessee for assessment year 2006 – 07 and 2007 – 08 is partly allowed

Bench: Shri Prashant Maharishi, Am & Ms Kavitha Rajagopal , Jm A.Y.2006-07 [ By Assessee] &

section 143(3) of the Act held that claim of the assessee was required to be disallowed in the light of the decision of the Supreme Court in Vijaya Bank Ltd. v. Addl CIT [1991] 57 Taxman 152/187 ITR 541 wherein it was held that such an expenditure is required to be capitalized and cannot be allowed as a deduction

HDFC BANK LIMITED,MUMBAI vs. THE DEPUTY COMMISSIONER OF INCOME TAX-2(3)(1), MUMBAI

In the result, the assessee's appeal for AY 2016-17 to AY 2018-19 is allowed and the Revenue's appeal for AY 2016-17 to 2018-19 is dismissed

Bench: Shri Kuldip Singh, Jm & Ms Padmavathy S, Am

Disallowance under section 14A – Ground No.1 22. The contention of the Revenue is that the CIT(A) erred in not appreciating that the amendment brought in by Finance Act 2022 to section 14A whereby it has been clarified that the provisions of section 14A can be invoked when the assessee has investments which have the potentional of yielding exempt income

DCIT 2(3)(1), MUMBAI vs. HDFC BANK LIMITED, MUMBAI

In the result, the assessee's appeal for AY 2016-17 to AY 2018-19 is allowed and the Revenue's appeal for AY 2016-17 to 2018-19 is dismissed

Bench: Shri Kuldip Singh, Jm & Ms Padmavathy S, Am

Disallowance under section 14A – Ground No.1 22. The contention of the Revenue is that the CIT(A) erred in not appreciating that the amendment brought in by Finance Act 2022 to section 14A whereby it has been clarified that the provisions of section 14A can be invoked when the assessee has investments which have the potentional of yielding exempt income

HDFC BANK LIMITED,MUMBAI vs. THE DEPUTY COMMISSIONER OF INCOME TAX-2(3)(1), MUMBAI

In the result, the assessee's appeal for AY 2016-17 to AY 2018-19 is allowed and the Revenue's appeal for AY 2016-17 to 2018-19 is dismissed

Bench: Shri Kuldip Singh, Jm & Ms Padmavathy S, Am

Disallowance under section 14A – Ground No.1 22. The contention of the Revenue is that the CIT(A) erred in not appreciating that the amendment brought in by Finance Act 2022 to section 14A whereby it has been clarified that the provisions of section 14A can be invoked when the assessee has investments which have the potentional of yielding exempt income

HDFC BANK LIMITED,MUMBAI vs. THE DEPUTY COMMISSIONER OF INCOME TAX-2(3)(1), MUMBAI

In the result, the assessee's appeal for AY 2016-17 to AY 2018-19 is allowed and the Revenue's appeal for AY 2016-17 to 2018-19 is dismissed

Bench: Shri Kuldip Singh, Jm & Ms Padmavathy S, Am

Disallowance under section 14A – Ground No.1 22. The contention of the Revenue is that the CIT(A) erred in not appreciating that the amendment brought in by Finance Act 2022 to section 14A whereby it has been clarified that the provisions of section 14A can be invoked when the assessee has investments which have the potentional of yielding exempt income

DCIT 2(3)(1), MUMBAI vs. HDFC BANK LIMITED , MUMBAI

In the result, the assessee's appeal for AY 2016-17 to AY 2018-19 is allowed and the Revenue's appeal for AY 2016-17 to 2018-19 is dismissed

Bench: Shri Kuldip Singh, Jm & Ms Padmavathy S, Am

Disallowance under section 14A – Ground No.1 22. The contention of the Revenue is that the CIT(A) erred in not appreciating that the amendment brought in by Finance Act 2022 to section 14A whereby it has been clarified that the provisions of section 14A can be invoked when the assessee has investments which have the potentional of yielding exempt income

DCIT-2(3)(1), MUMBAI, MUMBAI vs. HDFC BANK LIMITED, MUMBAI

In the result, the assessee's appeal for AY 2016-17 to AY 2018-19 is allowed and the Revenue's appeal for AY 2016-17 to 2018-19 is dismissed

Bench: Shri Kuldip Singh, Jm & Ms Padmavathy S, Am

Disallowance under section 14A – Ground No.1 22. The contention of the Revenue is that the CIT(A) erred in not appreciating that the amendment brought in by Finance Act 2022 to section 14A whereby it has been clarified that the provisions of section 14A can be invoked when the assessee has investments which have the potentional of yielding exempt income

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

In the result, appeal filed by the learned assessing officer in ITA number 3238/M/2018 for assessment year 2013 –

Bench: Shri Prashant Maharishi, Am & Shri Sandeep Singh Karhail, Jm

disallowance has been made by the learned assessing officer with respect to the category of investment available for sales, held for maturity or held for trading. He held that if the securities are held for trading then the brokerage expenses relating to that should be disallowed. Accordingly, he confirmed the disallowance of ₹ 384,405/– subject to verification by the learned

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

In the result, appeal filed by the learned assessing officer in ITA number 3238/M/2018 for assessment year 2013 –

Bench: Shri Prashant Maharishi, Am & Shri Sandeep Singh Karhail, Jm

disallowance has been made by the learned assessing officer with respect to the category of investment available for sales, held for maturity or held for trading. He held that if the securities are held for trading then the brokerage expenses relating to that should be disallowed. Accordingly, he confirmed the disallowance of ₹ 384,405/– subject to verification by the learned

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

In the result, appeal filed by the learned assessing officer in ITA number 3238/M/2018 for assessment year 2013 –

Bench: Shri Prashant Maharishi, Am & Shri Sandeep Singh Karhail, Jm

disallowance has been made by the learned assessing officer with respect to the category of investment available for sales, held for maturity or held for trading. He held that if the securities are held for trading then the brokerage expenses relating to that should be disallowed. Accordingly, he confirmed the disallowance of ₹ 384,405/– subject to verification by the learned

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

In the result, appeal filed by the learned assessing officer in ITA number 3238/M/2018 for assessment year 2013 –

Bench: Shri Prashant Maharishi, Am & Shri Sandeep Singh Karhail, Jm

disallowance has been made by the learned assessing officer with respect to the category of investment available for sales, held for maturity or held for trading. He held that if the securities are held for trading then the brokerage expenses relating to that should be disallowed. Accordingly, he confirmed the disallowance of ₹ 384,405/– subject to verification by the learned

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

In the result, appeal filed by the learned assessing officer in ITA number 3238/M/2018 for assessment year 2013 –

Bench: Shri Prashant Maharishi, Am & Shri Sandeep Singh Karhail, Jm

disallowance has been made by the learned assessing officer with respect to the category of investment available for sales, held for maturity or held for trading. He held that if the securities are held for trading then the brokerage expenses relating to that should be disallowed. Accordingly, he confirmed the disallowance of ₹ 384,405/– subject to verification by the learned

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

In the result, appeal filed by the learned assessing officer in ITA number 3238/M/2018 for assessment year 2013 –

Bench: Shri Prashant Maharishi, Am & Shri Sandeep Singh Karhail, Jm

disallowance has been made by the learned assessing officer with respect to the category of investment available for sales, held for maturity or held for trading. He held that if the securities are held for trading then the brokerage expenses relating to that should be disallowed. Accordingly, he confirmed the disallowance of ₹ 384,405/– subject to verification by the learned

IDBI BANK LTD.,MUMBAI vs. ACIT (LTU)-2, MUMBAI

In the result this ground of appeal is

Bench: Shri R.C. Sharma & Shri Pawan Singh

disallowance u/s 14A was warranted since the assessee was a dealer in shares although in its Balance Sheet, shares were disclosed under the head "Investments". We find that the Hon'ble Supreme Court in its recent judgment dated 12.02.2018 in the case of Maxopp Investment Ltd Vs CIT (supra) did not uphold this line of argument and held that even

ADVANCE CONSTRUCTION CO. P.LTD,MUMBAI vs. DCIT 8(1), MUMBAI

In the result, Ground No.2 is allowed for statistical purpose

Bench: Shri B.R. Baskaran & Shri Pawan Singhm/S Advance Construction Co. P. Dcit-8(1) Ltd. “Kavita” Plot No. 37, 2Nd Aayakar Bhavan, Churchgate, Floor, Vithal Nagar Co-Op. Vs. Mumbai-20. Housing Soc. 11Th Road, Jvpd Scheme, Mumbai -400049. Pan: Aabca0710B Appellant Respondent M/S Advance Construction Co. P. Dcit-8(1) Ltd. “Kavita” Plot No. 37, 2Nd Aayakar Bhavan, Churchgate, Floor, Vithal Nagar Co-Op. Vs. Mumbai-20. Housing Soc. 11Th Road, Jvpd Scheme, Mumbai -400049. Pan: Aabca0710B Appellant Respondent Appellant By : Shri Nirmit Mehta (Ar) Respondent By : Shri Virender Singh (Sr-Dr) Date Of Hearing : 09.05.2018 Date Of Pronouncement : 09.05.2018 Order Under Section 254(1) Of Income–Tax Act Per Pawan Singh; 1. These Two Appeals By Assessee Under Section 253 Of The Income-Tax Act

391/-. No voluntary disallowance was made by assessee. The assessee should have made voluntary disallowance of expenditure in 8 ITA No.999/M/12 & 5477/M/15- M/s Advance Construction Co. P. Ltd. relation to the income which does not or shall not form part of total income as per the requirement of section

THE DY CIT, CIRCLE-4(1)(2),, AHMEDABAD vs. VODAFONE WEST LIMITED,, AHMEDABAD

In the result, the appeal by the Revenue is partly allowed for statistical\npurposes

disallowance of depreciation\ndue to transfer of PI assets from one of the entities of the Vodafone Group to\nVodafone Infrastructure Ltd. has been deleted. From the perusal of the\ndecision in Vodafone Digilink Ltd. Vs. DCIT, in ITA No. 1073 and\n1158/Del./2015, vide order dated 14.10.2025, for the assessment year 2010-\n11, we find that the Co-ordinate

VODAFONE WEST LIMITED,(FORMERLY KNOWN AS VODAFONE ESSAR GUJARAT LIMITED),AHMEDABAD vs. THE DY.CIT, CIRCLE-4(1)(2),, AHMEDABAD

In the result, the appeal by the Revenue is partly allowed for statistical\npurposes

disallowance of depreciation\ndue to transfer of PI assets from one of the entities of the Vodafone Group to\nVodafone Infrastructure Ltd. has been deleted. From the perusal of the\ndecision in Vodafone Digilink Ltd. Vs. DCIT, in ITA No. 1073 and\n1158/Del./2015, vide order dated 14.10.2025, for the assessment year 2010-\n11, we find that the Co-ordinate