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.

1, wherein the Hon’ble Apex Court held as under: Section 43B falls in Part-V of the IT Act. What is apparent is that the scheme of the Act is such that ■ sections 28 to 38 deal with different kinds of deductions, whereas sections 40 to 43B spell out special provisions, laying out the mechanism for assessments and expressly

LARSEN & TOUBRO LTD,MUMBAI vs. ADDL CIT RG 2(2), MUMBAI

In the result the appeal of the assessee is partly allowed and that of the revenue is dismissed

41. The facts in brief are that the assessee has claimed deduction of Rs.7,86,000 under Section 80HHC of the Act, on the profits derived from export of goods. The appellant claimed to have computed deduction in the manner laid down under section 80HHC. The AO recomputed deduction u/s 80HHC of the Act after making following adjustments. No deduction

STATE BANK OF MYSORE,BANGALORE vs. JCIT, BANGALORE

In the result, the appeal of the Revenue Ground-3 is dismissed

Bench: Shri Narendra Kumar Billaiya, Account Member & Shri Anikesh Banerjeestate Bank Of India Vs Joint Commissioner Of Income-Tax, (Erstwhile State Bank Of Large Tax Payers Unit, Bangalore Mysore Prior To Merger) Local Head Office Compliance Department, 4Th Floor, 65, St. Marks Road, Bangalore-560 001 Pan: Aaccs0155P Appellant Respondent Deputy Commissioner Of Vs State Bank Of Mysore Income-Tax, Ltu, Circle-1, Head Office, Finance & Accounts Bangalore Department, Kg Road, Bangalore- 560 009 Pan: Aaccs0155P Appellant Respondent

disallowance of provision for bad and doubtful debts due to re-computation of deduction under section 36(1)(vii) related to bad and doubtful debts. The Ld.AO, during the assessment proceedings, added back under section 41

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

In the result, the appeal of the Revenue Ground-3 is dismissed

disallowance of provision for\nbad and doubtful debts due to re-computation of deduction under section\n36(1)(vii) related to bad and doubtful debts. The Ld.AO, during the assessment\nproceedings, added back under section 41

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

In the result, the appeal of the assessee is partly allowed and the appeal of the Revenue is dismissed, as indicated above

Bench: Sri Mahavir Singh, Vp & Sri G Manjunatha, Am आयकर अपील सुं./ Ita No. 3644/Mum/2016 (ननर्ाारण वर्ा / Assessment Year 2008-09) State Bank Of India The Dy. Commissioner Of 3Rd Floor, Corporate Centre Income Tax, Circle -2(2)(1) बनाम/ Madam Cama Road Mumbai Vs. Nariman Point Mumbai-400021 (अपीलार्थी / Appellant) (प्रत्यर्थी/ Respondent) स्र्थायी लेखा सुं./Pan No. Aaacs8577K

1% of the exempt interest and dividend income is to be disallowed under section 14A. 4.4 Without prejudice to the above, the learned CIT(A) erred in not appreciating that income of yielding any exempt income during the year will not be considered for the purpose of computing disallowance under section 14A.” Revenue has raised the following ground

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

1)(va), disallowed deduction claimed under section 80G in respect of CSR related payments amounting to Rs. 92,31,072/-, disallowed interest on delayed payment of tax deducted at source amounting to Rs. 3,29,345/-, and disallowed provision for leave encashment amounting to Rs. 57,63,634/-. The CIT(A) upheld all the aforesaid disallowances and granted

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

In the result, appeal of the assessee is partly allowed

disallowance under section 36(1)(iii) of the Act; and - Ground No. (vi) of appeal is with regard to interest charged under section 234A, 234B and 234D of the Act. 39. The ld. Counsel submitted that Ground No. (i), (ii), (iv) and (v) of appeal are identical to the grounds raised in the preceding AY and the facts giving rise

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

In the result, appeal of the assessee is partly allowed

disallowance under section 36(1)(iii) of the Act; and - Ground No. (vi) of appeal is with regard to interest charged under section 234A, 234B and 234D of the Act. 39. The ld. Counsel submitted that Ground No. (i), (ii), (iv) and (v) of appeal are identical to the grounds raised in the preceding AY and the facts giving rise

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

In the result, appeal of the assessee is partly allowed

disallowance under section 36(1)(iii) of the Act; and - Ground No. (vi) of appeal is with regard to interest charged under section 234A, 234B and 234D of the Act. 39. The ld. Counsel submitted that Ground No. (i), (ii), (iv) and (v) of appeal are identical to the grounds raised in the preceding AY and the facts giving rise

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

In the result, appeal of the assessee is partly allowed

disallowance under section 36(1)(iii) of the Act; and - Ground No. (vi) of appeal is with regard to interest charged under section 234A, 234B and 234D of the Act. 39. The ld. Counsel submitted that Ground No. (i), (ii), (iv) and (v) of appeal are identical to the grounds raised in the preceding AY and the facts giving rise

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

In the result, appeal of the assessee is partly allowed

disallowance under section 36(1)(iii) of the Act; and - Ground No. (vi) of appeal is with regard to interest charged under section 234A, 234B and 234D of the Act. 39. The ld. Counsel submitted that Ground No. (i), (ii), (iv) and (v) of appeal are identical to the grounds raised in the preceding AY and the facts giving rise

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

In the result, appeal of the assessee is partly allowed

disallowance under section 36(1)(iii) of the Act; and - Ground No. (vi) of appeal is with regard to interest charged under section 234A, 234B and 234D of the Act. 39. The ld. Counsel submitted that Ground No. (i), (ii), (iv) and (v) of appeal are identical to the grounds raised in the preceding AY and the facts giving rise

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

1)(va), disallowed deduction claimed under\nsection 80G in respect of CSR related payments amounting to Rs.\n92,31,072/-, disallowed interest on delayed payment of tax\ndeducted at source amounting to Rs. 3,29,345/-, and disallowed\nprovision for leave encashment amounting to Rs. 57,63,634/-.\nThe CIT(A) upheld all the aforesaid disallowances and granted\nlimited relief

ICICI BANK LTD.,MUMBAI vs. THE DY CIT -2(3)(1), MUMBAI

In the result, appeal filed by the assessee is partly allowed

Bench: Shri Prashant Maharishi, Am & Shri Sandeep Singh Karhail, Jm Icici Bank Ltd. The Dy. Commissioner Of Icici Bank Towers, Income-Tax 2(3)(1) Bandra Kurla Complex, Aaykar Bhavan, Vs. 5Th Floor, Room No.552, Badra (East), Mumbai-400 051 M.K. Road, Mumbai-400 020 (Appellant) (Respondent) Pan No. Aaaci1195H

disallow the deduction to 10% of rural advances of ₹122.30 crores which were not rural branches ICICI Bank Ltd; A.Y. 2015-16 vi. Excess deduction allowed under Section 36(1)(viii) of the Act of ₹138,52,06,494/- which should have been restricted to ₹961,47,93,509/- being 20% of allowable deduction. vii. Excess allowances of long-term

DENA BANK,MUMBAI vs. PRINCIPAL COMMISSIONER OF INCOME TAX 2, MUMBAI

In the result, appeal filed by the assesse is allowed

Bench: Shri G. Manjunatha & Shri Ravish Sooddena Bank Vs. Pcit-2 Room No.344, 3Rd Floor Accounts Department Dena Bank Building Aaykar Bhawan 2Nd Floor M.K.Road 17/B, Horniman Circle Mumbai-400 020 Fort, Mumbai-400 023 Pan/Gir No.Aaacd4249B Appellant) .. Respondent)

disallowed as per the provisions of Section 43 c) Provision for Wage arrears amounting to Rs 96,00,00,000/- In all the above cases, there is no Revenue loss. Any recovery made in respect of bad debts allowed ad deduction us/ 36(1)(vii), has to be offered to tax u/s 41

AGASKAR CIVIL & GARDEN CONTRACTORS,MUMBAI vs. NFAC, DELHI

In the result, the appeal filed by the assessee is allowed

Bench: Shri Amit Shukla, Jm & Shri Gagan Goyal, Am आयकरअपीलसं./ I.T.A. No. 1247/Mum/2022 (निर्धारणवर्ा / Assessment Year: 2019-20) National Faceless Agaskar Civil & Garden Appeal Centre (Nfac), Contractors बिधम/ Delhi Plot No. A-249, Namdeo Smruti, Vs. Sector-19, Koparkhairanine, Navi Mumbai-400 709 स्थायीलेखासं./जीआइआरसं./ Pan No. Abcfa6438K (अपीलाथी/Appellant) (प्रत्यथी / Respondent) : अपीलाथीकीओरसे/ Appellant By : None प्रत्यथीकीओरसे/Respondent By : Shri Mahita Nayar, Ld. Dr सुनवाईकीतारीख/ : 29.06.2022 Date Of Hearing घोषणाकीतारीख / : 29.06.2022 Date Of Pronouncement आदेश / O R D E R Per Amit Shukla: The Aforesaid Appeal Has Been Filed By The Assessee Against The Impugned Order Dated 30.03.2022, Passed By National Faceless Appeal Centre (Nfac), Delhi, In Relation To Adjustment Made U/S 143(1) For The Ay 2019-20. 2

41,55,700/-. 3. For the year under consideration, CPC has made adjustment and disallowed u/s 143(1) wherein contribution of PF and ESI has been disallowed u/s 36(1)(va) r.w.s. 2(24(x) of the Act. NFAC has held that amendment brought by Finance Act 2021 w.e.f. 01.04.2021 to section

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

1)(va), disallowed deduction claimed under section 80G in respect of CSR related payments amounting to Rs. 92,31,072/-, disallowed interest on delayed payment of tax deducted at source amounting to Rs. 3,29,345/-, and disallowed provision for leave encashment amounting to Rs. 57,63,634/-. The CIT(A) upheld all the aforesaid disallowances and granted limited relief

ACIT, CIRCLE-2(1)(1), MUMBAI vs. M/S BANK OF INDIA, MUMBAI

In the result, the appeal by the Revenue for the assessment year 2018-

Bench: Shri Vikram Singh Yadavshri Sandeep Singh Karhailita No.1452/Mum/2023 Assessment Year : 2016-17 Assessment Year : 2018-19

disallowed and added back to the income of the assessee bank. Penalty proceedings u/s.271(1)(c) are initiated for filing of inaccurate particulars of income.” 30. The learned CIT(A), vide impugned order, dismissed the ground raised by the assessee on this issue, by observing as follows: - “16.5 After considering the assessment order, submissions of the appellant and the relevant