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

JASHAN JEWELS PRIVATE LIMITED ,MUMBAI vs. PCIT -5, MUMBAI

In the result, the appeal of the assessee is stands allowed

Bench: Shri Om Prakash Kant () & Ms. Kavitha Rajagopal () Assessment Year: 2020-21 Jashan Jewels Pvt. Ltd., Pcit, Mumbai-5, 301-B Aman Chambers Room No. 515, 5Th Floor, Aayakar Premises Co. Soc. Ltd., Mama Vs. Bhavan, Maharshi Karve Road, Paramand Marg, Opera House, Mumbai-400020. Girgaon, Mumbai-400 004. Pan No. Aabcj 7040 D Appellant Respondent

42,550/-. The case was selected for scrutiny and assessment was completed The case was selected for scrutiny and assessment was completed The case was selected for scrutiny and assessment was completed under Section 143(3) read with Section 144B of the Act on under Section 143(3) read with Section 144B of the Act on under Section

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

In the result, appeal of the assessee is partly allowed

42. Both sides heard, orders of the authorities below examined. & 2917 M 15- APL Logistics (India) Pvt. Ltd. 43. In respect of disallowance under section 14A, the short contention of ld. Counsel is that no exempt income has been earned during the relevant period, hence, no disallowance under section 14A r.w.r 8D can be made. It is no more

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

In the result, appeal of the assessee is partly allowed

42. Both sides heard, orders of the authorities below examined. & 2917 M 15- APL Logistics (India) Pvt. Ltd. 43. In respect of disallowance under section 14A, the short contention of ld. Counsel is that no exempt income has been earned during the relevant period, hence, no disallowance under section 14A r.w.r 8D can be made. It is no more

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

In the result, appeal of the assessee is partly allowed

42. Both sides heard, orders of the authorities below examined. & 2917 M 15- APL Logistics (India) Pvt. Ltd. 43. In respect of disallowance under section 14A, the short contention of ld. Counsel is that no exempt income has been earned during the relevant period, hence, no disallowance under section 14A r.w.r 8D can be made. It is no more

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

In the result, appeal of the assessee is partly allowed

42. Both sides heard, orders of the authorities below examined. & 2917 M 15- APL Logistics (India) Pvt. Ltd. 43. In respect of disallowance under section 14A, the short contention of ld. Counsel is that no exempt income has been earned during the relevant period, hence, no disallowance under section 14A r.w.r 8D can be made. It is no more

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

In the result, appeal of the assessee is partly allowed

42. Both sides heard, orders of the authorities below examined. & 2917 M 15- APL Logistics (India) Pvt. Ltd. 43. In respect of disallowance under section 14A, the short contention of ld. Counsel is that no exempt income has been earned during the relevant period, hence, no disallowance under section 14A r.w.r 8D can be made. It is no more

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

In the result, appeal of the assessee is partly allowed

42. Both sides heard, orders of the authorities below examined. & 2917 M 15- APL Logistics (India) Pvt. Ltd. 43. In respect of disallowance under section 14A, the short contention of ld. Counsel is that no exempt income has been earned during the relevant period, hence, no disallowance under section 14A r.w.r 8D can be made. It is no more

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

Disallowance of deduction under Section 36(1) (viii) of the Act restricting the allowance only to the extent of ₹11 crores against the claim of deduction of ₹1,57,29,83,056/-. xii. Rejection of the revised claim of relief under Section 90 of the Act amounting to ₹120,42

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

disallowance of Rs. 54,93,734/- made under section 36(1)(va) of the Act. Thus, Ground No. I raised by the assessee for A.Y. 2022– 23 is allowed. Ground No. II - Short grant of consequential interest under section 244A of the Act 81. This ground relates to the grievance of the assessee that the Assessing Officer has granted short

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 deduction u/s 36(1)(viii) – Rs.55,14,65,399/- 22. The Ld.AR submitted that deduction under section 36(1)(viii) of the Act is allowed in respect of the profits derived from the eligible business computed under the head Profits and Gains from Business and Profession. During the year under consideration the assesse transferred R.60,42

SIR RATAN TATA TRUST,MUMBAI SUBURBAN vs. ADDITIONAL /JOINT/DEPUTY/ASSISTANT COMMISSIONER OF INCOME TAX, NFAC, MUMBAI

In the result, both the appeals of the assessee in both AY 2014-15 and AY

Bench: Ms Padmavathy S, Am & Shri Rahul Chaudhary, Jm

42,316 1997-98 Bonus Shares received 1:2 21,158 63,474 1999-2000 Bonus Shares received 1:2 31,737 95,211 2000-2001 to No Variations - 95,211 2018-19 Total - As on 95,211 31.03.2014 10. From the above table it is clear that holding of the assessee Trust as of 31.03.2014 mainly consists of bonus

SIR RATAN TATA TRUST,MUMBAI SUBURBAN vs. DEPUTY COMMISSIONER OF INCOME TAX (EXEMPTION)-2(1), MUMBAI

In the result, both the appeals of the assessee in both AY 2014-15 and AY

Bench: Ms Padmavathy S, Am & Shri Rahul Chaudhary, Jm

42,316 1997-98 Bonus Shares received 1:2 21,158 63,474 1999-2000 Bonus Shares received 1:2 31,737 95,211 2000-2001 to No Variations - 95,211 2018-19 Total - As on 95,211 31.03.2014 10. From the above table it is clear that holding of the assessee Trust as of 31.03.2014 mainly consists of bonus

BANK OF INDIA,MUMBAI vs. ACIT-2(1)(2), 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

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

M/S. TATA INDUSTRIES LTD,MUMBAI vs. THE ITO 2(3)(3), MUMBAI

In the result, appeal of the assessee is treated as partly allowed

Bench: Shri G. S. Pannu, Accoutant Member & Shri Sanjay Gargtata Industries Ltd., Vs. The Income Tax Officer, Ward- Bombay House,24,Homi 2 (3) (3), Room No.555, Mody Street, Fort, Mumbai Aayakar Bhavan, Maharshi 400 001 Karve Road, Mumbai 400 020 Pan: Aaact 4058 L Appellant .. Respondent Appellant By Shri Dinesh Vyas, Ar Respondent By Shri Alok Johri, Dr Date Of Hearing 22-06-2016 Date Of Pronouncement 20-07-2016

section 37, it is not necessary that the loan amount should be exclusively used in the business of the assessee. However, the requirement is that it should be used for the purpose of the business which need not necessarily be the business of the assessee itself. What is to be seen is that the transfer of borrowed funds

NAVNIDHI STEEL AND ENGG CO. P.LTD,MUMBAI vs. DCIT 5(2)(1), MUMBAI

The appeal of the assessee is dismissed

Bench: Shri Joginder Singh, Assessment Year: 2007-08

disallowing deductions, allowance or relief. 13. One thing further to be noticed is that intimation under section 143(1)(a) is given without prejudice to the provisions of section 143(2). Though technically the intimation issued was deemed to be a demand notice issued under section 156, that did not per se preclude the right of the Assessing Officer

ASST CIT 19(3), MUMBAI vs. PAHILAJRAI JAIKISHIN, MUMBAI

In the result, the appeal is allowed

Bench: Shri Shailendra Kumar Yadav & Shri Ramit Kocharआयकर अपील सं./I.T.A. No.1562/Mum/2014 ("नधा"रण वष" / Assessment Year: 2010-11)

section 40(a)(i) of the Act and tax should have been deducted at source by the assessee firm u/s 195 of the Act or an application should have been made by the assessee firm for no deduction of tax at source u/s 195(2) of the Act . Thus the AO held that these payments to non-resident by assessee