STATE BANK OF MYSORE,BANGALORE vs. JCIT, BANGALORE

Bench: Justice (Retd.) C V Bhadang & Ms Padmavathy S, Am

Disallowance of deduction under section 36(1)(viii) – Ground No.5 in assessee's appeal 26. For the year under consideration the assessee has claimed deduction under section 36(1)(viii) to the tune of Rs. 43

DOW CHEMICALS INTERNATIONAL PRIVATE LIMITED ,MUMBAI vs. DEPUTY COMMISSIONER OF INCOME TA-14(1)(2), MUMBAI

In the result, the appeal by the assessee for the

43(6) of the\nAct have no applicability to the facts of the present case.\n25. As regards the reliance placed by the Revenue on the provisions of\nsection 49(1)(iii)(e) and section 55(2)(a)(ii) of the Act, it is pertinent to note\nthat these provisions form part of the Chapter dealing with “Capital Gains\"\nand

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

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

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

section 37(1) of the Act, aggregating to Rs. 16,43,60,000/-. The Ld. AO disallowed an amount of Rs. 8,10,18,335/- on the ground

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

1,45,31,43,595 Disallowance under section 14A @ 1% Disallowance under section 14A @ 1% 1,45,31,436 1

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

STRIDES PHARMA SCIENCE LTD.,NAVI MUMBAI vs. THE DY CIT -5(1)(2), MUMBAI

In the result ITA number 1004/M/2021 filed by the assessee for assessment year 2016 – 17 is allowed

Bench: Shri Prashant Maharishi, Am & Shri Sandeep Singh Karhail, Jm Strides Pharma Science Ltd. Dcit 15(1)(2) 201, Devavrata, Sector-17, Aayakar Bhavan, M K Road, Vs. Vashi, Navi Mumbai, 400703 Mumbai 400020 (Appellant) (Respondent) Pan No. Aadcs8104P

1 The learned Assessing Officer ("AD"), the learned Transfer Pricing Officer (“TPO”) and the Honorable ("Hon'ble) Dispute Resolution Panel (“DRP”) erred in making adjustment under section 92CA of the Act amounting to INR 9,5,.43,090, details of which are provided below. 2. Imputation of interest on the Share application money pending allotment

ACIT - 14(2) (2), MUMBAI vs. PFIZER LTD, MUMBAI

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

Bench: Shri Prashant Maharishi, Am & Shri Rahul Chaudhary, Jm M/S Pfizer Limited The Capital, 1802/1901, Acit-14(2)(2) Plot No.C-70, G-Block, 461, 4T H Floor, Aaykar Bhavan Bandra Kurla Complex, Vs. Mumbai-400 020 Bandra (East), Mumbai-400 051 (Appellant) (Respondent) Pan No. Aaacp3334M

disallowing the claim of depreciation. The CIT (Appeals) has confirmed the action of the Assessing Officer and therefore the claim of depreciation is not allowable as per the 5th proviso to Section 13(2)(1) of the Act. The Id. DR has also referred to the Expln. 3 to Section 43

PFIZER LTD,MUMBAI vs. DCIT - 14(2) (2), MUMBAI

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

Bench: Shri Prashant Maharishi, Am & Shri Rahul Chaudhary, Jm M/S Pfizer Limited The Capital, 1802/1901, Acit-14(2)(2) Plot No.C-70, G-Block, 461, 4T H Floor, Aaykar Bhavan Bandra Kurla Complex, Vs. Mumbai-400 020 Bandra (East), Mumbai-400 051 (Appellant) (Respondent) Pan No. Aaacp3334M

disallowing the claim of depreciation. The CIT (Appeals) has confirmed the action of the Assessing Officer and therefore the claim of depreciation is not allowable as per the 5th proviso to Section 13(2)(1) of the Act. The Id. DR has also referred to the Expln. 3 to Section 43

BANK OF INDIA,MUMBAI vs. THE NATIONAL FACELESS ASSESSMENT CENTRE, MUMBAI

section\n37(1) without appreciating that the payment was penal and punitive and was\nfor infraction of public policy? (Tax Effect: Rs.8,90,11,776/- @34.61% of\nRs.25,72,00,000/-)\n7. Whether on the facts and circumstances of the case and in law, the Ld.\nCIT(A) erred in allowing relief to the assessee relying on the decision

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 excess depreciation on Automated Teller Machies\n[‘ATM’] and other computer peripherals by reclassifying as plant and machinery\n– Rs.9,74,43,086/-\n12. On this issue, the assessee claimed depreciation under section 32 of the Act\nat 60% by treating the ATMs and the UPS as a part of the computer machinery. The\nLd.AR stated that both

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

In the result, appeal of the assessee is allowed

disallowed Rs.471,05,05,075/-.\n5. 1. The assessee agitated the matter before ld. CIT(A) and vehemently\ncontended that the assessee had written off bad debts of Rs.923.67 Crore\nafter reducing the opening credit balance in the provision for bad and\ndoubtful debts account u/s 36(1)(viia) of Rs.452.61 Crores and claimed\nthe balance amount of Rs.471.06 Crores

DOW CHEMICAL INTERNATIONAL PRIVATE LIMITED,THANE vs. DEPUTY COMMISSIONER OF INCOME TAX - 14(1)(2), MUMBAI

43(6) of the\nAct have no applicability to the facts of the present case.\n25. As regards the reliance placed by the Revenue on the provisions of\nsection 49(1)(iii)(e) and section 55(2)(a)(ii) of the Act, it is pertinent to note\nthat these provisions form part of the Chapter dealing with “Capital Gains\"\nand

DIPEN KUMARPAL PAREKH,MUMBAI vs. NFAC- DCIT, NEW DELHI

In the result, the appeal of the assessee is dismissed

Bench: Shri Amit Shukla () & Shri Om Prakash Kant ()

disallowance u/s 143(1) of the Act is justified. He accordingly submitted that order of the Tribunal Act is justified. He accordingly submitted that order of the Tribunal Act is justified. He accordingly submitted that order of the Tribunal (supra) need to be rectified or recall for deciding in the light of the (supra) need to be rectified or recall

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

43. We heard the parties and perused the material on record. The ld. AR presented similar arguments with regard to the commission expenditure and prayed that the issue may be remitted back to the AO with a direction to disallow only the commission paid those vendors which the AO disallowed in the earlier years. The ld AR also submitted

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

43. We heard the parties and perused the material on record. The ld. AR presented similar arguments with regard to the commission expenditure and prayed that the issue may be remitted back to the AO with a direction to disallow only the commission paid those vendors which the AO disallowed in the earlier years. The ld AR also submitted