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

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

BRILLPHARMA PVT. LTD.,MUMBAI vs. ACIT, CPC,BANGALORE, BANGALORE

In the result, appeal by the assessee is allowed for statistical purpose

Bench: Shri Pramod Kumar & Shri Sandeep Singh Karhail

disallowance does not come into play when the payment is made well before the due date of filing the income tax return under section 139(1). Viewed thus also, the impugned adjustment is vitiated in law, and we must delete the same for this short reason as well. 10. In view of the detailed discussions above

HERCULES HOISTS LTD,MUMBAI vs. CPC, ITD,, BANGALORE

In the result, this appeal is allowed

43-2B, Savroli Kharpada Road, Dhamani, Raigarh 410202 [PAN: AAACH2706D] Vs. Deputy Commissioner of Income Tax, CPC Bengaluru ………………….Respondent Appearances: M.A Gohel for the appellant Dinesh Chourasia for the respondent Date of concluding the hearing : April 20, 2022 Date of pronouncement the order : April 28, 2022 O R D E R Per Pramod Kumar, VP: 1

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

43 | P a g e State Bank of India ITA Nos.3644&4563/Mum/2016 the appellant that only 1% of the exempt interest and dividend income is to be disallowed under section

JASBIR SINGH KABERWAL,MUMBAI vs. ADIT CPC, , BENGLURU

In the result, this appeal is allowed

43,63,226/- and Admin charges of Rs. 2,12,607/- does not fall within the definition of Income u/s. 2(24) and are not governed by the provisions of Sec. 36(1)(va). Hence a disallowance of Rs. 45,75,833/- is incorrect and liable to be deleted. The appellant prays that the disallowances is against the provisions

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

In the result, appeal of the assessee is partly allowed

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 res-integra that where no tax free income is earned during the relevant period, no disallowance under section

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

In the result, appeal of the assessee is partly allowed

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 res-integra that where no tax free income is earned during the relevant period, no disallowance under section

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

In the result, appeal of the assessee is partly allowed

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 res-integra that where no tax free income is earned during the relevant period, no disallowance under section

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

In the result, appeal of the assessee is partly allowed

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 res-integra that where no tax free income is earned during the relevant period, no disallowance under section

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

In the result, appeal of the assessee is partly allowed

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 res-integra that where no tax free income is earned during the relevant period, no disallowance under section

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

In the result, appeal of the assessee is partly allowed

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 res-integra that where no tax free income is earned during the relevant period, no disallowance under section

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

1) merely prohibits allowance of CSR expenditure as business expenditure while computing income under the head “Profits and gains of business or profession”, but does not operate as a bar against claiming deduction under Chapter VI-A, particularly under section 80G of the Act. 32. The Co-ordinate Bench in the said decision has further held that section 80G itself

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

Accordingly, this ground is allowed

1) merely prohibits allowance of CSR expenditure as business expenditure while computing income under the head “Profits and gains of business or profession”, but does not operate as a bar against claiming deduction under Chapter VI-A, particularly under section 80G of the Act. 32. The Co-ordinate Bench in the said decision has further held that section 80G itself

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

Accordingly, this ground is allowed

1) merely prohibits allowance of CSR expenditure as business expenditure while computing income under the head “Profits and gains of business or profession”, but does not operate as a bar against claiming deduction under Chapter VI-A, particularly under section 80G of the Act. 32. The Co-ordinate Bench in the said decision has further held that section 80G itself

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