HINDUSTAN PETROLEUM CORP LTD,MUMBAI vs. DCIT 1(1)(2), MUMBAI

Bench: us. 2.

disallowance of INR 26.31 Crores under Section 14A of the Act read with Rule 8D(2)(iii) of the Rules sustained by the CIT(A). Ground No. 1 raised by the Assessee is, therefore, allowed and Ground No. 4 raised by the Revenue is dismissed. Additional Ground No. 1 raised by the Assessee 5. By way of Additional Ground

DCIT-1(1)(2), MUMBAI vs. M/S HINDUSTAN PETROLEUM CORPORATION LTD., MUMBAI

disallowance\nof INR 26.31 Crores under Section 14A of the Act read with Rule\n8D(2)(iii) of the Rules sustained by the CIT(A). Ground No. 1 raised\nby the Assessee is, therefore, allowed and Ground No. 4 raised by\nthe Revenue is dismissed.\nAdditional Ground No. 1 raised by the Assessee\n5. By way of Additional Ground

M/S UNION BANK OF INDIA,MUMBAI vs. DEPUTY COMMISSIONER OF INCOME TAX, CIRCLE-(LTU)-2, MUMBAI, MUMBAI

In the result, the appeal of the revenue is dismissed

section\n36(1)(vii) of the Act, if there is any recovery, it can be charged to tax under\nsection 41(4) of the Act. Therefore, the proposed addition of recovery of bad\ndebts by the Assessing Officer is not proper and observation of Ld.CIT(A) is\nalso not correct, the revenue has to appreciate the actual claim of deductions

ACIT CIRCLE ,3(4), MUMBAI, MUMBAI vs. UNION BANK OF INDIA, MUMBAI

In the result, the appeal of the revenue is dismissed

section\n36(1)(vii) of the Act, if there is any recovery, it can be charged to tax under\nsection 41(4) of the Act. Therefore, the proposed addition of recovery of bad\ndebts by the Assessing Officer is not proper and observation of Ld.CIT(A) is\nalso not correct, the revenue has to appreciate the actual claim of deductions

ACIT, CIRCLE -3(4), MUMBAI, MUMBAI vs. UNION BANK OF INDIA, MUMBAI

In the result, the appeal of the revenue is dismissed

section\n36(1)(vii) of the Act, if there is any recovery, it can be charged to tax under\nsection 41(4) of the Act. Therefore, the proposed addition of recovery of bad\ndebts by the Assessing Officer is not proper and observation of Ld.CIT(A) is\nalso not correct, the revenue has to appreciate the actual claim of deductions

M/S UNION BANK OF INDIA,MUMBAI vs. DCIT, CIRCLE-(LTU) 2, MUMBAI

In the result, the appeal of the revenue is dismissed

section\n36(1)(vii) of the Act, if there is any recovery, it can be charged to tax under\nsection 41(4) of the Act. Therefore, the proposed addition of recovery of bad\ndebts by the Assessing Officer is not proper and observation of Ld.CIT(A) is\nalso not correct, the revenue has to appreciate the actual claim of deductions

CONCENTRIX SERVICES INDIA PRIVATE LIMITED (FORMERLY KNOWN AS MINACS PRIVATE LIMITED, MINACS LIMITED & ADITY BIRLA MINACS WORLDWIDE LIMITED ),MUMBAI vs. JOINT COMMISSIONER OF IT (OSD)10(2)(2)ASSISTANT COMMISSIONER OF INCOME TAX-9(2)(2), MUMBAI

disallowed the same under both the & ITA No. 5823/Mum/2019 AY 2011-12 & 2012-13 & AY 2013-14 normal provisions of the Act as well as book profits returned under clause (c) of Explanation 1 of section 115JB of the Income-tax Act. 23. Aggrieved, the assessee preferred an appeal before the CIT(A) reiterating the submissions made before

CONCENTRIX SERVICES INDIA PRIVATE LIMITED (FORMERLY KNOWN AS MINACS PRIVATE LIMITED, MINACS LIMITED & ADITY BIRLA MINACS WORLDWIDE LIMITED ),MUMBAI vs. DEPUTY COMMISSIONER OF INCOME TAX-10(2)(2), MUMBAI

disallowed the same under both the & ITA No. 5823/Mum/2019 AY 2011-12 & 2012-13 & AY 2013-14 normal provisions of the Act as well as book profits returned under clause (c) of Explanation 1 of section 115JB of the Income-tax Act. 23. Aggrieved, the assessee preferred an appeal before the CIT(A) reiterating the submissions made before

M/S. PATANJALI FOODS LTD (FORMERLY KNOWN AS RUCHI SOYA INDUSTRIES LTD),MUMBAI vs. DY COMM OF INCOME TAX- CENTRAL CIRCLE-7(2), MUMBAI

In the result, the appeal and cross objections of the assessee are partly allowed and the appeals of the revenue are dismissed

Bench: Shri Aby T. Varkey, Jm & Shri S Rifaur Rahman, Am आयकर अपील सं/ I.T. A. No. 1172/Mum/2023 (निर्धारण वर्ा / Assessment Year: 2010-11) & आयकर अपील सं/ I.T. A. No. 1175/Mum/2023 (निर्धारण वर्ा / Assessment Year: 2012-13) & आयकर अपील सं/ I.T. A. No. 1176/Mum/2023 (निर्धारण वर्ा / Assessment Year: 2012-13)

section 234B and section 234C of the Act was not chargeable with respect to tax liability determined under minimum alternate tax (MAT)?” ITA. No.320/Mum/2023 & CO No. 51/Mum/2023 A.Y Nos. 2010-11 & 2012-13 M/s. Patanjali Foods Ltd. 12.4 The relevant findings of the Hon’ble High Court as noted by us are as under: “32. This brings

DCIT, CC-7(2), MUMBAI vs. M/S. PATANJALI FOODS LTD.,( FORMERLY KNOWN AS RUCHI SOYA INDUSTRIES LTD,, MUMBAI

In the result, the appeal and cross objections of the assessee are partly allowed and the appeals of the revenue are dismissed

Bench: Shri Aby T. Varkey, Jm & Shri S Rifaur Rahman, Am आयकर अपील सं/ I.T. A. No. 1172/Mum/2023 (निर्धारण वर्ा / Assessment Year: 2010-11) & आयकर अपील सं/ I.T. A. No. 1175/Mum/2023 (निर्धारण वर्ा / Assessment Year: 2012-13) & आयकर अपील सं/ I.T. A. No. 1176/Mum/2023 (निर्धारण वर्ा / Assessment Year: 2012-13)

section 234B and section 234C of the Act was not chargeable with respect to tax liability determined under minimum alternate tax (MAT)?” ITA. No.320/Mum/2023 & CO No. 51/Mum/2023 A.Y Nos. 2010-11 & 2012-13 M/s. Patanjali Foods Ltd. 12.4 The relevant findings of the Hon’ble High Court as noted by us are as under: “32. This brings

DCIT, CC-7(2), MUMBAI vs. M/S. PATANJALI FOODS LTD.,( FORMERLY KNOWN AS RUCHI SOYA INDUSTRIES LTD,, MUMBAI

section 234B and section 234C of the Act was not\nchargeable with respect to tax liability determined under\nminimum alternate tax (MAT)?\"\n12.4 The relevant findings of the Hon'ble High Court as noted by us\nare as under:\n\"32. This brings us to the second question which deals with\ncharging of interest under sections 234B and 234C when

DCIT, CC-7(2), MUMBAI vs. M/S. PATANJALI FOODS LTD.,( FORMERLY KNOWN AS RUCHI SOYA INDUSTRIES LTD,, MUMBAI

In the result, the appeal and cross objections of the assessee are\npartly allowed and the appeals of the revenue are dismissed

section 234B and section 234C of the Act was not\nchargeable with respect to tax liability determined under\nminimum alternate tax (MAT)?\"\n61\nITA No.1172, 1175 & 1176/M/2023\nITA. No.320/Mum/2023 & CO No. 51/Mum/2023\nA.Y Nos. 2010-11 & 2012-13\nM/s. Patanjali Foods Ltd.\n12.4 The relevant findings of the Hon'ble High Court as noted by us\nare as under

THE GREAT EASTERN SHIPPING CO. LTD,MUMBAI vs. ASST CIT CIR 5(3)(2), MUMBAI

In the result, appeals of the assessee are allowed and appeals of the Revenue are dismissed

1,80,76,104/-, which was earlier capitalized to the vessels, as the income of the assessee by resorting to the provisions of Section 28(iv) of the Act. The AO has stated that the gain is not related to the vessel as the vessel has not been acquired by the assessee and hence, the gain cannot be related

ACIT-CIRCLE-5(3)(2), MUMBAI vs. M/S GREAT EASTERN SHIPPING CO. LTD., MUMBAI

In the result, appeals of the assessee are allowed and appeals of the Revenue are dismissed

Bench: SHRI AMIT SHUKLA (Judicial Member), SHRI S.RIFAUR RAHMAN (Accountant Member)

1,80,76,104/-, which was earlier capitalized to the vessels, as the income of the assessee by resorting to the 12 The Great Eastern Shipping Co. Ltd. provisions of Section 28(iv) of the Act. The AO has stated that the gain is not related to the vessel as the vessel has not been acquired by the assessee

DCIT CIR 5(3)(2), MUMBAI vs. THE GREAT EASTERN SHIPPING CO. LTD, MUMBAI

In the result, appeals of the assessee are allowed and appeals of the Revenue are dismissed

Bench: SHRI AMIT SHUKLA (Judicial Member), SHRI S.RIFAUR RAHMAN (Accountant Member)

1,80,76,104/-, which was earlier capitalized to the vessels, as the income of the assessee by resorting to the 12 The Great Eastern Shipping Co. Ltd. provisions of Section 28(iv) of the Act. The AO has stated that the gain is not related to the vessel as the vessel has not been acquired by the assessee

THE GREAT EASTERN SHIPPING CO. LTD,MUMBAI vs. ASST CIT CIRCLE 5(3)(2), MUMBAI

In the result, appeals of the assessee are allowed and\nappeals of the Revenue are dismissed

1,80,76,104/-, which was earlier capitalized to\nthe vessels, as the income of the assessee by resorting to the\nprovisions of Section 28(iv) of the Act. The AO has stated that the\ngain is not related to the vessel as the vessel has not been\nacquired by the assessee and hence, the gain cannot be related

RELIANCE INDUSTRIES LIMITED ,MUMBAI vs. DEPUTY COMMISSIONER OF INCOME TAX -CIRCLE 3(4) , MUMBAI

In the result, the appeal of the Revenue is dismissed whereas\nthe appeal of the assessee is allowed

disallowance has been made by the AO in\nrespect of claim of depreciation, therefore, penalty could only be levied\nin respect of furnishing of inaccurate particulars of income. As\ndiscussed above, during the assessment proceedings, the appellant\nfurnished all the relevant information/documents/explanation to the\nAO, therefore, the AO had wrongly come to the conclusion that the\nappellant furnished inaccurate particulars

M/S. BANK OF AMERICAN , N.A,MUMBAI vs. THE JT DIT (I.T)3, MUMBAI

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

1, raised in Revenue's appeal, is\ndismissed.\n8.\nGround No. 2, raised in Revenue's appeal, pertains to the deletion of\nthe disallowance made under section 44C of the Act.\n9.\nThe brief facts of the case pertaining to this issue, as emanating from\nthe record, are: During the year under consideration, the assessee claimed\nexpenditure amounting to Rs.1